ML20235D702
| ML20235D702 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1598, NUDOCS 8707100268 | |
| Download: ML20235D702 (346) | |
Text
QM.SW/ fin' OR!GLNAL O UNITED STATES i NUCLEAR REGULATORY COMMISSION !
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IN THE MATTER OF: DOCKET NO: )
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON INTEGRATED SAFETY ASSESSMENT PROGRAM (ISAP)
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O LOCATION: WASHINGTON, D. C. PAGES: 1- 279 I
DATE: TUESDAY, JULY 7, 1987 f0. /I'] F l
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.(. [ , y A I h w/ e Ii % k ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North Capitol Street i Washington, D.C. 20001 87071O0,768 870707 (202) 347-F00 f
PDR ACRS j T- 1598 PDR NATIONWIDE COVERACE I
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5940 01 01 1 l rysimons 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 INTEGRATED SAFETY ASSESSMENT PROGRAM (ISAP) SUBCOMMITTEE 5 Nuclear Regulatory Commission 6 Room 1046 7 1717 H Street, N.W.
8 Washington, D. C. l l
9 Tuesday, July 7, 1987 10 The subcommittee convened, pursuant'to notice, at 11 9:00 a.m., David Ward, Chairman of the Subcommittee, 12 presiding.
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13 ACRS MEMBERS PRESENT:
14 D. WARD l
t 15 J. EBERSOLE 16 C. SIESS 17 ACRS CONSULTANTS PRESENT:
18 P. DAVIS i
19 ACRS COGNIZANT STAFF ENGINEER: l 20 R. SAVIO l
1 21 NRC STAFF AND INDUSTRY PRESENTERS:
22 M. BOYLE 23 C. THOMAS 24 A. WANG O 25 ACE-FEDERAL REPORTERS, INC.
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5940 01 01 2 rysimons 1 B. ATEIFI 2 E. MROCZKA )
l 3 R. FACTORA j 4 R. KACICH l
5 J. CUINN '
i 6 P. BLASIOLI 7 J. BICKEL 8 M. LEDERMAN 9 * * * *
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) PUBLIC NOTICE BY THE j j
UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS TUESDAY, JULY 7, 1987 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at O~ this meeting accepts any responsibility for errors or l inaccuracies of statement or data contained in this transcript.
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1 5940 11 0 01 3 rysimons 1 PROCEEDINGS 2 CHAIRMAN WARD: The meeting will now come to 3 order.
4 This is a meeting of the Advisory Committee on 5 Reactor Safeguards Subcommittee on the Integrated Safety 6 Assessment Program.
7 I am David Ward, the Subcommittee Chairman.
8 Other ACRS members in attendance are Mr. Ebersole and Dr.
9 Siess, and we also have ACRS consultant, Mr. Davis.
10 The purpose of this meeting will be to discuss 11 the NRC Staff's and the Northeast Nuclear Energy Company's 12 experience with the ISAP process and to use the Millstone 1 ,
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13 and Haddam Neck.ISAPs to understand how the process 1 l
14 functions. .
l 15 Dr. Savio is the Cognizant ACRS Staff member for 16 this meeting.
17 The rules for participation in today's meeting i
18 have been announced as part of the notice of this meeting ]
19 previously published in the Federal Register on June 26, 20 1987.
21 A transcript of the meeting .is being kept and j 22 will be made available within five working days. I request i 1
23 that each speaker first identify herself or himself and .
l 24 speak with sufficient clarity and volume so that she or he :
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25 can be readily heard. !
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5940 01 01 4-rysimons 1 We have received no written statements or 2 requests for time to make oral statements from members of 3 the public.
4 I would just like to make a brief comment on our 5 purpose and the committee's purpose in reviewing this.
G program.
7 I think we want to review the program in some 8 depth, in as much depth as we can with the resources we 9 have available to do it and the time, but not so much for 10 the specific application to the Millstone and Haddam Neck 11 plants, but more to understand the process.
12 I think we see more and more of the-regulatory O 13 program and particularly the programs to resolve unresolved 14 safety issues seem to be evolving into programs actually to 15 make fairly broad assessments to identify risk contributors 16 at the great variety of plants we have out there in this 17 country.
18 If we look at the IPE program under the severe 19 accident policy and if we look at what the resolution of 20 Task Action Plan A-45 might end up being, a number of these 21 programs really call for a licensee to make a detailed'and 22 thoughtful review of his plant and then react to what is 23 learned in that review.
24 That seems to be of course exactly what the ISAP O 25 program is doing or is attempting to do in what appears to ACE-FEDERAL REPORTERS, INC.
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aarysimons 1 be a rather comprehensive and well integrated way, and if 2 it is as good as it looks, it may very well serve as a f l
3 model in my mind for much broader application in the 'j l
4 industry. ;
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5 I guess on the down side is the concern that we ,
I 6 all have about the too literal application of the results 7 of probabilistic risk assessment studies. There is concern 8 that the elaborate studies sometimes are at risk of f 9 becoming a house of cards.
i 10 So I think it is those issues that we want to 11 keep in front of us as we hear about and think about the 12 ] ISAP process as applied to these two particular, plants.
13 Do any of the other members or, Pete, do you have l 14 anything you would like to say at this point?
15 MR. EBERSOLE: I just want to say that I think 16 this is a very important program and it's kind of a i
17 coincidence here. I remember in 1966 we took Millstone 1,
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18 the original PSAR and took a red crayon and doctored it to i 19 make the Browns Ferry PSAR and noted the existing licensing 20 criteria, and I'm anxious to hear how you took up and 21 solved some of the problems we thought we saw.
22 I'll just name a few, there was GDC 19, there was 23 the qualification of steels for service water piping, there 24 was the absence of any control criteria on heating and O 25 ventilating systems and a whole host of things. There was ACE. FEDERAL REPORTERS, INC.
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an RBCCW in the design which 6 was made 3
which controlled the temp of screwed fittings 4
looking forward to hearin g how erature of the dry well, and m I' current perspectives. all these 5 are viewed in the MR. SIESS:
6 been answered in the SEPThose wereshould questions have that 7 lt MR.
weren't they?
8> EBERSOLE:
of I'm not sure, Chet.
the SEP program. I wasn't part 9
10 MR. SIESS:
was. Sure you were.
The whole 11 I committee MR.
EBERSOLE:
O 12 MR.
SIESS:
Well, yes, in that context.
13 }d current code The SEP looked at deviati ons from 14 i MR.
EBERSOLE:
15 l that horrible in terpretation One particular one I re i
you member was 16 l must extend, l
17yl!down the plant exterior tor rather you must have an of GDC 19 where it was said 18 o the ability to shut
- Commission at that control room, and the 19 time was l
industry and permitted extensionvery cooperative the the with 20 l 21 ;
control rooms and run offcords to be drawn out of really extended fire vulne to distant paints which 22 find these rability.
I 23l as an erroneous extensions of vulnerabilit And to this day we y to fire in 24 f existence 25 which requirements.
was subsequently e corrected in those years by thint
- current fire
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5940 01 01 6 rysimons 1 an RBCCW in the design which was made of screwed fittings 2 which controlled the temperature of the dry well, and I'm !
3 looking forward to hearing how all these are viewed in the 4 current perspectives. 1 5 MR, SIESS: Those were questions.that should have (
6 been answered in the SEP, weren't they?
7 MR. EBERSOLE: I'm not sure, Chet. I wasn't part 8 of the SEP program.
9 MR. SIESS: Sure you were. The whole committee i
10 was, i 1
11 MR. EBERSOLE: Well, yes, in that context.
12 MR. SIESS: The SEP looked at deviations from )
O 13 current code --- a l
14 MR. EBERSOLE: One particular one I. remember was i l
15 that horrible interpretation of GDC 19 where it was said j i
16 you must extend, or rather you must have an. ability to shut 17 down the plant exterior to the control room, and the .
l 18 Commission at that time was very cooperative with the
, 19 industry and permitted extension cords to be drawn out of i
20 the control rooms and run off to distant points which 21 really extended fire vulnerability. And to this day we 22 find these extensions of vulnerability to fire in existence ;
23 as an erroneous interpretation of GDC 19 in those years 24 which was subsequently corrected by the current fire O 25 requirements.
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5940 01 01 7 rysimons 1 Those circuits ought to be cut off because they 2 are true extensions of vulnerability. Yet I expect you 3 protected those extended circuits rather than snipped them 4 off by providing fire protection to them. That's the 5 classic way of NRC covering such illogical arrangements.
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6 You ought to take a scissors and cut them off, all of them.
7 That's all I've got to say.
8 CHAIRMAN WARD: Okay. Are you looking for a 9 response, or expecting that there might be one?
10 MR. EBERSOLE: No. I'm just saying I'm looking 11 forward to these sorts of things to come out as we go 12 along.
O 13 CHAIRMAN WARD: Whether that will or not, I don't 14 know.
15 Well, let's go ahead.
16 Pete, did you have anything you wanted to way?
17 MR. DAVIS: No.
18 CHAIRMAN WARD: Okay. Let's turn to the staff 19 then. I understand Mike Boyle is going to lead the 20 discussion.
21 MR. BOYLE: My name is Mike Boyle. I'm the 22 Integrated Assessment Project Manager for Millstone 1.
23 (Slide.)
24 What I'm going to talk about first today is the O 25 history objective and scope of ISAP, what it was all about ace-FEDERAL REPORTERS, INC.
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l 5940 01 01 8 rysimons 1 and where it came from.
1 2 CHAIRMAN WARD: Mike, let me interrupt you before 4
3 you start. I guess I'm continuing to try to study the now l d
4 organization, and I see you are in a division which is ---
5 MR. BOYLE: Region III, IV, V and Special f a
6 Projects. [
7 CHAIRMAN WARD: This is in the Special Projects, 8 part of that?
9 MR. BOYLE: No. I 10 MR. THOMAS: This.is'still the Integrated Safety 11 Assessment Project Director. We were one of the few 12 branches that did not change in the last reorganization.
O 13 MR. BOYLE: Now we have both learned something J
l 14 new. Now I know where I am. j 15 (Laughter.) I i
16 Back in 1977 the staff started the Systematic 1
17 Evaluation Program, SEP. The purpose of that program is to 18 review certain of the oldest operating plants against 19 regulatory requirements that have come into existence since ;
20 the time the plant was licensed.
21 That program developed in Phase I of SEP 22 approximately 130 topics to be reviewed, and out of those 23 maybe 80 or 90 were applicable to any one of the 10 plantv 24 that were being reviewed in the program.
