ML20209G778
| ML20209G778 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 09/05/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20209G725 | List: |
| References | |
| NUDOCS 8509190691 | |
| Download: ML20209G778 (202) | |
Text
f- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
Meeting on TMI 1 In-Service Testing - Pumps and Valves
, Review of Second 10-Year Program Docket No.
l t
Location: Bethesda, Maryland Date: Thursday, September 5, 1985 Pages: 181 - 279 8509190691 850916 PDR ADOCK 05000289 T PDR ANN RILEY & ASSOCIATES Court Reporters s'
1625 I St., N.W.
Suite 921 Washington, D.C. 20006 (202) 293-3950 u
181 Su;W 1 UNITED STATES OF AMERICA f
s 2 NUCLEAR REGULATORY COMMISSION 3 l
--_____________________________x 4 Meeting on TMI 1 In-Service ,!
i 5 Testing - Pumps and Valves !
~
6 ! l i
7
. l i
8 Review of Second 10-Year j i
9 Program l
___________-_____________--____g 10 11 Room P-ll4 12 Phillips Building
( 'i 13 7920 Norfolk Avenue 14 Bethesda, Maryland 15 Thursday, September 5, 1985 16 17 18 The TMI-l In-Service Testing Group convened at
. N 8:08 a.m., pursuant to notice, Owen Thompson presiding.
20 ATTENDEES:
21 Owen Thompson 22 Richard Conte 23 Bob Knight 24 Joe Colitz
\ _.
j 25 J. R. Bashista i
l _
182 Su;W 1 Julian Abramovici t 2 Mark Sanford 3 Henry Shipman 4 Richard Barley 5 Rick McGoey 6 Clair Ransoin 7 Herb Rockhold 8 Joel Page 9 George Lear 10 Frank Cherny 11 Owen Rothberg l
12 13
(
14 15 16 17 18
- 19 M
21
' El 23 24
\ ,.- 26
183
- 1-1-SueW I PROCEEDINGS o- l 2 MR. THOMPSON: We are ready to reconvene the '
3 meeting on in-service testing of pumps and valves for TMI-1.
4 We covered a lot of ground yesterday, around ninety or some 5 questions in the GPU Response of August 22, 1985.
~
6 We have some items that were still open. The 7 last two, particularly those relating to pumps, we went over 8 rather quickly. And I think this morning we probably should g maybe redo those.
10 Or, does the Licensee have some other way of ap-11 proaching things this morning?
12 MR. COLITZ: No. I think we can, you know, re-13 visit the ones that we talked about towards the end of the
{i 14 meeting, where Joel wasn' t present. And you people said is basically that you wanted to touch on them this morning.
16 I guess I would like to get a flavor after that.
17 How else do you want to handle the session today?
18 MR. THOMPSON: Okay. We provided you last night
. 19 with handwritten notes the Staff had made on each question 20 as we covered it. Some of them are clear-cut where you have 21 some minor changes to make to your program. And you have 3 agreed to do that. ,
23 And some we have some things to do.
24 . MR. PAGE: What I think would be good is to go I
s ahead and go through the last three ,or four items we had, go
{
l l
, 184
- 1-2-SueW 1 over those and maybe I can go upstairs and get cranking.
,m 2 Do ya'll have any problems with that?
3 MR. COLITZ: We met on other things last night on 4 some of these. But we did go through these. On a lot of l
5 these where you refer to Licensee's response, in some cases !
6 where the item was totally acceptable you said refer to 7 Licensee's response.
8 In other cases, you said the Licensee's written 9 response is acceptable. To me, that's a clear indication if 10 you look at this that there is probably a dif ference here.
11 And we would like all of them --
12 MR. PAGE: To read the same?
13 MR. COLITZ: -- to read the same, the written
(
14 response is acceptable, rather than refer to pages. Is that 15 what that meant?
16 MR. PAGE: No, that's what that meant. Refer to 17 meant the response is acceptable.
18 MR. COLITZ: But then in another case, you said
. 19 the Licensee's written response rather than say refer to, 20 that the Licensee's written response is acceptable.
21 MR. PAGE: We can change that.
22 MR. COLITZ: And I think, for the record, for' l
! 23 those that were clearly acceptable we would like to see it 24 stated as such.
25 And I think we ought to go through it for any other l
l
185
- 1-3-SueW 1 small errors that may exist in it.
,- s 2 MR. PAGE: Certainly. We would prefer that also.
l l
3 Yes. Are there a bunch of them?
4 MR. COLITZ: It's just that Rick McGoey and Mark 5 Sanford, who were here yesterday, and Dick Wilson, our Vice 6 President, will be getting here about 8:30 I guess.
7 .
MR. PAGE: Okay. And what I was thinking, at the 8 end of that I could go get Frank and we could go over some 9 of these items that seem to be sticking out, and go anything to that might be considered an Appeal from your letter.
11 MR. THOMPSON: We need to get a lis ting, an 12 itemizing, an itemized list, of those issues where we are not 13 together.
14 On many of these, we are all together. And they 15 don't require any further discussion. I think there is no 16 technical disagreement.
17 We need to get that listing of areas where we 18 technically disagree so that we can then get management to 19 give us some ruling or decide where we go with those. That 20 is the whole purpose of having Mr. Wilson here, and getting 21 our management down to the meeting.
22 We don't want to burden them if we can avoid 23 it with routines.
24 Let's go ahead and cover the last few items u from last night and make sure we are all together on those.
l l
r
186
- 1-4-SueW I Then, I would suggest that we go through them one by one as 2 quickly as we can and just give a checkmark, particularly if 3 it's okay, on account of your commitment to do something to 4 add to the program, a particular valve or so on, and then we 5 can identify which numbers, which ones, are still not in 6 agreement.
7 Then, they can be grouped into probably I think 8 four or five issues. Some of them are the same issue applying g to dif ferent questions.
10 MR. COLITZ: Yes.
11 MR. THOMPSON: Okay. Herb, why don' t you proceed 12 with those last few items from last night?
13 MR. ROCKHOLD: Okay. Probably the first one we
[
14 really discussed was Question DD.1 on Page 30, 15 MR. THOMPSON: We are on Page 30 of Attachment 2 16 to the August 22, 1985 Licensee Response to questions from 17 the Staff. Item DD.l.
18 MR. ROCKHOLD: Okay. This is Herb Rockhold speak-
. 19 ing. This particular item I think we discussed briefly. But 20 since it was an Appeal item we did not go into any real great 21 detail on it.
22 But I wanted to get Joel's input on this particular M item on the testing of the~ CA-P1, these boric acid pumps , and 24 the WDL pumps.
t .
25 MR. PAGE: Those are valves, aren' t they?
187
- 1-5-SueW 1 MR. ROCKHOLD: Ye ah .
2 MR. THOMPSON: WDL-P13.
3 MR. ROCKHOLD: Yeah, pump and associate' 'alves.
4 They are in an Appeal item right now.
1 5 And the current situation is the only way they 6 can really test the pumps is by pumping boric acid into the 7 reactor coolant system via makeup system.
8 MR. PAGE: That is the only path available?
9 MR. ROCKHOLD: That's my understanding. They to briefly discussed a potential recirc system installation which 11 requires system modification at a cost of nearly half a 12 million dollars.
', 13 And we just kind of left it there, since it is an 14 Appeal item.
15 MR. PAGE: Did you report on that?
16 MR. ROCKHOLD: Ye ah . We have some of that discus-17 sion down.
18 MR. PAGE: So, basically it boils down to a lot
. 19 of radioactive waste problens and reprocessing and extending 20 cold shutdown or something.
21 I mean, I realize that pumping into the reactor 22 coolant system with boric acid I guess would cause you n real problems on the cold shutdown frequency.
24 MR. ROCKHOLD: The generation of additional waste.
25 MR. PAGE: How big of a problem is it?
188 91-6-SueW 1 MR. COLITZ: During power operations, it's 2 basically out of the question. Okay. During cold shutdown, 3 depending whether it's beginning the life , middle life ,
l 4 end of life, the numbers vary as far as how much rad waste.
5 MR. PAGE: So, your Appeal would be to test on 6 a refueling frequency?
7 MR. COLITZ: On a refueling frequency. That's 8 what we are doing right now. And that's what we are pre-9 sently doing.
10 MR. THOMPSON: Does anyone know what other Licensee s 11 do that have maybe a similar type of problem?
12 MR. ROCKHOLD: All the ones that I'm f amiliar with 13 have recirculation systems so they can recirc the tanks to 14 test the pump. And there might be one or two valves, check 15 valves, in the lines that are tested on a full shutdown 16 frequency when they add boron for excess boration shutdown 17 margin.
18 MR. PAGE: A half million dollars?
. 19 MR. THOMPSON: At the present time, the Staff's 20 position is that the testing should be done in accordance 21 with the Code.
22 I think that was included in our SSER.
l l
23 MR. PAGE : And, Herb, do you have any feel for i
f 24 how much trouble it can be at cold shutdown?
25 MR. ROCKHOLD: Well, like they were saying, the
l I
, 189 l
- 1-7-Suew 1 amount of waste would tend to vary, depending on plant life. I kg) 2 I can understand that.
3 But I don' t personally see it generating that 4 much waste. I don' t know. Maybe generation of processing of 5 rad waste is significantly different at their facility, but 6 it doesn't seem to be that much of a problem at the other 7 plants that we have interfaced with.
8 MR. PAGE: So, I guess ya'll don't have any real 8 numbers of what that means in terms of cold shutdown fre-10 quency?
11 MR. BASHISTA: The end of life number for one pump - -
i 12 but there are four pumps. You have to multiply this number
() 13 by four.
14 End of life number is thirty-two thousand gallons Hi of rad waste that would be generated. You would have to 16 multiply that by four, because there are four pumps.
17 There are four separate pump tests.
! 18 MR. PAGE : And how long does it take you to do i . 19 a test?
20 MR. BASHISTA: A shif t for maybe two pumps. I 21 would say another shift for another two pumps. I would say 22 it would take two shif ts.
l 23 MR. PAGE: I guess I was asking about pump running 24 time.
25 MR. BASHISTA: The pump running time is minimal. Th 6 l
190
- 1-8-SueW 1 might be at most fifteen minutes.
- It sounds like a lot of liquid 2 MR. ROCKHOLD:
3 transported in fifteen minutes.
4 MR. SHIPMAN: Tlte recovery of it is what generates 5 so much rad waste. You are pumping in concentrated boric i - 6 acid into the makeup tank. You have got to remove that by 7 dilution.
8 MR. PAGE: Since this is an Appeal, why don't we 9 wait until Frank gets here. And we can discuss it then. It 10 is no use spending any more time on that one.
11 What is the next one?
12 MR. ROCKHOLD: The next item of discussion was a 13 brief discussion about Item DD.3 where we talked about tech
{.
14 spec required system tests versusSection XI testing, and 15 how they may not necessarily satisfy the same requirements.
16 The question is really more of just a statement 17 of fact, since tech spec required tes, ting is typically 18 utilized to verify system operability; and,Section XI testing 19 is used to verify individual component operability. Then, 20 testing in accordance with tech specs may not meet the 21 requirement of Section XI.
22 This was more or less a generic discussion and 23 not about any particular pump or system. But I mentioned 24 that this is one item that you would like to express some 25 concern to the utility on.
i I
l
. 191
- 1-9-SueW l MR. PAGE: I think this is going to be a big item, e
2 especially when the Regional people show up. It sounds to 3 me like you are not using Section XI to perform operability.
4 That is what this says.
5 MR. ROCKHOLD: I think in a few instances , for 6 example, Relief Request 3, they make the statement that this 7 testing satisfies the tech specs, therefore, it should be 8 good enough for Section XI.
9 And that's what generated that particular ques-10 tion.
11 MR. COLITZ: I think on that one, though, we do 12 give you additional justification. And it was also a request 13 for relief from the Code.
14 I think what we have done is , in some cases we have is used this as additional justification on our part to support 16 the relief from the Code.
17 MR. PAGE: The recovery system test? Eve rybody 18 else does a system test, too.
. 19 MR. COLITZ: I'm just saying tech specs find it 20 adequate to prove the safety of the system. Okay.
21 And we use that as additional justification to i
22 support our relief request, even though we gave you additional 23 j us tification.
24 MR. PAGE: Nobody ever answered the first question,
/ 25 though. Does testing by Section XI, does that verify the l
l
192
- 1-10-SueW l operability of the individual components at TMI-l?
2 MR. COLITZ: By Section XI, yeah. l 3 MR. PAGE : Okay. So, if you f ailed a Section XI 4 test, that component is inoperable?
5 And it is declared inoperable?
- 6 MR. COLITZ: Yes.
7 MR. PAGE: Okay. Now, that may mean that one 8 group of a system, or whatever is out of service -- okay.
9 It just says individual component operation. I didn' t know 10 whether that meant operability or not.
11 Okay. Did you run into any specific problems 12 with that, Herb? You know, that's a real general discussion
- 13 we've just had.
14 MR. ROCKHOLD: Yeah. The -- my only example that 15 I could find right offhand was that Relief Request 3. But, 16 like they said, they did provide some additional basis.
17 But it sounded like the potential was there for --
i 18 well, Relief Request 2 also uses it for a similar statement.
19 The very last sentence. Relie f Reques t 2 s ays : Therefore, 20 the tech spec's frequency of testing is judged acceptable for 21 Section XI requirements.
22 There was -- I didn't mark all of them, but it 23 seemed like that could be a general thought.
24 MR. COLITZ: Again, though, like on that emergency l
- 25 feedwater, our real request for relief was concern on oxygen l
l l
193
- 1-ll-SueW l into the steam generators.
2 MR. PAGE: That's what we were zeroing in on.
3 MR. COLITZ: I think we kind of tacked this on as 4 a concluding type statement, as additional support. Again, 5 it was not our sole reason for requesting the relief.
I
- 6 MR. PAGE: I think we were concerned about the 7 oxygenated water.
8 MR. ROCKHOLD : Oh, yes.
9 MR. PAGE: And you said one other one. What was i
10 the detail on that one?
I .
11 You said Relief Request 2 and 3.
12 MR. COLITZ: The other one I think was on decay
, 13 heat, the check valves.
14 And that's an item that is open for further discus-U5 sion.
16 MR. ROCKHOLD: Yeah, the emergency feed system and 17 the decay heat valves.
18 MR. PAGE: What were the details on the decay 19 heat valves?
2D - MR. ROCKHOLD: DH-V14A and B, and it's still an 21 open item.
22 MR. COLITZ: It's one of the items that we will 23 check off that we are not together on yet.
24 MR. PAGE: Okay. That was one of the ones in the I i 25 SSER, DH-V14s?
i I
194
- 1-12-SueW 1 MR. ROCKHOLD: Yes.
2 MR. CONTE: This is Rich Conte. To summarize --
3 correct me if I'm wrong, Joe -- I don' t think the Licensee 4 misunderstands us in terms of this thing of tech spec surveil-5 lance being a system functional oriented testing, whereas IST
- 6 is component oriented.
7 The residual issues in this item appear to be 8 covered by individual Relief Requests, or what have you, 9 EFW-1, the DH-PI, the boric acid injection, what have you.
10 So, I'm not sure there is any residual open issue in this 11 whole thing.
12 I think the Licensee understands what our position i 13 is. This particular item is really dead, if you will.
14 Do you have any misunderstandings , Joe?
15 MR. COLITZ: I don' t think any of us do.
16 MR. PAGE: Maybe we ought to just go on through 17 the last three , I guess. We have already discussed basically 18 boric acid pumps.
19 MR. COLITZ: DD.4 and DD.5 are all tied in with the 20 boric acid pumps and valves.
21 MR. PAGE : All right.
22 MR. ROCKHOLD: Pump Question A.1, we discussed 2 flow rate instrumentation available for EF-P1 and 2A and B.
24 And there I believe, is that where we discussed the l
l 25 range of the instrumentation versus not having any instrumentati@
195 4 #1-13-SueW 1 at all? Okay. That one we found acceptable yesterday, j* 2 where they -- the range of the instrumentation is more than 3 three times the reference value during pump testing. That's !
4 because the pump is tested in a recirc flow path.
5 And then the instrumentation is actually put in
- 6 for full system flow. So, we have accepted relief requests 7' of that nature before, and it doesn' t present any problem.
8 MR. PAGE: Is there ' a question here on this?
9 MR. ROCKHOLD: Yeah. Pump Ques tion A. l .
10 MR. PAGE: Did you have anything on D.4?
11 MR. ROCKHOLD: No. D.4 was tied to D.l. D.5 12 also. DD.4, 5 and 1 are all the same issue.
13
( MR. PAGE: Okay.
14 MR. ROCKHOLD: On Pump Question A.1, the Licensee i
2 is going to request relief from the range of the instrumenta-18 tion utilized in measuring flow during the pump test.
! 17 And I believe that we will find that acceptable.
M MR. PAGE: But the instrumentation is in the flow 18 line during the test?
l 20 MR. ROCKHOLD: Right.
21 MR. PAGE: It sounded like the response here was 1
i 22 indicating that the flow rate was an independent variable.
E MR. ROCKHOLD: Well, that was the first discussion.
24 And then we discussed that there was an instrument, but its
'- 25 range was out of spec as far asSection XI was concerned.
196
- 1-14-Suew i And I explained to them that --
a, i () 2 MR. PAGE: So, that 's okay.
3 MR. ROCKHOLD: -- that would have been acceptable ,
4 or would be acceptable.
5 MR. PAGE: All right. Do you know how much the
. 6 instrument was off as far as the test?
7 MR. BASHISTA: I think the instrument goes up to 8 five hundred gallons a minute, or maybe it's even a thousand.
g But the recirc flow rate is only a fraction of 10 that.
11 MR. PAGE: What kind of fraction?
12 MR. BASHISTA: The motor driven pumps, it's 13 ninety gallons a minute. For EF-P1, the turbine driven
, 14 emergency feed pump, it's a hundred and eighty gallons a is minute.
16 MR. PAGE: Ten 'to twenty percent?
17 MR. B ASHISTA: Yeah, that's the recirc flow l
18 path testing. And our flow instrument doesn't have the 19 required Section XI scale range criteria.
l ,
20 MR. PAGE: That's going to make it tough I think 21 on testing.
i 22 MR. COLITZ: On this issue, we went round and round j 23 on this one. I think the last time we were down here, I 24 think we both agreed that a fixed resistance test for this
(?)
iP 25 particular case would be acceptable. And I think --
197 4
- 1-15-SueW 1 MR. PAGE: I don' t recall that.
2 MR. B ASHISTA: The flow path for this test is on 3 the recirc piping. The recirc piping has an orifice, and 4 you only can get so much flow through that orifice.
5 And those are the numbers of a hundred and eighty
. 6 and a hundred and ninety gallons a minute.
7 MR. PAGE: Well, I think that you are banking on 8 the ' 74 Codu where they said measure one or the other. And 9 immediately that was discovered at the time that that was a 10 mistake and you should measure both.
11 And all the Code since then have always required 12 both --
( '. 13 MR. BASHISTA: We do measure flow rate and record Q
14 it in that procedure.
2 MR. PAGE: I think --
16 MR. BASHISTA: The flow rate is always constant.
17 MR. PAGE: -- that like Herb says , that's good 18 that it's constant, but, boy, that could make it tough if 18 it didn' t get constant for some reason.
(
20 What was the next one, Herb? Do you just want to 21 go right through them?
22 MR. THOMPSON: Let's --
23 MR. PAGE : Do you want to introduce the people 24 that just came in?
~a 25 MR. THOMPSON: I will introduce the people that I
l
198
- 1-16-SueW 1 just arrived.
- 2 MR. WILSON: Dick Wilson with GPU.
3 MR. McGOEY: Rick McGoey , GPU.
4 MR. SANFORD: Mark S anford, GPU.
5 MR. THOMPSON: To bring you up to speed, we
- 6 were just re-covering the last few questions from last night 7 that we wanted to go back and revisit.
8 Essentially, the last one now, looking at your 9 August 22 Response to Questions, and we are at Page 32.
10 MR. CONTE: This is Rich Conte. I wanted to 11 bring up the broader issues we discussed yesterday, and that 12 was the position we gave them that the 1980 edition of the 13 Code no longer allows you to rely on fixed resistance measure-14 ment. It has to be the recirculation -- the recirculation is flow has to be instrumented, and the flow measured in addi-16 tion to the Delta P.
17 Licensee was somewhat silent around the table.
18 Is this -- we talked a specific issue in this Question A.1 19 on the EFW which sounds like it will get resolved by an EFW 20 by relief request, because the range of the instrumentation 21 is not -- it's somewhat consistent with the Code.
22 How much of a problem is this with the other pumps?
23 Are all your other pumps recirculation flows instrumented so 24 that you can comply with the Code based on the position that 2 we gave you yesterday?
I t
l 1
199 '
l
- l l
- 1-17-SueW 1 MR. BASHISTA: There are other recirculation
' '- Later on, you will 2 flow rates that are not instrumented.
3 see -- one of the Questions talks -- I think it's D.1 that 4 talks about reactor building emergency cooling water pump.
5 MR. CONTE: Yeah, because that's what I'm wonder-6 ing about. Based on my knowledge, it's not -- I think it's 7 like seventy-five percent of your pumps are not instrumented.
g But I don't have the plant specific information.
j g Does that mean that each one of those pumps are going to y) have to have some kind of relief request?
11 MR. PAGE: Relief requests can, of course, be put 3 in. They should be put in wherever you are not measuring
~
13 whatever you are required to by the Code, of course.
(.)h 14 But I know that my management's position has been 1
H5 that the lack of instrumentation is not a reason to not be 18 testing. And basically, it is what kind of schedule can the 17 Licensee provide.
18 You know, they don' t feel that instrumentation, at i
l . 19 least as a broad subject, should just be left out because it's i
30 not there now. And if there is a real good reason like you 21 just can' t instrument it because it's so tremendously expen-l 22 sive that it's just not feasible, that is a different reason. j 23 But that means you have looked into it in those 24 cases and you know what the details are. But in general they 26 want to know when the instruments can arrive.
- . - - - . . ~ . _ . - - . . - - _ . --- - - . _ . _ - - - - - -
200
- 1-18-SueW 1 MR. B ASHISTA: I think we have to point out that 2 where we don' t have -- in most cases where we don' t have 3 instruments for the quarterly tests, other frequency tests 4 we do measure flow rate. Other frequency tests , we do 5 measure flow rate.
6 MR. PAGE: And Delta P?
7 MR. BASHISTA: And Delta P.
8 MR. PAGE: Well, maybe those are details you 9 could bring out in the Relief Request.
10 MR. BASHISTA: Those details are in the submittal.
! 11 MR. ROCKHOLD: We reviewed a few of those. There i
12 are a few that I think are not reviewed.
t 3
13 MR. PAGE: It doesn' t give you very good informa-14 tion, does it? You can't do the other tests very of ten.
15 MR. ROCKHOLD: One example is the containment 16 coolers, the river water through the containment coolers.
17 I believe that's one where you don' t have flow measurement l 18 during the quarterly test where you basically just go through
. 19 a recirc back into the intake structure or wherever it's 20 sucking from.
21 But during an annual test, or a refueling outage 22 test, they do measure flow rate then. And the reason that 23 they don' t do that particular test flow path more frequently 24 is the river water in the coolers, which would sound like a 25 very good basis to us. So we let that one go.
201 61-19-SueW 1 And their test flow path basically just comes 2 right out of the pump directly back into the river and 3 it --
4 MR. CONTE: So that means that the actual test is 5 only going to be done on a refueling. There won' t be 6 quarterly pump testing. By the relief request that's granted, 7 there won' t be quarterly pump testing for trending.
8 So there won't be any information.
9 MR. ROCKHOLD: There will be quarterly pump testing ,
10 in that the pumps will be run and vibration will be monitored.
11 Pump flow rate I believe was about the only parameter that 12 would not be measured.
13 So, there is additional information that they are
(}
14 gathering on the pumps. It's just they are not gathering 05 a hundred percent of the information.
16 And we found that acceptable, since installation 17 of additional instrumentation right at the pump discharge 18 is, from our past experience, that it appeared that it would
. 19 not be practical.
20 MR. CONTE: Have we granted that exemption yet?
21 MR. PAGE: We haven' t granted it yet. But, did 22 the Licensee provide the information that you were discussing i
l 23 right now?
l 24 MR. ROCKHOLD: Yes.
~
25 MR. PAGE: That it is not feasible to put in the I
i
202
!#1-20-SueW 1 instruments?
'[. l 2 MR. ROCKHOLD: No, they did not.
l l.
END #1 3 Joe f1ws 4
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203 2-1-Joe W 1 2 MR. PAGE: I think we ought to make a list of 3 those.
4 MR. COLITZ: We can go back and look at those l 5 and look at the fixed resistance test. Look at what we 6 supplied in the way of relief request, and if we need to
. 7 supply you any more to back that up you know on a quarterly 8 or on an annual-type test, we do a full test where we 9 measure flow and so forth, we will add that in our next 10 revision to the submittal.
11 We can go back and look at those cases where 12 we are doing the fixed resistance test, and make sure taat 13 we have adequately addressed specifically what we are doing.
(
14 We adequately request relief request with enough 15 detail to give you people what you need.
16 MR. PAGE: Maybe we can go through the last 17 couple then, and I will go get Frank and maybe recap where 18 we are.
- 19 MR. COLITZ: I think E.1 was the only other l
20 thing. -
21 MR. ROCKHOLD: And we are basically talking 22 about E.1 now also.
23 MR. COLITZ: Okay.
24 MR. PAGE: There is a question here on B.l.
N The question was: Did plant heat load during cold shutdown
204 2-2-JosW 1 require operation of more than one service river water 2 pump. What the answer was: For cold shutdown of short 3 duration.
4 It sounds like a different question was answered.
5 Is that cleared up?
6 MR. ROCKHOLD: We talked about that yesterday.
7 I asked the question: What is the short duration cold 8 shutdown?
9 The response that we got was it could be as long 10 as 30 days or more,. I guess.
11 The heat load during the cold shutdown depends 1
12 a lot more on previous plant operating conditions on whether 13 they can shut down all but one pump or not.
("'-
14 Correct me if I am wrong..
' ~
I 15 MR. COLITZ: Sest 'o'f' the time we 'have tiwo
~
16 running. You know, it is ba' sed on riveIr temperature,
~
17 .
ambient temperature, whether we have an 'evapor,ator running 18 *down rad waste, and so forth. -
19 4
In most cases, and I think even right now, we 20 t .
probably even while, shutdown we have been rtidn'ing tw6.
21 MR. ITILSON: Is that a matter of choice?
22 MR. COLITZ: It is need.
23 MR. PAGE: It is-really required. You'need to 24 run both.~of them almost all the time.
25 MR. SANFORD: There is a special evolution of our I
205 2-3-Jo W 1 plant, down to one pump.
2 We have been able to, on some special occasion, 3 but not routinely.
4 MR. PAGE: How many pumps are involved in B-l?
5 MR. COLITZ: Three.
6 MR. PAGE: Three pumps?
7 MR. COLITZ: Same with C. Same conditions.
8 MR. PAGE: That is pumps in terms of flow rates; 9 you have to-run at least two at a time? Could it be possible 10 to run like A and B together, and then B and C, and A and 11 C?
12 MR. BASHISTA: Yes.
MR. PAGE: And then you can compare them, and
(; 13 14 just tell which one is suffering any problems, if there are is any problems. <
16 MR. ABRAMOVICI: We do test, use --
17 MR. BASHISTA: We do test two pumps at the same I 18 time.
- 19 MR. PAGE: As I described?
20 MR. BASHISTA: A, B; B, C; and A C. Three 21 separate tests.
El MR. PAGE: That is pretty good. And the last i
23 thing you said, that there was one other one.
24 MR. ROCKHOLD: The very last item, E.1., we 25 discussed a few minutes ago, as we were talking about A.1 l
l 1
2-4-JoeWal 206 l i I guess it was, the lack of installed instrumentation is j
' not a suitable justification, or long term justification 2 ,
3 for not performing the required testing.
4 So, I guess we have talked about it.
5 MR. PAGE: It sounds to me like the reason it
- 6 is supplied here is again system oriented, as opposed to 7 component oriented.
8 MR. COLITZ: System oriented -- I think you have 9 got to look at on screen wash pumps, is the function of 4
10 the system.