O 25 Phase II of the program was the review of each ACE FEDERAL REPORTERS, INC.
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5940 01 01 9' rysimons 1 plant against that list of topics, and most of those plants i
2 had the review in the 1984/1985 time frame. ,
3 As part of the TMI Action Plan in NUREG 0660 the l i
4 interim reliability evaluation program was developed which i
1 5 was going to review a short and quick. review PRA review of ]
I 6 a few plants to look for risk outliers, i l
7 When both SEP and IREP have] been completed or 8 are nearly completed, the Commission was looking for ways 9 to continue those programs.. SEP was supposed.to be 10 continued.in Phase III which was going.to be the same 11 program applicable to all plants. The interim reliability l
12 evaluation program was going to supposedly continue with j
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13 the national reliability evaluation program for all plants. ]
14 The Commission saw that one of the significant j 15 conclusions drawn for SEP and IREP is that issues related 16 to safety of operating nuclear power plants could be more 17 effectively and efficiently addressed if they were J
18 addressed in an integrated and plant specific manner rather 19 than in a generic manner.
20 The NRC in 1984 decided to integrate the PRA part 21 of the IREP program together with the technical evaluation 22 part of the SEP program into a new program called the 23 Integrated Safety Assessment Program. That program was 24 formalized in a Federal Register Notice in November of O 25 1984.
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5940 01 01 10 j rysimons 1 For one reason or another the original ISAP 2 program was redefined into a pilot program of just two 3 plants, and the details of that were presented in SECY 85- !
l 4 160.
5 (Slide.)
1 6 The objective of ISAP was to perform integrated 7 assessments of operating nuclear power plants on a plant 8 specific basis to evaluate all licensing options that the 9 NRC currently had for that plant, all licensee initiated 10 plant improvements and selected unresolved generic safety 11 issues to establish implementation schedules for each one ;
12 of those items.
O 13 In addition, the staff and licensee were to 14 develop procedures to allow periodic updating of that 15 schedule.
l 16 The major elements of ISAP were review of the 17 lessons learned from SEP. After SEP Phase II was completed 18 the staff took a look at all the major findings for the 10 l l
19 plants that had the reviews completed. From all those l 1
20 findings the staff found about 25 major issues common to l 21 most of those plants. Those were the lessons learned.
22 The lessons learned were then supposed to be 23 evaluated in ISAP for each plant going through that 24 review. However, in the pilot program the staff limited O 25 the pilot program to just two plants, and those had already ACE-FEDERAL REPORTERS, INC.
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< 5940 01 01 'll rysimons 1 gone through SEP. So the review of lessons learned was 2 already completed on the day those plants started ISAP.
3 (Slide.)
4 The next step in ISAP was the performance of a 5 plant specific risk assessment. The two plants,_ Haddam j 6 Neck and Millstone 1 in ISAP, for those two plants the ,
d 7 staff had performed very limited issue oriented risk 8 assessments. l
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9 Here was asked the licensee and ISAP to perform a ]
10 Level 1 PRA. The utility had already started that before I
11 they got into ISAP. '
12 As a continuation of SEP the staff also was going O 13 to use the operating experience analysis. In ISAP the u
14 operating experience analysis was updated from the SEP end 1
15 date to the current time frame, and we also asked the )
l 16 people doing the operating experience analysis to look for 17 trends and to try to tell us what all those LERs and 1
18 information meant. I 19 We then asked the licensee to perform an j 20 integrated e.ccs isrcent of all the topics that got into ISAP, 21 and out of that assessment came an integrated 22 implementation schedule for everything that needed to be 23 done. j 24 (Slide.)
25 ISAP was conducted by the staff by an integrated l
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n bdrysimons 1 assessment team that was made up of the Integrated
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l 2 Assessment Project Manager, the Operating Reactor Project 3 Manager, the Branch Chief, Project Director, Resident' 4 Inspector, a risk analyst and other specialties as needed 5 such as a human factors analyst. )
I 6 The first step of ISAP was getting that j i
7 integrated assessment team up to the plant and get.them as 8 familiar with the plant as possible. Luckily, since both 9 of these plants had' participated in the SEP, we had a lot )
10 of carryover in personnel. So everybody was fairly 11 familiar with the two plants. j l
12 The integrated assessment team and the licensee l O 13 independently put together a list of all the NRC actions, i
14 all the licensee plan initiatives, generic issues and 15 whatever that we wanted to consider in ISAP.
16 The integrated assessment team and the licensee 17 then met to develop the definitions of each topic, their i l
18 scope, their criteria that we were going to evaluate that I i
19 the topics would be evaluated on and the justification for l
20 the plant to continue operating while these topics were 21 still open.
22 Not every issue that was a' licensing action or 23 licensee plan initiative was deferred and put in ISAP. We 24 made sure in the beginning of the program that the licensee O 25 would have enough work in the interim to keep them busy, ACE FEDERAL REPORTERS, INC.
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5940-01 01 13 rysimons 1 and also is a licensing action was almost complete or was
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2 of high safety signif(cance or something of that nature, we 3 didn't defer it. We asked them to get it done immediately.
4 CHAIRMAN WARD: I didn't understand what you 1 5 said. You made sure the licensee had enough work to keep.
6 him busy?
7 MR. BOYLE: Well, the purpose of.ISAP was to take 8 everything on the books and evaluate and prioritize it and-9 then put it in a schedule to get it done. Well, that could 10 take a year'or two years or three years to do, and in the 11 meantime what is the licensee going to do.
12 We tried to make sure that there were enough near-0 13 term actions for them to complete te keep their work 14 schedule ---
15 CHAIRMAN WARD: Why are you worried about what 16 the licensee is going to do? I don't understand.
17 MR. BOYLE: Well, a lot of the things that they I i
18 had to do were NRC liceraing actions, and if they were of 19 high safety significance we wanted to get them done now l 20 rather than defer them for a year or two years so that they 21 could get into the schedule.
1 22 CHAIRMAN WARD: Okay. Well, I can see an j 23 explanation for why you didn't want to see high priority 24 safety issues postponed for a year, but the way you stated O 25 it is you didn't want to see the licensee not doing l
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s rysimons 1 anything for a year, which is a little bit of a funny way i 2 to put it.
i 3 (Laughter.)
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4 It's perhaps reflective of an attitude which is 1 5 troublesome.
l 6 MR. BOYLE: There were also things like bulletins I 7 that they had to do immediately. We wanted to make sure I
8 that things that had to get done would get done in'the time !
l 9 that ISAP was being conducted. )
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10 MR. EBERSOLE: When these plants were built there l I
11 were no SRPs. It was a regular free for all, you know. So j 12 now there are SRPs. Do I understand that the SRPs are kept !
13 current as new issues are brought up and solutions are 14 determined for them so we always have fresh SRPs? Do you 15 go back and fix these or are they getting obsolete, too?
16 If criteria other than current SRP requirements i
17 are used, I take it you are primarily using those l l
18 requirements, but how do I know they are not out of date?
19 MR. BOYLE: You have to have faith in the staff.
20 (Laughter.) l 1
21 MR. EBERSOLE: Well, do you maintain them?
l 22 MR. BOYLE: The SRPs are maintained. However, 23 when we did SEP and ISAP we did use a cut-off date for new !
24 requirements. I mean you just had to freeze it at some ;
O 25 point so we all had a common base to work from.
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l 5940 01 01 15 rysimons 1 The ISAP evaluation was divided into three 2 parallel phases. The first one was topic evaluations. In 3 the original program this was also supposed to include the 4 SEP lessons learned. They were the deterministic reviews. ;
i
'5 Since they had already been accomplished in SEP there was i l
6 not much for the licensee to do.
l 7 However, some of the other topics that were 8 included in.ISAP, they also included a deterministic 9 evaluation to try to resolve that topic. At that point )
10 they submitted it and we reviewed it. ;
i z
11 MR. EBERSOLE: May I take just a particular point l 12 to see if I can understand what you did.
O 13 In those times simple redundancy was considered i
14 adequate or so-called safety systems, including both I q
l 15 dynamic and static systems, and sometimes a static. system )
l 16 didn't even have but one train or function like pipes.
17 This simple redundancy led to designs in what !
18 I'll call auxiliary support systems which were on 19 continuous duty whose trip-out or failure would initiate a 20 severe accident potential if the sole remaining active 21 component didn't rise to the challenge. It was an 22 invalidation really of the single failure criterion in the 23 service systems because when you entered the emergency 24 condition you didn't have any redundancy.
O 25 What did you all do about that on those old ACE FEDERAL REPORTERS, INC.
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2 MR. BOYLE: You're asking the wrong person.
3 MR..EBERSOLE: Well, this was a serious business. ;
-i 4 MR. BOYLE: I would have to go back to the SEP 1
5 reviews to see what was done on redundancy. I know we did ,
l 6 address it in electrical systems. l 1
7 MR. EBERSOLE: Evidently it was not recognized 8 early on that a service system failure would precipitate l
9 unless you made it up a progression toward disaster, and .
10 yet you had only one train to raise to that kind of 1
11 emergency, but you were very enthusiastic to have a I l
12 multiple set of trains to rise to a LOCA that was never I
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13 going to occur. It was an illogical set. l l
14 MR. BOYLE: To be' frank with you, I do not know ,
15 the answer to that question offhand.
16 For those topics included in ISAP for which a 17 risk assessment was amenable we asked the licensee to 18 perform a topic specific probabilistic review. That came 19 for probably a third of the topics.
20 At the same time the topic evaluations were going 21 on the licensee was performing their probabilistic safety 22 assessment, and the staff was performing the plant 23 operating experience review.
24 Besides the topics that got into ISAP because of O 25 the screening review when the licensing was performing a ACE FEDERAL REPORTERS, INC, 202-347 3700 Nationwide Coverage 800-336-(M6
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barysimons 1 probabilistic safety assessment and the staff was doing an 2 operating experience review, they were looking for outliers 3 or trends or other issues that could be also evaluated in 4 ISAP, and the staff came up with two or three of those 5 topics for each of the plants specifically oecause of the 6 review of the PSA and operating experience.
7 The staff then asked the licensee to perform an 8 integrated assessment of the topics to determine which 9 warranted corrective actions based on perceived safety ;
i 10 significance and to develop a cost effective action to I 11 resolve multiple issues if that was practical. l 12 After the licensee submitted their integrated
() 13 assessment, the staff reviewed that and integrated their q l
14 draft integrated safety assessment report which was NUREG )
l 15 11-84 of which you have received a copy. That draft report 16 was issued to the licensee, to a peer review group similar 17 to SEP and to the ACRS for comments.