11 You are not cooling the core any. You are washing 12 trash off the screens.
13 MR. PAGE: So if that stops washing trash off 14 the screen, it will be okay?
15 MR. COLIT Z: Well, we are saying the test for 16 watching the visual observation that you are getting an l 17 adequate flow velocity and so forth to do the job is l
18 probably as meaningful, and maybe more meaningful, than l
19 flow.
20 Along with the other parameters you check on 21 when you run that pump.
j 22 MR. PAGE: If that pump operation was significantly 2 degraded in terms of flow rate, would it still wash the 24 screen?
25 MR. COLITZ: Significantly degraded? What does
2-5-Jo;Wnl 207 I that mean?
2 MR. PAGE: Where you are down to 80 percent 3 flow rate from where it was.
4 MR. COLITZ: You would either have the velocity 5 to wash the screen or you wouldn't.
6 MR. SHIPMAN: It would be protected.
7 MR. PAGE: I don't understand why we keep looking 8 at it if the system operates, and all the components are 9 okay, is what it sounds like.
10 MR. McGOEY: You can look at the screen and tell 11 whether it is going to work or not.
12 MR. PAGE: Sometimes the component is having
(', 13 problens, because if it is not giving off heat transfer, or 14 whatever; internal recirculation of the fluid, it could be is any number of problems with the component, yet it is still is doing, quote, 'its funct on,' but how long it will do that 17 function, we don't know.
18 MR. BASHISTA: For this pump we do monitor 19 vibration, and we do monitor Delta-P, and we verify adequate 30 flow rates.
21 MR. WILSON: How would the traditional inservice 22 test of that pump give you assurance that some time in the 23 future it would still perform its function, which I guess 24 is the gist of your argument.
25 MR. PAGE: The gist of the Code is to monitor
2-6-JogWal 1 individual components. ;
b 2 MR. WILSON: I understand the Code, but let's l 3 talk about what the function is.
4 I detect from what you said that measuring the 5 traditional test of variables that somehow it gave you more i 6 assurance of the plant being safe than simply looking at 7 the end result of what you are trying to accomplish.
8 MR. PAGE: Any time you measuring parameters on 9 an individual component, such as flow rate and Delta-P, you 10 have a better fix on where that component is.
11 We have seen some pumps that have gone down 12 pretty far, and what happens is they actually start to have 13 heat transfer problens in some cases where they are actually CN}
14 not transferring the heat through the fluid that is being Hi pumped, and not keeping a close look at that and merely is looking at what its functions could do.
17 I am sure that you could take the cooling pumps 18 and probably degrade them down to almost no pumping at all,
. 18 and it still works just fine, however you have 90 percent i
- of the pumps could be within an inch of dying.
=
i 21 And the whole point of the code is to monitor each i
22 component. To have these other tests, supplementary tech 23 spec tests and everything, which try to monitor individual 24 systems to see how they perform, they are rated strictly
\ ('a 26 on something that is system related.
l
2-7-Jo;W 209 1 It is not looking at the individual component.
'.' 2 You may have an injection system that has to be 3 on line in less than sixty seconds.
4 Does that mean that a solinoid valve in that 5 system has sixty seconds to operate? Would that be adequate?
6 Fifty second stroke on a solinoid valve?
7 Monitoring the individual degradation of each s pump and each valve that is in the program, and that is the 9 point. It is required by law. 10CFR50, and when it is 10 impractical to do the test, truly impractical, then that is 11 what we discuss here.
12 But to say that just because it performs whatever 13 the function is from a systematic standpoint does not mean 14 that the component is fine.
2 MR. WILSON: Yours is a legal argument.
i 16 MR. PAGE: No, it is a technical argument. Withou b i 17 knowing the flow rate on the pump, you can truly degrade the 1
18 pump without knowing about it. Beyond where it should be
, 19 degraded.
20 Beyond the point where you can count on it being
) .
21 operable.
22 It sounds to me like you all arc taking issue 23 with the Code.
24 MR. COLITZ: That is what we basically requested lV 25 some relief from.
i
2-8-JonW 210 1 We do vibration, Delta-P, and a velocity check.
, ~.s f 2 We haven't had problems with these pumps, and 3 if you lost both of them, the operators could manually 4 clean the debris off the screen.
5 It is not a safety issue.
6 MR. GOEY: And we aren't taking issue with the 7 Code, because we are satisfying the intent of the Code by 8 what we are doing, so we are just saying when you are 9 satisfying the code --
10 MR. PAGE: You are not satisfying the intent of 11 the code. Let's talk the requirements of the code, not 12 the intent of the code. The requirements are to measure 13 flow rate and meansure Delta-P.and vibration.
14 MR. WILSON: What you are saying is a legal 15 argument.
18 You are arguing that the Code says so and so, 17 therefore because the Code says do that --
18 MR. PAGE: I guess looking at it from your stand-
, 19 point, you don't need to do it for any of the pumps really.
20 MR. THOMPSON: I think what Joel is saying is 21 that the measurements will slow degradation over time, and Zt without necessarily that degradation affected the operability 23 of the system initially, at some point in time it will 24 but when you visually recognize that the system is not wash-25 ing the screen properly, for example, your pump is severely I
2-9-JorW 211 I degraded, so I think that his pointis throughout the entire 2 Code is for the purpose of looking: Is your pump working 3 properly the way it should be? Whether it is studdng to 4 degrade when you measure flow rate.
5 For example, Delta-P, that will tell you that 6 you have a problem even though your system is still operating ,
, 7 and that applies to all of them, doesn't it?
8 MR. PAGE: The criteria is basically the same 9 for all of them. What the actual function of the pump 10 is -- the Code docan't really address those things, meaning 11 that screen warning pump has less emphasis than a safety 12 injection pump.
() 13 They are all treated the same by the Code.
14 MR. ABRAMOVICI: One thing that is worth 2 mentioning, Joel, is the fact that those pumps -- the only is reason they are in the program is because they get emergency i
17 power, and the only reason they get emergency power is 18 because where they are located that is the only power
. 19 available.
l 20 MR. PAGE: Well, then maybe they don't need to 21 he in the program at all.
! 22 MR. COLITZ: You did grant relief first time i
23 around, these pumps. That is what our answer basically says.
24 Relief has previously been granted for measuring i-
- flow rates.
z _ _ - . _. ._.
2-10-JoeW 212 3 .
1 MR. THOMPSON: Joe, we can come back to that 2 point, because there is another aspect of that and I !
l 3 want to talk a little bit later on about the appeal l
4 process, because I think you are all interested in that.
5 I would rather try to resolve this technically
< 6 rather than going back to legal arguments.
7 What- you are really seeking then is relief from 8 measuring flow rate and what is the basis for your relief?
9- .We can grant relief based on an adequate justification.
!1 10 The justification is -- what you are saying here 11 in the response is -- oh, and the question is: Lack of 12 instrumentation in and of itself is not a basis for relief 13 unless, as Herb was saying, you can go a step further and
{
14 say it would be unreasonable to put in the instrumenation.
15 So, is there something more you can add to why 16' you --
, 17 MR. COLITZ: Well, we again, we feel that the 1
- 18 testing we do,-which is -- running the pump, vibration i
19 checks, Delta-P, assure an adequate flow velocity.
80 You know, it has given us the type performance 21 monitoring we need on the pump for the function that it 22 serves.
23 MR. WILSON: Plus, I think you said that even 24 if the pumps weren't functioning, you could manually clean l
l m __
i - - _ - _ _ _. _
2-ll-JoLWal 213 1 MR. THOMPSON: I think that is a separate 2 issue whether or not they need to be in the program. If l
3 they are in the program, then you need to get relief for l 4 not measuring flow in accordance with the regulations, 5 and the basis for that relief needs to be given to us so 6 we can justify it, and I haven't heard -- other than you i
7 don't think it is a good idea -- why you should not be 8 measuring flows.
9 MR. COLITZ: We didn't say it is not a gcod to idea. We are saying that what we are doing is adequate.
11 It was adequate before when relief was granted, and we 12 haven't changed our position on that.
' 13 We are giving you basically the same technical 14 justification.
15 MR. SANFORD: Basically, what the argument that 16 we are using is that the operators observation of the 17 discharge velocity is equivalent to measuring flow in this 18 case.
. 19 If you had a flow meter on the end of the pipe j 20 where it comes out, that would be acceptable, even though ,
21 it has moved away from the pump itself. That would still
-22 be acceptable.
2 And what we are saying is viewing the stream of 24 fluid discharging onto the screen provides the equivalent .
i
'/ 25 We are able to detect information of a flow meter to us.
a- %__ - - - + - m. ,,.
l i 2-12-JoSWal
, 214 1 that it is or is not performing correctly.
'fJ The operator really -- observing
~d i 2 MR. PAGE:
3 the spray-- spraying the screen wash is equivalent to a 4 flow measuring instrument?
s I guess this is considered an appeal, then?
l 6 MR. PAGE: Is this a back fit item?
7 MR. THOMPSON: Not yet. I guess there are two
- 8 other things that we need to look at. First of all, it 9 doesn't need to be in the program at all.
10 MR. PAGE: I think that would be a lot better 11 route to take, is that it is not safety related.
12 MR. THOMPSON: They say they have an alternate
= 13 method of cleaning the screens, when they are probably not u /
14 important to safety even if you want to use that old is fashioned term.
16 MR. CONTE : Don't say it is old fashioned.
17 MR. PAGE: All I can say is that I don't agree l
- 18 with this statement.
l
. 19 MR. THOMPSON: You don't agree?
20 MR. PAGE : I don't agree with their basis.
21 For not measuring flow. rate.
l 22 MR. THOMPSON: The first question is does it l
23 need to be in the progran.
24 MR. THOMPSON: The first question is does it t
- ' 25 need to be in the program.
l f
l
215 2-13-Jo;Wal 1
MR. PAGE: They have not put up a case for that.
2 Cleaning the screen is not safety related.
3 MR. THOMPSON: Well, that is not what they are 4 saying. They are saying they can do it manually.
5 MR. PAGE: Is that the dedicated source if I 6 pull out the FSAR, you say you send a guy down there to clean 7 the screens manually.
8 MR. COLITZ: That is real life in the power plant.
9 MR. PAGE: I don't agree. I don't think my 10 management is going to agree, but that is up to them. They 11 can do what they want, I guess.
. 12 MR. THOMPSON: So where do we stand on this? Are 13 we going to discuss with management --
C.'J.h 14 MR. PAGE: We can recap how many open items there 15 are.
16 MR. THOMPSON: Let me finish this screen wash.
17 Are we going to discuss with our management'the argument l
18 that it doesn't need to be in the program. They haven't
. 19 presented it to us, but they presented it informally here 20 today.
21 MR. PAGE: I haven't heard it presented. Unless 22 they present it formally, I think we ought to discuss flow 23 instrumentation.
24 MR. THOMPSON: Do you propose to present the 1
2 argument that this pump is not required and is not needed in
2-14-Jo;Wal 216 I the IST program?
2 MR. CONTE: I think they have to review that.
3 MR. PAGE: It is only hooked to emergency power 4 because of convenience then.
5 MR. CONTE: It sounds like it doesn't belong
. 6 to the program because it is hooked to emergency power.
7 MR. THOMFSON: And if it doesn't belong to the 8 program, the easier it goes away; and if it does belong to 9 the program, your argument for not measuring flow rate is 10 that your alternate testing would be to visually observ:,
11 flow rate, and based on the experienced eye of the operatcr 12 you can adjudge the flow rate is within operability range.
13 Is that basically the argument?
{'
14 The staff then could look at that technical is perspective, and say is that adequate, and at this point in 16 time Joel is saying he doesn't agree that that is an adequate 17 technical argument, and I think we ought to present that 18 to management, and come back to you on that.
19 MR. WILSON: I thought there was a little bit 20 more of a twist on that, thought, because I thought what 21 Joe Colitz was saying was that a visual observation is M adequate in conjunction with the other measurements.
23 MR. THOMPSON: Good.
24 MR. WILSON: And I thought also that this appears 25 to be a change in the Staff position, since this was granted
2-15-JoIWnl 217 1 as I read this earlier in '71.
2 MR. CONTE: Yes, and because now you are 3 committed -- the source of it is because now you are 4 committed to the 1980 addition of the Code, which deleted l
5 the permission to rely on fixed resistence.
. 6 And I have a generic question, Joel, and maybe 7 yo'a can help me and perhaps some of the licensee represen-8 tatives.
9 What was the gist of that change from the earlier 10 versions of the Code. What was the reasoning?
11 MR. PAGE: I wasn't involved with Section XI 12 when they made the change. However, I talked to people and 13 they said it was immediately recognized when the '74 Code 14 was put out that that was a mistake.
15 You should measure both all the time. Fixed 16 resistance or.no.
17 MR. CONTE: If the fixed resistance flow -- are 18 there reference values on the fixed resistance flow?
19 MR. PAGE: You have got to have flow meters. You N have a reference value for every parameter.
21 MR. CONTE: This fixed resistance flow keeps 22 trending downwards, does the Code say the licensee has to 23 do something?
24 I thought it was the dependent variable that 25 licensee acts on. He adjusts his independent variables, and
2-16-Jo;Wal 218 I then he acts on a degradation of the dependent variable, 2 which in this case would probably be D-P.
3 MR. PAGE : That is right. But you are assuming 4 that it is fixed resistance, too. Nothing has changed.
5 MR. CONTE: So the measuring of fixed resibtance 6 flow provides you a measure of the degree at fixed 7 resistance, a degradation of such resistance.
8 I am a little confused on that point, does the 9 Code really trigger action because that flow --
10 MR. PAGE: Oh, yes.
11 MR. CONTE : It does? ?
12 MR. PAGE: Yes. What if you were getting clogging
( ,. 13 in the line, and then all of a sudden your D-P goes way up, 14 and somebody says the pump is better now than it was three 15 months ago. It is getting better. It is improving.
16 Oh. Did you want to recap the overall situation?
17 MR. THOMPSON: Yes. At some point in time it t
l 18 might be worth while to go through very briefly the appeal
, . 19 process and backfitting, if that is of interest to you.
20 You mentioned that last night. Do you want to do a
21 it formally, or do you want to just discuss it off the H record.
23 MR. McGOEY : Well, I think maybe as we ge t into 24 the individual issue, we can discuss where it is going 25 through the process, like the Board appeal items are at
2-17-Jo;W 219 1 various stages of backfit review.
2 MR. THOMPSON: Let me just clarify the term, 3 'backfit' a little bit first.
4 It will take a couple of minutes, and it will be 5 on the record, and then the attorneys can have a look at it 6 and make sure what I am telling you is exactly right. It 7 is sort of new to the staff because of the revised manual 8 chapter 0514.
9 The rule on backfitting, as I understand them, 10 backfits are acceptable provided there is safety justifi-11 cation for it.
(} 13 process. They get reviewed. There is a regulatory analysis; 14 essentially a cost benefit analysis made, and at some point is in time there is a decision made that yes, this backfit will 16 be applied to plants.
17 It becomes part of the regulations. Plants will 18 backfit. They generally result in a generic letter, which
. 19 may require plant modifications or all sorts of other things.
20 They become legal requirements under the regulations. Then 21 there are plant specific backfits, which again, in 22 accordance with this revised manual chapter, they go through 23 a fairly similar process whereby a regulatory analysis is 24 done, and a decision is made yes, there is safety benefit to 25 be gained from this backfit, and it will be imposed on a
2-18-JoiWcl 220 1 licensee.
2 It ceases to become a backfit if the licensee 3 voluntarily decides yes, it is of safety significance, and 4
I want to do it, and the licensee chooses to do it.
5 .There is an appeal process for backfits, and
~
6 backfits are essentially requirements that were not in effect 7 at the time that the licensee got the license, or requirement.s 8 that have not been imposed by subsequent regulations.
9 The event -- the order, for example, if the backfit was 10 a backfit at the time, you are still required to do it, so 11 anything that you have to do under the 5055 AG, this section 12 we are working with now, that is in the regulations, and it says you will do these.
{ 13 So, they are not plant-specific backfits.
14 2 MR. MCGOEY: That was a generic backfit.
16 MR. THOMPSON: It was basically a generic backfit, 17 MR. McGOEY: Which underwent both a safety benefit is review, as well as a cost benefit review, so I mean that is
, is an analysis that says on that regulation there is a cost i
20 benefit to do that, and that cost benefit is compared to the 21 incremental increase in safety of doing all these things.
22 MR. THOMPSON: Right.
, 23 MR. McGOEY: So, if we ask for that cost benefit 24 analysis that shows that installing instrumentation that does ;
2 not now exist is cost beneficial for the safety increment,
2-19-JoeWol 221 I we can get that.
~
' ' 2 For example, on this one case we are talking about ,
3 putting in a flow meter on this pump, the incremental cost 4 gives us the safety benefit.
5 That analysis has been done by the NRC somewhere, l
- 6 and we can have access to it.
7 MR. PAGE: I don't think that is true.
8 MR. THOMPSON: I don't believe that that -- this 9 was done generically. The adoption of the Code was 10 generically decided that yes, this will apply to all the 11 plants. Now --
12 but. McGOEY: But there is a cost benefit analysis
]
13 done, right? The incremental benefit to safety has been 14 reviewed from the cost to accomplish that, to see if the 2 cost of putting in all this additional instrumentation
- 16 gives you an improvement in amount of increase in safety.
17 That is what I understands the backfit rule 18 requires, a cost benefit analysis both for generic and 19 plant specific.
20 MR. THOMPSON: _Yes, and what is available, that l
21 is true.' For generic backfit, there is a -- what we call 1
22 a regulatory analysis done, but you won't find in that the 23 cost benefit for putting in a recirc line for your boric acid 24
) ,
pumps, for example.
t: -
>5 s 25 MR. McGOEY: Doesn't the backfit review process
2-20-Jo:W 222 1 require that, to have a cost benefit analysis that F.) ~
2 justifies taking that action?
3 MR. THOMPSON: I believe, and I am not exactly d
4 sure this is correct, but what was done generically was l
5 there were some assumptions made about how much in the way i
. 6 of modifications would be required on various plants,'and i 7 this was taken in a generic sense for all operating plants
) 8 and the decision was made yes, it was a safety benefit to j 9 implementing the latest revision of the code.
[ 10 MR. McGOEY: And there is a cost benefit 11 associated with that.
l 12 NGt. THOMPSON: Well in a very -- I believe in 13 a very general sense.
(^ '
14 MR. PAGE: Can I read a couple of things to the i
t a licensee. This is from a seminar that was given on the is backfit, and this is a description of backfit.
1 17 A staff position that would cause a licensee to 1 18 change the design, instruction, or operation from that l
j ,
19 consistent with already applicable regulatory staff 20 positions.
21 And that is underlined. Taken after certain I
Et design construction or operation milestones involving various 23 NRC approvals, have previously been achieved.
l 24 Now, applicable. regulatory staff positions are s . 25 described as, and there are three basic types, but I am only e--., - _,s-.-- - - - . , ---,- ge., ,% --g. , , , - - - - - .-----4 - a e-w-- Y -,y 5 ww- -w-i'y--7ywrw w--n--w e- 4--r+- w w --v.- ' -w-
223 l
2-21-Jo;Wal 4
i i going to tell you one, because this is the one.
l 1
'i 2 Legal requirements, such as an explicit regulation 3 order, plant licenses, amendments, conditions, technical
! 4 specifications, note that some regulations have update s features built in.
6 As, for example, 10CFR50.55A. Such update 7 requirements are applicable as described in the regulation.
8 MR. McGOEY: So that has been generically back-1 9 fitted to old plants. As long as there is some safety 4
10 benefit, you have to do it regardless of cost.
, 11 MR. THOMPSON: Right. So, as I understand it, j 12 according to that section of the regulations, you have to 13 meet the Section XI, put in all the recire lines, and
[
l 14 everything else that made your flows, and whatever else is l
i ul required by the regulations.
16 The next step is that then you can seek relief i
17 on a specific basis. That becomes -- it is a techical 18 appeal, and where the cost comes in is not real clear because
. . 19 once we have the regulations, our interest is supposed to be 20 safety, not cost.
4 21 Generally, the way the Staff approaches this is i
l '
j 22 we look for an alternate -- some alternate procedures that 1
23 will compensate for not doing the required testing.
24 So, the mode that you are in, and the letter that 25 came back from Denton on August the 16th, went through a i
i
- - - -,_._-.--...,_...m - . , - , , , a . . . , , . m _ _ . . .- --
2-22-JoeW21 224 1 concurrence through the technical line to Denton, to -- I
' agreed and signed off a letter to you, saying that these 2
3 are not backfits.
4 But you still have the technical appeal, and 5 that is the route that we are taking.
End 2. 6 Su;W fois.
7 8
.9 .
10 ,
11 12
)
14 15 .
16 17 18
. 19 l 2 21 22 23 24
': a y
225
- 3-1-SueW 1 Now, when it comes to issues or requirements 2 that the Staff has previously approved we then change our 3 position. That becomes a backfit, even approval of re-4 lief requests, to then disapprove them subsequently to 5 become a backfit, whether or not we should have approved 6 it. Okay.
7 MR. MC GOEY: So, it's not applicable. For 8 example, this last one --
9 MR. THOMPSON: Well, I think this last item, to you stated that -- your response was on the screen wash 11 that you already had been granted relief. Okay.
12 MR. MC GOEY : Right.
13 MR. THOMPSON : B at --
{
14 MR. MC GOEY: 50.55 now imposes that as a require- -
15 ment, to put in that instrunentation. It's a built-in i 16 update.
17
, MR. THOMPSON: Okay. The relief was granted 18 before the update; therefore, it's not a backfit. Relief
. 19 granted af ter the update -- if we granted relief last month 20 and then came back and denied that relief, that would be a 21 backfit.
n Any commitment made by you, whether or not it 23 was required by the regulation, any commitment made by 24 you becomes essentially a regulation. If you want to then i -
25 change that commitment, if you -- let me reword that.
1 1
226 63-2-Suew 1 If you go beyond the regulations, for some reason, 2 you make a commitment to go beyond the regulations and then 3 want to back off to a lesser position which is still in 4 compliance with the regulations, and the Staff denies that, 5 that is not a backfit.
6 You have committed to something more stringent than 7 required, then want to back off and. Staff does not approve 8 that, that is not a backfit.
9 Is that clear?
10 MR. KNIGHT: There is something I would like to 11 know. Are you describing the backfit process that was ap-12 proved by the Commission just recently?
3 13 Or, are you describing the backfit process that 14 is reflected by your Chapter 514?
15 See, what I'm wondering is if your Chapter 514 16 has been updated to the backfit rule?
17 MR. THOMPSON: It's in the process. It is still 18 in only a draft. And I don't know whether that has been 19 finalized.
20 But, yes , that is --
21 MR. KNIGHT: So the process you are describing 22 might not be the same backfit rule process that has been .
23 approved recently?
24 MR. THOMPSON: To my knowledge, I'm describing 25 the latest position on backfitting which is Commission-approved
227 l#3-3-SueW 1 policy.
2 MR. KNIGHT: What was the date on that Chapter?
l
! 3 MR. THOMPSON: I'm referring to April 18, '85, 4 which is an internal memo from Eisenhut to NRR Staff.
4 5 MR. KNIGHT: Okay. That's on plant specific.
6 MR. THOMPSON: NRC Draft Manual Chapter 0514, i
7 NRC Program for Management of Plant Specific Backfitting at 8 Nuclear Power Plants.
9 MR. KNIGHT: So any changes that were made to that to as a result of that fact, thenthe rule would have to be updated 11 by CRGR, whenever they update your Chapter.
t
- 12 But until they do, you are describing a process
() 13 that the Staff follows in accordance with the revision of 14 the Chapter 514.
]
i Hi MR. THOMPSON: I'm not sure about that, because i 16 I don't know that the CRGR updates the Manual Chapters. They 17 are Staff papers that's' the Staff interpretation of regula-18 tions, which is done with the assistance of legal staff but 1
l , 19 not the CRGR.
l 20 MR. MC GOEY: Our understanding of the way it is 21 approved required consideration of installation continuing i 22 costs associated with the backfit.
23 MR. THOMPSON: That's if it is a backfit. What we 24 are saying is on this --
l i
! 26 MR. MC GOEY: That's part of the review that has to
228
- 3-4-SueW 1 be considered in the backfit review -- in other words , when 2 we appeal and it goes to the appeal process, the Staff in j 1
3 reviewing whether it's a backfit or not has to consider )
4 costs.
1 5 MR. THOMPSON: No.
6 MR. MC GOEY: That's --
7 MR. THOMPSON: What has already been accomplished 8 is the Staff looks at the issue strictly in light of the 9 regulations. Is it a backfit, or is it not a backfit?
10 In this case, the Staff looked at the issues apply-11 ing to IST and concluded they are not backfits. There was 12 no cost assessment made.
13 It was simply a legal assessment, is it a backfit 14 or is it not. The determination was that they are not back-Hi fits legally.
16 MR. MC GOEY: Okay. Then, maybe it's a misunder-17 standing what the latest 0514 is.
18 MR. THOMPSON: We did have some fairly recent 19 guidance on that. It's a two-stage process , almost similar 20 to the Sholly (phonetic) process . You look at the issue 21 strictly from a legal perspective and make the determination, 22 yes, it is a backfit; no, it's not a backfit.
23 If it is not a backfit, the Office Director then 4
24 sends a letter to Licensee with that determination. If it 25 is a backfit, then we would notify you -- yes. Yes, if it
229
- 3-5-SueW 1 is a backfit, we would notify you, yes, it is a b..ckfit, and 4
2 we will go through the backfitting process, which then the 3 Staff looks at the regulatory analysis of that which includes 4 cost benefit.
5 If the Staff then comes to the conclusion it's a i
6 backfit and it's justifiable from a safety perspective, then 7 we will inform you of that. Then, you can appeal.
8 And you appeal through the Division of Licensing, 9 through the Assistant Director to the Director, and through 10 to the Director of NRR.
11 MR. MC GOEY: Okay.
12 MR. THOMPSON: On the technical side, if it's
'~N 13 not a backfit but you can still appeal technically, then the 14 appeal process goes through the Technical line, which in this 4
2 case is the Division of Engineering.
16 Again, it can ultimately end up with the Director 17 of NRR. And I think there is some process beyond that I 18 suppose, a hearing or something like that. I'm not sure what
. 18 happens beyond that.
i
- MR. MC GOEY: Okay. All right. I think that's 21 enough. I don't want to get --
22 MR. WILSON: It seems to me that this meeting can 23 be best served if we come to a clear understanding of what we 24 agree on and what we don't agree on, because then we can- go 25 back and I think make some determination.
l
, - ..--g - , . - -
l 230
- 3-6-SueW I MR. THOMPSON: So, Frank Cherny has arrived. He 2
is the Branch Chief in Mechanical Engineering.
3 Let me suggest we take maybe a ten minute break l
4 and we can get our thoughts together, and you can get your 5 thoughts together. I think what we should do is try to 1
1
- 6 identify the items that we are not together on and bypass 7 the ones we are essentially together and have minor cleaning 8 up to do.
9 Can we take maybe a ten to fifteen minute break, 10 and you can make your list and we will make our list and see 11 if we can identify those --
12 MR. MC GOEY: Mr. Wilson has to leave at ten o'cloc c.
13 If we take fifteen minutes, we are losing time.
, f- We are ready
\/
, 14 to start talking now.
I 15 But if you need five or ten minutes , well then
- 16 go ahead and take it.
I 17 MR. THOMPSON: Give us five minutes.
18 (Whereupon,., a recess is taken at 9 :16 a.m. , to i
19 reconvene at 9 :24 a.m. , this same date.)
!l 20 MR. THOMPSON: Okay. We are ready to reconvene 21 here. We have added to the group George Lear who is, as i 22 many people in this organization are acting, he is the 23 Assistant Director for Components and Structures Engineering, l
24 Division of Engineering.
l 26 And we've also got Frank Cherny, who is Acting Branc h 1
i l
I
- - , , . , , - - - - - -, - , , - , - ~ , , , - , , .- - - - . . - ,--~ --. --,-, ---
b i 231
- 3-7-SueW 1 Chief in the Mechanical Engineering Branch. And these two 2 represent management, the management side of the NRC house t '
3 that will be in a position to make decisions.
I 4 And you have Dick Wilson, Vice President; and, 5 Joe Colitz , who is --
1 l - 6 MR. COLITZ: Director of Engineering.
- 7 MR.' THOMPSON
- -- Director of Engineering. So i
8 we have management from both sides of the house here to look i
- '8 at the few, shall we call them, hard issues where the Staff 10 and the Licensee are not together.
1 j 11 Herb, can you -- do you want td take -- who is i
12 going to take the lead here?
i
')
. ,,/
13 MR. MC GOEY: I thought at least I would give a 14 p roposal. We are down to about a half an hour. And we want i
2 to focus on some issues. There are quite a few items that i
16 we need to go back to from yesterday. We are not going to j 17 be able to get to all of those within a half an hour.
18 But if you look at the items that are remaining
{ ,
19 from the initial ten year period, actually there are four 30 items. All of those four items were on the list yesterday.
- 21 And we know that we fought through some review, 22 some appeals, some disagreements already on those four items.
23 I would propose we concentrate on those four items.
i F- 24 And they do overlap with the issues from yesterday.
i N MR. THOMPSON: These items were those that were
-A. . _ . . . . . - . . , _ . - - . _ . . . _ . _ . - , . , . . , _ _ _
, 232
- 3-8-SueW 1 denied as backfit appeals by Denton's letter of August 16.
' l 2 MR. MC GOEY: Righ t. And these essentially are -- l 3
we are pretty much at a standstill at this point.
I 4 We requested an appeal, you denied it. And now 5 we are --
1 6 MR. THOMPSON: On technical appeal.
7
, MR. MC GOEY: On a technical. We are a,t a stand-8 still. And I think, for example, the CA-PlA and B, it is 9 really related also to yesterday's items, DD.1, DD.4 and DD.5, 10 So if we could at least talk about that item first 11 I think that picks up three items from yesterday. So, I N would propose taking that approach.
{ ', 13 MR. THOMPSON: Would somebody take the lead and 14 describe the issues on both sides?
ul Herb, do you want to do that?
16 MR. ROCKHOLD: I'm not sure. Maybe they could 17 bring the focus to the surface a lot quicker on what the is real problem is.
19 I have to get a drawing out on how to explain the
! 20 system configuration.
21 MR. CHERNY: Was there new information that ,
22 came out yesterday or today?
23 MR. PAGE: Initially, the Licensee's case was
, 24 that the pumps were not safety-related pumps. And that's 25 based I believe -- correct me if I'm wrong -- on just redundar c)
I
233 63-9-S ueW I They were redundant sources which, in our normal 2
review process, we don' t accept that. We say that if they 3 are dedicated, whether they are the fourth one, the fifth 4 one, whatever, they are all required to be in the IST program, 5 Okay. Now, in this case here the Licensee said 6 that these are included in the Appeal and that testing at 7 cold -- I'm not really sure what is being appealed here ,
8 because I think we told them in our SSER, we just told them 9 to meet the Code.
10 Okay. So they must be included in the IST program 11 and meets the Code. So, I guess that at this point the 12 Appeal appears to me to be testing at less frequent intervals i
13 than what the Code requires.
~..
14 I believe that's the nature of the Appeal, not 2 appealing whether they should be in the IST program or not.
16 MR. CHERNY : What's the frequency involved?
17 MR. PAGE: Refueling. The case presented by the 18 Licensee is that it takes about fifteen minutes run time to 19 test each pump. .Ls that correct, fifteen minute run time?
- MR. B ASBISTA: Yes.
1 .
21 MR. PAGE: Okay. Which generates their four 22 pumps, involves approximately thirty-two thousand times four 2 gallons of liquid waste at the end of life on the PORV, which 24 seems like a lot to us.
25 I don't understand how that much gets generated.
234
- 3-10-SueW 1 But then again I guess it's some sort of a clean-up thing 2 involved there which is really much more than is actually 3 being pumped in, I would assume.
4 So I guess it came down to whether we should 5 grant them relief to test only at refueling intervals.
6 MR. CHERNY: The Code -- for George's benefit, 7 the Code is quarterly.
8 MR. PAGE: Quarterly . That's cold shutdown 9 testing if it's impractical to do during power operation.
10 MR. CHERNY: Okay.
11 MR. PAGE: However, it doesn' t discuss refueling.
12 That's the Staff position. That in those cases where you
()
\.. ;'
13 really cannot, or it's not practical, or very, very difficult, 14 This could be a case. I'm not sure on this.
15 I'm not familiar with this particular situation as to why 16 so much waste is generated. Maybe they can explain that.
17 MR. SANFORD: Joel, let me give you kind of a 18 thumbnail of where that waste comes from.
l . 19 What we are doing in this test is putting in 20 concentrated boric acid into our system. We then have to l
21 dilute the entire system back dcwn to get back to the proper 2 concentration.
i 23 Although the injection occurs, it has a relatively 24 small amount of concentrated boric acid. It's totally mixed 25 with the entire RCS, which is then cleaned up or diluted
235 1
- 3-11-SueW through a feed and bleed process.
2 Feed and bleed is a dilute concentration. It is 3 a very ineffective means of getting them out. It takes a 4 lot of water to see a small reduction in concentration.
5 And that's why that magnification of waste genera-6 tion occurs. It's most pronounced toward end of life when 7 the target boron concentration is very low, less pronounced 8 at the beginning of life when it's higher.
8 MR. THOMPSON: Could you describe the compensatory 10 measures, if any, that Staff could use as justification for 11 bending the testing frequency?
12 As I mentioned earlier, if testing is not going to 13 be done in accordance with the Code we can of ten look at
{~
14 alternate procedures that you are adopting that compensate.
15 MR. COLITZ: You know, initially we told you we 16 have two boric acid pumps, two reclaimed boric acid pumps.
17 We normally have a bleed tank with high boron concentration.
18 So, you have several redundant sources of boric 18 acid.
20 Now, the tech specs require you to have either 21 boric acid mix tank pumps or reclaimed boric acid mix tank 22 pumps. There is four of them.
23 You are only required to have one for the tech 24 specs. You know, again based on not having recirc lines with
_. m flow instrumentation and everything to do the full Code test,
236
- 3-12-SueW 1 our only available means of really coming up with a reasonable 2 test is to pump to the . makeup tank and by level changes 3 determine basically what the flow is.
4 And we do that on all four pumps on a refueling 5 interval basis. And we do, depending on which one of those
. 6 pumps, which tank we have available -- sometimes we don' t 7 even have any boric acid in the reclaim boric acid tank, we 8 may just have the boric acid mix tank.
9 When we do shut down in cold shutdown conditions, 10 we basically would add boron at that time with one of these 11 pumps.
12 MR. PAGE: You only use one approaching a cold 13 shutdown?
14 MR. COLITZ: Yes.
15 MR. PAGE: One pump?
16 MR. COLITZ: You would use one, and you basically 17 don' t ran a full IST while you are doing that.
18 You would just add what was required to come to 19 cold shutdown conditions. So, there is another -- you know 20 that you have the capability adding. from that source at the 21 time you go to cold shutdown.
22 Again, you are using one pump at that time. And 23 it would be dependent on how your system is set up at the 24 time.
-- 25 MR. PAGE: So you are really reducing the f
237
- 3-13-SueW 1 frequency by only testing that one pump.
2 MR. LEAR: In reality, the Code requires a 3 quarterly testing of all four. So, you are dramatically 4 changing --
5 MR. PAGE: Actually, no, they are not even
. 6 testing one.
7 MR. COLITZ: We are not doing a complete IST 8 test.
9 MR. LEAR: Showing that it's operable.
10 MR. COLITZ: Showing that it's operable.
-11 MR. LEAR: You said that you do not have a recire 12 or a bypass capability for these pumps --
, 13 MR. COLITZ: Not on the boric acid mix pumps.
{ 'S 14 Pardon me?
15 MR. LEAR: You are looking at pump operability, 16 not system operability?
17 MR. COLITZ: Pump operability, yeah.
18 MR- PAGE: You did make a judgment on how much 18 it would cost to get a recirc capability on those pumps I
- believe.
21 MR. COLITZ: That was -- I think Tech Functions
! 22 did a cost estimate of putting in a full recire line along 23 with flow instrumentation. And I think it was on the order 24 of a half a million.
25 MR. PAGE: This is for four pumps?
l
l 238 i l
^#3-14-SueW 1 MR. COLITZ: For two. That was strictly on the
- 2 boric acid mix pumps.
3 MR. ' CHERNY : I guess I'm a little confused. Are 4
4 we really only talking about boric acid pumps? Or, are we 1
8 talking about more than boric acid pumps?
. 8 MR. COLITZ: There is boric acid and there is 7 reclaim boric acid pumps in there.
8 MR. CHERNY: So there is more than CA-PlA and B, i
8 there are two other ones , too.
10 MR. COLITZ: WDL-P13A and B.
11 MR. WILSON: And two of those pumps are positive 12 disp 1 wwnerit pumps.
13 MR. BARLEY: The other item that should probably 14 be mentioned is the tech spec that requires the operability 18 of the boric acid mix pumps and the reclaim boric acid pumps.
18 The tech spec that deals with the backup capability for 17 adding boric acid to the reactor coolant system, the primary l
is method being the decay heat removal pumps from the BWST, or 18 the BWST is the primary source of the makeup system.
l 20 So there is another source of boric acid and 21 that's always available.
' 22 MR. LEAR: These other four pumps come into play 23 as a backup?
[ 24 MR. BARLEY: That's correct, sir.
'. / 26 MR. CHERNY: So, the proposal is to do a complete
239 43-15-SueW 1 IST on each one at refueling outage?
2 Is that the proposal?
3 MR. PAGE: I believe that is what it is. And 4 there are no reliefs associated with those.
5 MR. BASHISTA: We have provided you with relief
- . 6 requests.
7 MR. PAGE: You are requesting relief from some 8 of the testing even on your refueling basis?
9 MR. BASHISTA: On a refueling interval, we can 10 do the complete IST test.
11 MR. LEAR: Oh, I misunderstood what you said i
! 12 earlier, then. ,
s 13 What you are saying is at a refueling outage you gb 14 would test all four pumps?
2 MR. BASHISTA: At a refueling, we would test all 16 four pumps.
17 MR. PAGE: And it would not require any relief 18 f rom --'
19 MR. BASHISTA: Right.
30 MR. PAGE: It wouldn' t be any relief associated 21 with specific parts.
M MR. BASHISTA: That's right.
23 MR. PAGE: So it would be all primary requirements .
l 24 MR. CHERNY : On a cold shutdown, how do you 2 decide which of the four pumps to use each time?
l l
[
- .- - . - .- . _ . . .=- - - . = _ = - _ . . _ . _ _ _ _ - - . . . .
240 1#3-16-SueW 1 MR. SHIPMAN: It would depend on the system line- !
D 2 up. Normally we do have the boric acid mix tank filled with 3 the tech spec required concentration.
- 4 And I guess if you are a percentage person, j 5 ninety percent of the time we would go for the mix tank. If e the reclaim boric acid tanks were our tech spec tank, it's 7 probably ten percent chance we would use them.
i
~
8 Rignt now, the reclaim boric acid tanks do not
{ 9 have any reclaimed boron in them. We've got domin water in i 10 them.
j 11 If we got the restart Order, the mix tank would l 12 be our tech spec tank. We would probably use that if we
, la were to go to shutdown as the source.
14 MR. CHERNY: If I understood what you said cor-I
- 18 rectly, two out of the four pumps would get much more use i
i le than the others would, right?
17 MR. SHIPMAN: Well, in reality, if we have re-I a s j 18 claimed boric acid those pumps stay on recire a hundred per-I J , to cent of the time.
j .
I i m So in terms of usage, if we have reclaim boric 1 .
{ 21 acid, those tanks -- those pumps are continuously running.
I
{ 23 MR. CHERNY: Do we have all of that documented?
1 j 23 MR. PAGE: Not that. '
i 24 MR. ROCKHOLD: This is Herb Rockhold speaking.
~
88 You said you had those other two that are reclaimed boric acid i
241 t' 63-17-SueW 1 tanks on recirc --
n
! b -
2 MR. SHIPMAN: Yes.
3 MR. ROCKHOLD: Utilizing these pumps that we are l 4 talking about now?
5 MR. SHIPMAN: Using the 13 pump, WDL-P13.
!
- 6 MR. ROCKHOLD: It was my understanding that there 7 was no recire flow path available.
) ,
j 8
~
MR. COLITZ: On the boric acid mix tanks , the i 9 CA-PlA/B, there is no recirc. We have a mixer in the tank.
10 Okay.
i 11 That's really the issue. ,
7 12 MR. ROCKHOLD: Okay.
l 13 MR. COLITZ: On WDL-P13A and B, there is s recirc 14 path. There is no flow indication or anything in that.
ul '
It's just a recire off the pump back to the tank 18 to keep the tank mixed.
I
! 17 (The Staff members are conferring.)
18 MR. COLITZ: The other thing is,13A and B are 19 not basically emergency powered.
20 MR. PAGE: The tech specs indicates that at 21 least one of these four must be operable if there is no 22 emergency power.
23 Why is there any credit assigned to that? ,
i 24 MR. COLITZ: Just another source available.
I 26 MR. S ANFORD: This is a backup to the backup at i
1 I
---.. -- . _ . _ - . , . . - _ -, _ .- ~.-__.. - .... - . - _ _ , , _ _ _ _ _ _ . - - . , . . - . . - , . _ _ - _ - , _ . , . . . . . , , . -
242
- 3-18-SueW 1 boration.
o
, 2 MR. BARLEY : Design function is to borate to 3 accommodate xenon reactivity changes, which is a function you ,
4 normally have several hours. It's not an immediate automatic 5 startup sort of function that takes manual action to start.
MD #3 g Joe flws 7 8
D 9
10 11 I
12
. 13 14 j 1.
17 14 19 N
21 1 22 23 24 26
243 4-1-JoeW21
=
1 MR. PAGE: Are you saying that safety related 2 pumps, anything on manual action is not safety-related, 3 is dhat what you are saying?
4 MR. BARLEY: I am saying that the reason that 5 it was included, although it is not emergency powered, is 8 that there are a period of hours to set up that process.
1 -
7 MR. PAGE: I thought you were making the point 8 that because there is not an automatic signal going to l 9 it, that somehow it is not safety related.
10 Some long term items, of course, are up to the 11 option of the operator, depending on what the scenario 12 looks like. They are safety related, they are not auto-13 matically responding to any signal, but they are still 14 safety related.
15 MR. CHERNEY: There seems to be a minor code 18 problem.
17 MR. PAGE: The tech spec says that one of these 18 four has to be operable. If you don't put two of them in 19 the IST program, our viewpoint has been that those two are J'D automatically not operable. ,
21 (Discussion among NRC Staff members.)
M MR. CHERNEY: It sounds like a reasonable 23 compromise might be that the 13-A and B ones, they could
- 24 measure what they can measure readily, quarterly as t
8 specified by the Code, and measure everything at refueling l
l l . _ _ . . -- - .-
4-2-JoeWal 244 1 outages on all four, without installing any additional bypasa 2 lines or anything like that, right?
3 MR. PAGE: That wouldn't require any plant 4 modifications.
5 MR. McGOEY: Except we can't measure flow for 6 WDLD-13.
i
, 7 MR. CHERNEY: I understand that.
8 MR. PAGE: On a quarterly basis to measure 9 everything except flow.
10 MR. CHERNEY: Right. In other words, measure i
11 what you can measure. That is what we are saying.
12 MR. LEAR: And that will be what? What parameters (1 13 can be measured?
14 MR. CHERNY: Delta-P and vibration.
16 MR. LEAR: Delta-P. So you have some indication 16 of degradation or f ailures, or whatever.
I 17 MR. PAGE: Are you umasuring bearing temperatutes?
J 18 MR. BASHISTA: No. I am not positive. I think
)- 19 those have an oil reservoir that surrounds the bearings.
20 I think that is an exception there.
21 MR. PAGE: Is there any relief from --
22 MR. BASHISTA: I think there is, I am not positive ,
23 It is a minor issue.
24 MR. CHERNY: I think what I would like to see 26 on those as a rule is to have a recap document on how I
4-3-JoeWS1 245 I normally, when the tank has the stuff in it and is normally
- All that stuff. I think they ought to document, 2 on recirc.
3 (Discussion among NRC Staff members.)
4 MR. PAGE: We gave you relief request on bearing s temperature. Do you have any trouble with the bearing e vibrations for that design?
, 7 MR. BASHISTA: We measure by vibration.
8 MR. PAGE: No trouble measuring vibration?
9 MR. BASHISTA: No trouble at all.
10 MR. PAGE: Is that all we need on that item? What 11 exactly is the action on that?
12 MR. McGOEY: It sounds to me that you are giving at least, speaking out loud about it, a possible compromise
{". 13 14 position so long as we provide additional information for ul you to consider, and the action on our behalf to provide
~
18 additional --
17 MR. CHERNY: To provide the information, and we 18 will respond kind of like what I was just saying. Do you !
. 18 have a problem with that particular approach?
3D MR. SANFORD: Tech spec pump for boric acide, test I 21 it quarterly; as much testing as we can do, and on a refueling 22 basis run..a complete IST. I 23 MR. LEAR: I would suggest rather than saying 24 as much as we can do, specify --
e 4-4-JoeW21 246 1 MR. SANFORD: As far as the clarification we i.
' 2 are trying to make here, when there is not a tech spec 3 pump, it would not fall under that surveillance.
4 MR. PAGE: What exactly do you mean by when 5 it is a tech spec pump?
6 MR. SANFORD: We declare the pump that is the 7 tech spec pump.
8 MR. SHIPMAN: If it would be out, it would i
i 9 simply be inoperable.
l 10 MR. ROCKHOLD: You could utilize the Code to i
l 11 establish that. .
12 MR. SHIPMAN: That is what we would have to do --
13 MR. ROCKHOLD: Declare it as a pump in a system 14 out of service, or a pump out of service. ,
2 MR. COLITZ: Right now, the tech specs allow me
\
16 if I claim the boric acid mix tank is my tech spec tank, and 17 my pumps is a tech spec pumps, I could throw the reclaimed 18 boric acid -- I could remove the reclaimed boric acid tanks 19 and pumps from the plant. I don't need them.
- so MR. PAGE: What does that mean in the overall?
i 21 These four pumps, then you could take four of them and just ,
i 22 ignore them so long as one --
l 23 MR. COLITZ: No. I have to have one operable for 24 us to meet the tech specs , and I also have to shutdown.
i 25 MR. PAGE: One of the four.
4-5-JoeW21 247 4
! 1 MR. COLIT : Yeah.
es
', j 2 MR. PAGE: Say that is CAP-1-A.
3 MR. COLITZ: Yes.
4 MR. PAGE: And you declare I have done my s refueling test.
s MR. SHIPMAN: Excuse me. You do the refueling
, 7 test on all four of them. Whether or not you are going to
- a use them at this particular moment as a tech spec tank.
9 You do all four on a refueling interval.
10 MR. PAGE: Okay. Let's just say you came out 11 of a refueling and you tested all four pumps, and you decided 12 that CAP-1-A was going to be the one that --
( *; 13 MR. SHIPMAN: Is operable.
l 14 MR. PAGE : Yes, for your tech spec. What would
[
u that mean to the quarterly testing of the liDL pumps? Would is you leave that behind until whenever, as long as CAP-1-A was i
17 filling the gap? Would you declare those out of service is because you didn't really need them?
, is MR. SHIPMAN: In a practical sense, if there was so fluid in the tank, we would probably continue to run the 21 quarterly testing, because the pump is running anyway.
22 MR. PAGE : Well, you said, 'we would probably,'
23 and I was just wondering --
l . 24 MR. SHIPMAN: Well, if there was nothing in the 26 tank --
l r
I 4-6-JoGW31 248 1 MR. PAGE: No, no. Assuming that you are recircingq 7 -w ,
'q 2 MR. SANFORD: I don't know if that is a good 3 assumption. During the ten year period, it is quite possib1<t 4 that the tank will be empty for some period of time.
5 If it is empty, we are not going to be running
~
s pumps, and we are not going to fill the tank to run the
, 7 recirc-test.
8 MR. CIIERNY: I think we understand that.
9 MR. THOMPSON: Let me ask. Rather than doing to it quarterly, if the WDL pump pumps are declared tech spec 11 pumps, and if they are not you won't do the testing for it.
u Well, let me suggest that you then commit to doing the testing at the next time that the reclaim tanks
{ 13 14 are fullest.
2 Because conceivably you could go from one is refueling to the next and never use the reclaim -- that that 17 reclaim tank would be full wouldn't coincide with a three is month interval if we would and up never checking these WDL
. 19 pumps.
20 MR. COLITZ: What we would do if we had the boric 21 acid mix tank and pumps tech spec pumps, before we reclaim 22 that boric acid tank and pumps as the tech spec pumps, we as would ensure that we had a valid IST test run on them.
24 MR. THOMPSON: If they hadn't been on the
"-' 26 previous three months?
249 4-7-JoeW21 1 MR. COLITZ: We would run them.
/.
\' 2 MR. CHERNY: I think you should put all that in 3 your documentation. The only comment I want to make was 4 maybe by tech specs right now you can take out the one 5 system you were talking about. When we write our SER in i
6 granting the relief on both of these two sets of pumps,
. 7 they are going to be tied to each other, so you won't be 8 able to take out the one set of pumps without us changing 9 our relief write-up. ,
J 10 MR. P AGE : It sounds to me like you can ignore l
{
11 three of them as long as you say that one of them is the 12 one.
(' 13 MR. CHERNY: But as far as the basis of the relief on four of them, it is a fact that they are tied 14 N to each other, okay?
16 They are all there as a package, all four of 17 them. That is part of the back-up.
l I
18 MR. PAGE: There is a concern, because if one
- 19 pump were, quote, the ' dedicated one' to meet a tech spec, 30 that these could easily jump from refueling to refueling, 21 and pick out one pump, and then go to the next refueling.
. 22 It is possible , so we are hoping to see a
- 23 writeup that could kind of tie them together as a group, 24 and that that wouldn't happen.
26 MR. CHERNY: I think all the elements ane there
I 4-8-JOCW31 1 to document the points we are making here.
- MR. THOMPSON: What about the associated valves?
2 3 MR. CHERNY: Associated valves.
4 MR. THOMPSON: DD-1 and DD-5.
5 ( Discussion among NRC Staff members.)
6 MR. McGOEY: DD-4 and DD-5.
. 7 MR. PAGE: I don't see any discussion except a on DD-5.
9 MR. ROCKHOLD: The drawing that we have does to not show the recirc line for the reclaimed boric acid 11 tanks.
t3 We have the ISI drawing, and then the revised PNID.
') 13 14 MR. SHIPMAN: 692, 3, or 4, is the Print 15 number that has that on there.
16 MR. ROCKHOLD: This one is chopped off.
17 MR. SHIPMAN: Here is the recirc line right is in here (pointing.)
, 19 MR. ROCKHOLD: Recognizing that some people here so have some time constraints, why don't we try to forge through 21 the rest of this boric acid makeup system, and at least try 22 to come to some near conclusion and the way this side of the 23 table sees the operability testing of the valves, is all of 24 the power operated valves are identified for the WDL pumps, 26 and boric acid tank oumps.
251 4-9-JocW21 1 We see no obvious reasons why those valves 2 cannot be exercised quarterly. Exercised in stroke time.
3 The check valves on the discharge of the 4 recycle pumps, we see as being no problem being exercised s as long as there is liquid in the tanks.
- 6 Whether it is boric acid or whether it is demin 7 water.
3 If there is liquid in the tank and you can run g the pumps, we see no problem with stroking the discharge 10 check valves.
11 Now, may I identify the other three check valves 12 that we see you may have a problem with.
13 CAB-177, WDLV -- it looks like it is 362 and 361.
('s )
Those three check valves we would entertain any arguments 14 ul you have right now concerning quarterly testing versus any le other testing freq0ency
- proposed.
17 MR. COLITZ: Those you can't test unless you 18 run the pump and inject, is that true?
19 MR. BASHISTA: That is correct.
20 MR. COLITZ: Again, going back to -- what I think 21 we concluded earlier, that we would do a full code test on 22 CAP-1-B on the refueling basis. The check valves would 23 fall into the same category.
24 The only way you are going to check them is to 25 put flow through them.
l
1 252 4-10-JoeW21 1 MR. ROCKHOLD: Okay. That is the way we see ,
1 2 the system also.
3 Now, you are saying CAP-1-A and B?
4 MR. COLITZ: Yes.
5 MR. ROCKHOLD: Whereas' all of the air operated 4
6 control
- valves that are identified in the IST program 7 be associated with these pumps, you will full stroke and 8 stroke time quarterly.
9 MR. COLITZ: We.will do them quarterly.
10 The only other comment on the 13-As and Bs, again where 11 we said we would do the full code test on those two pumps 12 on a refueling basis, and then we would look at doing what
'; 13 we could and tell you what testing we would do on the
(
14 quarterly basis, we will address again how we look at them 15 as tech spec tanks, and specifically when we will test them 16 and take credit for them, and I think the the check valves 17 then associated with those two pumps would fall into that i
18 frequency.
. 19 MR. ROCKHOLD: Okay. I believe we all understand P
20 where we are on this particular topic, and again knowing tha-:
21 people have time constraints here, do we want to attack the ,
H other major open item that we have, which I believe is Q.4 23 is the one I had marked.
24 The basic issue on items 0 3 and 4, is one, the 2 safety significance of the emergency turbine driven --
4-11-JoeWal 253 1 MR. McGOEY: Excuse me. Before we get into (n
q, 2 Q.4, do you want to talk about pressure isolation valves e
3 at all?
4 Denton's letter to us said you were going through 5 a review.
~
6 MR. THOMPSON: I think the Denton letter explains
. 7 it. You are not obligated to include those at this time 8 in the testing of those.
9 Let me get the wording out of the letter.
10 MR. McGOEY: I don't know if you can shed any 11 other additional light as to the status. I mean that --
12 MR. CHERNY: Yeah, I can shed some additional In terms of generics, not in terms of your
( 13 light on it.
, 14 particular valve work at this time, but we have met with 15 CRGR late in July, and basically described the fact that 16 we were in the process, or have been in the process the last
, 17 couple of years of backfitting, and used this kind of a 18 valve list on older plants as part of the IST. review, and
. 19 had imposed these same testing requirements on all the NTOLs 20 that have been licensed since March of '79.
21 And basically their instructions to us at that 22 meeting -- the meeting was specifically on July 24th -- we
- 23 were approved to continue to proceed on NTOLs to impose the 24 full testing requirements, and we were asked to come back wit 1 M a somewhat reduced list as an interim measure on older i
4-12-JoeW21 254 1 plants.
2 We haven't fully worked out what that interim 3 thing is yet, but until we do that, and until we go back and a
4 have another meeting with them, we are really not in a 5 position to tell you, for example, which ones of these will 6 be on the interim list and which ones wouldn't. We don't
, 7 know yet.
a So that is really where it stands today.
g We are not stopping IST reviews. We are just to putting all of this PIV stuff kind of on hold.
11 MR. PAGE: Logistically speaking, the SER still 12 has the information. However, the transmittal letter.
That way at least you will know where we are coming from.
13 14 Which valves we think they are and stuff like that.
15 However it clearly says in the transmittal letter 1,
16 that no action is required at this time on Item 3.1.4, 17 because it is under CRGR review, and at that time we will is have the generic resolution.
. 19 MR. McGOEY: Okay. We will get that type 20 response for the initial ten year period. Valves in 21 que.stien, as well as the second ten year period valves 22 in question.
2 MR. PAGE: What does the initial ten year period u, have to do with it?
2 MR. ROCKHOLD: Those six decay heat valves you
_. _ m _ _ _
4-13-JoeW21 255 I 1 are talking about. !
2 MR. CHERNY: The valves that you already have 1 3
under an order, the Event V Order, they are not affected 4 by this ongoing discussion with CRGR. You are stuck with 5 those.
6 MR. McGOEY: Right.
7 MR. PAGE: The Event V valves are all state of a the art.
g Did you give them a copy of the list?
10 MR. THOMPSON: The resident inspectors now will 11 be working also from that Denton letter which clarifies t
i 12 which valves need to be excluded under this PIV.
MR. McGOEY: Okay. Okay, that is fine. I just
{ 13 14 wanted to clarify that, because we thought it would be a worthwhile to get an update on where you were on that issue.
16 Why don't you go back to the Q.4.
17 MR. ROCKHOLD: Okay. Q.3 and 0.4 are both open 16 items. Both of the same general topic. Item 1 discusses
, , 19 the steam supply check valves and the partial stroke that so they currently receive, and a brief discussion of the 21 possibility of full stroke exercising, and then in 4, I 22 believe that is where we started discussing whether the j
2 EFP-1 is truly safety related pump. ,
24 We were going to get some additional input for 26 that topic.
l 1
I 4-14-JoeW31 25s 1 MR..CHERNY: You lost me with that last one.