18 The comments from the licensee, the peer review I i
19 group and the ACRS are going to be included where practical l
20 in the final report. At the same time the licenses submits 21 their comments on the report, they are also to submit a 22 proposed integrated implementation schedule. The 23 integrated implementation schedule and the methodology to 24 maintain and update that schedule will then somehow be tied 25 to the license.
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l 5940 01 01 18 j rysimons 1 (Slide.)
i 2 The next three sides are some of the major l 3 milestones that the staff has gone through with the i 4 licensee in the last three years starting in March of '84 1
5 with the initial proposal for the integration of SEP and 6 NREP into ISAP. l l
7 If there are no questions on any of these. It's 1 8 just basically when things were.done in ISAP, when the 9 reports were done and what issues Were looked at.
10 MR. SIESS: When did the SEP conclude? Can you 11 give us the SEP history on there two plants, or does that 12 come later? You started with March '84.
O 13 MR. BOYLE: If I'm not mistaken, the final report 14 for SEP on Millstone was like April of '83.
15 MR. SIESS: The SEP had been completed on both 16 Millstone and Connecticut Yankee before March '847 )
17 MR. BOYLE: Yes. I think it was like April and 18 June of '83 that the final reports were completed.
19 MR. SIESS: Now, let's see, there was a full-term 20 license on Millstone?
21 MR. BOYLE: Pardon me? I l
22 MR. SIESS: Millstone had to get a full-term 23 license? 1 24 MR. BOYLE: They have gotten that.
O 25 MR. SIESS: And that also came before this ACE-FEDERAL REPORTERS, INC.
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2 MR. BOYLE: Yes. The full-term license did not, 3 but the initiation of it -- the full-term license was i 4 independent of SEP.
l 5 MR. SIESS: That's not true, is it?
6 MR. BOYLE: That's the way it was done, yes. !
7 MR. SIESS: The full-term license'is independent 8 of SEP?
9 MR. BOYLE: The full-term license used findings 10 of SEP, but it did not rely on the absolute conclusion of 11 SEP in order for it to be issued.
1 12 MR. SIESS: Now maybe a lawyer-could understand l 0 13 the distinction, but I can't.
i 14 The only reason Millstone was in the SEP program 15 was because it did not have a full-term license at the time 16 the SEP began. So I'm having difficulty understanding how 17 these are separable.
18 MR. BOYLE: That was one of the reasons it was 19 put into SEP. SEP was theoretically concluded when the 20 yellow book came out. However, you will notice that there 21 were 50 or so issues that had not been completed, but we 22 knew what was required to complete those issues. At that 23 point SEP was concluded and we went on with the FTOL 24 license issuance. However, the individual topics were not O 25 completed before a license was issued.
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5940 01 01 20 rysimons 1 MR. SIESS: But the FTOL for Millstone had to 2 consider items that were not included in the SEP, such as 3 generic items, the USIs, et cetera, and those items are 4 included in ISAP; am I correct?
5 MR. BOYLE: Many of them are, yes.
6 MR. SIESS: What you're saying is that the FTOL I
7 operation could be separated and it could have been carried 8 on without having either SEP or ISAP?
9 MR. BOYLE: It probably could have, yes.
10 However, we used a lot of the safety evaluations to support 11 the license.
12 MR. DAVIS: I have a related comment. I found it O 13 a little bit curious that the utility applied for an FTOL l 14 on Millstone 1 in 1972, September, and it was granted in l 15 October of 1986, 14 years later.
i 16 MR. SIESS: That's illegal. J 17 MR. DAVIS: And there was only six months left to 18 finish ISAP. I find it a little curious that it took 14 19 years t9 issue it and if they had waited a few more months 20 they would have had all of this information from ISAP.
21 MR. BOYLE: They still wouldn't have had all the 1
22 generic issues completed. There are a lot of things that 23 are always coming up and ongoing that you would never get 24 completed to issue a license.
25 MR. SIESS: If you think that is peculiar, I ace-FEDERAL REPORTERS, INC.
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5940 01 01 21 arysimons 1 could give you more peculiar ones like Dresden 2 and 3.
2 (Laughter.)
3 MR. BOYLE: The current schedule calls for the 4 final report on Millstone to be issued sometime this month.
5 The Haddam Neck draft report will be issued 6 shortly and the final report should be issued by the end of 7 the fiscal year.
8 (Slide.)
9 ISAP did find some interested facts about both of 10 the plants that wouldn't have been found otherwise.
11 The risk assessment, the probabilistic safety 12 assessment performed for both plants identified for
() 13 Millstone 1 that 64 percent of the calculated core melt 14 irequency was due to the failure to maintain adequate long-15 term decay heat removal. The licensee identified that to 16 us, took specific short-term actions to help reduce that 17 number and has an ongoing study to help reduce it further.
18 MR. EBERSOLE: Is that decay heat removal from 19 the core or from the containment?
20 MR. BOYLE: From the core.
21 MR. EBERSOLE: Well, what about the containment 22 problem, the heat removal? I thought that was the 23 wulnerability since you dump it into the suppression pool 24 and you can't get it out without power.
O 25 CHAIRMAN WARD: We are probably going to hear I ACE. FEDERAL REPORTERS, INC.
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2 MR. BOYLE: I'm just trying to give an overview.
3 They are going to get into detail on this later.
4 CHAIRMAN WARD: Let's see, you said that that 5 wouldn't have been discovered without the ISAP program.
]
{
6 MR. BOYLE: Without the licensee performing a l 7 risk assessment I don't believe.
8 MR. EBERSOLE: I don't understand that at all. {
l 9 That was like sticking it square in front of your face that 10 you had to get the heat out. )
11 MR. BOYLE: But you don't have a relative feeling 12 for how important something was compared to other things in O 13 the plant.
l j
1 14 MR. EBERSOLE: Well, that I think instantly l 15 should condemn the high degree of compartmentalization in l l
16 the review effort, or the design effort, and a broad view !
17 taken at the voids in that process.
18 MR. DAVIS: Well, wait a minute. I think we are 19 jumping to a conclusion here. Sixty-four percent is not a l 20 significant numbar unless the overall core melt frequency 21 is high. There is always going to be something that l 22 dominates, and it doesn't necessarily mean that you have to 23 fix something just becauce it has a high ---
24 MR. EBERSOLE: Well, was it high then?
O 25 MR. BOYLE: The overall core melt number was, or ACE FEDERAL REPORTERS, INC. ,
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<arysimons 1 the staff thought was rather high.
l 2 MR. DAVIS: Yes, I recognize that, and that I i
)
3 guess will come out later. l I
4 MR. SIESS: Excuse me. I thought that the only l l
5 way I could melt the core was by not taking the heat out of 6 it. Is there another way of doing it?
7 MR. EBERSOLE: That's the only way.
/
8 MR. BOYLE: I think that's it.
9 MR. SIESS: Then you make a distinction between 10 long-term heat removal and short-term heat removal. Is i
11 that the significance of the 64 percent?
12 MR. BOYLE: Yes.
( 13 MR. SIESS:
So the other 36 percent of the ways 14 to melt the core would be short-term heat removal, failure 15 of short-term heat removal?
16 MR. BOYLE: I think later today Mr. Bickel will 1
17 discuss that detail.
I 19 MR. BOYLE: Yes. ]
20 For Haddam Neck it was found that the loss of l 21 motor control center 5 in the switch gear room would cause i l
22 a loss of function of a lot of critical equipment that 23 could prevent saf e shutdown of the plant. The licensee is 24 T understand putting in a new switch gear room.
O 25 MR. EBERSOLE: Let me ask you a question to get ACE-FEDERAL REPORTERS, INC.
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5940 01 01 24 rysimons 1 to a long-range point. Has Millstone 1 gotten at this time 2 through equipment and operational procedures the privilege l 3 of venting the containment before core melt?
4 Okay, that will come later.
5 MR. BOYLE: Yes.
6 CHAIRMAN WARD: Well, when you say,. Mike, these.
7 are the major ISAP findings, both of these things really 8 are the major risk assessment findings.
9 MR. BOYLE: Right. We found a lot of what the 10 risk assessment found was backed up by the operating 11 experience. The trends that showed in the operating 12 experience were kind of born out in the risk assessment O 13 also.
14 CHAIRMAN WARD: That's because they were factored 15 into the risk assessment.
16 MR. BOYLE: Yes.
17 CHAIRMAN WARD: Or I mean hopefully it was. )
18 MR. BOYLE: Sometimes you can see trends over the l l
19 years we were looking at. .
]
20 CHAIRMAN WARD: Okay. Well I'm trying to figure 1 i 21 I out why you're saying the ISAP process was necessary to 'l 22 have discovered these things. I guess I don't quite ---
23 MR. BOYLE: Well, there is no real other impetus .
l 24 right now for the licensee to perform a risk assessment on l O 25 their own, i
l ace-FEDERAL REPORTERS, INC. 1 202-347-3700 Nationwide Coverage 800 336 4 46
5940 01 01 25 rysimons 1 CHAIRMAN WARD: All right. Well, we'll talk more l 2 about that later, but if that's the point you're making I 3 can understand.
4 MR. SIESS: I think we are going to have a 5 problem here in keeping separate, or at least partly i
6 separate the ISAP program and the severe accident review 7 process.
8 CHAIRMAN WARD: Yea.
9 MR. SIESS: ISAP has to do with certain things j 10 prior to the plant not all of which are related to severe i
1 accidents, but many of which are related to existing rules 11 12 which probably don't have that clear if a connection to O 13 severe accidents. I know our thinking over the past 14 several months has been so tied to severe accidents that 15 it's sort of hard to get back in looking at GDCs and the 16 standard review plan and reg guides which an awful lot of 17 these items relate to.
18 Now as I recall, there was discussion in the 19 staff's ISAR about the relationship of the ISAP review to 20 the severe accident polic,' statement. Somehow we have to j 21 sort of keep ourselves straight on it.
22 MR. BOYLE: Just to expand on that what we tried ;
1 23 to do in ISAP was to address those generic issues.
24 However, they weren't resolved at the present, but they O 25 were clearly enough defined that we knew probably what it Acr-FEDERAL REPORTERS, INC.
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5940 01 01 26 n\_arysimons 1 took to resolve the issue and we asked the licensee to )
i 2 address those. Among them were station blackout and severe 1
3 accidents and in this case the Mark I containment.
4 MR. SIESS: There are some items in here that are i
5 a little hard to relate to severe accidents. j 6 MR. BOYLE: Yes.