', 2 Say that again?
3 MR. PAGE: Basically, previously we had been 4 banking on licensee supplying information which indicated 5 that 48 percent flow rate through the valve indicated an 6 eighty percent open -- nachanical qpudng of the valve.
7 Further study, though, has indicated that i s morit 8 in-line a 36 percent opening, so what has happened is 9 that they have in the interim period between our SSER and not, 10 disassembled one of these two valves, the 9's. The MSV-9s, 11 and found it to be in excellent condition.
12 They said they would supply a disassembly report.
( ; 13 And I believe they are the~ones they have photographs of, or 14 not?'
15 MR. COLITZ: We have probably photographs.
16 MR. CHERNY: There is one piece of missing 17 information. How far open does it have to be? Does anybody 18 know? Does it have to be full open, or doesn't it?
18 MR. PAGE: I guess it would have to do with what 20 maximum flow rate on the aux feed pump is.
21 MR. ROCKHOLD: Well, as far as flow rates are 22 concerned, then they say they only get about 40 percunt of 23 design flow.
24 End 4. #
SueW fois.
l
257 85-1-SueW 1 MR. SHIPMAN: Forty-eight percent.
2 MR. ROCKHOLD: Okay. So that's still less than 3 half.
4 MR. CHERNY: I'm sorry. I didn' t hear the first 5 part of what you said.
6 What did you say?
7 MR. ROCKHOLD: Their current test got, what, 8 forty-eight percent? Was that the number? What flow rate 9 was --
10 MR. SHIPMAN: Forty-eight percent flow rate.
11 MR. ROCKHOLD: Forty-eight percent of rated flow 12 through the check valve during the current testing.
(
13 MR. CHERNY : Okay. Now --
1* MR. ROCKHOLD: As f ar as valve position is ' con-1.5 cerned, I think it's irrelevant.
16 MR. CHE RNY : Let me ask the question a different 17 way.
13 What do you have to do to push rated flow through 19 the valve? What is the procedure?
20 MR. ROCKHOLD: One way of doing it is to pump 21 condensate storage tank water into the -- a hot steam 21 generator. It has to be steam available to drive the turbine.
%I Therefore, the steam generator has to be hot, 24 putting cold oxygenated water in a hot steam generator.
26 Their concern there is degradation to the steam generator, I
l
258
- 5-2-SueW 1 which I think is a valid argument.
2 MR. CHERNY : I can understand that.
i 3 MR. ROCKHOLD: Okay. The recirculation test 4 flow path is how they get this forty-eight percent rated 5 flow.
6 MR. CHERNY : I see. I understand now. What is 7 the question about the turbine driven pump?
8 I did not follow what the issue was there.
9 MR. ROCKHOLD: Okay. There was a discussion 10 yesterday about the turbine driven emergency feedwater pump I
11 and whether it is truly a safety-related pump, whether they 12 actually take credit for it.
4 u
( 13 MR. SHIPMAN: But that was related to four, five 14 other valves , MS-V8, MS-V22 and MS-V6.
15 MR. ROCKHOLD: Well, if the pump is safety-related l
16 then it is safety-related for all associated valves. If it's
) 17 not safety-related, then it's not safety-related for all 18 associated valves.
. 19 MR. MC GOEY: We can divide it into two issues 20 that we should address. I think we should address Q.3 first 21 which is -- I guess we are looking for a response to our 22 proposal dealing with the MS-V9s that we made yesterday.
23 Then, we can talk about the Q.4 which deals with 24 the MS-V6, 8 and 22.
26 MR. PAGE: AS-V47
259 45-3-SueW 1 MR. MC GOEY : AS-V4 I thought yesterday that 2 our proposal was acceptable.
i a 3 MR. PAGE: Okay. I didn't pick that up in my 4 notes.
8 MR. CHERNY : What was acceptable?
- a MR. PAGE: AS-V4.
7 MR. CONTE: To further clarify the P1 pump is a not seismically qualified. There fore , you can ' t say it's
! 8 fully safety-grade.
10 It's relied on in tech specs as -- it is a tech 1 11 spec pump, similar to the CA-P and the WDL, not fully 12 safety-grade but it is relied on in the tech specs.
13 The P1 pump is a hundred percent capacity pump.
j
(~
l 14 The two motor driven pumps are fif ty percent capacity; however ,
is any one electric driven pump has sufficient flow requirements is to remove decay heat within I think three minutes or five 17 minutes, seven minutes, after a reactor trip.
18 So, from a small break LOCA, which I think is i
19 a primary need for EFW, one electric driven pump -- the two 20 electric driven pumps are redundant to one another. Technically 21 I guess you wouldn' t need the P1 pump, but apparently there 22 is a lot of Staff reliance on the P1 pump.
23 So the question came up yesterday, what is the 24 safety-grade status and what is the design licensing basis
{
25 of the P1 pump, because it's not seismic.
I
260
- 5-4-SueW 1 MR. PAGE: Okay. From our past experiences, if 2 it is a tech spec pump we usually require it be in the IST 3 program.
4 liR . CONTE: So that sounds like that issue is 5 resolved. There is no problem.
6 MR. CHERNY : We can take that as an action item 7 to check it with the Systems people. But I would say that 8 is what they are going to say.
9 MR. CONTE : But that's going to generate the 10 questions on the MS-V8s as to whether you are going to be
~
11 diverse. The MS-V8 is a potential -- if it f ails , it may 12 divert steam from that P1 pump.
13 Licensee position on MS-V8?
14 MR. COLITZ: I'm still trying to get back to 15 0.3. We are jumping around here. I think we need to take 16 one issue at a time.
17 We were talking about MS-V9A and B. And we 18 disassembled one.
19 MR. CHERNY : When was the last time you disassembled 20 the other one?
- 21 MR. COLITZ: Well, we committed yesterday -- or, 22 we proposed yesterday that we would disassembly the 9A prior 23 to the next cycle.
24 And we would also, since we didn't include the 25 disassembly report for -- we didn' t include our inspection in
261
- 5-5-SueW 1 9B because it was after the -- we submitted the disassembly 2 report, we would go back and give you the details of that 3 inspection.
4 MR. CHERNY : So, I think what he just said was 5 they are going to disassemble the other valve at the next
. 6 refueling outage , or something like that.
7 MR. COLITZ: Yes.
8 MR. PAGE: I would say pending receipt of that 9 information, we could probably try to adjust some alternating 10 schedule.
11 MR. CHERNY : I think what we would do is, assuming 12 it comes out in a similar fashion, we would try -- we would
{', 13 think of some longer inspection interval.
14 But just of fhand, I would say one valve each 15 five years or something of that nature.
16 MR. MC GOEY: Our proposal yesterday is that we 17 looked at 9B and it was clean, that we would look at the 9A 18 valve at the next outage, or next cycle.
19 And if that was okay, like we found on 9B that 20 we would inspect al,ternately each valve every ten years. If 21 one does not look good in that inspection, then we would 22 automatically look at the other one.
23 That's what our proposal was.
24 MR. CHERNY: Let's see, how long -- just for sake 25 of discussion, how long have those valves been in service?
l t
262
- 5=6=SuaW 1 Thnt'c an cary qu:stion to ancwnr concidaring 'they hnv::n' t l l
' 2 been in service for a few years.
3 If the plant had been operating -- when was that 4 plant licensed?
5 MR. COLITZ: In '74.
6 MR. CHERNY: '74.
7 MR. PAGE: Basically it's five years service.
8 MR. CHERNY: The last five years it has just been 9 sitting there.
10 MR. SHIPMAN: There has been testing performed 11 in the last five or six years that would be no different 12 than if we were at power, because the tech spec requirements 13 for these pumps are above the 250 degrees and we have been 14 at hot shutdown several times in the last six years.
M MR. PAGE: So you are saying that the service of 16 these valves has been identical over the whole ten year IT period?
18 MR. SHIPMAN: It has not been at zero. We have 19 been using them, probably not as much as the first five 20 years.
. 21 MR. PAGE: Would you say it's very comparable to 22 the very first five years, or dramatically different?
23 MR. SHIPMAN: I would say it's close.
24 MR. PAGE: Very close?
2 MR. CHE RNY : When you send in that additional
263-64
- 5-7-Suew 1 report, why don't you -- I think that would be helpful --
l 2 describe that a little bit? Otherwise, we are liable to 3 lose track of that.
4 I would like to have that document. We will take 5 a look at t.' at and give that some thought. Maybe we can
. 6 justify five years.
7 I'm not going to say we will agree with ten today, 8 but we will look into it.
9 MR. THOMPSON : So, let me try to summarize that.
10 MR. CHERNY: Yes , why don' t you try.
11 MR. THOMPSON:
Let's see how I do. On -- this is 12 on the MS-V9A and B valves. You are going to provide a 13 description of the testing that has been done during the
{
14 approximate four years of operation and six years of not 15 operation.
16 MR. CHERNY : It's not so much testing I guess as 17 the operational service that the valve has seen.
18 MR. THOMPSON: Okay. So, the operational service 18 the valve has seen, summarize the testing that_ has been 20 done particularly during the last six years which has been 21 more than zero but presumably something less than it would 22 have been had you been in operation.
23 You are going to describe the disassembly of one 24 of those, I halieve the B valve some time in the last couple
! 25 of -- that was very recent, correct?
l l
l
[
265
- 5-8-SueW 1 MR. SHIPMAN: '84.
2 MR. THOMPSON: Since the October -- or, since the 3 recent disassembly report, you've done the 9B and you will 4 describe that disassembly.
5 And I think yesterday, you said you would provide 6 photographs.
7 MR. SHIPMAN: If we have them.
8 MR. PAGE: I think they said they would provide 9 photographs and the disassembly report on the valve that was 10 done in late '84.
11 I presume we will get a similar report following 12 the next refueling.
13 MR. THOMPSON: And you are proposing to do 14 another disassembly of the A valve at the next refueling.
15 Is that correct?
16 MR. SHIPMAN: Correct.
17 MR. THOMPSON: And subsequently alternating every 18 ten years with disassembly of the second valve if the first 19 one shows degradation.
20 MR. SHIPMAN: Correct.
21 MR. THOMPSON: And the Staf f has said that we 22 are not satisfied that the ten year interval is acceptable 23 and indicated that a five year interval certainly appears to 24 be acceptable , and we would look at the five year or ten year 25 disassembly interval.
266
- 5-9-SueW 1 MR. PAGE: Your discussion on the five or ten
' 2 years I think was correct, except that that's assuming that 3 the other valve is perfectly clean.
4 MR. THOMPSON: That's a given. We have already 5 agreed that if the first valve that they disassemble is de-
. 6 graded in any way they will then do the second at the same 7
time.
8 MR. PAGE: Okay.
9 MR. THOMPSON: So, we are together except for 10 the frequency of disassembly, and getting the reports.
11 MR. CHERNY: I think they have agreed on the U report.
Okay.
~
13 MR. THOMPSON. That resolved then, 0 3 14 which was also Item B.2.b of the Denton letter, the --
15 MR. CHERNY : It was?
16 MR. PAGE: B.2.b, yes.
17 MR. CHERNY : I only have MS-V9A and B on mine.
18 MR. THOMPSON: Now, we are going to move on to 19 Item Q.4.
20 MR. CHERNY: My understanding was there is one 21 more Appeal.
22 MR. THOMPSON: We would like to now go to the 2 third Appeal item which is Item 3.3. A of the Denton letter.
24 MR. CHE RNY : I guess from this little write-up 25 I don' t recall -- I'm not up-to-date on what the concern t
l , - -
l
I 267
- 5-10-SusW 1 is at the moment.
2 MR. THOMPSON: Let me identify what it is for 3 the record. Item B.3. A of the Denton letter, Item I.1 of 4 the August 22 Response to Questions, and it's the emergency 5 river water source check valve, EF-V3.
6 And yesterday -- Herb, why don't you proceed?
7 MR. ROCKHOLD: Okay. The valve in question, 8 EF-V3, is the river water supply to the suction of the 9 emergency feed pumps. Okay. \
10 Currently, the testing you are performing is a 11 very small part stroke through a drain line and a vent line ,
12 correct. And you have disassembled this particular valve 13 one time , visually examined the internals , found it to be
{.
14 like new condition.
la And your proposal from here on out is to perform 16 this partial stroke exercise, utilizi vessi. arid drai4 114=s 17 quarterly. Is that correct?
18 And no subsequent disassemblies?
19 MR. COLITZ: Until we remove the internals.
20 MR. PAGE: Excuse me. You are assuming that the 21 internals will be removed. We don't really know at this 22 point that they are going to be removed; is that correct?
23 Is that --
24 MR. CHERNY : Where does that evaluation stand?
25 I was in some meeting with some of you a couple of years ago
268
- 5-ll-Suew 1 and --
6 2 MR. COLITZ: We basically committed yesterday 3 we will have a package by this end of this month to remove 4 the internals. If we don't have the internals removed by 5 the end of our ninety day eddy-current outage, which was 6 committed to when we go back into power operation, we commit 7 to a disassembly of that valve.
8 MR. PAGE: On what frequency?
9 MR. COLITZ: Once every ten years.
U) MR. PAGE: They did provide photographs of the 11 valve yesterday. It looked good. And it looked like a 12 pretty decent design, too.
/7N 13 MR. THOMPSON: They showed us photographs and
(. . )
14 they will be providing us --
15 MR. PAGE: Yes. I thought they were going to 16 provide the disassembly report.
17 MR. CHERNY : Did you ever have occasion -- I 18 mean, that's just sort of an ultimate heat sync kind of a up valve. You don't really ever use that thing in service, 20 do you?
. 21 MR. BASHISTA: No.
22 MR. COLITZ: We would have to exhaust three other 23 backup sources before we got to that one.
l 1
( 24 MR. CHERNY : So, you can't say that it's in any 25 kind of a flow situation where it is fluttering or anything l
l
I 269
- 5-12-SueW 1 like that. It's just sitting there.
' 2 . MR. ROCKHOLD: The only real flow through the 3 valve is to quarterly test. I believe this is a six inch 4 valve, and they are utilizing a temporary hose connection 5 on a vent line that is a one-inch line.
- 6 ( A discussion among the Staff members ensues.)
7 MR. CHERNY: Is it normally dry in there? Is 8 there water in that line norma,lly or not?
9 MR. SANFORD: Yes.
10 MR. ROCKHOLD: It is water in the line, but it 11 would be my guess that you are using some kind of fresh 12 water. I don't know if it would be demin water, to perform 13 this quarterly test.
{
14 So it's not river water that is on the pump, is that are in the valve internals. Normally it's cleaner 16 water just because of the water they use to perform the I 17 quarterly valve test.
18 But it's still water.
- 19 MR. CHERNY
- Whatever they have been using
\
l l 20 doesn't seem to disturb it.
\
21 MR. PAGE: Not so far, that's correct.
l 22 MR. SHIPMAN : There is one correction to your 23 write-up that says we will do something prior to the eddy-24 current outage.
J
25 MR. P AGE : By the end of.
270
.#5-13-SueW 1 MR. SHIPMAN: We said we would do by the end 2 of that outage.
3 MR. CHERNY : So the proposal is just to remove 4 the internals, I guess is the real proposal.
5 MR. PAGE: Yes. But I think we have to think 6 about it in terms of what does apply even through their own 7 plant procedures. See, we are not even really sure they are 8 going to be gutted or not.
9 And if we were sure, I think it would be a moot to point anyway. It would be just a matter of when.
11 MR. THOMPSON: The question really is the ten 12 year interval.
MR. CHERNY: Well, they can' t make two proposals.
(~, 13 14 What is the proposal that is being made?
H5 MR. COLITZ: The proposal is that we remove the 16 valve.
17 MR. CHERNY : We don' t have any problem with that, 18 right?
19 MR. PAGE: We can' t grant that, though. That so is in somebody else's ball park.
- 21 MR. COLITZ
- Our intent is to remove the valve 22 and get this issue off the book, okay.
23 MR. PAGE: If it's removed, obviously you won't 24 have to test it.
's 26 MR. COLITZ: If that toesn' t happen, we are going l
f 271 i #5-14-SueW 1 to do quarterly testing, part stroke, and a disassembly 2 once every ten years.
2 3 MR. PAGE: Since you feel so much assuredness 4 that it will be gutted -- and I kind of got that in between a
s the lines, ? hat you do feel that -- would you have any 6 trouble committing to a five year disassembly, since 7 obviously if you gut the valve that goes away anyway?
8 MR. CHE RNY : Well, why do you have to do it that 9 way? Let's have them make the commitment at this time to 10 remove the thing and --
11 MR. PAGE: I don' t think they can make the 12 commitment to remove the valve.
MR. BASHISTA: We are presently evaluating it's
{ 13 14 safety significance.
15 MR. CHERNY : They are not that far along, then.
16 MR. PAGE: It's going to the plant at this 17 time --
18 MR. ABRAMOVICI: At the end of the month.
19 MR. PAGE: At the end of the month, the proposal 20 is going to the plant for their review. So, we are not 21 really banking. We don't know for sure how the plant is l
22 going to react to that.
23 MR. CHERNY : Why is it there?
24 MR. PAGE: Well, that was our question, why is
. 25 it the re . And nobody could answer it. So, we said if
272
- 5-15-SueW 1 nobody knows why it's there why don't we take it out and 2 see what happens.
3 So, that was where we lef t it.
4 MR. CHERNY : Well, they are going to know in a 5 month whether they are going to do it or not?
6 MR. PAGE: No, no, no. They are going to submit 7 it.
8 MR. CONTE: No, you will know.
9 MR. SANFORD: Within a month, the engineering 10 package will be on site to do the job. There will be a 11 decision to do it at that point.
12 MR. PAGE: In a month, you will know for sure 13 whether it's going to be gutted or not?
(
14 MR. CHERNY: Well, they are going to have to 2 give us some additional information anyway as a result of 16 open items.
17 Cant that just be an open item until that 18 time?
19 MR. PAGE: I don' t know. When is it going to be 20 the turnaround on this next thing we are asking for? Do 21 you know, Owen?
22 There are going to be some upgrades to the 23 program. Could that all be part of this same package?
24 They have some open items to get back to us.
3 MR. CHERNY : We have some for them. But they
273
- 5-16-SueW 1 are going to have some for us, too.
- 2 MR. MC GOEY: I don't know why it cant be in 3 the same package.
4 MR. THOMPSON: I suspect that it will be.
5 MR. CHERNY: It sounds to me like it's about
. 6 in the same time frame.
7 MR. THOMPSON: I think that probably the best 8 thing to do is that it probably will be a month before all 8 of the results of this meeting get turned around, at which 10 time you may very well know what the resolution of this 11 EF-V3 is, at which time you can give us a positive position.
12 And if the internals are not being removed, 13 then you will come in with a proposal for -- similar to 14 what you talked about today. And if you put in ten years, 15 you put in ten. And if we dodt like it, we will come 16 back and we will have to have another go-around on it.
17 MR. MC GOEY : Fine.
18 MR. THOMPSON: We don' t have to agree to a ten 18 year period right now, and nor do you.
20 MR. CHEPNY: The best thing to do is get rid 21 of the valve.
M MR. THOMPSON : So, that sounds like we have 23 either resolved this issue or essentially resolved it 24 depending on whether the internals are removed or not.
l 25 And --
274
- 5-17-SueW 1 MR. MC GOEY: Right.
2 MR. THOMPSON: -- I don ' t think that that five 3 year versus ten years is going to be a real sticking point.
4 I think we can probably work that out at the Staff level 5 without management having to make any decisions on it.
. 6 MR. PAGE: It certainly doesn't present itself 7 right now.
8 MR. CHERNY : Okay.
9 MR. ROCKHOLD: Okay. Were there any other 10 important topics that we wanted to discuss right now with 11 everyone currently present?
12 Any Appeal items that you wanted to discuss?
} 13 MR. MC GOEY: That's it for the four Appeal 14 items.
15 MR. ROCKHOLD: Okay.
16 MR. MC GOEY: We haven't got into Q.4.
17 MR. CONTE: It's my understanding that the 18 Appeal items are no longer Appeal items; they are going to 19 turn into Relief Requests.
20 Is that what is happening here? That is based 21 on these proposed solutions we just discussed on these three ZZ items .
23 MR. THOMPSON: We denied the Appeal as backfits.
24 The letter stated that -- or suggested that if they wish they M could come in and make a technical appeal. There was no
)
275
~
- 5-18-SueW 1 formal request for technical appeal. We handled it in-2 formally, having the Assistant Director represented here 3 today.
4 So, we have actually gone through the first 5 stage technical appeal. And it seems like everything is 6 essentially resolved such that I don't anticipate any 7 further appeal on a technical appeal on these items.
8 MR. CHE RNY : They are relief from Code require-9 ments.
10 MR. THOMPSON: And essentially --
11 MR. CHERNY : The last one, of course , doesn' t 12 have a Code requirement. If they,take the internals out, 13
(~') it's not a valve anymore.
14 MR. THOMPSON: They have modified relief from is original proposals. We will need clarification in writing 16 from you.
17 MR. MC GOEY: Yes.
18 MR. CHERNY: So , we don ' t have any -- you 19 don't have any more for George; is that what you are saying? ,
20 Okay. You are welcome to stay, of course, j
21 MR. LEAR: Thank you.
22 (Mr. Lear leaves the meeting room.)
M MR. PAGE : I guess now we can go back and start 24 recapping in whatever order you wanted to.
26 Did you-all want to finish those valves?
i
276
- 5-19-SueW 1 MR. MC GOEY: It seemed like we had started G 2 on Q.4. We touched upon it and then dropped out.
3 MR. CHERNY : Okay.
4 MR. ROCKHOLD: Before we jump on the wagon again 5 here, would this be a good time to take a break? Or, do
. 6 you want to plug right along?
7 I've got one pressing problem right now. But 8 it will only take me a minute. ,
9 MR. THOMPSON: Okay, time out.
10 (Whereupon, a recess is taken at 10 :35 a.m. ,
11 to re convene at 10 :50 a .m. , this s ame day . )
12 MR. ROCKHOLD: Okay. I believe everyone is 13 here who is expected to be here for the continuation of 14 this. To get rolling would be to all of our mutual benefit.
15 Okay. Rich wanted to continue on with a 16 discussion on Item 0.4 and then we would go back to the 17 very beginning and discuss each open item and see who has 18 the action on it and any other information that was discus-19 sed.
20 MR. MC GOEY: Only because we already got into 21 Q.4.
22 MR. ROCKHOLD: Sure. I understand. So, we 23 will pick up on further discussion of Item 0 4 which per-24 tains to the turbine driven emergency feed pump and associated a valves that are not currently included in the IST program.
f
277 i Let me first of all introduce
- 5-20-SueW 1 MR. THOMPSON:
,' 2 Owen Rothberg, a member of the Mechanical Engineering Staff 3 who is a reviewer on other IST programs. And he is here 4 basically as an observer.
5 MR. ROCKHOLD: Okay. Ques tion Q. 4. What
- 6 particular part of Q.4 did you want to discuss? Do you 7 want to recap it?
8 MR. COLITZ: Well, I think you said AS-V.
9 was okay. And then we got into the other three valves.
10 And I guess we talked about what the licensing 11 basis of EF-P1 was. And depending on that, we needed then 12 to further discuss what, if any, testing we do to these 13 valves.
(-)
14 MR. ROCKHOLD : Okay. From this side of the 15 tab le , I think we can safely say that we feel the emergency 16 feedwater pump does perform a safety function and will need 17 to be included in the IST program. Associated valves we 18 have identified, we feel should be in the IST program, namel y 19 MS-V8A and B, MS-V6 and MS-V22A and B.
20 I guess that's where we -- our differences lie ,
21 in the safety significance of those six valves.
22 MR. COLITZ: Can you just summarize the 23 licensing basis for EF-P1, then? l l
24 MR. ROCKHOLD: The licensing basis for EF-Pl?
25 MR. PAGE: We took the position that since the
278
- 5-21-SueW 1 EF-P1 is a tech spec pump, in our past we have always Ef > 2 followed that it has to be in the IST program.
3 MR. MC GOEY: Okay. So regardless of safety 4 function, because it is tech spec --
5 MR. PAGE: We assume it is tech spec, because
- 6 it has that safety function.
7 MR. CHERNY : We can take that as an action 8 item and check that out.
9 MR. PAGE: We can double check it, but my 10 past experience has been one hundred percent. I have never 11 had one drop out because of that kind of a discussion.
12 MR. COLITZ: Okay. Assuming you are going to 13 come back after this, let's discuss MS-V8A and B.
i 14 We still don't understand your justification 15 or your reasoning on why that valve needs to be in the IST 16 program and tested. It's the isolation valve for the 17 atmospheric dumps.
18 Tech specs don't allow me to close that during
'9 power operation or above even 250 degrees , as Henry points 3D out.
21 And it seems to me that your concern is that you 22 are concerned about a seismic break downstream of it, at 23 which time the operator would close MS-V2A and still have a 24 steam supply from the other line to the turbine driven 25 emergency feedwater pump.
~
279
- 5-22-SueW 1 MR. ROCKHOLD: Okay. During our reviews, some c
h_ 2 of the ground rules that we take when we perform these IST 3 reviews is reviewing the systems, we assume that non-Code 4 class, non-seismic piping attached to safety systems just 5 goes away during an accident scenario. It's not there.
6 In -- and in this particular case, if the down-
, 7 stream piping, which appears to me to be non-seismic, non-8 Code class piping, if it should go away, just isn' t there 9 anymore , those two valves , MS-V8A and B , have to close.
10 otherwise , the turbine driven emergency feed-11 water pump is no longer available.
12 MR. B ASHISTA: If you look at Drawing 302-0-11,
(. 13 why can' t we just close MS-V27 14 MR. ROCKHOLD: MS-V2 I believe isolates the 2 steam to the turbine , correct?
I l
16 We assume both sides go.
i 17 MR. CONTE: Both sides go.
t 18 MR. ROCKHOLD: Yeah, because it's non-Code
. 19 class, non-seismic piping. It goes away.
20 MR. CHERNY : Isn't there another little wrinkle l
21 on this? Somebody made the statement before that that 22
! particular pump isn't seismically qualified either.
23 MR. SHIPMAN: I believe that not only would 24 the 8s go but the 4 would go also. And then the turbine 25 driven pump can't be operated at all.
l
280 1
- 5-23-SueW 1 MR. PAGE: Not according to this drawing.
2 MR. SHIPMAN : AS-V4 taps into that line, to the 3 EF-Pl.
4 MR. PAGE: The MS-V8 valves are within the 5 seismic one boundary.
6 MR. CHERNY: Well, what is -- there is something 7 that still doesn' t make sense.
8 What does being within the seismic boundary
~
9 mean if that pump isn't seismically qualified?
10 MR. ROCKHOLD: That's a wrinkle we usually 11 encounter.
12 MR. CHERNY : Maybe the GPU people can explain 13 what that means.
14 What is the significance of that seismic valve 15 if the pump isn't seismically qualified? What does it mean?
16 END #5 17 ( An off-the-record discussion ensues.)
- Joe flws 13 19 21 22 2
23 24 25 I
l l
281 6-1-Jo4WCl .
1 MR. THOMPSON: Let's go back on the record.
2 Still back to the Question O.4. And the issue is the 3 response regarding MS-V8A and B, which says that they are 4 normally open, and not required to bring the plant to hot 5 shutdown after a transient.
6 You do not have to change position during a 7 transient.
8 MR. CHERNY: So, I was asking would you make 9 the same statement for all three AFW pumps, that none of 10 them are needed for transients?
11 MR. SHIPMAN: If we can qualify what ' transient' 12 is. If the transient happens to be loss of offsite power,
~
. 13 or loss of main feed water, emergency feedwater is required; 14 s for any condition which main feed water is available, any is transient, under which main feedwater remains available, it is is used and emergency feedwater doesn't start.
17 Emergency feed water' starts under two auto 18 actuatioEs present. Loss of all four reactor cool pumps, l 19 and loss of both main feed pumps.
20 MR. CHERNY: So if you had something like a 21 spurious MSIV closure --
l 22 MR. SHIPMAN: It would not start emergency feed 23 pump, and we would not start it.
24 MR. CHERNY: That doesn't sound right. If you
- closed all your MSIVs, you still wouldn' t trip off the feed l
, _ . - _ . _ - . ~ . _ . . _
6-2-JoeW 282 l 1 wntar?
'> 2 MR. SHIPMAN: If you close all of them, you l 3 have lost both main feed pumps, and it would auto 4 actuate.
5 MR. CHERNY: What would be the normal auto 6 actuation; the electric cnes or turbine one.
7 MR. SHIPMAN: All three.
8 MR. CHERNY: All three. All three of them at 9 the same time?
10 MR. SHIPMAN: Yes.
11 MR. CHERNY: All right, okay.
12 MR. ROCKHOLD: The capacity of one would 13 probably fill the need, but all three do auto start, and 14 they take credit for all of them starting.
15 MR. CHERNY: Well, then, I am really at a loss 16 for this argument. Why aren't these safety related valves?
17 MR. PAGE: I think it is just the way the 18 sentence is written on the MSV-8. What is meant by a 19 transient.
20 MR. CEERNY: Well, yeah, but you don't just put
. 21 valves in the program that are only for transients; they 22 are for accident locations", too.
23 MR. FAGE: That is right.
24 MR. ROCKHOLD: He see these turbine-driven, 25 emergency feed water pumps as being required for accident
l 4-3-JosWal
\
t mitigation, and for that pump to be available.
- ' To have steam available to the t trbine, these 2 1 3
two valves, MS-V8A and B may have to close.
4 MR. CHERNY: May have to close.
MR. ROCKHOLD: So we requested that they oe in-5
- e cituded.. If there was no question about piping integrity or failure of the bypass valves, then the significance would j 7 8
be a whole lot less, but the bypass valves are not safety
, grade valves. Piping is probably not protected from 10 missiles. It is non-code class piping, and therefore we i
11 feel that the isolation capability of MS-V8s is important 12 to have the EFF pump 1 available.
l i 13 MR. CHERN7: I think I agree, unless some system
- 14 branch overrules us, and says for some reason they don't l 15 need that thing.
j 16 I say it sounds like it is safety.related, and i
g7 should be in the program.
] 13 MR. ABRAMOVICI: A point of clarification of what .
gg we were discussing earlier. The EFW pump is seismically a qualified. It is not environmentally qualified.
~
21 MR. COLITZ: If you have a steam line break
! 22 there down stream at the 8As and Bs, you can't take credit 1 for that pump anyway if it is not environmentally qualified. !
23 i 24 You would be using the two motor driven, which are i z environmentally qualified.
i
}
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l l
G-4-JoeWal 284 1
1 MR. SANFORD : I don't believe so, but I am not l 2 entirely up to date on what the latest EQ program is.
3 MR. ROCKHOLD: Couldn' t the line break be some 4 distance away, and still be in that pipe before the turbine 5 bypass valve -- I mean, not even in the same area as 6 EFW-1. I mean just by saying that if the pipe goes away, 7 the pump is not available, isn't qtite a valid q uestion s either.
i 9 Or valid statement, I should say.
, 10 MR. CHERNY: Well, that is our position on that
- 11 one.
12 MR. THOMPSON: We are going to come back to ycu
~, 13 to confirm what we believe is the Staff position that if 14 P-1-A is required to perform a safety function, therefore --
is and it is in the tech specs, and it is tech spected, and to the valves that could be needed in order for that to be j 17 operable should be included in the IST program.
.1 18 Okay, we will provide that to you. And I will 19 let you know if there is any change in that.
30 MR. ROCKHOLD: Okay. In light of that discussion, 21 would you like to talk about MSV-6 now?-
22 MR. COLITZ: Yeah.
23 MR. ROCHOLD : Okay. Does MSV-6 have a required 24 fail safe position.
26 MR. COLITZ: That is one we said we have to get
6-5-JoeWul 285 1 back to you on.
2 There are a number of valves that fell into 3 a fail safe position, and we need to go back to the plant 4 to determine that.
5 I guess if that does have a fail safe position, 6 I would like to hear what type of testing you would be 7 looking for on that valve.
8 MR. PAGE: Excuse me. This is Joel Page. Any 9 valve that has a fail safe position, in this case it is 10 a regulating valve, you can' t be' assured of where the 1
11 position of the valve is at the time it loses power, so 12 it becomes automatically a safety related active valve, and 13 as such, has to have a fail safe test, stroke-to-stroke
[',
14 time test.
15 MR. SANFORD: I think though in this case MSV-6, 16 we have to get back to you what is the basis for that 17 fail safe position.
18 MR. PAGE: Is it just by nature of the design, or 18 is it required to have that fail safe --
20 MR. CHERNY: Can I ask a question.
21 MR. SANFORD: No, it may be more detailed than 22 that, but I think we will have to get back to you.
23 It is not clear from my memory, at least, whether 24 that has a fail safe position for the function of the EFW
- pump, or whether it has a fail safe position to be within the l l
1
~ 1 i
286 I 6-6-Jo Wal ,
I relief valve capability of the 22s.
2 In which case the pump isn't operable in any 3 event, and I am not sure which one of those really applies 4 on that fail safe position.
5 I am not sure the testing would be the same i
6 in the two cases.
7' MR. PAGE: It indicates that it is open here, i
a and if it is required to fail open, I assume it is trying
~
9 t6 keep the pump available, it would seem, at least at this J.
10 point.
a 11 MR. BASHISTA: Is the fail safe only required, 12 or is the fail test and a stroke time test required.
13 MR. PAGE: It becomes an active safety-related 14 valve.
15 MR. BASHISTA: You are' telling me both the is stroke time test and the fail safe test is required?
17 ,
MR. PAGE: You don't agree?
18 MR. BASHISTA: We are thinking these are 19 regulating valves, and normally regulating valves don' t 20 have the abifity -- don't have an open-close push button.
21 How do you time something that is self-regulatingT 22 MR. PAGE: You are getting into the specifics 23 now of whether something is practical to do or not.
24 The first decision was it is active because s
25 it would have to perform a motion. If it is impractical s.
l l
6-7-Jo;Wnl 287 1 to do the tnct, that is a continuation of the same 2 conversation.
3 MR. BASHISTA: Also whether or not it is 4 meaningful.
5 MR. PAGE: I don't think I would follow that 6 path too well, because then you are taking issue with the 7 code. It sounds like you are saying it is not meaningful 8 to perform a stroke test on a control valve would be your 9 point, an active safety-related control valve... I don't to think --
11 MR. SANFORD: I think this is a point that is 12 not clear in the Code, even though you have a partial 13 clarification from the Code people, and that is control 14 valves were excluded from the code.
15 MR. PAGE: Only for control.
16 MR. SANFORD: "Okay, that is right. But what 17 the Code did not adress was specifically what kind of 18 testing is required if a control valve is used for some 19 other function as well.
20 I don't know, maybe you have got that clarification.
21 whether all other tests are directly applicable to that type 22 of valve in that service or not.
23 I didn't hear that from what you discussed before.
24 MR. PAGE: I think it is covered by the term, 25 ' passive' versus active. It must perf in a motion to perfornt l
6-8-JoeWal 288 1 its safety function, then it is automatically active. l l
- 2 Active valves has a set of tests required in 3 the Code.
4 MR. ROCKHOLD : In light of your discussion there 5 on the requirements of the code for active valves, there are
. 6 a few examples of active valves that are not required to be 7 stroke timed, one being a manual isolation valve.
8 There can be a manual isolation valve that is 9 active, that you do have to stroke, but I think we recognize 10 that stroke timing in manual valve has little significance.
11 MR. SANFORD: And that is really my point, is 12 there was an oversight in the code, that if it wasn't clearly 13 covered;it leaves the question in my mind whether it wasn't 14 clearly covered in more than one section.
15 MR. PAGE: I don't really think it is an over-16 sight in the code, and I think what Herb is saying is when 17 you get down to the specifics of some active valves, in 18 that case manually operated only, by handling it, the 19 variance between one test and another could have nothing 20 to do with the condition of the, valve.
21 But that gets down to the specifics of actually Zi performing the test, rather than whether the test needs to D be done or not.
24 MR. CHERNY: What I am hearing is I may need a M relief request.
289 l 6-9-Jo1W:al 1 MR. PAGE: If thny dst: irs not to otroke time 2 or stroke test. If they can't meet the code for an 3 active safety related valve, then you need a relief request, 4 but at that point they may get relief from us.
5 Not that it is not meaningful. That is a 6 different reason.
7 MR. ROCKHOLD: Okay. Do we need any more 8 discussion now on MS-V6? Okay. The last valve on this 9 particular topic is MS-V22 A and B, which are the relief 10 valves on the steam line to the aux steam pump turbine.
11 So, the stand on MS-V22 A and B as well as 12 MS-V6 is open for both sides of the table, is that correct.
13 The NRC side ic going to do some research with 14 their systems people to find out just exactly where the NRC 15 stands on the topic, and we verify our presented stand on is the topic, and then it is open for your gentlemen to maybe 17 to a little research on your part to see what arguments you 18 can come up with to counter any -- our current argument.
19 MR. McGOEY: In this an item for subsequent 20 phone conversation?
21 MR. CHERNY: Yeah, I think it is.
M MR. McGOEY: Instead of your writing us a' letter, 23 before putting out a letter.
24 MR. THOMPSON: Before any further discussion.
- M liR. ROCKHOLD: We need the time, i
0 6-10-JoeWal 1 MR. CHERNY: I wouldn't mind asking though, the 2 first time I read that paragraph setting here a few minutes 3 ago, it doesn't make a lot of sense to me.
4 First, it says that B-22 A and B prevent 5 over-pressurization, and then it seems to go on to say
. 6 no, they really don't, because MS-V6 does that job, and 7 therefore the conclusion seems to be they are not really 8 needed for anything.
9 Is that what that paragraph is supposed to say, 10 or am I reading it wrong.
11 MR. SANFORD: The relief valves are there 12 primarily as a component of p'otection r for the EFW pump.
- , 13 MR. CHERN'l
- For the pump itself.
14 MR. SANFORD: The turbine pump -- well, not the 15 pump, for the turbine.
16 MR. CHERNY: For the turbine.
17 MR. SANFORD: On the main steam line. EFP-6 18 is the control or regulating valve going to that turbine.
19 MR. CHERNY: Right.
! 20 MR. SANFORD: Generally, one doesn't provide 21 over-pressure protection of a component using a control H valve.
23 MR. CHERNY: True.
24 MR. SANFORD: And that is why we have the relief 25 valves on there.
t l
6-ll-JoeW21 291 1 MR. CHERNY: Requirements in Section 3 of the 2 Code, at least for some of the code classes, that if you 3 can show by analysis or system design that there is no way 4 to over-pressurize anything, such as the turbine, then you 5 don't need relief valves.
. 6 That is sort of why I asked the question.
7 I am not sure what your answer was yet. They 8 are still needed because you can get some over-pressure, 9 is that true?
10 MR. SANFORD: You have to assume a control valve 11 doesn't give you absolute isolatioh, tha~t is right.
12 MR. CHERNY: Well, we will discuss that with 13 our systems people to see how they feel about it.
14 MR. McGOEY: We would like to at this point M propose going back down the list quickly and make sure 16 we understand.where we are on each item.
17 MR. ROCKHOLD: Do you want to jump into that 18 before lunch, or continue to go through lunch?
18 MR. COLITZ: We would like to continue through 20 this meeting, and not break for lunch if that is possible.
21 Some of us have to work at the Island yet today.
22 I guess it depends how much time you want to 23 spend rehashing each item we went through yesterday. It 24 is about fifty. I would just say -- there is about another 25 25'where we basically agreed to go do something, and we will '
i i
r I
- e- -
l 6-12-JLcW21 292 !
I restate it to make sure it is clear.
1 2 I think there may be three or four issues that 3 we would have to get into more discussion on.
4 MR. CONTE: So from a summary point of view, 5 you say we can be done by 12:30?
. 6 MR. COLITZ: I thotght the meeting would be 7 one day initially, and I was wrong, so I don' t want to --
8 MR. ROCKHOLD: I can see at least another 9 couple of hours. That is my opinion.
10 Now, I may be wrong, but I am certainly willing 11 to work through if that is what everyone else wants to do.
12 MR. PAGE: Two hours is going to be quite a
(^ 13 while. I don't know about you guys, but I don't eat 14 bre akf ast.
15 MR. McGOEY: Can we stard- push for 12 :30, and 16 if we haven't finished --
17 MR. THOMPSON: Let's go and see how we proceed.
18 MR. RANSOM: Before we start, give me half a 19 second here.
20 MR. CHERNY: I guess for my own participation, 21 I would like to do the hard items and then the summary.
22 rather than hitting them as we go.
El MR. THOMPSON: Now, are we working from the notes 24 that were made from yesterday? I suggest that that would be 25 a good way to go, and if you have revisions or modifications,
- 293 6-13-JoeWol 1 ~ then we could incorporate those into the notes, and
~'
2 have Clair revise them accordingly.
3 MR. PAGE: What I would like to do first, since 4 Frank's time is limited, there were some that were real 1
I 5 general in nature that involved two or three, or in some i,
i 6 cases maybe four, and one was the testing of some components
. 7 in the cold shutdown mode, which would require switching i
a loops, decay heat loops, I believe that was B-2, G-6, G-8, 4
9 and maybe one more, I am not sure.
,1 i 10 MR.ROCKHOLD: 'B-2, G-6, and G-8 identify the I
a l 11 stroking of valves on the decay heat lineup during cold i
1 4
12 shutdown, where you have proposed to exercise the valves 1
13 in one train each cold shutdown, and then the alternate i 14 train the following shutdown.
4 I
15 MR. SHIPMAN: No, I don' t believe that was it.
j!
16 I think it starts off with a discussion on whether we i
l 17 full stroke er:~ part stroke CPv-5.
I 4
! 18 MR. ROCKHOLD: That is part of B-2, I believe.
l I
19 See asterisk shows up on that particular location. That
)
1 80 See - asterisk I believe was a topic that Joel wanted to 1 .
21 discuss.
i 22 MR. SHIPMAN: The See asterisk develops from the i
j 23 discussion on CF %5 into a discussion of both trains tested I 84 during refueling, at least one train every cold shutdown.
i
! 26 Not that we would alternate each cold shutdown
}
i I ,
. , _ . . _ _ . _ _ _ _ . , _ . _ _ . _ _ . . . _ _ , _ _ _ _ _ _ , . _ _ . . . ____,_-c_.-._.___.. , _ . - . . . _ _ _ _ _ _ .
6-14-Joe Wal 294 I between the trains.
' MR. ROCKHOLD: Maybe I misinterpreted you the 2
3 first time around then.
4 It was my understanding that for example, you 5 would run Train A this cold shutdown, and the following
. 6 cold shutdown you would run Train B, and alternate until 7 refueling, at which time you would test both.
8 MR. SANFORD: That was a misinterpretation.
9 We do not propose to control two.
10 MR. ROCKHOLD: I ask at this point maybe Joel 11 should present his --
12 MR. CIIERNY: I am not sure I understand what 13 the proposal is yet.
14 MR. PAGE : Thero are several components 15 associated with these two loops that need to be tested in the 16 IST program, and what they have proposed is to test the 17 components in one loop for the other each cold shutdown 18 but not necessarily alternating, meaning that Loop A 19 could be done three shutdowns in a row.
30 There is no particular sequence of how they 21 would be done.
22 Our case is that it isn't a big deal to switch 23 loop operation during a cold shutdown.
l 24 MR. CIIERUY: Are we talking all check valves, 26 is that what we are talking about?
c l
l i
6-15-JoeW31 295 1 MR. PAGE : No, they are not all check valves.
~
2 MR. 23CKHOLD: The ones G-6.
3 MR. SHIPMAN: 14, 16, 25.
4 MR. CHERNY: So you do have to run the systems a for all these valves.
. 6 MR. PAGE: And our position was, we really didn't 7 hear anything that sounded impractical.
3 MR. CHERNY: So, some valves could go for the 9 whole fuel cycle without being stroked.
10 MR. SHIPMAN:
No, that isn't true. The way we 11 see it, from our point of view, is that we part stroke all 12 of these set valves.
13 The actual design flow through the check valve, 14 we can't test. It is impractical, and I don' t know of a un safe way to do that test. CFV-5, particularly, we do it 16 three thousand gallon per minute LPI injection flow test 17 on one side every cold shutdown, because that is normal 18 decay heat removal, okay?
19 But that, in fact, is a part stroke. In the 20 decay heat system that is in operation during a cold 21 shutdown, then the 16 valve, which is the discharge check 22 valve, also gets that same LPI flow, and that is full flow I
23 through that check valve.
24 The two other check valves, the 14 valves, receive l l
25 a partial stroke test quarterly when we run the pumps on 1
6-16-JoeW21 296 i I recirc. l l
2 From my point of view, it is impractical to 3 swap the loops just to get the three thousand gallon flow 4 through the 16 and the 5, where -- I part stroke the 16 5 quarterly also.
, 6 MR. PAGE : The test you are demonstrating now 7 is also a part stroke, isn't it?
8 MR. SHIPMAN: Which test?
9 MR. PAGE: Quarterly shutdown.
10 MR. SHIPMAN: A cold shutdown on decay removal 11 is a part stroke. The injection, the LPI injection flow 12 test is also a part stroke.
) 13 MR. CHERNY: So, when do you do the full --
14 MR. SHIPMAN: The only full stroke testing I 15 do is on a 16 valve and the 22.
16 MR. CHERNY: It sounds to me like you have a 17 multitude of problems here, this swapping loops.
18 MR. PAGE: It reopened B-1 for sure here.
19 (Discussion by NRC staff members.)
20 MR. ROCKHOLD: Let me show you on the drawing, 21 Frank. It would be a lot easier to see it.
ZZ MR. CHERNY: The business about running just 23 one train each cold shutdown, from what I am advised here 24 no one else is doing it. Everyone else is running both M trains, so we are going to ask you to do what everyone else
6-17-JoeWal 297 I does.
2 I don't see any reason to let you do that 3 differently.
4 MR. COLITZ : Because everybody else does it, 5 that is not a reason.
. 6 MR. CHERNY: Our job is valve testing, okay?
7 Not worrying about -- that is our job. If you want to 8 appeal that to somebody, I guess you will have to appeal 9 it.
10 The regulation says meet the code. Just because 11 you don't normally do it, that is not our job to worry about.
12 That doesn't sound sufficiently impractical to me. If you 13 turn off one system, you turn on the other system.
14 That still doesn' t f ully meet the code anyway is even if you do that. You have several valves that even 16 doing that you never full stroke, and if you can' t full 17 stroke them you are going to have to periodically disassemble, 18 That is the position.
19 I am not sure where that all leaves us in terms 20 of number of valves and things, but those are the staff 21 positions.
22 MR. ROCKHOLD: The valves that we discussed just 23 now, Frank, tl.at are not full stroke exercised are individually 24 addressed in other questions, so we are not leaving them 25 open. We tend to ignore them a little bit right now.
i 6-18-JoeW21 ,
298 l l
1 MR. CHE RNY : Well, that should be a sifficient 2 generic statement, I would think to follow through on.
3 MR. PAGE: These valves are generically addressed 4 other places?
5 MR. ROCKHOLD: These valves are individually
. 6 addressed in other locations. The valves that are not full 7 stroke exercise, yes.
8 The topic of discussion right now is running 9 both trains of decay heat each cold shutdown versus running to one train each cold shutdown, and verifying both trains 11 during refueling outages. ,
M That is the thrust of the conversation right now.
( 13 14 MR. THOMPSON: Or alternating from subsequent 2 -- their proposal right now is to run one each shutdown, 16 each cold shutdown, and not necessarily alternating on 17 subsequent shutdowns.
18 So, coming -- backing off from that, you could 19 require running one each shutdown by alternating from 3D sequential shutdowns, or running both each cold shutdown.
l 21 MR. ROCKHOLD: Currently, all of the plants that I 22 I have reviewed, or participated in the review of, I know 23 of no' plant that is running only one train of decay heat 1
l 24 during each cold shutdown.
i 25 They are all required to demonstrate operability l
Q)-99-JoeW21 299 1 of the valves in both trains.
2 MR. SANFORD: Have you reviewed the B&W plant?
i 3 MR. ROCKHOLD: Yes.
4 MR. SANFORD: Because the Westinghouse design a calls for both decay heat loops to be used normally on a cool down, whereas we do not. We use one train.
, 7 MR. ROCKHOLD: I participated in the review for a the Occonna plants, Crystal River 3.
i 9 MR. PAGE: You worked on Arkansas, didn't you?
10 MR. ROCKHOLD: Worked on Arkansas 2.
11 MR. CHERNY: How about Davis-Besse?
12 MR. ROCKHOLD: We worked on Davis-Besse.
13 MR. CONTE: And I guess the wear and tear on the
(
14 system is mitigated from the point of view you don't have i Hi to do it any more frequent than once every three months if is you are in a cold shutdown condition.
17 MR. ROCKHOLD: The code requires valve testing 18 once every three months. If you have frequent cold shutdowns, 19 once every three months is sufficient.
20 MR. PAGE: You certainly don't have to exceed i
21 once every ninety days, that is for sure.
22 MR. COLITZ: You are also exercising valves that 23 are of a potential PID candidate. You think you are gaining 24 safety in one area, and you are losing it in the other as 26 far as I am concerned.
I I
l
6)-20-JoeW31 300 1 MR. PAGE: They have dual safety functions; both 2 to open and to close.
3 MR. SHIPMAN: One other point to be considered 4 is that they are redundant systems. If we were to see s a problem in one system, we would be required to test the
. e other system, in that -- if our position was accepted, 7 and we only tested the one train during each cold shutdown, e certainly if we saw a problem in that train, we would have 9 to test the other train.
to It boils down to starting the pump to see one 11 check valve swing.
12 MR. PAGE: We are talking about more than one 13 check valve.
14 MR. SHIPMAN: But it is only one check valve that to makes the dif ference. The 16 is really the only one that is gets exercised when you start the second loop.
17 I can exerciso the 22 on the opposite loop without is starting the pump by using the cross' connect.
19 By starting the pump, it only means I get that 20 16. I get f ull flow on the 16, and full flow on the 22.
21 But on the 22 I can give a partial stroke, and at I already -- I have already made procedural requirements 23 to stroke' those. Partial stroke those.
24 MR. ROCKl!OLD : Partial stroke is not identified 26 in the program.
End 6.
SueW fois.
301
- 7-1-SueW 1 MR. SHIPMAN: Our position would be if we did 2 not have to swap loops each cold shutdown, all valves would 3 be checked except the 16.
4 MR. S ANFO RD : The 16 would get a partial stroke 5 every quarter. They would just not get a full stroke overy
. 6 cold shutdown.
7 MR. CHERNY : Again, all of this did not come 8 through .
9 MR. ROCKHOLD: You are right. We are getting a 10 little bit more information each time we discuss this it 11 seems.
12 ( A discussion among the Staf f members onaues.)
13 MR. ROCKHOLD: Do you have a feel for the
(
14 quantity of the part stroke that you get on the 16 during 15 the monthly pump test?
16 MR. S ANFORD : The quarterly pump test is nine 17 hundred and twenty-five , about a thousand GPM versus three 18 thousand design flow.
19 ( A discussion among the Staf f members ensues.)
20 MR. CHE RNY : We are going to ask you to do what 21 we think overyone else is doing, and that's test both loops, 22 because we don' t see any basis for -- we think you have got D to do a lot of screwing around to hcok up all of those by-24 passes and everything also.
m It seems like it's just as easy not to do all L_
302
- 7-2-SueW 1 of that and just turn the other pump on.
2 MR. S ANFORD : That may look casier from the 3 flow print. In fact, I think a tour of the plant to see 4 the locations of those valves and what is involved would 5 show you otherwise.
. 6 MR. PAGE: Why does the location of the valves 7 make any dif ference?
8 MR. S ANFORD : Because you have to operate the 9 12 valves to switch loops, the HV-12s. It's not a non-10 valve operation to switch pumps.
11 MR. PAGE: Do you have to be at the valves to 12 do that?
13 MR. S ANFORD: On the 12s, yes.
14 MR. CHERNY : I don' t unders tand that.
15 MR. ROCKHOLD: That aligns the suction from the 16 hot leg to one pump or the other.
17 (Mr. Rockhold is showing Mr. Cherny the drawing.)
18 !!R. CHERNY : Oh, I see.
19 MR. THOMPSON: So, each cold shutdown you can 20 exercise all except the 16s and the 16 would be depending 21 on which loop you are operating, and in order to be sure 22 that both 16s were full stroked at each cold shutdown re-23 quires some measurable effort to switch loops, whereas to 24 do the rest of them by cross-connect changes is manageable.
25 MR. S ANFORD : It's an easier ef fort.
303 ,
- 7-3-SueW 1 MR. THOMPSON: Is that sort of the position?
- k. j' 2 MR. SHIPMAN: Yes.
3 MR. CHEPHY: Why can' t you run with both 12s 4 open?
8 MR. S ANFORD: Then, you are in another concern.
- 4 (Laughte r. )
7 MR. CONTE: Boron. Long term boron precipita-8 tion. You are into another safety issue.
9 MR. SHIPMAN: They tie both loops together.
10 MR. CONTE: I think it's a hearing commitment, 11 or an appeal board commitment to keep one valve locked open, 12 another locked shut.
(} 13 MR. S ANFORD: Originally to keep the trains 14 separated.
18 MR. ROCKHOLD: But the trains would be at the 14 same point anyway.
17 MR. SHIPMAN: But that's not a safety point.
Is MR. CONTE : If you start fooling around with the to 12s, you are going to go into another issue, a safety so issue. So, stay away from the 12s.
21 MR. CHERNY : The only thing I can see here is 22 it sounds like we certainly don't have enough information to 23 write an SER that would say that we have looked at this and 24 it certainly seems to be impractical not to do both loops.
26 So, I -- you know, if you think you have got a
. 304
- 7-4-SueW 1 whole bunch of good stuff to send us that you haven't sent
', / 2 us, I guess you had better send it. That's the way it l 3 looks right now.
4 And if there really is a horror story involved, 5 in just using r ne of the 12s and then changing to the other
- 6 one and so on, that isn't documented.
7 MR. SHIPMAN: I'm hearing if we document our 8 approach they may think it's reasonable and would accept 9 it?
10 MR. SANFORD: May. I think we should submit 11 the whole picture and let them review it.
j 12 MR. CHERNY: Yes, If you've got a horror story 13 that you haven' t presented, present it.
14 MR. COLITZ: We will submit further information 16 on this item.
16 MR. THOMPSON: I think it's more than document
)
i 17 your approach. I think that sort of has pretty much been j
l 18 explained. But I think the story we need is why it is so l' impractical to switch loops during each cold shutdown in 20 order to exercise the 16s.
21 That is in lieu of using the cross-connects and 22 testing everything else but the 16s.
23 MR. SHIPMAN : The cross-connects we already 24 do. It has already been proceduralized.
26 MR. ROCKHOLD: And you do perform a full stroke
]
4 i
a I
305 I
- 7-5-SueW 1 on both of the 22s?
2 MR. SHIPMAN: No. That's not a full stroke.
3 Using the cross-connect on the 38s , I'm not sure what 4 the flow rate is going through the opposite. It's going 5 to be less than full stroke because you don't want to run 6 out the pump.
. 7 You will balance it.
8 MR. ROCKHOLD: So you have downstream isolation 9 capability on each leg?
10 MR. SHIPMAN : Yes.
11 MR. ROCKHOLD: So you could run A pump, discharge 12 through B.
13 MR. SANFORD: There may be some small drop of
(~.
14 flow. There may be some loss of additional capability --
H5 MR. POCKHOLD : I think you can appreciate our 16 interest with getting all valves tested at close to the 17 Code specified frequency as possible.
18 And if the deal with the pumps , or the pump 19 discharge check goes through, then we would still be in-20 terested in discussing as close to a full stroke as possible 21 on the alternate 22 valve.
22 That's a negative feature of the alternate pump.
23 ( A discussion among the Staff members ensues.)
24 MR. PAGE :- I think the next item we need to 25 discuss while Frank is here is NR-V18, which is Item U.2.
306 47-6-SueW I (A discussion among the Staff members ensues.)
2 MR. PAGE: We were discussing this NR-V18 valve, 3 and we feel that it is an active Category B valve. And I 4 guess obviously quarterly testing would probably not be 5 appropriate, but I think you had some trouble with tempera-
= 6 ture in the river or something.