7 MR. EBERSOLE: In these two plants did you find i
8 that the design and construction process was what I'll call 9 a projectized process or was it a functionally oriented f 10 process more characteristic' of large engineering groups, I i
11 you know, where you have the mechanicals and the I
12 electricals, et cetera, all strung out on their own courses O 13 and they never run in the same direction.
14 MR. BOYLE: Our review didn't even get into that.
15 MR. EBERSOLE: They didn't? )
l 16 MR. BOYLE: No. !
17 MR. SIESS: Did SEP get into that? Let's see, l
18 where you around for SEP? j i
19 MR. BOYLE: Yes, I was. There was no specific 1
20 topic that would look at anything like that.
I 21 Besides finding outliers in the two plants from l
22 doing the risk assessment, ISAP also identified some issues I I
23 that the staff or the licensee thought had a high priority 24 and we found compared to the other topics being evaluated o 25 that they weron't quite as high, or in fact they could 1 i
i
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'Q
%arysimons 1 degrade safety.
2 In the case of Millstone 1 the staff had required 3 operating reactors to provide some kind of degraded grid 4 voltage protection and gave them guidelines on how to do 5 that.
6 The licensee in this one specific instance 7 followed those guidelines and were about to implement the 8 design changes. When they ran the design changes through 9 the PSA they found that it actually was going to degrade 10 the overall risk. So from that they went back and were 11 doing a redesign which they are finishing up soon. That is 12 one case of integrating the risk assessment into the design O 13 of the plant.
14 For Haddam Neck they found that the mechanism for I 15 the demijneralized water storage tank was also not as 16 important or a degraded risk.
I 17 The next few pages I didn't even make a slide for 18 i because the printing is exceedingly small, but there is no j 19 other way to get the information ---
{
20 ,
MR. EBERSOLE: In connection with that second one {
I 21 l it rather sounds something like the current plannings that 22 I the CO-2 systems can blow up the rooms that they are 23 supposed to protect rather than just really put the fire 24 l out i; em.
6 25 MR. BOYLE: I don't think that is what the
(
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5940 01 01 28 rysimons 1 problem was though.
I 2 The purpose of the next four pages was to_show 3 just what the topics were and where they are found in the 4 report. Ignoring the middle of the chart, and taking a 5 look then at the last two columns, the NRC rank, which is 6 high, medium or low, and then what rank the utility gave 7 those issues in their integrated assessment, we found that 8 the licensee and the staff correlated fairly well on what 9 was important and what was not important.
10 CHAIRMAN WARD: What's the definition of your i 11 ranking, high, medium and low?
12 MR. BOYLE: In risk space and in engineering O 13 judgment we took a look at how important we thought each '
14 one of these topics was, and if we completed a topic, what 15 would that do in regards to safety to the plant and if it 16 had a high effect. It's judgmental what was high, medium L i
17 or low.
18 CHAIRMAN WARD: But it's the risk reduction 19 potential for that particular issue? l 20 MR. BOYLE: Yes, that's one of the inputs to it.
21 It's probably the chief one we looked at. We also did take 22 a look at things like cost. However, we didn't do it with 23 a safety goal ---
, 24 CHAIRMAN WARD: Well, that confuses it a little O 25 bit. It's some sort of a judgmental risk reduction cost ACE. FEDERAL REPORTERS, INC.
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l 5940 01'01 29 (brysimons1 ratio or is it ---
2 MR. BOYLE: No, just the ratios.
i 3 CHAIRMAN WARD: I don't understand how you. i l
4 factored cost into it.
i 5 MR. BOYLE: We could take a look in a relative I l
6 way if something was extremely high or extremely low cost' 7 dollar-wise or in some cases even man-rem wise. We tried 8 to factor that in the best we could without developing a 9 specific equation to plug all these numbers in, which is i
10 one thing that the licensee did do.
{
t 11 CHAIRMAN WARD: I'm not talking about being l
12 highly quantitative, but I just want to know how you I O 13 handled the question of cost qualitatively. I mean if you 14 had an issue where there was potential for a major risk 15 reduction, but it looked like it was going to be very 16 expensive to implement --- j 17 MR. BOYLE: Then the staff would sit back and 18 take a look at ---
19 CHAIRMAN WARD: How would you rank that one?
I 20 MR. BOYLE: We would take a look at each topic j I
21 individually and in that case say is this a really major I i
22 risk reduction and, if it is, it's almost hang the cost of 23 what it is. Like if we found a plant without an ECCS l 24 system, which would be high risk reduction but extremely l O 25 high cost, too, we would say do it.
1
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5940 01 01 30 arysimons 1 MR. EBERSOLE: I take it that you would have to 2 say that your investigations and IRAP and SEP and this 3 thing here were oriented for a cutoff below certain modes 4 of operation something like four because, you know, the l 5 recent flap that we have in the current one ongoing about 6 when you get down to low temperatures and you even take the 7 reactor vessel off and you begin to depend on RHR and you 8 begin to put juryrigged level indication in and run now the 9 risk, for instance, of AC power failure getting you into f
(
I 10 trouble quite quickly, that that was not within the scope.
11 Where did you cut off in the operation modes?
12 MR. BOYLE: In SEP I'm not sure where they cut O 13 off.
14- MR. EBERSOLE: There was a cutoff at the point 15 where the residual heat removal system had to do its 16 function without any evaporative cooling.
17 MR. BOYLE: I'm not even sure. You have to 18 understand that SEP took a look at certain specific 19 requirements.
20 MR. EBERSOLE: That's merely a regime of 21 operation.
22 MR. BOYLE: I don't think that that was 23 addressed. ISAP does not address any of those kind of 24 things unless it was an open licensing action or it was a O 25 licensee planned initiative. They didn't bring up anything ACE FEDERAL REPORTERS, INC.
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5940 01 01 31 rysimons 1 new except what was found from the operating experience or
(
2 from the risk assessment itself. )
3 MR. EBERSOLE: Well, Diablo Canyon is now on the 4 hot seat you know for losing RHR and approaching open 5 evaporative cooling.
6 MR. BOYLE: Well, if that is to be a generic )
i 7 issue or whatever, that will then be factored into the 8 living ISAP program for this plant. )
a 9 (Slide.) I i
10 The basic conclusions that the staff found was 11 the performance of the PSA by the licensee and the review 12 of the PSA and the operating experience by the staff led to O 13 a much greater understanding by both the staff and the <
)
14 licensee of the plant's capabilities and its operating ,
1 15 characteristics. l 16 We also found that the integrated assessment had 17 the potential to identify many common elements that were 18 from separate reviews and had the ability to propose a 19 single action that could resolve those issues.
20 The integrated assessment provided the staff and 21 the licensee an opportunity to address pending regulatory 22 requirements and hopefully for some of them resolve them 23 before they are actually issued.
24 ISAP also provided a formal process to evaluate 25 all the actions that were presently on the NRC's and the ACE-FEDERAL REPORTERS, INC.
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1 i
I 5940 01 01 32 rysimons I licensee's books. So they both had a common handle on what )
2 was most important and when it should be done.
3 A pilot program has demonstrated the potential 4 benefits to licensees and the public of integrated 5 assessments using plant specific PSAs and operating 6 experience reviews.
7 MR. SIESS: Looking at your second item which has 8 to do with what I would call integrated solutions, to what .
9 extent are these plant specific, or to what extent are
{
10 these things that the staff might well integrate for other I 11 plants learning from this experience that three generic 12 issues might be resolved by one action rather than three O 13 separate actions? )
14 MR. BOYLE: Our found from our experience in I
15 these two plants that plant specific part of it is a major
]
16 factor, that instead of looking at a generic issue across 17 the board for all plants, we are going to slice down 18 through all the generic issues for one plant and the
]
l 19 resolution becomes very plant specific.
20 I have tried to keep this extremely general and 21 not really tried to dwell on ISAP for these two plants, but 22 if you have any specific questions.
23 CHAIRMAN WARD: Go ahead, Pete.
24 MR. DAVIS: I just had one. What are the NRC's O 25 plans now for a continuation of ISAP?
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--rysimons 1 MR. BOYLE: I think we will address that later i 2 today, but we do have a paper before the NRR Office !
3 Director now for concurrence and there will be a SECY paper ;
4 issued within a month or two. l i
5 MR. DAVIS: Thank you. j 6 MR. SIESS: Now your last bullet stopped short of 7 saying that ISAP was a good idea. i I
8 MR. BOYLE: We think ISAP is a great idea. l 9 MR. SIESS: You don't say it though. You say I
10 that the potential benefits of an integrated assessment j l
11 using plant specific PSAs. Now is that ISAP in your mind? l l
12 MR. BOYLE: Yes, I think it's ISAP and it O 13 possibly affects quite a number of other initiatives that i
14 NRC has before it. 1 15 MR. SIESS: Thank you. l l
16 CHAIRMAN WARD: In the last line when you say !
17 integrated assessment using plant specific PSAs and 1 18 operating experience reviews, you're saying that's ISAP?
19 MR. BOYLE: That is ISAP how it is presently ;
l 20 configured, yes. It is a requirement in the pilot program 21 in ISAP to perform a plant specific risk assessment and a 22 plant specific operating experience review.
23 CHAIRMAN WARD: Okay. Well, that way of 24 describing it doesn't seem to include I guess what you O 25 would call the topic reviews or the third element of the ACE FEDERAL REPORTERS, INC.
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5940 01 01 34 O( arysimons 1 program. Is there some reason ---- i l
2 MR. BOYLE: Since SEP had already been completed 3 for these two plants, it was hard for ISAP to expand upon 4 further why those lessons learned were better now than they 5 were in SEP. They pointed out a great deal of things that 6 we learned in SEP that had to be fixed for these two plants 7 to make them safer.
8 The only part of SEP that got into ISAP were 9 those items still not completely finished. They were still 10 on the books that there were procedures that had to be 11 changed and hardware modifications made or even analyses 12 that still had to be done. We looked at those and O 13 prioritized the completion of those and they will be put in 14 the integrated implementation schedule, but we did not go 15 further and do actual evaluations in ISAP.
16 The bottom line on the pilot program.is basically 17 a prioritization of issues and to look for some new 18 outliers.
19 CHAIRMAN WARD: Mike, would we go back to your --
20 well, you didn't have a slide I guess -- the detailed 21 tables where you showed the several dozen topics and the 22 formal numerical ranking that Northeast derives and then 23 your subjective ranking.
24 Now despite what you said about there being a n
25 pretty good correlation, it doesn't look to me just ace FEDERAL REPORTERS, INC.
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1 1
1 5940 01 01 35 l rysimons 1 glancing at it that there is particularly good i
2 correlation. You know, that could be for several different ]
3 reasons. It could be that your subjective judgment isn't 4 very good, or it could be that the quantitative ranking
]
5 process really is not very good and maybe it's a house of I 6 cards or it could be that you're using different criteria.
7 That's what I haven't been able to understand.
8 MR. BOYLE: The licensee, and we did use j i
I 9 different criteria, they came up with an analytical ranking )
i 10 methodology which I believe they will discuss later, but j 11 they evaluated each topic in terms of public safety, l l
12 economic performance, personnel safety, personnel O 13 productivity and effect on outside interests like 14 ourselves, the NRC. They gave each one of those a score, ,
j 15 they integrated the scores and they factored cost into and 16 came up vith a final score for each topic.
I 17 We looked at that score, and we also looked at ;
I i
18 the PSA, what the operating experience had to say and- ;
)
~
19 engineering judgment about how important things were and 20 came out with a high, medium or low.
1 21 This table, I have it listed with all the highs !
22 in ascending topic number, all the mediums the same way and i 23 then all the lows in the same way.
24 So it may not look from their rank that they are C:) 25 juggled around, but there is a 4 here followed by a 1, l
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5940 01 01 36 rysimons 1 followed by a 20. {
I 2 CHAIRMAN WARD: I just divided them into three, 3 and I don't know that they particularly correlate even ---
1 4 MR. BOYLE: I think in general when you take a j l
5 look there, I think they --- l l
6 CHAIRMAN WARD: I mean I think I understand what q J
7 they were doing. What I don't understand is what you were-8 doing and how you got the ranking.
9 MR. BOYLE: Okay. The high, medium and low 10 really in the long run doesn't mean as much as what their 11 rank is. They performed an integrated assessment and tried 12 to prioritize the issues in the order that they thought O 13 appropriate. I think they numbered the actual hardware 14 modifications, and there were about 42 numbers, and the
]
15 ones with stars next to them were studies that they had .
I 16 ranked in order and there were about 10 of those. I 17 The NRC found that their ranking was in most l
18 cases very appropriate. The relative ranking is-fine. We I l
19 only argued I think on a few issues where it would not go 20 from a low to a high, but from medium to a high or a medium 21 to a low or the other way around.
22 CHAIRMAN WARD: Well, their No. 1 ranking was 23 getting rid of I guess the big chlorine tanks; is that 24 right?
O 25 MR. BOYLE: On site they had chlorine tanks, yes.
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5940 01 01 37 rysimons 1 CHAIRMAN WARD: And you didn't rank that high l l
2 because it's not a radiological risk; is that it? l 3 MR. BOYLE: That was one of the rea3or.a. We also l
4 thought that they exaggerated the risk, not e 3ggerated, l 5 but the risk was too high and we downplayed that. But it i 1
1 6 became a moot point because half way through ISAP the tank j 7 cars were removed from the site.
8 MR. EBERSOLE: They also have fire barriers as ]
l 9 low. Was that limited to fire barriers or the whole fire .)
i 10 hazard?
11 MR. BOYLE: Fire barriers and the whole topic of l 1
12 fire protection had, and I forget how many different parts O 13 in it here, but each one of those were either for an 1 14 exemption request or something of that sort. It wasn't the 15 whole fire protection program. We didn't look at that as l l
16 an overall topic because most of it had been completed.
17 There were just a few specific places in the fire 18 protection program that were still ongoing that we wanted 19 to prioritize when they should be dorse if at all. ]
20 MR. EBERSOLE: Now wait a minute. You didn't 21 look at it because it had been completed? This says that !
22 you don't include in here issues which were there, but had 23 been dealt with some way or other.
24 MR. BOYLE: Fire protection is a rather large 25 issue and has been going on for quite some time.
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I
-5940 01 01 38-rysimons 1 MR. EBERSOLE: Well, that doesn't suggest that it J
2 not be here.
3 MR. BOYLE: Okay. Let me continue. Since it has l 4 been going on for quite some time, the licensee had already I
5 made quite a number of the modifications to the plant that j 6 were required. The only parts that we evaluated in the 1
7 fire protection in ISAP were those items of the overall i 8 program that were still left to be completed.
l 9 MR." EBERSOLE: We'all know that when that issue 10 came up the fire protection process or the needs were dealt 11 with in a compromise fashion.
12 MR. SIESS: Jesse, they have had to meet Appendix
( 13 R and that's the regulation.
i i
14 MR. EBERSOLE: Is this an historical record of l
15 what I call issues that have been fixed?
)
16 MR. SIESS: This is a list of things that remain 17 to be done on USI's generic issues.
I 18 MR. EBERSOLE: So this really is not an 19 integrated safety assessment of the original issues which 20 have been laid to rest. ;
21 MR. BOYLE: If something is complete and not on 1 22 the books to be done, we did not look at it.
23 MR. EBERSOLE: But those old issues remember you 24 did dig up -- well, you used the original design ---
25 MR. BOYLE: The licensee was required to meet ace-FEDERAL REPORTERS, INC.
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594'O 01 01 39 )
n
\,.cA ry simons 1 Appendix R.
)
2 MR. EBERSOLE: Well, what I'm saying is you say 3 in here that you looked at the old design criteria and you .
4 evaluated it against new criteria --- I
)
5 MR. BOYLE: No, we did not. That was done in 6 SEP.
7 MR. SIESSr That was done in SEP, Jesse. ]
8 MR. BOYLE: That's a different program. ,
I 9 MR. EBERSOLE: So this then is that which is left l 10 after SRP?
l 11 MR. SIESS: Or is has been added since as a USI
{
i 12 or a generic issue. 1
()
. 13 MR. EBERSOLE: So this is really the tailend of a 14 larger process.
i 1
15 MR. BOYLE: For this specific plant that is true 1 i
l 16 if the SEP had already been completed for this plant. ;
17 MR. EBERSOLE: The term " integrated" really i 18 doesn't mean integrated. It means the residual.
19 MR. SIESS: It's an integrated approach to all 20 the things that this plant has to do.
21 Vs R. EBERSOLE: But then that would have included 22 the historically compromised solutions to old issues 23 because they have been changed by new requirements.
24 MR. BOYLE: That's right.
O 25 MR. SIESS: Anything that they are required to do ACE FEDERAL REPORTERS, INC.
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5940 01 01 40 rysimons 1 to meet the NRC's regulations, this is an approach to how 2 you fix it.
l 3 MR. EBERSOLE: Then I would think that this would i 4 absolutely include fire protection as a topic.
5 MR. SIESS: That's what he said.
6 MR. BOYLE: Those parts of fire protection that 7 have not been completed.
8 MR. EBERSOLE: That's the part that bugs me. It 9 says whatever we did to the pieces which have not yet been 10 fixed ---
11 CHAIRMAN WARD: Hell, you're not satisfied with 12 the fix, but the NRC staff has been satisfied.
O 13 MR. EBERSOLE: Well, I don't know what the fix 14 was at all. )
15 MR. SIESS: The fix met the regulations, whatever 16 they were.
17 MR. EBERSOLE: But then you say in here, Chet, 18 whatever they were has been looked at against what they 19 should be now. In fact, I read in here where you took the 20 old design criteria and re-evaluated it against current 21 requirements.
22 MR. SIESS: The plant has been modified to some 23 extent to meet Appendix R. There are still some things ]
24 left to be done to meet Appendix R, and this is an attempt l i
25 to assign priorities to those things that have to be done.
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O k_arysimons 1 MR. EBERSOLE: The issue, whatever the issue is, 2 if it has been dealt with by the staff, the tracks have 3 been brushed away and I don't know how it was done because 4 they are not in ISAP; is that right? i 1
5 MR. SIESS: ISAP is what they have to do in the f 6 next 10 or 15 years or 10 or 15 months.
7 MR. EBERSOLE: So it's not the integrated picture 8 of resolution of issues. See, that conflicts with my ;
9 concept of integrated.
10 MR. BOYLE: Well, let's go back. If this plant 11 had not been in SEP, it would have had f.o go back.and taken 12 a look at the SEP lessons learned and evaluate those new
() 13 issues against an older ---
I l
l 14 MR. EBERSOLE: You're telling me if it had not ---
l 15 MR. BOYLE: They had already finished that.
16 MR. SIESS: Wait a minute. If this plant had not l 17 been in SEP and there was a generic issue which was not a 18 backfit, would you have had to go back and look at it?
19 MR. BOYLE: Right. l 20 MR. SIESS: SEP plants were evaluated against 21 existing criteria.
22 MR. BOYLE: Correct.
23 MR. SIESS: They were looked at as if every new 24 regulation applied to them whether or not the regulation
/'
25 was backfit?
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5940 01 01 42 l l
(krysimons1 MR. BOYLE: That was part of the Commission's 1
2 policy statement that any plant participating in ISAP would 3 have had to do that.
4 MR. SIESS: And a requirement of ISAP was that l 5 everything be evaluated against existing criteria whether j 6 or not they were backfit; is that right? In other words, l
7 ISAP plants --- !
l 8 MR. BOYLE: ISAP plants would have had to have 1 9 been evaluated against the SEP lessons learned, which is a 10 sub-set of all the SEP topics.
11 MR. SIESS: A plant that comes in under ISAP 12 would have to undergo effectively an SEP review. j 13 MR. BOYLE: Yes.
14 MR. SIESS: That I didn't realize. 1 1
15 CHAIRMAN WARD: Wait a minute. But presumably 1
l 16 the SEP roview for a more modern plant would be less l
17 exhaustiv3 than it was for the original 10 SEP plants.
l 18 MR. SIESS: You want to bet?
19 CHAIRMAN WARD: Then something is wrong because 20 that is wh/ the process was started with those 10 ---
21 MR. BOYLE: For a plant that had just been 22 licensed recently, the SEP review would have been almost 23 non-existent.
24 MR. SIESS: Yes, if it nad just been licensed, 25 but give it 5 years back to 10 years back ---
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5940 01 01 43 rysimons 1 MR. BOYLE: It would have been a little 2 different, yes.
3 CHAIRMAN WARD: So there is a continuum.
4 MR. SIESS: There is a continuum.
5 MR. BOYLE: I should point out this was a 6 voluntary program, too. We didn't go out and make'anybody 7 do this. We asked if anybody wanted to do this.