7 I don't know if ya'll are fully prepared at 8 this point to discuss those detai,ls.
9 MR. COLITZ: I guess we tend to differ on whether 10 it's a tive or passive. We tend to classify it as passive.
11 You set it once for deicing at the start of the 12 ice season and then reset it when it's over. And we set
^
, 13 it once a quarter when we do our IST testing on pumps.
14 So it's very infrequently operated.
15 MR. PAGE: I guess we felt strongly because of 16 the seriousness of failure or closed or at near-closed, or 17 in the closed position could really cause problems with the 18 sys tem.
19 MR. SHIPMAN: It doesn't go to that position.
20 MR. BASHISTA: It fails as is.
21 MR. PAGE: If you were to push the button to go 22 towards the close position to use your deicing and it just 23 kept going to the closed position --
24 MR. SHIPMAN: We would make it a manual valve.
26 MR. PAGE: I wonder why they didn't do that at
, 307 7-7-SueW I Davis-Besse. They closed a valve and were unable to reopen 2 the valve.
3 MR. B ASHISTA: Then we would go to 19 valve.
4 18 and 19 work together.
5 MR. COLITZ: If 18 were closed, I could open 19
- 6 and I would continue to have cooling. I would violate 7 temperature limits for the State, but I --
8 MR. S ANFORD : If that valve were manual as 9 opposed to having a motor, which the motor is there as an 10 operator conveni,ence , if it were manual it would not be 11 part of this test program.
12 MR. PAGE: It's not part of the test program 13 anyway, is it?
14 MR. S ANFORD : Well, you are asking it to be part 15 of the test program. So, if it's a manual it would not even 16 be an issue. It wouldn't even show up with you.
17 MR. PAGE: I think we would have looked at in 18 terms of what we were discussing, but then realizing it was 19 a completely manual valve as opposed to a motor operated 20 valve then we would make the second judgment that it 21 probably wouldn't do much good.
22 MR. CHERNY : Is that just locally operated?
23 MR. PAGE: It would not run into the situation 24 we are trying to picture.
25 MR. SANFORD: There is a jog control push button
308
- 7-8-SueW 1 in the control rocm. And the reason the motor is on there
' 2 is because it's so hard to get to.
3 MR. CHERNY : The reason th'e motor is on there 4 is what?
5 MR. SANFORD: It's just for convenience , to be
- 6 able to do it from the control room.
7 ( A discussion among the Staff members ensues.)
8 MR. ROCKHOLD: I think because it has a motor, 9 there are significantly more failure mechanisms available 10 for that valve to fail in the closed position.
11 MR. CHE RNY : That's not my question. My 12 question is, is it active or passive. That's a little bit 13 different than what the normal active valve is that we talk 14 about.
15 MR. PAGE : Well, deicing I believe is safety-16 related. So you have to move this to do that.
17 And by virtue of the f act that you do move 18 it so many times --
19 MR. ROCKHOLD: They said they can manually do N that .
21 MR. PAGE: That is actually written up in the 22 SFER, that the deicing mechanisms are not really necessary, 23 if necessary a person can go down and manually deice?
l 24 MR. SHIPMAN: I can deice from the circ water 25 system also. ,
1 l
309
- 7-9-SueW 1 MR. PAGE: That is in the FSAR write-up, saying b 2 that basically there is no credit assigned to this deicing 3 mechanism shown here.
4 MR. SHIPMAN: Both those deicing mechanisms are 5 described in the FSAR.
. 6 MR. PAGE: See, our basic position in the past 7 has been that redundancy of a system is not a reason not to 8 do a test.
9 We realize this is kind of a unique valve. I 10 don't remember running across this before. And --
11 MR. CONTE: Can the valve be tested on a refuel-12 ing, or are you still going to get yourself into an NPDS 13 p roblem?
14 MR. SHIPMAN: The problem is, you are still going 15 to send heated waste to the river without going through 18 the mechanical draft cooling tower.
17 That's not consistent with what the State wants 18 us to do.
19 MR. SANFORD: It just seems to be inconsistent 20 with what we are trying to do. The test would be to drive 21 the valve closed to see if we can open it, to prove that 22 the valve won't fail in the closed position.
23 So, we send it to the position we are trying to 24 avoid just to show that we don' t end up in a problem when 25 we get to that position. That just doesn' t make any sense.
. 310
- 7-10-SueW 1 MR. ROCKHOLD: Well, as it turns out I think a 2 lot of your pump or valve testing involves placing a valve 3 in the non-conservative position to verify that it will 4 move to the conservative position.
5 So, I don't think that is a valid argument.
6 MR. SHIPMAN: I think the difference that I see
. 7 with placing valves in their non-conservative position is 8 that during a transient or an accident it could go in that 9 non-conservative position, and it would defeat some of the 10 mitigating systems that we have for the accident.
11 In this case, this valve doesn't have to change 12 position for the accident.
13 MR. SANFORD: Really, what you ace talking about
('
14 here is that valve going closed as an initiating event; or, is not in response to an accident, because the valve doesn't 16 move in response to an accident.
17 You are looking at that valve going to the 18 closing position as an initiating event.
19 That's different.
20 MR. ROCKHOLD: That's a good point.
21 MR. S ANFORD: It's passive in response to some H other event.
23 -
MR. BARLEY : Then, there is a further dif ference 24 I think in the argument you pointed out where you have other 26 valves. In other valves , it's true you put them in
l 1
311 !
l
- 7-ll-SueW 1 non-conservative positions but in other systems you can l 2 take other compensating system line-up measures to ensure 3 you don't get the consequences of that valve going to 4 that --
5 MR. ROCKHOLD: Most valve testing requires you
- a to essentially remove the component from service for the 7 tes ting.
8 MR. BARLEY: So there is a difference.
! 8 MR. ROCKHOLD: We are not asking you to remove 10 the component to perform the test.
11 I think, Frank, the argument whether it's really 12 active or passive is not really a valid argument here.
() 13 14 MR. PAGE: It's a very unique situation.
! MR. CHERNY : He makes a good point though that 2 it doesn' t have to do anything in particular in response 16 to a regular transient or accident event.
17 MR. ROCKHOLD: Unless the valve is closed at 18 the time. So, in light of that the probability of it being 18 closed when an accident occurred is extremely small.
20 MR. CHERNY: I think so, too.
! 21 MR. ROCKHOLD: So it might qualify as being a 8 passive valve.
23 MR. CHERNY : Just submit it in the program --
24 MR. PAGE: There is no testing required.
26 MR. ROCKHOLD: There is no testing required for
l 312
- 7-12-SueW 1 Category B passive valves, so we have not been pushing 2 having those in the program.
3 MR. PAGE: It's nice to have them in there for 4 completeness so everybody knows what their assignment is.
5 There is no actual test requirement.
- 6 MR. CHE RNY : I think maybe at this point we 7 can just say that we will require the utility to do nothirg 8 at this time, and maybe if we have subsequent discussions 9 with maybe Systems people we might bring the topic up again.
10 I guess we are not going to impose anything on 11 that one right now. We will talk some more to our Systems 12 people.
13 That's a pretty gray case.
(
14 MR. ROCKHOLD: Okay. So, on Question U.2, 15 Item NR-V8 --
16 MR. SHIPMAN: 18.
17 MR. ROCKHOLD: 18. My mis take . The current 18 NRC position on that one is, we will not require you to 19 include that valve in the IST program.
20 However, this side of the table may take a 21 little closer look at it and in talking with our Systems 22 people you may hear about it again. But at this time you 23 are required to do nothing more.
24 Okay. Was there any other particular question?
i 25 MR. PAGE: One last one I think we need to talk 1
. 313
- 7-13-SueW 1 about while Frank is here for sure is the PORV discussion.
3 MR. PAGE: I think that this was categorized in 4 Category -- as a Category C, so it's a power operated 5 valve.
- 6 MR. CHERNY : Let me digress.a little bit. I 7 think I know what the issue is. And le t me j us t -- the re 8 are all kinds of things I could say about this valve.
I'm going to make a short speech first and T
9 i
10 make a long one later.
' 11 I'm on three ASME Committees, okay. And I can 12 tell you right now that PORVs are not Category C valves.
13 All right. You are improparly applying Section XI to
{'
14 categorize that as a Category C valve.
2 Category C was intended only for self-actuated 18 valves with no energy source. Check valves and relief i 17 valves, that's it. Okay. There isn' t anybody else that l 18 calls those things Category C valves.
18 We've got all kinds of IST programs around here.
30 So, that means it's a Category B valve and that's really 21 what everyone else calls it, Category B. It's a B active i 22 valve, okay.
23 The Code basically would require you to test it 24 quarterly except that there is a little provision in the i
i 26 Code that sort of says if you put the plant in an unnafe l
l r n__ - - - -
,1-,-- -
314 l
- 7-14-SueW 1 condition by so doing that you can test, what is it, cold E l' 2 shutdowns I guess is the fallback position, right. l 3 What we have generally been doing with those 4 things with other people is that we have been recommending 8 that they stroke that thing as they go into a cold shut-
- 8 Own at zero power after the reactor is scrammed. And 7
generally speaking, people have been going along with that.
8 However, there is one more little wrinkle that l 5
8 has been occurring recently that we would also be willing .
10 to support. I don't know if you guys are aware of it or j 11 not.
H There has been an industry effort the last two ,
( ; la ywars to write a specific in-service testing standard for
- 14 PORVs. And that ef fort is fairly far along. 5 i is I think that document -- the number of it is
} 14 OM-13, is the main Committag ASME Operation and Maintenance 17 Main Committee is level right now. The last thing we heard l
i W on that was the intent is to ultimately have that referenced j 18 in Section XI of the Code.
j 20 And I'm not really trying to impose anything i n from a Draft Standard but all I want to say is what it says 22 in there. What it says in there is that you should test i
23 them once each fuel cycle, and you should do essentially j.
M what I just said. It recommends testing at zero power on 1
25 the way down to shutdown, a stroke, so that you don't have l
f i
..,n----._. . . , , . , - - - - - - - - _ , . - .
. 315
- 7-15-SueW 1 all kinds of problems with small break LOCAs if it sticks 2 open and everything. You are supposed to have the plant 3 shut down by that time.
4 We wo;1d kind of look at this situation in this 5 respect. We think that what you have here is a Category B
. 6 valve that shouldn't be tested quarterly, because we some-7 what share your concern that you don' t want to just stroke 8 those things at power because if they stick open you've got 9 a messy situation.
10 on the other hand, we've kind of gone along 11 with, you know, the testing as you go into cold shutdown 12 situation. Our Systems people kind of pededthat at us right
{'s 13 after the TMI-2 event.
14 But we've also gone along and have actively 15 participated with this Code group which is really coming 16 forth with an even somewhat lower frequency. But I must 17 point out that on this Code group, several valve manu-18 facturers, several utilities are represented, Babcock and 19 Wilcox. So, their Number One valve guy went along with M this testing. Harry Honi'g. Okay.
- 21 So, if you cam in with'a' Belief Ibquest and said:
22 Hey, we propose to stroke these things as we go into cold 23 shutdown just before the refueling outage, okay, we would 24 entertain that as an acceptable Relief Request.
2 We think that is the way the industry is going t -
316 67-16-SueW 1 and ultimately that~ is what Section XI is going to have in 2 it for those kind of valves.
3 The once every five years thing is not going 4 to cut it around here. Also, it's just not right. That 5 part of the Code wasn't set up for these kind of valves
- 6 that way.
7 So, what we would -- if you maintained that 8 position we would just write back to you and tell you that 9 you are misapplying the Code requirements
- and 'the regulationo 10 would require you to do something more.
11 MR. COLITZ: What we will do on that is, I 12 have not seen this , what was it, MO-13?
13
( MR. CHERNY : OM-13. I tell you, I don' t know 14 how often you guys talk to B&W. You might want to talk to 15 Harry Honig. He has been more actively involved in this.
16 MR. COLITZ: Probably Jim Carea (phonetic) is 17 more closer to this up at Tech Functions. We will take a
} 18 look at that and get back to you.
19 l
With the sensitivity of the PORV, I don' t want 30 to commit to anything here today without going back to my 21 management.
22 MR. CHERNY : Okay. I don' t blame you for feel-23 ing that way. The Code group was also very sensitive.
24 But they felt that that was the minimum frequency 26 that was reasonable, was once each fueling outage.
l
317 MR. SHIPMAN: Was there a minimum RCS pressure
- 7-ll7-SueW I 2 that that OM-13 talks about?
3 MR. CHERNY : There is some discussion in there.
4 It is highly recommended that it be done at normal operat-5 ing pressure.
- 6 There is some words and music in there. I 7 don't know if they are ultimately going to go through, but 8 they are in there now, that sort of says that if there is 9 great and severe hardship doing it at full pressure, that 10 you can do it if you do certain other things which I don't 11 remember what they all are to justify that your lower M ,
pressure test gives you adequate assurance that you are 13 okay.
14 There is something that you can do there , too.
15 MR. SANFORD: Is the Code's requirements , are is those requirements, particularly the full pressure ones, 17 associated with opening the valve or more associated with 18 reclosure?
MR. CHERNY : The concern is really kind of 19 20 bo th . Re ally . It depends on the valve design.
21 I don't think I gave you a hard and fast answer.
22 On some models, you may be worrying more about the one than 2 the other. But on your design, I think you probably are 24 more worried about the closing than you are about the 25 opening.
i I
318
/ .
$7-18-SueW 1 MR. S AE!/ORD: Certainly that seems to have been
. 2 a more frequent failure mode.
3 MR. BARLEY: One additional point jus t to 4 clarify. The submittal here does not address all of the 5 testing requirements that are proposed for this valve. It 6 only addressed the Code categorization.
7 There is other Tech Spec required testing that 8 is done on the PORV to verify the setpoint and controls.
9 MR. CHERNY: That was mentioned to me. But to I guess unfortunately it doesn't test the valve itself.
11 I might point out there are some plants that 12 have -- that I guess , as you do , take credit for that
() 13 thing for vessel low temperature protection. Some of the 14 more recent plants do have a requirement to stroke the 15 valve in their Tech Specs.
16 And I think what's in those newer Tech Specs 17 I think is at least once per every eighteen months.
18 MR. SHIPMAN: The credit we take on that valve 19 at low pressure is at 425, 485 pounds which, you know, a 20 test at 485 pounds is different than one at 2155 pounds.
21 MR. CHERNY : I understand. And there are some 22 valve designs, too, that some manufacturers will argue that !
23 if you do the test at a lower pressure becausa of the tight 24 fitting of the parts and things it's actually a harder test.
M It depends upon the valve design. I don't
l l
319 know. Your's is a Dresser. And there are certainly
- 7-19-SueW 1 o'
r3
'" 2 some -- I don' t know whether - . I can' t recall. I have 3 had discussions, a f air number of discussions, with Dresser ,
4 about that valve design.
5 I don't remember them ever bringing that parti-
. 6 cular one up.
7 MR. SHIPMAN: The dilemma that I feel from it 8 is that the Unit 2 PORV opened after the reactor was shut 9 down and caused a lot of problems.
10 So, testing at hot shutdown following a hundred 11 percent power still frightens me personally. If I can 12 consider testing down at lower pressures, that frightens
( 13 me, too, because then I don't have the capability to re-14 plenish the reactor coolant system if. it did stick open M and I couldn't get the block valve shut because I'm not 16 allowed to use my makeup pumps.
,j II I have low pressure restrictions on the makeup M pumps at low pressure. So, it's a dilemma that --
19 MR. CHERNY : I can't honestly say that anybody
- mentioned that last one during the very extensive discus-21 sions on all of this during those Code meetings.
22 MR. CONTE: But you can get LPI.
23 MR. SHIPMAN: Not at four hundred pounds, I can't.
24 MR. ROCKHOLD: What is the difference in the damage to the plant at 480 versus 200 that the LPI will END #7
! Joe flws start pumping at?
l i
L8-1-JoLW21 320 1 MR. SHIPMAN: I think if I put tan thousand i . 2 gallons of water on the floor in the reactor pump, damage or 3 no damage, I think that is a significant event.
4 MR. ROCKHOLD : Will the PORV go to the --
5 MR. SHIPMAN: It will go to the floor. The 6 pressurizer is pretty high at 400 pounds. I am not so s ure 7 you wouldn't pump the drain tank.
8 MR. CFERNY: I just don't see a whole lot of 9 trouble just offhand in. closing that block valve at 200 10 psi. It just doesn't sound -- three or four hundred either 11 side.
12 Now, there is a post-TMI requirement that those
^
13 block valves have to be able to shut against stuck open 14 PORV at full operating pressure, so that thing ought to 2 close at 400. That doesn't sound -- unless you have an 16 awfully suspect block valve.
17 MR. SHIPMAN: No, I don't suspect my block valve.
18 It is just creating a LOCA to see if I can stop it, and I 19 just think that -- that frightens me.
3D MR. CHERNY: You seem to be under the impression
~
21 it is going to stick open, I guess. That is the way you 22 are sounding, anyway.
23 MR. SANFORD: We are certainly concerned with 24 it sticking open. Some of the experiences we have had.
25 MR. CHER11Y: Why don't you talk to B&W. Talk
321 8-2-JoeW I to Harry. He didn't think that wac a big dnal at zero
' 2 power.
3 MR. COLITZ: That was Harry who?
4 MR. CHERNY: Honig. H-o-n-i-g.
5 And we had -- I think there was a guy from Duke 6 Power, whose name escapes me. I think he was on that group, 7 too.
8 MR. PAGE: The other guys name is Bob 9 Johansson at Oconee.
10 MR. RANSOM: You say it is part of the NRC 11 position that they test during cool down --
12 (Discussion by NRC Staff.)
'- 13 MR. CHERNY: By the way, the standard requires 14 it be stroked twice.
15 MR. SANFORD: Once open, once closed.
16 MR. CHERNY: Twice open, twice closed.
17 I am not suggesting that for this right now. We are just 18 asking for one stroke. I am saying that is what the draft 19 standard has in it is two.
20 (Discussion between NRC Staff members.)
21 MR. PAGE: We also talked to Frank yesterday 22 testing during cool down versus heat up on the Event V, 23 the PIVs, and we seem to be in agreement. And in reading 24 this thing again, that isn't -- your interpretation, we l 25 feel, is not the intent of what this order meant or what 1
j i
l
8-3-JoeWal 322 t
1 it ocys.
2 It says very clearly unless testing has been 3 performed within the previous nine months -- we really don't 4 mean that that.was.during..the cool down,.that particular s cold shutdown.
6 All we think that means is that if you did it 7 during heat up in the previous nine months.
8 MR. CHERNY: I gather you guys sent us a 9 procedure not too long ago that shows how you implemented to your testing. We just haven't stumbled over it.
11 We sampled a whole bunch of plans and there doesn't seem 12 to be a general disagreement on that subject.
13 We think you guys have misinterepreted what 14 everyone else is doing on the way up.
5 MR. PAGE: It is the first time we have heard to that interpretation. -
17 MR. CHERNY: I think what we are going to do is 18 probably send you something on it. I am not real sure to 19 tell you the truth whether that belongs in IST SER or not.
20 That is something that sort of fell out of 21 review in this procedures.
22 MR. PAGE: Because all pressure isolation valves 23 and event V valves were thrown into the IST arena once that 24 review was done separately.
M MR. CHERNY: Maybe it should be in that SER, or
8-4-JoeWal 323 1 maybe it should be in a separate letter, I don't know, i
2 MR. SHIPMAN: It is unclear to me the importance 3 of the position that you have taken, that it has to be done l 4 on heat up.
5 MR. CHERNY: The idea was to do it as close as 6 Possible to reactor operation, to be sure the valves are 7 in the right position.during reactor operation.
8 MR. SHIPMAN: If it goes nine months between 9 tssting --
10 MR. CHERNY: The nine months was a frequency 11 thing. Unfortunately, they threw it all in the same 12 sentence.
N 13 The other part of it was the intent was to really 14 do it not after the plant -- not to do it on the way down, is and then they set there for six months and no one knows 16 what the heck happened to the position of the valves, or 17 the condition of the valves, and then you start the plant is up and you might even have a couple of them stuck open and 19 don't even know it.
20 MR. SHIPMAN: But worse would be if you did it 21 ~ on the heat up;within the next nine months you do hundreds 22 of cool downs, and not know the position of the valve.
23 MR. PAGE: That would be a highly tnlikely. Four 24 or five, but hundreds?
25 MR. SHIPMAN: Four or five during that nine month
324 8-5-JoeWel 1 period, dhat is not unlikely.
2 MR. CHERNY: You guys have that disease but 3 all new plants don't. You see, the new plants it is quite 4 simple. The tech specs say you test them after each 5 disturbance, and you don' t have this -- we recognize that 6 five years ago that the order could have been worded more 7 specifically than that.
8 We fixed that in the new standard tech specs.
9 It just says after each disturbance, so that takes care 10 of that problem.
11 MR. COLITZ: Do I understand then that we are 12 going to get same type of letter clarifying that it must
'; 13 be done on heat up?
14 MR. CHERNY: I don't know if it will be a 2 separate letter, or if it is something that should go in the 16 IST SER, or where it goes.
17 I think you will get something.
18 MR. COLITZ: Okay.
19 MR. McGOEY: Is this some type of separate 20 review?
21 MR. CHERNY: No, that is just a separate 22 issue. These are the valves that you have to test by the 2 Event V Order. This really isn't involved with CRGR.
24 MR. McGOEY: Okay.
2 MR. CONTE: There were two heat ups before hot
8-6-JoeWal 325 1
functionni tsat whera you did dstect -- appdrantly you 2 dete cted leakage maybe from an operational point of view I
3 that resulted in your cooling down and doing a leak check 4 of those valves.
5 MR. CHERNY: How did that come about. --
6 MR. BARLEY: A function of our abnormal 7
schedule situation, shut down for many months before 8
we have to establish operability of the valves to conduct 9 the heat up. On refueling outage, from our standpoint, 10 it is desirable to use the test on the cooldown. If you 11 had any problem after refueling outage, conduct a corrective 12 maintenance, and not find out you had problems at the last
'N 13 minute.
~.] At this point, is there any 14 MR. ROCKHOLD:
un more significant items that you feel that Frank Cherny 16 should participate in the discussion on?
17 Recognizing the time also, does anyone object 18 to a lunch break now.
19 NGt. COLITZ: Lets limit it to half an hour 20 instead of an hour if possible.
~
21 I think maybe though before he leaves there 22 are two items I would like to discuss. The spent fuel n . cooling system, that whole issue I think you people were 24 going to go back to your systems people. Maybe that is 25 where that is still left if you want more time to get
8-7-JoeW21 326 I back to the systems people, but that seems to be a 2 controversial area.
3 MR. CHERNY: Does he have it characterized 4 right.
5 MR. ROCKHOLD: I think so. Open items for the
. 6 NRC to determine safety related functions, spent fuel 7 cooling s'ystem, and for the licensee to determine the 8 failure mode of Category B valves.
9 MR. PAGE: I think that is where I left the 10 discussion yesterday.
11 MR. THOMPSON: What' number is that?
12 NEl. ROCKHOLD: BB.1 on page 28 of your written
{ s 13 response.
14 MR. SHIPMAN: We have the Category B valve Mi responses accepted. Our action to add 7 and 8 in our 16 submittal, and then we fell apart when we said what is 17 their function to close 7 and 8, discharge check valves.
18
- MR. CHERNY: No answer on that today.
MR. COLITZ: The last one we would like to 19 touch on, and we spent some time on it before you got here 20 this morning, was Item E.1, which was on the screen wash 21 pump.
l 22 MR. ROCKHOLD: The very last page.
23 MR. COLITZ: Question E.1 on page 33.
24 (Discussion between members of NRC Staf f. )
25 MR. CHERNY: And this is a safety related pump?
I
8-8-Jor.W21 327 1 MR. PAGE: That was a separata diccuncion.
2 It is emergency powered, but there seems to be some question 3 as to whether it was required to be emergency power, or 4 just convenient because emergency power was the nearest 5 source.
. 6 MR. CHERNY: Very simple system. Do those 7 run continuously, or are they cycled?
8 MR. SHIPMAN: They cycle. They cycle on a 9 timer and they cycle on DP across the screens.
10 MR. PAGE: My concern was that really wouldn't 11 pick up the degradation.
12 That you could have considerable degradation 13 and still be performing the functional requirement that 14 get the possibly near failure on one or two pumps, maybe.
15 MR. ROCKHOLD: It is more of a qualitative 16 assessment instead of a quantitative.
17 MR. CHERNY: I am still a little bit puzzled 18 about the safety function.
19 MR. PAGE: One of the questions was: Are'they 20 safety related or not? I don't know if we got the answer.
21 MR. SANFORD: We were not prepared to answer 3 that at this point.
23 MR. PAGE: Maybe we could leave it at that, and 24 if you give us that answer, then we could research --
25 MR. SANFORD: We would like to kind of hear
8-9-JoCW21
, 328 1 your answer.
2 If it turns out that they are safety related --
3 they may very well be mentioned in the FSAR. In fact, they 4 are mentioned.
5 MR. CONTE: There are a lot of them that aren't
. 6 safety related.
7 MR. SANFORD: I think that is going to be open 8 for a lot of interpretation.
9 MR. COLITZ: We would not shut down if we 10 lost both of those pumps.
11 MR. PAGE: Tech spec does not require you to 12 shut the pumps down?
13 MR. COLITZ: They are not tech spec pumps.
14 MR. PAGE: They are not. That is another 15 important aspect.
16 I really think the best thing to do is for 17 you all to figure out if they are required to be on 18 electrical power, and at the same time we concurrently --
19 because we both have homework anyway, I think --
20 MR. CHERNY: If you have clogged screens and 21 you lose both pumps, how much time do you have before you 22 have to take action?
Z3 MR. COLITZ: Send operators down to the utility 24 people, down to the screen house to manually keep them clean i
! 25 until we got a pump back. Use fire hoses.
329 I 8-10-JoeW21 ,
1 You have a great number of options.
( 2 You got rakes upstream of the screens, bar 3 rakes.
4 MR. CEERNY: Yeah, but how much time do you have 5 for him to do that before you get into some kind of a
. 6 temperature problem somewhere?
7 MR. SHIPMAN: I saw it happen in Unit 2 prior s to their commercial operations.
9 Their screens did clog, and they did develop to a significant Delta-P across the screen, and it was at least 11 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before we had that problem resolved.
12 At no time was there a cooling concern.
13 MR. CHERNY: That is what I am thinking.
14 MR. SHIPMAN: If the water does get through, and 2 you do maintain cooling.
16 MR. PAGE: Is it possible to have maybe a worse 17 event than that. Same exact scenario, only a more severe 18 clogging.
19 MR. SHIPMAN: You can develop any scenario you So want.
21 MR. PAGE: I am not trying to be Unrealistic.
22 I am .trying t6 be as~ realistic as I can be.
23 MR. ABRAMOVICI: I think you have got to look 24 that you will get a gradual pressure build-up. It is not 26 going to be instantaneous.
8-ll-JoeW31 330 1 MR. CHERNY: My parconal ft911ng 10 I bst thsy
. 2 are not safety related.
3 MR. PAGE: There was a discussion about the 4 emergency power because it was a convenient -- that is an 5 exemption from the Code. If it is strictly convenience, 6 it spells it out very clear ly in the Code.
7 If you are using emergency power strictly because 8 it was a convenient source of power.
9 (Discussion among NRC' Staff members.)
10 MR. THOMBSON: Okay. So, we both have action 11 on that.
12 MR. ROCKHOLD: Okay. We will recess until --
13 MR. COLITZ: 1:15 we will reconvene.
a v
14 (Luncheon recess taken at 12:45 p.m.)
15 (1:15 p.m. The meeting resumes.)
16 MR. THOMPSON: All right. We are all back on 17 deck. I think we are ready to go through all of the items 18 one by one, and basically check off those that are acceptable, 19 and briefly go over who has commitments and who has action 20 on the items from the October 22 letter list.
21 MR. RANSOM: I was wondering, I have made a lot 22 of changes. -
23 MR. THOMPSON: Let me --
I ,
24 MR. PAGE: Are we going to be going through here, i
2/ 25 and then side-by-side having this open to each item.
l I _ _
8-12-JoeW21 331 1 MR. THOMPSON: No. Wa cra going to go to tha
'- 2 summary, and where necessary we will clari fy. I think we 3 are going to work on the summary.
4 Let me take those and --
5 MR. MCGOEY: I think if there is a change, 6 you can just read it to us.
7 MR. THOMPSON: Let me suggest that we can get 8 started, and I will just run some copies while we start 9 on the first few lines.
10 MR. RANSOM: Well, I have one I am write in the 11 middle of rewriting here.
12 MR. THOMPSON: Let me take the other pages and 13 we will do that verbally.
14 MR. ROCKHOLD: The only change you made is in 15 that big wholesale change. I am sure there is going to be 16 more changes.
17 MR. PAGE: We will be making more changes as 18 we go through anyway. It would save time just tc go through.
19 MR. McGOEY: Okay. Let's just go through them.
20 MR. PAGE: See what the changes are. And at 21 the end, make a new set of copies. I think that would be H quicker.
23 MR. THOMPSON: Is it sufficiently good with what 24 they have got that we can proceed with that? Proceed with M that and we will give you a fresh copy at the end.
8-13-Jo;WCl 332 1 MR.ROCKHOLD: Okay. In light of that diccussion,
', 2 I believe it would be to our best interest to go through 3 these things one at a time, having clair read exactly what 4 he has written down, and you can read along.
5 If it differs from yours, and chances are it will 6 differ in a few instances, but in most cases it should be 7 fairly obvious what the differences are.
8 If you have a problem with it, we will stop and 9 discuss it. If you have no problem, we will continue to the 10 next item.
11 Recognizing that these handwritten notes are 12 somewhat a summary of what was actually said, we expect to
- 13 make changes to quite a few of the items that we have written 14 down.
l 15 If you have any problem with the terminology or l
l l 16 the acronyms that we have used, if we say residual heat 17 removal instead of decay heat, feel free to bring it to our 18 attention and we will change it, and try to make everything 19 as correct as possible, considering the space and time 20 restraints that we have.
21 So, as soon as Clair gets this one more statement 22 written down we will head into Item A.l.
23 MR. RANSOM: Okay. Are we ready?
24 MR. ROCKHOLD:Are we going to need to read the
'/ Wi questions out loud and then the answers?
l 8-14-JoeWal 333 1 MR. COLITZ: No.
" 2 MR. RANSOM: A-1. Refer to Appendix A in the 3 GPUN --
4 MR. McGOEY: No , no . Accept as written.
5 We don't want you to read it.
. 6 MR. ROCKHOLD: Is that the way you want to 7 handle it.
8 MR. COLITZ: He just started reading something 9 different than what we have seen.
10 MR. ROCKHOLD: That might be a good reason to 11 read every item that is written down.
12 MR. RANSOM: Refer to Appendix A in the GPUN respoE 13 dated August 22, 1985. Valves AH-VlB and AH-VlC have
(" ' -
14 limiting values of stroke times less than two seconds and 2 will be added to relief request IX as rapid acting valves.
16 MU-V51 will also be added to Relief Request IX.
17 The change I made there instead of Table I put 18 Appendix A, because that is what was identified in that 19 submittal.
20 MR. McGOEY: Okay. So you made change to items 21 other than what was discussed this morning.
22 MR. RANSOM: A few. Not very many.
23 MR. McGOEY: Okay. That is okay as written, let's 24 go to the next one.
l 25 MR. BASHISTA: I have to comment there. I l
l 8-15-JoeWol 334 1 think wn are adding all four valves to that relief requnct.
-3
!' ', 2 All four.
v,,:
3 MR. COLITZ: Okay as written.
4 MR. RANSOM: 2, the licensee's written response s from their August 22, 1985 submittal is acceptable.
6 MR. McGOEY: ,
Okay.
7 MR. RANSOM: Okay. 3, the Licensee!s written 8 response is acceptable.
9 MR. McGOEY: Okay.
l 10 MR. RANSOM: Okay. B.l. The licensee's written 11 response is acceptable.
12 MR. McGOEY: Okay. ,
13 MR. RANSOM: B.2. The licensee desires to only 14 test one train of the decay heat removal system each cold 5 shutdown due to the inconvenience of switching loops. This i
16 is not in accordance with the Code or the current NRC 17 position.
18 CF-V5A and V5B do not receive a full-stroke 19 exercise. The NRC position is that these valves which are 20 not full-stroke exercised with flow must be disassembled and 21 exercised.
Et This remains an open item for the licensee to 23 provide additional information on their proposed testing 24 (full or partial stroke exercising with percentages of partial:
26 strokes) and the testing frequency for all decay heat
8-16-JoeWni , 335 1 removal system components, and to provide additional e
2 information on the problems associated with switching the 3 decay heat removal loops.
4 MR. SHIPMAN: I would like you to remove the 5 word, ' inconvenience' at the front there. You use the 6 word, ' impractical.' It doesn't change anything.
- 7 MR. RANSOM: Okay.
8 MR. McGOEY: Impracticality of switching loops.
9 MR. COLITZ: So that is an item where we owe 10 you additional information.
11 MR. RANSOM: Yes.
12 '
MR. PAGE: You will get it typewritten, and 13 it will be underlined, all caps , so that it stands out on
(
14 the page.
15 End 8.
SueW fols.
16 17 18 19 21 22 23 24 1
~~ g i
336 69-1-SueW l MR. RANSOM: C.l. The licensee's written 2 response is acceptable.
3 D.l. The licensee will provide a relief re-4 quest for valve CA-Vl92 stating that the valve will. be 5 verified closed during refueling outages by performing a
- 6 leak rate test.
, 7 MR. COLITZ: That's okay.
8 MR. RANSOM: Okay. 2. The licensee's written 9 response is acceptable.
10 E.1. Some of these control valves may have a 11 required fail-safe position and would then be considered 12 active valves that should be tested in the IST program. It
'}, 13 remains an open item for the licensee to determine if any 14 of the valves do have required fail-safe positions and if 15 any do, to determine how to test those valves.
16 MR. SHIPMAN: Do you want to tie the other ones 17 together that are effected by that same statement?
18 MR. ROCKHOLD: When we approach the first one, 19 why don't we let it stand alone?
20 Then, when we get the similar valve later in the 21 report, we will say similar to D.1 or M.1 or whatever.
22 MR. RANSOM: Okay. F.1. This remains an open 23 item for the NRC to check the TMI-1 Technical Specificaion 24 Amendment to determine if the IST testing frequency is 25 adequate.
337
- 9-2-SueW 1 MR. MC GOEY: You might want to add Tech Spec
' 2 Amendment 78.
3 MR. RANSOM: Okay.
4 MR. MC GOEY: Other than that , it's all right 5 as is.
. 6 MR. RANSOM: Okay. G.l. There are valves
, 7 that perform a pressure boundary isolation function other 8 than those covered by the Event V order. Testing of these 9 valves is an item presently under discussion by the NRC.
10 A PIV candidate list will be provided to the 11 licensee. This remains an open item for the NRC.
12 MR. MC GOEY: You might put candidate list r' 13 has been provided to the licensee. You gave it to us last 14 night.
15 MR. THOMPSONi I think it's an open item for 16 NRC as f ar as this IST program.
17 MR. PAGE: It's an open item, long term CRGR.
18 MR. ROCKHOLD: Do you want us to identify 19 it as long team NRC open item?
20 MR. THOMPSON: I don't think you need to say 21 long term.
U MR. PAGE: It's definitely in our court, not 23 TMI's court. It's important to say that the list was 24 provided.
25 MR. ROCKHOLD: The question is, do we need to
338
- 9-3-SueW 1 leave: This remains an open item for NRC?
2 MR. SANFORD: Yes. I think we need a statement 3 in there that says this is not an open item for the TMI 4 IST program.
5 MR. PAGE: Go ahead and add it at the end if
. 6 you want.
7 MR. THOMPSON: I would rather not use the term 8 "Open Item." It's under consideration by the NRC. It's 9 closed for TMI IST program at this time.
10 MR. ROCKHOLD: Okay.
11 MR. THOMPSON: So, change that , these valves 12 are presently an item presently under consideration by the 13 NRC. The PIV candidate list has been provided to the
(}
14 licensee. This item is closed at the present -- at the 15 present time , this item is closed for the TMI-l IST 16 program.
' 17 MR. COLITZ: Is this the place to add the 18 words that I'm getting some piece of paper from you on 19 your position on doing this testing during heatup rather 20 than cool down?
21 MR. PAGE: No.
%! MR. COLITZ: Okay.
23 MR. PAGE: These are the non-Event V valves.
24 MR. COLITZ: Okay.
M MR. THOMPSON: Maybe this is not an open item.
I
i 339
-#9-4-SueW 1 Maybe we should say it that way, double negative. This is i /I:h 2
'+:jf not an open item.
j 3 MR. RANSOM: Or no action.
4 MR. PAGE: No action is required at this time 1
5 by the licensee. ,
. 6 MR. RANSOM: At the present time, no action
.- 7 is required for the TMI-1 licensee.
8 Okay. I will read the last two sentences of j 9 this G.1: A PIV candidate list has been provided to the 10 licensee. This topic is presently under consideration by 11 the NRC. At the present time, no action is required in t
M relation to this topic for the TMI-l IST program.
13 Is that --
{}
14 MR..MC GOEY: Good. '
i N MR. RANSOM: Okay. G.2. The licensee will 16 include additional justifications as identified in their 17 written response in the footnote justifying cold shutdown 18 testing of DH-V1 and DH-V2.
19 The functional operability of the mentioned 20 interlocks is verified during the ESFS -- make that AS --
21 testing.
- 22 MR. MC GOEY: Good.
El MR. RANSOM: Okay. These valves do not receive
,e Se an Appendix J leak rate test.
1
(.>.,
"~' Licensee response 25 MR. MC GOEY: Can you say i
, 340
- 9-5-Suew 1 is acceptable?
Un.
If/ 2 I think you should at least add that.
3 MR. COLITZ: Ye ah .
4 MR. PAGE: Are you going to want that behind 5 every one of these?
- 6 MR. MC GOEY: 'He already has it in most -- he
- 7 has it in every single one where that was the case.
8 MR. PAGE: Okay. I thought there may be some 9 o the rs .
10 MR. ROCKHOLD: There may be one or two.
11 MR. RANSOM: Okay. 4. The sump is pumped and a 12 flange is installed which prevents water from entering the
(} 13 decay heat removal system prior to testing these valves 14 during refueling outages.
U5 Due to the time required to perform these 16 evolutions , it is not priatical'.to perform this testing 17 during cold shutdowns. The licensee will augment Relief 18 Request to include this justification.
19 MR. PAGE: One " R. "
Q 20 MR. RANSOM: I have a hard time. I struggle 21 with double letters. When they are supposed to be there, 22 I omit them. And when they are not supposed to be there, 23 I put them in.
24 MR. MC GOEY: I would like to have you say:
25 Due to the time, manpower, and exposure required to perform I
341 89-6-Suew I these evolutions. We also talked about the exposure in-2 volved.
3 MR. RANSOM: Okay.
4 MR. PAGE: Would you say and/or?
5 MR. MC GOEY: Fine. That's okay with us. G.4.
. 6 MR. RANSOM: Just a second.
7 MR. MC GOEY: Okay.
8 MR. RANSOM: Okay. Now I just put: Due to the 9 time, manpower, and personnel exposure required to perform 10 these evolutions , it is not practical to perform this test-11 ing during cold shItdown.
12 Is that what you had --
13 MR. MC GOEY : Af ter " personnel exposure" why
\_/
. 14 don't you put in parentheses "(ALARA)?"
15 MR. RANSOM: Okay.
16 MR. MC GOEY: Good.
17 MR. RANSOM: 5. This remains an open item 18 for the NRC to determine if the partial-stroke of these 19 valves, approximately sixty-seven percent of required flow, 20 is sufficient to demonstrate operability of these valves.
21 MR. MC GOEY: Okay.
M MR. RANSOM: 6. One of these valves is full-23 stroke exercised during each cold shutdown. It remains an 24 open item for the licensee to provide additional informa-25 tion and justification to support their proposed testing of
342
'#9-7-SueW 1 these valves. Refer to Question B.2.
- n . 2 B.2 is a discussion on testing each loop, 3 switching loops.
4 okay. 7. The licensee will categorize valves 5 DH-V22A and B A/C instead of C.
6 MR. MC GOEY : Yes.
7 MR. RANSOM: Okay. 8. These valves are full-8 stroke exercised one valve during each cold shutdown. It 8 remains an open item to determine whether both valves be 10 exercised during each " cold shutdown not to exceed once 11 every ningty days. Refer to Questions B.2 and G.6.
12 MR. MC GOEY: We should say who it is an open 13
( item for, NRC or GPU.
14 See , on B.2 I think we have that, MR. RANSOM:
16 an open item --
16 MR. COLITZ: We owe the information.
17 MR. RANSOM: -- for the licensee. So, I guess 18 we could put after "open itea" put "for the licensee."
19 MR. MC GOEY : O.' ay .
30 MR. RANSOM: Well, hold it now. The licensee 21 isn't going to determine whether -- okay. For the licensee 22 to provide additional justification, but the NRC is the one 2 that will make the decision whether the valve should be 24 exercised during each cold shutdown.
25 MR. MC GOEY: We will gladly make the
343
- 9-8-SueW I determination, but I think the NRC would want to review 2 it.
3 (Laugh ter. )
4 Just say we will submit the information dealing 5 with that.
6 MR. RANS OM: This reads a little awkward. What
. 7 I have here now is: It remains an open item for the 8 licensee to submit additional justifications to allow 8 determination as to whether both valves be exercised during 10 each cold shutdown, not to exceed once every ninety days.
11 MR. MC GOEY: Good.
12 MR. RANSOM: Refer to Questions B.2 and G.6.
13 Okay.
14 9. The licensee's written response is acceptablie.
15 MR. MC GOEY: Good.
16 MR. RANSOM: 10. The licensee's written re-17 sponse is acceptable.
18 MR. MC GOEY: Goed.
19 MR. RANSOM: H.l. Refer to the licensee's 30 response. The licensee will test the vacuum breakers 21 quarterly by manually stroking the valve flappers open.
22 MR. MC GOEY: We would like to say: Licensee's 23 response is acceptable.
24 MR. RANSOM: Ye ah . That is --
25 MR. ROCKHOLD: It is acceptable with the
344
- 9-9-SueW l exception of the discussion -- well, wait a minute. Maybe e
2 it's acceptable for everything.
3 Wasn't it?
4 MR. MC GOEY: Yes.
5 MR. ROCKHOLD: Okay.
6 MR. RANSOM: I will just put this sentence at
. 7 the end: This testing method is acceptable.
8 MR. ROCKHOLD: Is that going to work?
9 MR. MC GOEY : Why don' t you just say : Licensee 's; 10 response is acceptable, period?
11 MR. ROCKHOLD: We need to leave that extra 12 sentence in there just for our clarification.
13 MR. MC GOEY: Okay.
14 MR. RANSOM: I can replace that first little 15 sentence and still say: Refer to licensee's response.
16 I will say: Licensee's written response is 17 acceptable and then leave that sentence in there.
18 MR. MC GOEY: Yes.
19 MR. RANSOM: Okay. I've got it in.there.
20 I.l. Okay. The licensee will provide a set 21 of pictures that were taken of the disassembled internals 22 of EF-V3. If the removal of the valve internals is not 2 approved and accomplished by the end of the eddy-current 24 outage -- and I have ninety to a hundred and twenty days 25 after restart.
, 345 49-10-SueW 1 MR. SHIPMAN: I rould suggest you just simply a
2 refer to the eddy-current outage as required. Amendment 3 103 to our license specifies what that is.
4 MR. BARLEY: You haven' t quoted it exactly 5 right here. Rather than spell it all out, just refer to
. 6 the Tech Spec Amendment.
. 7 MR. THOMPSON: Amendment 103.
8 MR. ROCKHOLD: Tech Spec Amendment?
9
- MR. BARLEY: Right.
10 MR. RANSOM: Okay. By the end of the eddy-11 current outage (Refer to Tech Spec Amendment 103) .
U MR. THOMPSON: Required by Amendment 103.
13 MR. RANSOM: Pardon me?
I' MR. THOMPSON: Required by Amendment 103.
15 MR. ROCKHOLD: Basicslly, we put that paren 16 in there to say if you want more definition on eddy-current 17 outage go to Tech Spec Amendment 103. We weren't trying to 18 say how long it's going to be.
19 MR. THOMPSON: We are referring to the specific 20 eddy-current outage in the Amendment rather than any other 21 that they might have.
22 So, I think it would be better to say at the 23 end of the eddy-current test outage required by Amendment 24 103, to be quite specific. That should be eddy-current 25 test outage I think.
l l
1^
346 (9-11-SueW 1 MR. RANSOM: Okay. That sentence now reads :
2 If the removal of the valve internals is not approved and 3 accomplished by the end of the eddy-current test outage 4 required by Tech Spec Amendment 103, the licanoce will propose 5 to disassemble this valve once every ten years.
6 This remains an open item for the licensee.
. 7 MR. MC GOEY: Good.
8 MR. RANSOM: Okay.
9 MR. PAGE: Is someone keeping tab o'f which page 10 the changes are on?
11 MR. RANSOM: I think it would be easier to just 12 copy everything.
13 2. Refer to the licensee's response. This remains 14 an open item for the NRC to determine if the licensee's 15 testing frequency, cold shutdowns exceeding thirty days, 16 is acceptable.
17 EF-VilA and VllB cannot be partial-stroke exercis-18 ed quarterly since the vent and drain connections are isolated 19 by closure of EF-V10A and B during the pump test procedure.
2 MR. MC GOEY: Okay.
21 MR. RANSOM: Okay. 3. Refer to the licensee's M response. The licensee will include EF-Vl9A/B and EF-V21 23 in the TMI-l IST program and they will be exercised quarterly 24 in accordance with the Code.
25 MR. MC GOEY: Okay.
4 347
- 9-12-SueW 1 MR. RANSOM: Okay. J. The licensee indicated I
2 that the flush of the emergency feedwater system --
3 MR. BARLEY: Let's back up to I.3. Are you 4 going to say that you accepted our written response on 5 EF-V1 and 27 i
6 MR. RANSOM: We can do that. Yeah.
7 MR. CONTE: But wasn't the comment on the 19A 8 and B and 21, that the program specifically include them?
9 MR. ROCKHOLD: The write-up was acceptable, but 10 it left out the discussion about whether they were or were 11 not going to be included in the program.
12 We asked that question. The result was : Yes, they would be added. Licensee's written response
( 13 So , put :
14 is acceptable. The licensee will include 19 and 21 in 15 the program.
16 So, it's kind of an additional comment.
17 MR. CONTE: Okay.
18 MR. RANSOM: Okay. Are we ready to go on to J.l?
19 The licensee indicated that the flush of the 20 emergency feedwater system, which involves a slow fill and 21 drain through small valves, does not remove all of the con-Et taminants from the system, which is the justification for not 23 testing EF-V4 and the EF-V5 during cold shutdowns.
_ 24 The licensee does not feel that the additional 25 testing, which with its possible introduction of contaminants
348
- 9-13-SueW 1 is warranted for these valves.
2 This is an open item for the NRC.
3 MR. COLITZ: I don't think that is an open item 4 for the NRC. I think we agreed to supply some of this 5 additional justification in the footnote.
6 MR. ROCKHOLD: Okay. I think that's right.
7 MR. COLITZ: I think it is Licensee needs to 8 supply. We did not give you this type of information in our i
8 footnote.
10 MR. THOMPSON: But the Staff still needs to 11 , consider this justification.
12 MR. COLITZ: Right.
(. 13 14 MR. MC GOEY: Are you saying you don't need additional information?
15 MR. ROCKHOLD: We need additional information.
16 We are not a hundred percent positive we are going to approve 17 it, but we are leaning that way.
18 MR. BARLEY: Licensee will provide this additional 18 justification for NRC review.
Okay.
20 MR. RANSOM: The licensee will provide 21 additional information in their justification for NRC 22 review.
23 Okay.
24 MR. MC GOEY : Okay.
26 MR. RANSOM: Okay. K .1.' This remains an open i
349 49-14-SueW 1 item for the licensee to determine if the current system 2 testing provides sufficient information to determine 3 individual valve operability.
4 MR. MC GOEY: Okay.
5 MR. RANSOM: Okay. 2. These valves are 6 similar to thermostats on automobiles where there are no
. 7 external controls. The valves could f ail either closed or 8 as is.
9 It may be possible to determine by observing to temperature readings during the full load test whether the 11 valve is open. ,
12 This remains an open item for the licensee.
13 MR. MC GOEY : Okay.
14 MR. RANSOM: L.l. The licensee's written 15 response is acceptable.
16 MR. MC GOEY : Okay.
17 MR. RANSOM: M.l. The licensee's written response 18 is acceptable. The Cycle 6 refueling outage is the next 19 refueling outage.
20 MR. MC GOEY: Okay.
21 MR. RANSOM: N.l. The licensee's written re-22 sponse is acceptable. The valve position indication is M verified to be correct at least every two years.
24 MR. MC GOEY : Okay.
25 MR. RANSOM: 0.1. Same as fo r N . l .
. 350 2
49,15-SueW I MR. MC GOEY: Okay.
a 2 MR. RANSOM: P.l. The licensee's written re-3 sponse is acceptable. These are non-safety related valves 4 and will be identified as such in the TMI-l IST program.
5 MR. MC GOEY: Okay.
6 MR. RANSOM: Okay.
7 MR. MC GOEY : You might want to highlight that s and say -- do you want to highlight it as a licensee 9 action?
10 MR. PAGE: You can do that.
11 MR. RANSOM: Okay. The licensee's written 12 response is acceptable. The licensee is required to i ..
. 13 perform a test on the ESAS quarterly which results in a i 14 partial-stroke exercise of these valves to the mechanical 5 block.
16 MR. MC GOEY: Okay.
17 MR. RANSOM : Q.l. The licensee's written 18 response is acceptable.
19 MR. MC GOEY : Okay.
20 MR. RANSOM: 2. The licensee's written response 21 is acceptable.
22 MR. MC GOEY: Okay.
23 MR. RANSOM: 3. This remains an open item for g<
24 the N RC. The eighty percent valve opening in the August 22, s~. . -
26 1985 licensee transmittal is incorrect.
4
351
'49-16-SueW 1 The proper value is approximately thirty-six 2 pe rcent. The licensee will propose to disassemble one valve 3 every ten years on a sample disassembly program.
4 MS-V9B was disassembled in 1984 and the licensee 5 proposed to disassemble MS-V9A during the Cycle 6 refueling 6 outage and submit a report on the inspection to the NRC.
7 MR. SHIPMAN: We would also provide our service 8 record.
9 MR. PAGE: The one you did last November or 10 whatever it was, that will come I guess with whatever --
11 MR. THOMPSON: Do you specifically want that 12 to be submitted for your review?
i 13 MR. PAGE: Ye ah .
I 14 MR. THOMPSON: Okay.
15 MR. RANSOM: Okay. So the report on the 16 MS-V9B disassembly will also be provided to the NRC.
17 MR. SHIPMAN: Yes. Herb, this morning we also 18 said we would give you a service report on those two valves.
19 MR. ROCKHOLD: Yes.
1 2D (Mr. Cherny enters the meeting room with a 21 document.)
22 MR. CHERNY : Let me give this to them before 23 they leave so they see what we are talking about.
l i
24 The other thing is, we did a little review up-l ,
\:~ 1 25 stairs and testing is allowed at full pressure. Anyway, j 1.
, 352 69-17-SueW 1 that is the latest one. I wanted to make clear that we
'; 2 did a little review upstairs and there is a provision in 3 there for the test but it's every full cycle at full 4 pressure .
5 (Mr. Cherny leaves the meeting room.)
6 MR. RANSOM: Okay.
7 MR. MC GOEY: Before you read, can we give you 8 one other word change?
9 The eighty percent valve opening in the August to 22nd, 1985 licensee submittal is incorrect.
Licens ee 11 believes the proper value is approximately thirty-six 12 percent. Licensee will verify and document the correct
" 13 value.
14 MR. SANFORD: I would say it appears to be Hi_ correct.
16 MR. MC GOEY: In other words, we looked at the 17 calculations sitting at the table, and it looks like the 18 right number but we just want to go back and have a chance 19 to look at it a little more carefully.
20 MR. RANSOM: Okay. I will read this again now.
21 Okay. The eighty percent valve opening in the August 22nd, M 1985 licensee transmittal is incorrect. The licensee
- believes that the proper value is thirty-six percent and 24 they will verify this value.
26 MR. S ANFORD: Why not change "is" in the statement
353
, #9-18-SueW 1 there to " appears to be" so it says: The eighty percent 2 valve opening in the August 22nd 1985 licensee transmittal 3
j appears to be incorrect?
4 MR. RANSOM: Okay. Appears to be incorrect.
5 The licensee believes that the proper value is thirty-six a
percent and they will verify this value.
7 MR. MC GCEY: Fine.
8 . MR. RANSOM: Okay. We are okay on the rest 9 of this?
10 MR. ROCKHOLD: No. You haven't read it yet.
11 MR. RANSOM: Okay. I haven' t read it.
12 The licensee will propose to disassemble one
{ 13 valve every ten years on a sample disassembly program.
14 MS-V9B was disassembled in 1984 and the licensee is proposed to disassemble MS-V9A during the Cycle 6 refueling 16 outage and submit a report on the inspection to the NRC.
17 The license will also submit an operating history of 18 MS-V9A and B and the report on the disassembly of MS-V9B 19 to the NRC.
20 MR. MC GOEY: Okay.
21 MR. RANSOM: Okay. Q.4. The licensee's written 22 response is acceptable for AS-V4.
23 It is an open item for the NRC to determine if
. 24 EF-P1, the turbine driven emergency feedwater pump, is 25 safety-related. If it is determined that EF-P1 is safety-rel sG
354
- 9-19-SueW 1 it is the Staf f position that MS-V8A and B perform a safety 2 function and should be included in the IST program and be 3
tested in accordance with the Code.
4 The licensee indicated that the valves cannot 5 be exercised quarterly during power operation since there 6 are administrative requirements that the valves remain open 7 during operation. Therefore , if EF-P1 is safety-related, 8 the licensee will propose to exercise MS-V8A and B during ,
8 cold shutdowns.
10 It is an open item for the licensee to determine 11' if MS-V6 has a required fail-safe position. If MS-V6 does 12 have a required f ail-safe position, it is an active safety-13 related valve that should be included in the IST program and 14 be tested in accordance with the Code.
is The licensee indicated that if MS-V6 is 16 determined to be safety related, they would include a 17 request for relief from measuring stroke times for MS-V6.
18 The status of MS-V22A and B hinges on the resolu-19 tion of MS-V6 and, therefore, remains open for both the NRC 20 and the licensee. .
21 That's a mouthful.
22 MR. THOMPSON: Let me take a time out.
23 (An off-the-record discussion ensues.)
24 MR. THOMPSON: Okay. We can go back on the 26 record now.
355
.#9-20-SueW 1 Okay. The first of that is : It is an open et 2 item for the NRC to verify that --
3 MR. RANSOM: Well, mine is a lot different. I 4 don' t have anything like that in there.
5 MR. THOMPSON: Start right at the beginning.
6 The licensee --
7 MR. RANSOM: Well, I could -- why don ' t I jus t 8 ,make --
9 MR. THOMPSON: Verify that it's in the IST 10 program. ,
11 MR. RANSOM: I have a whole page, and he has 12 just a little bit. The verbage is completely different.
13 I could --
14 MR. SHIPMAN: Why don' t we allow the transcript, 15 to identify this item instead of rewriting the notes?
16 MR. RANSOM: I will just put It is an open 17 item for the NRC to determine if the EF-P1, the turbine 18 driven emergency feedwater pump, should be in the IST progran .
19 If it is determined that the EF-P1 should be in
- the IST program, it is the Staff position that MS-V8A and B 21 perform a safety function?
22 MR. PAGE: Right. It should be in the IST END #9 23 program.
Joe fws 24 25 l
l 10-1-Jcewn1 356 1 MR. RANSOM: I think I have got it. Listen l
\
2 to me closely. and see if I say something here I shouldn' t.
3 Okay, I am going to go over 4 again. The 4 licensee's written response is acceptable for AS-V4.
5 It -is an open item for the NRC to determine if 6 EF-P1 (the turbine driven emergency feedwater pump) should
=
7 be in the IST program.
8 If it is determined that EF-P1 should be in the 9 program, it is the staff position that MS-VSA/8 perform to a safety function and should be included in the IST program 11 and be tested in accordance with the Code.
I 12 The licensee indicated that the valves cannot 13 be exercised quarterly during power operations since there 14 arenadministrative requirements that the valve remain open is during operation.