8 MR. SIESS: The SEP plants were not chosen 9 strictly chronologically. It went out to a point and then 10 it was the plants that hadn't received a full-term license.
11 MR. EBERSOLE: Integrated means something. What 12 you're te] ling means to me if I want to get an integrated O 13 safety assessment picture of a plant and it has gone 14 through SEP and IRAP, I have to look at SEP and IRAP and 15 the integrated safety assessment program as an integral 16 package, and I can't eliminate the first two because this 17 last third of the effort is not an integrated picture, but 18 it's the last third.
19 CHAIRMAN WARD: Well, I think that granted it's 20 not an integrated ---
21 MR. EBERSOLE: But if I have a plant though that 22 you are going to subject to ISAP that never went through 23 SEP or ISAP, then that would be a true integrated package.
24 MR. BOYLE: The purpose of the pilot program was 25 to get a handle on the process.
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5940 01 01 44 l rysimons 1 MR. EBERSOLE: But to me it conveys something 2 more than it really is, which is not uncommon. l l
3 MR. SIESS: I disagree. I think it's extremely 4 integrated.- The fact that they_can come up with one fix )
I 5 and take care of three generic issues is what I consider 6 integrated.
7 MR. EBERSOLE: But what I heard, Chet, was that 8 an SEP solution to a problem is not even mentioned in the 9 integrated assessment.
l 10 MR. SIESS: ISAP, as I understand it, is to take j l
11 all the outstanding issues left over from an SEP plant ---
12 MR. EBERSOLE: That's not integrated.
O 13 MR. BOYLE: Let me try and clarify.
14 (Laughter.)
15 If something was done in SEP and a solution was ]
16 implemented at the plant and that same solution now applies I
17 in some part to fire protection or some other issue, we i
18 would go back and reference that SEP action as having 19 helped resolve this other issue and we would have l 20 integrated that in there. !
I 21 MR. EBERSOLE: But it would almost seem that you 22 would have to say you've done this program and these are 23 the integrated, outstanding issues.
24 MR. BOYLE: That's the way the pilot program O 25 ended up. The overall program though is different, yes.
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(\rysimons 1 MR. EBERSOLE: So it says there may be 10,000 l 2 other issues which have gone into the shadows of time,.and ;
3 I don't know what they were. ;
I 4 CHAIRMAN WARD: We are assuming that they were l
l 5 satisfactorily written off under the SEP program.
6 MR. EBERSOLE: I know that. What we know though 7 is we knew that plants were built and when the issue arose l l
8 the solution was difficult and therefore compromised. l i
9 MR. SIESS: Not necessarily. There were some )
10 things in the SEP that it turned out just weren't important {
i 11 from the standpoint ---
12 MR. EBERSOLE: Well, of course, but then there 13 were some that had to have been ---
i 14 MR. SIESS: And there were some that were fixed, )
15 and the SEP plants spent millions of dollars in many cases.
16 MR. EBERSOLE: Well, I'm getting a new picture of 17 the integrated ---
1 18 MR. BOYLE: Integration refers to quite a number 19 of different processes in the program. .
20 MR. SIESS: Suppose you did this say for l 1
l 21 Millstone 2, and when did it get an operating license? 4 22 MR. KACICH: It was August 1st, 1975.
23 MR. SIESS: '75, that makes it pretty old. So 1
24 you would start off with Millstone 2 with eaaantially an ]
25 SEP type thing.
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rysimons 1 MR. BOYLE: If the program stands as it is now, 1
2 yes, that's true. j 3 MR. SIESS: Now the SEP didn't address every 4 issue. Those issues were screened out of those that we j 5 thought were most important to safety, right?
i 6 MR. BOYLE: Yes.
7 MR, SIESS: But you would take Millstone and you i
8 would have a PSA, a PRA or whatever the nomenclature is l I
9 now, and look at it in terms of current criteria and risk j
10 and come up with a list of things.
11 MR. BOYLE: That's correct.
12 MR. SIESS: Then you would ask the licensee ---
O 13 MR. BOYLE: You would also take a look at their 14 plan initiatives, licensing actions and pending regulatory l
15 requirements at the same time.
16 MR. SIESS: So they would have a lot of things ,
i 17 that have been tacked on ---
18 MR. BOYLE: An awful lot of things.
l 19 MR. SIESS: --- out of the USI. !
l 20 MR. BOYLE: Yes. I l
l 21 MR. SIESS: And you would look at all of these 22 and try to assign priorities to them? '
l 23 MR. BOYLE: Correct. ;
24 MR. SIESS: Things they wanted to do, thingc they 25 had to do and things you thought up as a result of ---
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5940 01 01 47-rysimons 1 MR. BOYLE: We would also try and find common 2 elements between all those different things and resolve 3' them at one time. l l
4 MR. SIESS: So the integration would involve not l I
5 only problems, meaning. pulling together their plant I 6 improvements along with risk related things and already ,
i 7 applied requirements, but integrated in terms of the order l 1
8 in which they did it, and'let's do the most important l i
9 things first and you can't do everything at once.
10 MR. BOYLE: That's right.
11 MR. SIESS: And integrated to the extent that l i
12 maybe one fix will take care of three things.
O 13 MR. BOYLE: Absolutely, yes.
14 MR. EBERSOLE: Let me ask, primarily for
]
15 earthquake considerations, how did you rationalize the 16 absence of quality control other than the old ASME control .
17 on service water pipes and welding thereof? l 18 MR. BOYLE: There was a large SEP topic on seismic 19 considerations. The plant was thoroughly reviewed against ]
20 current requirements at the time SEP was going on, and we 21 asked the licensee to make fixes to pipes or to hangers. i 22 MR. EBERSOLE: Can you bind that pipe now?
23 MR. BOYLE: Pardon me?
24 MR. EBERSOLE: Can you bend that pipe now at the j O 25 welded joints and it's ductile? 4 ACE. FEDERAL REPORTERS, }NC.
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5940 01 01 48 rysimons 1 MR. BOYLE: I have no idea.
2 (Laughter.)
3 MR. DAVIS: Mr. Chairman, I have one comment and 4 also a related question to Mr. Ebersole's concern about 5 seismic.
6 I noticed in reading the ISAR, NUREG 11-84, there 7 are still some issues that haven't been closed yet, and 8 there are several instances where the NRC recommends that 9 this be done or urges the utility to do something else, and 10 one of those in on the seismic problem.
11 On page 383, for example, the staff recommends 12 performing a seismic fragility analysis on Millstone 1, and O 13 I'm wondering has that been done, and how do you compel the l 14 utility to do that if you really think it is necessary?
15 MR. BOYLE: We have taken a look at the things 16 the licensee has done, and they have done a risk assessment q 17 and they have done a fire hazard study. j I
18 MR. DAVIS: They did a flood also. !
19 MR. BOYLE: Right. And we thought what other l l
20 area haven't they looked at'as far as risk does and seismic 21 was one of them. We recommended to them that they might 22 consider doing this and working it into their integrated l l
23 schedule. That's all the staff tried to do was make ,
24 reonmmendations for further improvements. We cati't compel l
) 25 them to do it.
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k<arysimons1 MR. EBERSOLE: That's because you don't think 2 there is a risk factor large enough to do so?
3 MR. BOYLE: No, that's not exactly true. This I
4 was an area where we thought we could further refine the 5 analysis done by the utility in taking a look at its 6 seismic considerations.
7 MR. EBERSOLE: I'm trying to figure out whether 8 lawyers run this business or engineers. )
9 MR. BOYLE: I think in the long run both are in j 10 there, and I'm not sure who is winning.
11 (Laughter.)
12 CHAIRMAN WARD: Did you have another one, Pete? ,
O 13 MR. DAVIS: No.
14 CHAIRMAN WARD: Mike, looking at the SEP process 15 for a minute and their slightly different tact, I've 16 forgotten whether this was discussed in the SEP program 17 itself for its conclusion, but there must have been a lot 18 of lessons learned for the staff in the SEP program, let's 19 say from the perspective of streamlining regulations and 20 eliminating unneeded and obsolete regulations, if there are 21 any.
22 I mean if we find, for example, in the SEP 23 programs that there are a lot of things that an older plant 24 licensee really doesn't have to do because there is no real O 25 ; risk potential involved in not doing it, then has the staff ACE-FEDERAL REPORTERS, INC.
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5940 01 01 50 i rysimons 1 turned that back and said well, why on earth do we have 1
2 those regulations then, and do we have regulations that are !
j 3 antiquated and unnecessary? Has there been any formal 4 attempt to do that? 4 5 MR. BOYLE: No, but reports have been written 6 that I've noted had the same kind of thing. When we were 7 going through SEP in areac such as seismic design we saw 8 that we coulcr't evaluate the plan against absolutely the 9 current criteria and we had to do something that we found 10 to be equivalent. We tried to get at the same end results 11 safety-wise through a different route and we saw that we 12 could.
O 13 In other areas we saw that maybe they didn't meet L
[
14 the requirement exactly. However, they had something else 15 in the plant, the GDC or the SRP, that was not related to 16 this issue. However, it provided backup protection so that 17 this other piece of equipment now wasn't as important as it l
18 could be. You had two or three pieces hooked together that 19 overall performed at least at an equivalent level of safety i 20 in the plant.
21 CHAIRMAN WARD: So what you're saying is in cases j 22 where an older plant didn't meet a modern requirement and j 23 you found it unnecessary for it to meet the requirement, it 24 wasn't because the requirement was unnecessary, but rather O 25 that the plant met it in some indirect way.
1 l
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5940 02 02 51 fysimons 1 MR. BOYLE: It found compensating features in the 2 existing design. Rather than taking a look at each 3 requirement on its own, we tried to take a look at the 4 plant as a whole to see how it would perform and not each 5 individual item in the plant. l l
6 CHAIRMAN WARD: Was there an attempt to see i 7 consider whether the process was telling you something 8 about unnecessary regulations? I 9 MR. BOYLE: I don',t think in a formal manner, but i 10 it has been recognized. How you deal with that is a whole 11 other problem.
12 CHAIRMAN WARD: Thank you, Mike.
]
() 13 Let's see, I'm not sure how we are following the 14 agenda. Cecil, I understand that you are going to tell us 15 something about this possible SECY paper?
16 MR. THOMAS: Yes.
17 CHAIRMAN WARD: And is that all the staff has to 18 present this morning?
19 MR. THOMAS: I believe so, yes,and then we can 20 respond to any questions you have.
21 My name is Cecil Thomas, and I'm Director of the 22 Integrated Safety Assessment Project Directorate.
23 As Mike indicated, we do have in preparation a 24 Commission paper that summarizes the experience of the ISAP 25 pilot program and basic recommendations to the Commission
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5940 02 02 52 rysimons 1 for continuation or non-continuation of the ISAP program,
[
2 about the pilot program and where do we go from here now 3 that we have completed the two plant pilot program.
4 The status of the paper is right now it's under 5 upper management review in NRR and will soon go to the 6 other offices whose interest is affected by the paper.
7 The status of the paper is of course preliminary 8 and we can't really say what is going to come out of the 9 EDO's office and go to the Commission, but I can give you i 10 the benefit of some discussions we have had in NRR and 11 generally tell you want is in the paper as it stands today.
12 To begin with, we think the ISAP program is a
() 13 very good program. The two plant pilot program showed it 14 to be of substantial benefit to the staff, to the licensee 15 and we believe to the public by taking maybe a slightly 16 different look at things or looking at things in different 17 ways than in the past.
18 The idea of looking at the various issues that 19 have to be completed, both licensee initiated issues, and 20 the issues that the staff has identified or required with 21 special insights from the PRA and the operating experience 22 we found to be very useful to give us some insights I don't 23 think we would have otherwise gotten.
24 So we do think the ISAP is a good program. We
(} 25 would like to make it available to everybody and not just ACE FEDERAL REPORTERS, INC.
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{ysimons1 as a continuation of the pilot program, but we believe in 2 going through the two plants we have.3 earned probably as 3 much as we need to make the decision to continue.
4 So we are going to recommend that the program be 5 made available to everyone. Exactly how is somewhat up in 6 the air right now. We feel that there are a number of 7 other programs or initiatives that are related to the ISAP 8 program that warrants consideration of integration with the 9 ISAP program.
10 For example, we have the integrated living 11 schedule program that would result in something fairly 12 similar to that from the ISAP program, that is an
() 13 integrated schedule of sorts.
14 He in the ISAP program are of course partial and 15 we believe that both the staff and the licensee have done l 16 substantially more work and have a lot more insights into 17 the importance of the topics and so on, and therefore the 18 integrated schedule we come out with from the ISAP program I
19 is better founded and better based, if you will, than that l 20 which is required in the integrated living schedule ,
i 21 program.
i 22 There is also another important difference and l l
23 that is that in the ISAP the potential exists for dropping 24 certain topics. If the topic is shown to be of relatively 25 low risk importance compared to everything else that needs
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to be done, we would certainly entertain a request from the
[]pysimons1 2 licensee to drop it.
3 The integrated living schedule program does not l
4 provide for that. So there is some potential benefit to 5 the licensee from going through the ISAP process versus 6 just the integrated living schedule. Nevertheless, there 7 are a lot of similarities, and it seems that these two 8 programs are redundant in some respects and at least the l 9 better elements of each should be defined.
10 The ISAP pilot program, as Mike pointed out, did 11 require --- J 12 CHAIRMAN WARD: I - thought you might give some
() 13 other examples of how it is closely related to ---
14 MR. THOMAS: I was going to do that, or one other 15 anyway. Obviously the ISAP pilot program required that a 16 PRA be done. We would also note that the severe accident 17 policy statement is going to require some sort of a PRA.
18 Exactly what kind, we don't know. That's pretty much up in 19 the air right now.
20 Because of the requirenent for PRAs in both 21 programs and because of the contribution of PRAs, insights 22 and all from both programs, and also both programs, if you 23 will, consider beyond design basis accidents and also-24 require an integrated look at things, the issues and topics 25 that certainly arguments could be made for combining those
({)
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2 Right now those are the two major programs that 3 we are considering maybe folding in with ISAP or 4 conversely, in other words, integrating the three programs.
5 CHAIRMAN WARD: The severe accident program 6 requires something, and it's been described in various
[
7 ways. I mean the IPEM isn't really, I wouldn't it a PRA, 8 but it's a sort of PRA approach. It's not a full-scope 9 PRA. I mean do you see *'at as an incompatibility with 10 what the ISAP program will want to do, or in an ongoing 11 ISAP program would be you be satisfied with an abbreviated 12 PRA of the sort that the IPE might accept?
() 13 MR. THOMAS: Well, I'm not sure, at least from 14 NRi/'s point of view, I'm not that sure whether an IPE is 15 going to do that.
16 For an ISAP type program to be meaningful you 17 need a certain level PRA. In this case, level one PRAs 18 were done for Millstone and Connecticut Yankee. Certainly 19 the type of PRA that would be required to have meaningful 20 results is considerably more than some of the IPEs that 21 have been discussed in the past.
22 We in NRR have just fairly recently come to 23 realize the potential benefits of integrating the ISAP 24 program with the severe accident policy program and are now
() 25 initiating discussions with the Office of Research to maybe i
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5940 02 02 56 fysimons1 adjust some of their thinking on what might be required for 2 severe accidents. In other words, we are just starting to 3 look at the potential benefits of combining some things, 4 and we may go back and ask them to take a look or to j 5 rethink what sort of requirements should be -- or what 6 should be required for severe accidents.
7 Maybe with a little bit stiffer requirement in j 8 terms of a PRA for severe accidents we could all benefit 9 from an ISAP type evaluation of issues. So we are going to i
10 go back and rethink that with cooperation with Research. j 11 So I can't really say today that what they had 12 originally proposed is going to be good enough. We don't l l
() 13 think it is for ISAP if the two programs were to be !
14 combined.
15 CHAIRMAN WARD: Okay. So you're saying for ISAP 16 that you would really like to see a full level one PRA?
17 MR. THOMAS: Yes, something of that order, yes.
18 CHAIRMAN WARD: I guess we'll hear more about 19 this. I don't quite understand why a level one is 20 sufficient.
21 MR. THOMAS: Well, rather than say it's 22 sufficient, I would characterize it as necessary to go as 23 far as we can. Obviously, the more the better. Once we 24 get into containment and so on, we can learn a lot more 25 than maybe even we did in the pilot program. But I would
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5940 02 02 57 rysimons I say that something of the order of level one is necessary.
[
2 CHAIRMAN WARD:- That level of detail. .
3 MR. THOMAS: Yes.
4 MR. DAVIS: By level one do you mean including 5 external events or not?
6 MR. ATEFI: My name is Bahmen Atefi from SAIC.
7 Each level that you do you can have external l
8 events if you want.to. The point is that as a minimum for 9 internally initiated events you need a level one as a part I
10 of it to get the kind of detail and insight you need. You 11 can supplement that for level one by doing external events i
12 if you want, or you can go to a containment analysis and i
13
(]) consequence analysis and supplement at each level with 14 external events.
15 So whether you are doing a level one or level two 16 or level three external events, you can do it irrespective i
17 of whether you are considering containment or consequences.
18 MR. DAVIS: I guess I'm talking about the ISAP 19 objectives and can they be met with a level one PRA that 20 does not include external events because there are a lot of 1
21 NRC regulations, as you are aware, that cover external 22 events, and I'm not sure how you are going to evaluate them 23 on an integrated basis unless you have that put in the PSA 24 or the PRA up front.
() 25 MR. THOMAS: Ideally they would include external
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l 5940 02 02 58 rysimons 1 events. We have just been through a pilot program that 2 touched on external events but it really didn't go into a ;
l 3 lot of detail on external events. Where we come out we are f I
4 not really sure. Yes, ideally it would. )
5 I believe that is all I had prepared.
6 CHAIRMAN WARD: Any other questions? ]
7 (No response.)
8 Okay. Thank you. We are considerably ahead of 9 schedule, but let's take a break now and come back at 20 1
10 minutes of 11 and we'll go to Northeast utilities at that 11 time.
I 12 (Recess taken.) l
(} 13 CHAIRMAN WARD: We will start now with the 4
14 presentations from Northeast, and I'll let you gentlemen 15 introduce yourselves, if you will, please.
16 MR. MROCZKA: Good morning.
17 My name is Ed Mroczka. I'm Senior Vice 18 President, Nuclear Engineering and Operations for Northeast l 19 Utilities.
20 Mr. Chairman and members of the ACRS, on behalf 21 of Northeast Utilities we thank you for the opportunity to 22 discuss our intearated safety assessment program.
1 23 (S iido. )
24 With me this morning are six gentlemen from our 25 staff. Each person is intimately involved in the
[}
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l 5940 02 02 59 ysimons 1 development of the ISAP for Millstone Unit 1.
2 They are Robert Factora, Manager, Generation q 3 Projects, Millstone Unit 1; -
4 Richard Kacich, Manager, Generation Facilities 5 Licensing; j 6 Jack Quinn, Supervisor, Millstone Unit 1 j
7 Engineering; 8 Paul Blasioli, Supervisor, Generation Facilities 9 Licensing; l 10 John Bickel, Supervisor, Probabilistic Risk 11 Assessment; and 12 Mich Lederman, Engineer, Generation Facilities O 13 ' ice # eta 9-14 (Slide.)
15 The agenda for our presentation is as follows:
16 Rick will provide for the ISAP background and 17 history.
18 John Bickel will describe the Millstone Unit 1 19 PSS activities.
l 20 Mich Lederman will define our ISAP methodology j l
21 and processing.
l 22 Paul Blasioli will relay some specific ISAP 23 experiences.
24 John Bickel will discuss PRAs at Northeast O 25 o'111'ies er e re 91 6 1 ver=9ective-ACE-FEDERAL REPORTERS, INC. I 202 347-3700 Nationwide Coverage 80(k336 6646 i
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/ wrysimons 1 And at the conclusion of John's discussion, I'll O
2 be back to share with you our plans for future activities 3 and our conclusions.
4 Basically the end result we eventually hope to 5 achieve is an integrated ISAP for all of our four nuclear 6 units which would allow us to effectively utilize our 7 combined resources to maximize overall safety.
8 Now I would like to introduce Rick Kacich.
9 MR. KACICH: Thank you, Ed.
10 I just have a couple of quick slides that are 11 somewhat redundant to the information that Mike Boyle 12 presented earlier. So I won't dwell on those portions that 13
(]) are redundant.
14 (Slide.)
15 Much of the genesis for this program actually 16 came out of the SEP process, and just to acquaint us all 17 with the timetable, there was a presentation to the 18 Commission in February of '83 near the conclusion of the 19 overall program for all of the then 10 plants that were in 20 the program at that state.
21 With Millstone being both an SEP plant and an 22 IREP plant and, as Mike described, recognizing the 23 commonality that those two programs had that led to ISAP, 24 Millstone 1 was certainly a logical candidate for 25 participation, and that led to one of our n. ore formal
[}
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3940 02 02- 61 specific proposals in September of '83 to participate in a
/}pysimons1 2 program which eventually became ISAP.