16 Therefore, if EF-P1 is required to be in the 17 program, the licensee will propose to exercise MS-V8A/B
' ~
18 during cold shutdowns. It is an open item for the licensee 19 to determine if MS-V6 is in required fail safe position.
20 The rest of it hasn't changed.
21 MR. BARLEY: We ought to cite the tech specs.
22 MR. McGOEY: Let's replace ' administrative' with 23 ' tech spec.'
24 Other than that, it is okay.
- MR. RANSOM: I have made that change.
4 10-2-Joewnl 357 1 MR. McGOEY: Okay. Next.
l# m 2 MR. RANSOM: R.l. The licensee's written 3 response is acceptable. The licensee will identify valves 4 MU-VlA and B as being non-safety related in the IST 5 program.
4 MR. McGOEY: Okay.
I .
7 MR. RANSOM: 2. The licensee's written response
. 8 is, acceptable.
9 MR. McGOEY: Good.
10 MR. RANSOM: 3.. The licensee's written response 11 is acceptable. Refer to Item P.2.
I
! 12 MR. McGOEY: Good.
l l / 13 MR. RANSOM: 4. The licensee's written response 14 is acceptable.
2 MR. McGOEY: Good.
16 MR. RANSOM: 5. The licensee's written response 17 is acceptable.
16 MR. McGOEY: Good.
. 19 MR. RANSOM: 6. The licensee's written response 20 is acceptable for valves MU-VilA and VllB.
21 The licensee will add MU-V47 to the IST program 22 as a Category C -- should have, ' valve' in there -- Category
- C valve, and will exercise it quarterly in accordance with 24 the Code.
- MR. McGOEY: Okay.
10-3-Jo;Wal 358 i
1 MR. RANSOM: S.l. The licensee's written 2 responses in their August 22, 1985 submittal and in i
3 reference 4 are acceptable.
- i.
i 4 MR. McGOEY: Okay. l 1
4 5 MR. RANSOM: Okay. 2. The licensee's written
~
s response is acceptable.
7 MR. McGOEY: Okay.
s MR. RANSOM: 3. The licensee will provide the 9 technical justification for not full stroke exercising I
to MU-V73A/B and C quarterly or during cold shutdown.
i '
11 The justification for not exercising quarterly l 12 is that the make-up pumps do not have sufficient head i
13 to pump into the RCS during power operation. During cold
{,
14 , shutdowns, they cannot be exercised due to low-temperature j is overpressure considerations.
I to MR. ROCKHOLD: Cannot develop full flow.
i 17 MR. THOMPSON: S.3. I think didn't we agree i
l 18 that that was acceptable justification. They would .
l . 18 document the justification, isn't that right?
l ,
30 MR. ROCKHOLD: They are going to include this l 21 information in their justification.
! i 22 MR. THOMPSON . Right.
f l 23 MR. PAGE: We don't want to disagree with what M their justification would say.
l SS MR. BARLEY: Just simply say we will provide r
additional justification.
i
--,.y_ _r -~ , _ , , , . - , , _ . ._,,,--..,..,_.s--..,._,,-.w.. - -,%--4.- , .y -. - r ,e,_ , . , _ ,, --..,,_,..r.
.- . . _ ~ - . - _ - - . . - . . -.. _ . .- - - _ - ~ . _ -
10-4-JoLW31 359 8
1
~
1 MR. ROCKHOLD: We like to write it down so we 2 will know what you are going to put in there. It is kind of 3 a cross check, so we expect to find that particular item 4 in the justification.
5 MR. RANSOM: Okay. It says now, that sentence The justification for not exercising quarterly 4 reads:
7 is that the make-up pumps cannot develop full flow into e the RCS during power operation. During cold shutdown 8 they cannot be exercised due to low-temperature over-L l
10 pressurization considerations.
I '
11 MR. McGOEY: Fine.
12 MR. RANSOM: Okay. 4. Refer to the licensee's response and to the response to Question S.3.
{'/ . 13 14 MR. McGOEY: Okay.
i M MR. RANSOM: 5. The licensee will provide -
le a relief request from verifying valve MU-V116 in its safety I
i 17 related position (closed) either quarterly c r during i
I is cold shutdown and will make this verification during the leak
!. 18 rate test at refueling o utages.
l .
80 Refer to licensee's response for MU-V219. No
{ 21 change is required in the TMI-1 IST program for valve !
J
] 22 MUV-219.
j 23 MR. McGOEY: That is fine. You could have said i
i j 24 licensee's response is acceptable for MUV-219. We are
' - as satisfied.
4 i
360 10-5-JoeWal ,
1 MR. ROCKHOLD: We have a minor word change
- The
) 2 on this first sentence here. Change it to read:
i 3 licensee will provide a relief request from verifying 4 valve MU-V116 in its safety related position (closed) i 5 quarterly and during cold shutdown, and will make this j 4 verification during leak rate test at refueling outages.
i l' 7 MR. McGOEY: Okay.
1 8 MR. RANSOM: 6. This valve is not safety l 9 related and will be identified as such in the TMI-l i
, 10 IST program. .
11 - MR. McGOEY: Okay.
4 12 MR. RANSOM: 7. The licensee's written response l
- 13 is acceptable.
(
14 MR. McGOEY: Okay. ,
i Hi MR. RANSOM: T.l. The licensee will check the a 9 i le TMI-l IST program to determine what leak rate testing is j- 17 performed on NI-V27.
i
! 18 MR. BARLEY: .I think that should be 26.
{ ,
19 MR. ROCKHOLD: 27 is currently in the program; 1
l
) ,
20 26 was our basic question.
i j 21 MR. ABRAMOVICI: Is it the IST program, or the
- 22 Appendix J program?
i 23 MR. ROCKHOLD: We are not asking you to amend t M your Appendix J program. '
If the valve is currently leak
/
l j 26 rate tested for Appendix J, then we expect to see it in the t
3
.-~ - - - . ,-.,-,.,,.v.--- , , - - , . - - m, ,-m----m. , , , , , . - , , , . . - . , . , , - - . . -
,n.. _ , . ,,, ,, - - .,, , , , . , . . , . , - -
_g, , ,., .n,.
361 10-6-JoeW21 1 IST program.
2 MR. RAMSOM: I think this should either 3 say Appendix J program or technical specification.
4 MR. THOMPSON: It is not in the tech specs.
5 MR. RANSOM: So, it would be Appendix J program 6 rather than the IST program.
7 MR. PAGE: Couldn't you say the licensee will 8 provide this information?
9 MR. THOMPSON: You can simply say: The licensee 10 if V26 is included in the Appendix J program, it will be 11 included in the IST program.
12 That is what you are asking, isn't it?
13 The -- if the V26 is included in the Appendix J 14 program, it will be included in.the IST program.
15 MR. ROCKHOLD: How about if we make that read:
16 The licensee will include NI-V26 in the IST program if 17 that valve is currently leak rate tested per Appendix J.
18 MR. McGOEY: Right.
19 MR. RANSOM: U.1, the licenseen written 20 response is acceptable.
21 MR. McGOEY: Okay.
22 2. The licensee's written response MR. RANSOM:
23 A concern is acceptable for all the valves except NR-V18.
24 was expressed that NR-V18 failing closed could defeat the 25 river water system, ..nd that the valve, therefore , is safety
10-7-JoeW31 362 I related.
E' 2 The remains an open item for the NRC, but will 3 not require the licensee to take any action at the present i
4 time.
5 MR. McGOEY: Okay.
1 6 MR. RANSOM: Okay. V.l. The licensee's written T
7 response is acceptable.
t 8 MR. McGOEY: Okay.
9 MR. RANSOM: V . 2 .' The licensee's written 10 response is acceptable.
11 MR. McGOEY: Okay.
12 MR. RANSOM: V.3. The licensee's written responso 13 is acceptable.
)
7 14 MR. McGOEY: Okay.
18 MR. RANSOM: V.4. This remains an open item l
! Is for the licensee to determine if any of the listed valves j 17 have a required fail safe position.
18 MR. McGOEY: Okay.
f 19 MR. SHIPMAN: Refer to E.1.
l 20 MR. RANSOM: Pardon me?
i 21 MR. SHIPMAN: This is the second one of those, i
22 MR. RANSOM: Okay. Put in paren (Refer to i
j g -- .
- 24 MR. SHIPMAN
- E.1.
26 MR. RANSOM: E.1. That is the first place we I,
i
10-8-JoeW21 ,
4 1 discussed fail safe.
2 Okay. W.l. The licensee's writ cen response 3 is acceptable.
4 MR. McGOEY: Okay.
5 MR. RANSOM: X.1. The licensee's written l 8 response is acceptable.
7 MR. McGOEY: Okay.
8 MR. RANSOM: 2. The licensee's written response .
9 is accepable.
10 MR. McGOEY: Okay.
11 MR. RANSOM: 3. The licensee's written response 12 is acceptable.
13 MR. McGOEY: Okay.
{'
14 MR. RANSOM: 4. The licensee's written response is is acceptable for valve NS-V12. It remains an open item i
18 for the licensee to determine if valve RR-V6 has a required 17 fail safe position.
18 MR. McGOEY: Okay. Do you want to refer to E.l?
- 19 MR. RANSOM: Okay. Y --
, , 20 MR. THOMPSON: Why don't you read all those 21 that are the same.
22 MR. RANSOM: Okay. Y .1, 2, 3, 4, the licensee's 23 written reponse is acceptable.
24 MR. McGOEY: Okay.
26 MR. RANSOM: Okay. Z.1, 3, and 5, I have the J
- - . ~ . . , - - - , - - . - . .- -., , - - - - - -
10-9-JoeW21 ,
364 1 licensee's written response is acceptable.
2 MR. McGOEY: Okay.
3 MR. RANSOM: Z.2 and 4, I have the licensee's 4 written response in conjunction with Reference 4 is 5 acceptable.
~
6 MR. McGOEY: Okay.
7 MR. RANSOM: Okay? AA.1, the licensee's written a response is acceptable. The licensee will indicate that 4
9 these valves are non-safety . elated in the TMI-l IST 10 program.
11 MR. McGOEY: Okay.
12 MR. RANSOM: 2. The licensee's written response 13 is acceptable.
[
14 MR. McGOEY: Okay.
2 MR. RANSOM: 3. The PORV at TMI-l is a pilot 16 operated valve that requires syste.9 pressure in order to 17 stroke the valve; therefore, in order to test the valve is they would have to initiate a small break LOCA which is
. 19 not desirable.
30 The PORV is a rapid acting valve, so stroke 21 timing need not be trended. This remains an open item 22 for the licensee. The NRC indicated that exercising the 23 PORV during cooldown to refueling outage should be 24 acceptable.
26 MR. ROCKHOLD: Would you like to hear that
10-10-JoeW21 365 I again, since you don't have it written down in your copy?
2 MR. McGOEY: Just the tail end of that again.
3 MR. RANSOM: Okay. The last two sentences: The 4 PORV is a rapid acting valve, so stroke timing need not s be trended. This remains an open item for the licensee.
6 The NRC indicated that exercising the PORV during cooldown 7 to refueling outage should be acceptable.
1 8 MR. McGOEY: Okay.
9 MR. THOMPSON: You are not tied down by that 10 at all.
11 MR. RANSOM: No. That is why I said that would 12 be acceptable.
13 MR. McGOEY: Okay.
(
14 MR. RANSOM: Okay. BB.l. Due to the amount Hi of time available to restore fuel pool cooling, if it is 16 lost, approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> immediately after inserting 17 fuel from the reactor, there may be sufficient time to make 18 system alignment changes or repairs to allow the restoration
. 19 of the cooling, if lost.
20 Therefore, it is an open item for the NRC to 21 determine the safety related function of the spent fuel 1
M pool cooling system. It is an open item for the licensee 23 to determine the failure mode -- or the required f ailure 24 mode of the Category B valves.
26 MR. ROCKHOLD: These are all new notes for you
10-ll-JoeW21 ,
366 1 p e r.i p l e , aren't they?
2 MR. McGOEY: Yes.
3 MR. THOMPSON: I have a suggestion on that.
4 Again, if they are safety related, I would prefer to say 5 -- start off and said 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to reallign. The Staff --
6 it is an open item for the Staff of the NRC to evaluate 7 or to determine -- we can look at that basis, and determine 8 whether that --
9 MR. SHIPMAN: Didn't you say yesterday that to the Category B valves agreed with our response? It was 11 only the Category C valve --
12 MR. ROCKHOLD: I think the whole thing is kind of up in the air. Another comment I would like to make,
(~\ 13 14 since they do not even have a rough copy of this, no copy 15 whatsoever, could we get copies made in just a few minutes 16 so that at least they can follow along?
17 I am sure it is confusing to them just hearing 18 this.
19 MR. THOMPSON: You are having trouble with this.
20 MR. ROCKHOLD : I think we have about six or 21 seven pages left.
%! MR. TIIOMPSON: Why don't we take a three minute El break.
24 MR. ROCKHOLD: All of this is brand new 25 today.
10-12-JoeWOl -
367 1 MR. RANSOM: I haven' t had a chance to change 2 all of these, so there will be some that we will want to 3 change .
4 Okay. On BB.1, we are changing an open item 8 for the NRC to determine if the spent fuel cooling system 8 should be included in the IST program. Determine whether 7 you include the spent fuel cooling system in the IST i 8 program.
8 MR. COLITZ: I guess rather than say all of 10 that, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> available af ter inserting fuel from the
- 11 reactor and all of that, I think if you are going to leave 12 it that the NRC is going to go -- it is an NRC open item
(; 13 to determine if the spent fuel cooling system is included 14 in the IST program.
15 I would like it to read that the111censee ~ will 16 go back and look -- take a further look at the valves l
17 that we discussed to see what the failure modes on them 18 and so forth were.
. 18 I don't know how you can -- we spent a lot of 80 time on this, and it was pretty complicated, and I think 21 the easiest for the transcript to read, for the notes to 22 read that the NRC will determine if it should be included 23 in the IST program, and we will look, and if it is going 24 to be included, what are we capable of testing?
26 We have all those inner-locks, and we will look i
i
_ . . -_- - - . . . - . - - . .. - - . = _ . - . - - - _-
l 10-13-JoeW31 368 i
1 at the whole -- revisit the whole issue. '
2 MR. Ti!OMPSON: And we were going to discuss this?
l 3 Is that the one we were going to discuss?
4 MR. COLITZ:. Well, the one we -- I made a note that we were going to have a phone call on with MS-V6 and 5
6 MS-V22A/B was the one we said we would have further phone 7 discussion on, and maybe that would be appropriate for us j 8 to do that on this.
i 9 After we really look at what capabilities do we 10 really have to test in this area if we are required to do 11 it.
12 (Discussion among members of NRC Staff.)
13 MR. THOMPSON:
. (~Tj <
Let me suggest that we have j 14 a simple statement that this is an open item for the NRC
[ t la to determine if the spent fuel cooling system should be 18 included in the IST program.
$ 17 If it is, further discussion will be needed with is the licensee.
19
, MR. McGOEY: Good.
!, 30 MR. THOMPSON: All the details we talked about j 21 are on the record anyway, and we can go back and review them j 22 there, and you will, I expect, be prepared for that 1
- 23 discussion.
24 MR. McGOEY: Absolutely.
j # MR. RANSOM: Okay.. So that brings us down to:
i i
10-14-JoeW21 369 1 This is an open item for the NRC to determine if the 2 spent fuel cooling system should be included in the 3 IST program; if so, further discussions will be held with 4 the licensee.
5 MR. McGOEY: Good.
6 MR. RANSOM: CC.1. Refer to the licensee's 7 response. It is an open item for the licensee to determine 8 if SW-V24A and B have a required fail-safe position.
9 MR. McGOEY: Good.
10 MR. RANSOM: Okay. DD.l. Testing the boric 11 acid pumps and the boric acid recycle pumps will generate 12 large amounts of liquid waste.
13 There are four pumps and it requires running
{}
14 approximately 15 minutes to test each pump which could H5 generate up to 32,000 gallons of radioactive liquid waste 14 per pump.
17 This much waste is generated because injecting 18 concentrated boric acidd requires dilution of the RCS.
19 The WDL-P13A and B boric acid recycle pumps do have a
.2 recirculation line and can, therefore, be cested quarterly 21 and the licensee can measure pump Delta-P and vibration.
22 Flow cannot be measured when the pumps are 23 running in a recirculation path because there is no installed 24 flow instrumentation.
26 When testing the pumps during refueling outages,
10-15-JoeW21 370
- l 1 pump Delta-P vibration and flow can be measured.
' 2 The licensee proposed to test WDL-P13A and B 3 whever these pumps are identified as technical specification 4 pumps by making the Delta-P and vibration measurements 5 quarterly and measuring the flow, Delta-P, and vibration 6 during testing performed during refueling outages.
7 Awkward.
8 The boric acid pumps do not have a recirculation 9 line and cannot be tested quarterly during power operation, 10 since this would add boric acid to the RCS, which could result 11 in power fluctations.
12 Due to the large amounts of radioactive liquid 13 waste generated when testing these pumps, the licensee does 14 not desire to test these pumps during cold shutdown, but 15 desires to tost CA-PlA and B during refueling outages.
16 All power operated valves in these systems that 17 are in the IST program will be tested quarterly in 18 accordance with the Code.
19 The check valves that are in the recirculation M flow path of the boric acid recylce pumps will be exercised 21 quarterly when the pumps are tested.
M The check valves in the flow path to the mix D tank can only be exercised during refueling outages when 24 flow can be established through the valves.
25 MR. BARLEY: That should be make-up tank rather
371 10-16-Joe W 1 than mix tank.
2 MR. RANSOM: You are right.
3 Okay. The flow path to the make-up tank can 4 only be exercised during refueling outages when flow can 5 be extablished through the valve.
- 6 The licensee will include a discussion similar 7 to this write-up in the appropriate relief requests.
8 MR. McGOEY: Okay.
9 MR. COLITZ: You spent an hour rewording that, 10 but I think it covered what we agreed to do close enough.
11 MR. RANSOM: It is pretty hard --
12 MR. COLITZ: I agree. We spent a lot of time 13 talking about this one. I think what is written here covers 14 what we basically talked about.
15 MR. RANSOM: Okay. 2. Refer to the response in 16 Item M.l.
17 MR. McGOEY: Okay.
18 MR. RANSOM: Okay. 3. It was pointed out that 19 technical specification testing requirements are to 20 demonstrate system operability and that the IST program 21 is to demonstrate operability of individual components, 22 and the two are not dependent on each other.
23 There fore , the technical specification testing 24 frequency does not override the Section XI testing 25 frequencies.
10-17-JocW 372 1 MR. ROCKHOLD:How about adding a word in the
' sentence there, about half way through, where it says.: And 2
3 the two.are not necessarily dependent upon each other.
4 MR. BARLEY: And the last sentence, it should 5 say the testing frequency doeds not necessarily override 6 the Section XI testing frequencies. Doesn't preclude relief.
7 MR. RANSOM: Added two 'necessarilys.' Okay.
8 4. This item is related to Item DD.1, and will depend on 9 resoluation of DD.l. This remains an open item.
- 10 MR. McGOEY
- Okay.
End 10. 11 SueW fois.
12
( ', 13 14 15 16 17 S
18 19 21 22
' 23 24 25 l
0
373
, ill-1-SueW 1 MR. RANSOM: Okay. 5. Same as DD.l.
~,.3,
? MR. COLITZ: Okay.
3 MR. RANSOM: The pump testing program, A.l.
i 4 MR. COLITZ: Go ahead.
! 5 MR. RANSOM: Okay. A.l. There is a flow instru- ,
I 6 ment in the test flow path. However, the range of the 7 flow instrument does not meet the required Section XI range 8 i requirements.
9 The licensee will provide a relief request for 10 measuring pump flow utilizing the installed flow instrumenta-11 tion.
12 The licensee's position that testing pumps in a 13 fixed flow path and measuring Delta P but not flow is not
(
14 consistent with the edition of the Code used by the licensee. !
2 I know, two Xs in the case. I saw that, too. l 16 (Laughter. )
17 Okay. Are we okay on that one?. It doesn' t read 18 - real pretty.
18 ('N o response.)
30 B.l. Refer to the licensee's response. The 21 time involved to go to one pump depends on many f actors which i 22 vary for each shutdown.
23 MR. MC GOEY : I thought this was licensen's 24 response was acceptable..
,f'! i
~'
25 MR. COLITZ: I thought B.1 and C.1 were acceptable.l 4
y_ , . , . . - , . . , , . . _ , . , , , .,
a _ _ _ - - _ _ _ .,
374 l
- 11-2-SueW 1 MR. RANSOM: Okay. B.1, C.1, D.1 and 2 were u_ 2 all acceptable. I haven't had a chance to get to this page 3 to make those changes. I was doing it in my spare time this 4 mo rning .
5 MR. ROCKHOLD: Can you do daat now?
6 MR. THOMPSON: Go ahead and finish what you are o
7 doing, and then you can polish that before we give the 8 licensee, or whoever wants to stay, a copy of that.
9 MR. RANSOM: Okay. C.1 will read: The licensee'o 10 written response is acceptable.
11 D.1 and D.2 will read: The licensee's written 12 response is acceptable.
() 13 14 Okay. E.1. The licensee cannot measure flow when testing the screen wash pumps due to the lack of 15 installed flow instrumentation.
16 The licensee stated that observing screen wash 17 flow provides the operator with a visual indication of the 18 . pump flow.
19 The NRC pgsition is that not making the Code 20 required measurements will prevent detection of pump 21 degradation and is, therefore, not acceptable. These pumps 22 are not covered in the plant Technical Specifications but 23 they are supplied with emergency power.
.. . y 24 It is an open item for the licensca and the NRC O?O 25 to investigate the safety significancy of these pumps.
375
- 11-3-SueW 1 + MR. COLITZ: Is this one we maybe should include r;
s/ 2 in our phone conversation?
3 MR. ROCKHOLD: It wouldn' t hurt.
4 MR. THOMPSON: Maybe say to investigate and 5 discuss.
- 6 MR. RANSOM: To investigate --
7 MR. THOMPSON: And discuss.
8 MR. RANSOM: -- and discuss.
9 MR. COLITZ: I guess, you know, we are going to 10 get a copy of this. I want to make sure I understand and 11 that it's clear to our Licensing Department what the next few 12 steps are as far as getting something in writing from ycu.
13 Us probably resubmitting whatever new additions we agreed to, 14 the ones that we said we would add to.
ui How do you see this -- the sequence and the time 16 frame?
17 MR. THOMPSON: Let me run through what I see will 18 be happening.
19 MR. COLITZ: Okay, 20 MR. THOMPSON: Today we will give you a copy of e
21 this after Clair has cleaned up the last few items.
1 22 We will prepare a typewritten copy of this, l l
23 probably --
24 MR. PAC-E : Which will include, of course, what s' your actual response was and then say this is acceptable.
25
376 But it will have Question, Answer, Question, Answer. It
- 11-4-SueW 1 2 will be just a running tally which is much easier to read, j 3 of course, than the way we structured it here.
4 And then we will --
5 MR. THOMPSON: We also have brief Minutes of the 6 meeting which will include a copy of the transcript and the c
7 one handout which was the PIV list and the testing of PORVs.
8 MR. PAGE: OM-13.
9 MR. THOMPSON: No. That was a courtesy copy 10 from Frank.
11 MR. PAGE: You don't want to include that?
12 MR. THOMPSON: No, I don' t think we need to put
( 13 that in the Minutes.
14 MR. ROCKHOLD: How about the General Considera-15 tion Section ,from the Code , SER?
16 MR. THOMPSON: Yes, but this is a publicly 17 available document so we can refer to that, the OM.
18 You have some work to do. We have some work to 19 do. We have some telephone communications to make.
20 Af ter that, we will be expecting an additional 21 submittal from you. And based on that additional submittal, E the Staff will prepare another SSE. The Staff will prepare 23 a Safety Evaluation for your second Ten' Year %IST program.
24 MR. COLITZ: I guess for now the best thing is 25 you and Bob to stay in touch on when is the right time frame
l 377
- 11-5-SueW 1 for the telecon, are we ready or are you ready. I don't 2 know if we can set dates now.
3 MR. THOMPSON: I don' t believe we can set dates 4 now. While we clearly don't want to drag --
MR. COLITZ: Neither do we. I think you and Bob 5
6 need to stay in touch and see if we can' t bring these to 7 some rapid conclusions.
8 MR. ROCKHOLD: Can you talk ball park figures?
9 Say, within the next two weeks or next three weeks or within 10 the next month for the telephone conversation?
11 MR. THOMPSON : How soon can you be ready for a 12 conversation? We can be ready within a week or so.
10 MR. COLITZ: I would hope in two weeks. We do
(
I4 have a f air number of valves to look at, f ail-safe , these 15 type things.
16 MR. THOMPSON: Okay. We will anticipate in two 17 or three weeks that we will have a telephone conversation 18 and your response after that.
, 19 Any estimate on written responses?
u 20 MR. KNIGHT: Some time af ter the first of next 21 month.
MR. THOMPSON: We will have to negotiate, then.
22 MR. COLITZ: I think we are talking somewhere 23 24 about a month.
l 25 MR. KNIGHT: We need to know what we are going to I
378 til-6-SueW 1 do with the V3 and we probably won't know about that until
~
2 after the first of the month.
3 MR. THOMPSON: Well, I thank you all for your 4 tolerance and dedication.
5 MR. MC GOEY: You say with respect to what you
- 6 see happening, it's going to be SSE on the second ten year 7 program. Well, won' t there also be an SSE on the first ten 8 year program?
9 MR. THOMPSON: No, that's complete.
10 MR. SHIPMAN: An -- daat's going to be an open 11 item.
12 MR. MC GOEY: So, it's for an open item?
12 MR. AB RAMOVICI : If they approve it for a second, 14 I assume it's good for the first.
15 MR. THOMPSON: No. I believe we closed out that 16 first ten year program with the Safety Evaluation and the 17 Supplemental Safety Evaluation and denied some of your 18 relief requests.
19 MR. MC GOEY: Okay. But, based upon what we learned hede /
20 MR. THOMPSON: The Appeal that you've made was 21 on your second ten year program. Okay.
22 MR. KNIGHT: No. l 23 MR. PAGE: It was on the SSE for the first ten 24 year program. ,
l 25 MR. MC GOEY: Yes, that was our Appeal.
I 1
379
- 11-7-SueW 1 MR. THOMPSON: Okay. As far as paper work, we 2 may have to close that out with a separate letter just to 3 keep the paper work clean.
4 MR. MC GOEY : That was our March 19th letter.
5 MR. THOMPSON: Wasn' t that in response to our
= 6 December letter that said we deny the relief request for 7 the second ten year program?
8 MR. MC GOEY: That would be the first program.
9 MR. THOMPSON: Do some of these people want to 10 leave?
11 Let's close the meeting. I think we are done 12 with the meeting. I think we had a pretty good two-day
^
13 session and accomplished an awful lot.
v 14 I think we are well on the way to cleaning this 15 up. So, I thank you all for your participation.
16 (Whereupon, the meeting is adjourned at 2 :50 p.m. ,
17 Thursday, September 5, 1985.)
18 ************
ENDDDD 19 1
21 22 23 l
24 25
b 1 CERTIFICATE OF OFFICIAL REACRTER l 2
3 4
e 5 This is to certify that the attached proceedings 6 before the United States Nuclear Regulatory Commission in the 7 matter of:
8 9 Name of Proceeding: MeetingonTMI1In-ServiceTesting-Pump 5 and Valves Review of Second 10-Year Prograa 10 11 Docket No.
/~ 12 Place: Bethesda, Maryland 13 cate: Thursday, September 5, 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 (Typed Name of Reporter) Myrtle E. Walsh 20 21 22 23 Ann Riley & Associates. Ltd.
l 24 25 In _ _
- CERTIFICATE OF OFFICIAL REPORTER l 1
w l
3 3
4 5 This is to certify that the attached proceedings 6 before the United States Nuclear Regulatory Commission in the 7 matter of:
8 9 Name of proceeding: Meeting on TMI 1 In-Service Testing - Pump
- and Valves Review of Second 10-Year Prograa 10 11 Docket No.
place: Bethesda, Maryland
('S 12 13 Date: Thursday, September 5, 1985 14 4
^
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 1 19 (Typed Name of Repor't%/) Garrett J. Wd , Jr.:
v 20 21 22 23 Ann Riley & Associates. Ltd. ,
I 24 25 f