3 MR. EBERSOLE: I notice you've made a statement 4 about integrating ISAP when ISAP is supposed t o be 5 integrated in its own right, and I couldn't help but 6 interpret that to mean that ISAP as you see it is the 7 combined SEP and IREP and ISAP, the whole bit.
8 MR. KACICH: Well, the intent of my comment was 9 to recognize that ISAP drew upon many of the elements in 10 the prior two programs. And so having that experience of 11 both working on the plant and working with the staff 12 personnel it became a logical place to try a pilot program.
() 13 MR. EBERSOLE: But in itself it doesn't provide 14 documentation for what went on SEP and IREP, does it?
15 MR. KACICH: Well, as Mike said earlier, if we 16 had not been an SEP plant we would have looked at those. l 17 MR. EBERSOLE: Right, but if I want to look at 18 the whole package, I've got to look at these three I
i 19 informational groups?
20 MR. KACICH: I would say that is correct. And 21 maybe just to capitalize further on what Ed said, in our 22 case it makes sense to apply this process to all four of l 23 our units. When we make decisions about where to spend 24 resources we have to look at it across the board and that's
() 25 all the more convenient if we can interface with the ACE-FEDERAL REPORTERS, INC.
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5940 02 02 62 rysimons 1 regulators in that context.
2 Again this was something that Mike mentioned, but 3 there was a Commission policy statement in November of '84 4 which was then titled the " Systematic Safety Evaluation of 5 Operating Nuclear Power Plants."
l 6 At the outset it was contemplated that there i 7 might be in the neighborhood' of six plants per year, .and 8 there was a discussion of a three year period so that there 9 were some 18 plants contemplated at one time. Then for 10 budgetary and other considerations that was scaled down to 11 a two-plant pilot program that was formalized in SECY 85- I 12 160 formalizing the start of the process for Millstone 1 13 and Haddam Neck.
14 Then over the next year or so we and the staff 15 did a lot of work towards looking at each of the topics and 16 that culminated from our end in the submittal of what we-17 term the final report, although it is certainly in need of i
18 updating as time goes on. It's a three volume what I would 19 represent is a fairly comprehensive report addressing each 20 of the some 80 topics in the program.
21 Similarly, we produced another report on Haddam.
22 Neck in December of that year and submitted that to the 1
23 staff, and the staff's response in draft form was published j l
24 as NUREG 11-84 in April of this year and we, among others, !
25 will be providing comments in our case later this month ace. FEDERAL REPORTERS, INC.
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5940 02 02' 63 fysimons I until we get that finalized in the near term.
2 (Slide.)
3 The other slide that I have is an attempt to just 4 perhaps refresh some of the members with prior reviews that 5 the ACRS has conducted on this plant with respect to ISAP.
6 There happened to be two ACRS Subcommittee 7 meetings dealing with Millstone 1 as part of SEP, and those-8 took place in October and November of '82.
9 That was followed up by a full committee meeting 10 in December of that year, and several days after the 11 meeting with a favorable letter from the ACRS generally 12 supporting the conclusions and the overall process.
() 13 The third item I've mentioned up here concerns a 14 full committee meeting of the ACRS that will be four years I
15 ago tomorrow when the staff was at the formative stages of 1 I
16 the overall ISAP program. So it was discussed by the full 17 committee at that point in time.
18 Then to just perhaps cover some ground that we 19 alluded to earlier with Dr. Siess, there was a subcommittee j i
20 meeting on the license conversion effort that took place at 21 the Millstone site in November of 1985, and that was 22 followed up by a full committee meeting in D<cember here in 23 1985.
24 Again several days after the meeting there was an
{} 25 ACRS letter that was generally supportive of the ISAP ACE FEDERAL REPORTERS, }NC.
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/~Tr concept, and it would be our hope today to secure an even
\-) ysimons 1 2 more favorable ACRS --- !
i 3 MR. EBERSOLE: If I can just try to get kind of a 4 time perspective on this thing, and I'll just speak of a l
]
5 specific problem that I recall.
6 Your Millstone plant, if I remember correctly, 7 had a tall stack origianlly. It could reach a number of 8 critical buildings if the tornadoes knocked it over or an 9 earthquake knocked it over. What did you ever do to that 10 and under what program did you fix it, if ever?
11 MR. KACICH: The issue of postulated toppling of ,
)
12 the stack was evaluated in SEP,
() 13 MR. EBERSOLE: Was it?
14 MR. KACICH: Yes, it was.
15 MR. EBERSOLE: As late as that, and when was 16 that? -
17 MR. KACICH: That was in the '81/'82 time frame, i
18 MR. EBERSOLE: So the plant has been running then i 19 since '66 or thereabouts, hasn't it been?
20 MR. KACICH: That's correct.
21 MR. EBERSOLE: That gives you a feeling for the 22 responsiveness of the regulatory process, i
23 (Laughter.)
24 And what did you do about it? Did you brace it l 25 or did you move it or did you ---
(]}
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l 5940 02 02 65 I rysimons 1 MR. EBERSOLE: Can you help me, Mike?
2 MR. BOYLE: I think if I remember right, the 3 stack was okay as is. I don't remember any structural l l
4 changes.
5 MR. EBERSOLE: Was it argued on a probabilistic 6 basis that it was --- )
1 7 MR. BOYLE: No. We did it in a deterministic l
8 view. i l
9 MR. EBERSOLE: And it will stand up in tornadoes 10 and earthquakes? 1
-i
)
11 MR. BOYLE: We believe so.
12 MR. EBERSOLE: That's the only stack I know of
() 13 then that can take that.
14 MR. BOYLE: Even if it fell and hit something, we 15 have had a tornado issue that.NS&P evaluated for that and 16 it was resolved. It's a backup system.
17 MR. EBERSOLE: It would not hit on a focal point 18 of vulnerability for shutdown?
{
19 MR. BOYLE: There would be a way to shut the l
20 plant down whether or not the stack was up or not. '
l 21 MR. EBERSOLE: Okay. I 22 (Slide.)
23 MR. KACICH: I only had just one other overhead 24 that I wanted to put up. I
(} 25 MR. EBERSOLE: Pardon me. Could it hit the ACE FEDERAL REPORTERS, INC.
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.i pysimons 1 diesel plant at a point in time when the offsite power was
[
2 lost? j 3 MR. KACICH: I don't believe that the stack could 4 reach the diesel.
5 MR. EBERSOLE: That was what I seem to recall. !
f 6 Okay. '
7 MR. BOYLE: There is a gas turbine nearby.
l 8 MR. EBERSOLE: Gh, okay.
9 MR. BOYLE: Which is protected from tornado 10 influence.
11 MR. KACICH: I hope you can see that all right. '
12 This is not in the handout, but this is just a slide that
() 13 was presented by the staff in the 1983 time frame when they 14 were talking about the start of ISAP.
15 Previously we discussed today the origin of some
]
16 of the inputs to the integrated assessment, including the 17 existing requirements and the SEP lessons learned and new 18 generic requirements and so forth. l l
19 There is a recognition that utility initiatives i
20 would be given equal importance in the overall process and i 21 it wouldn't be prerupposed that regulatory ones had some 22 inherent advantage to them, if you will, and it was 23 recognized that a plant specific probabilistic safety e 24 assessment was a necessary part of the overall process.
() 25 MR. EBERSOLE: At the top where it says existing 1
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5940 02 02 67 fysimons 1 requirements, that means existing and as yet unresolved.
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2 It's new things, it's things that didn't go into the 3 original design such as use of old criteria for a piping 4 design or structural design?
5 MR. KACICH: There was clearly a supposition that 6 there had to be something out there on the books that was a 7 forcing function to do to gain entry into the program that 8 way.
9 MR. EBERSOLE: Therefore, it had nothing to do 10 with the original solution to original issues?
11 MR. KACICH: In large measure that's right, yes.
12 MR. EBERSOLE: So it's not really a history of
() 13 the safety assessment of the plant.
14 M R ., KAClCH: There was an acceptance of the 15 acceptability of old resolutions, if you will, with the 16 caveat that the PRA did not assume that anything was or was 17 not ---
18 MR. EBERSOLE: Sure, the PRA would have been an 19 exception to that.
20 MR. KACICH: That assessment would have been for 21 all time ---
> 22 MR. EBERSOLE: The PRA would have looked at the 23 old issues, wouldn't it?
24 MR. KACICH: Pardon me?
25 MR. EBERSOLE:
(]) The PRA would have looked at the ACE-FEDERAL REPORTERS, INC.
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-nrysimons 1 original issues, woudin't it?
l 2 MR. KACICH: Sure, to the extent that you can l l
3 capture them in the probabilistic assessment; that's right.
4 CHAIRMAN WARD: Rich, at the time this was I 5 written, the thing there was called probabilistic safety )
6 assessment. Did that at the time mean something different 7 from a PRA?
I' 8 MR. KACICH: Not to my knowledge.
9 MR. QUINN: They are equivalent. I 10 CHAIRMAN WARD: Okay. When you use the term at i
1 11 Northeast of PSA do you mean PRA?
12 MR. KACICH: Yes. I'm being coached, yes.
(} 13 (Laughter.)
14 MR. EBERSOLE: Let me ask you about the 15 environmental qualification for apparatus, electrical l l
16 primarily. I'll take a critical component which is the 17 solenoid operated energized to function blow-down valves in :
1 18 which you blow down the primary vessel in order to get some 19 low-pressure water in it.
20 GE had a hell of a time getting those qualified 21 for the late-coming plant at that time 20 years ago for 22 Browns Ferry which led to a supposition which of course 23 locally we never investigated of what in thunder happened 24 at Nine Mile about environmental qualification of these 25 critical valves.
,)
{
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rysimons 1 Is environmental qualification a topic that has 2 been laid to rest in the integrated safety assessment )
i 3 program?
4 MR. KACICH: At the time ISAP was in the works, 5 the SER from the staff on the E0 rule was just about done.
6 So I don't recall the exact date, but I think it was in the 7 '85 time frame that we did get an SER from the staff 8 accepting our approach to the overall EO rule which 9 included the components you've questioned. I'm not 10 familiar with the particulars of them personally.
11 MR. EBERSOLE: They had a terrible developmental 12 problem getting them to survive the containment environment I h 13 in the presence of their own blow-down. That was at a time 14 prior to having pipes on the safeties. So the dry well i
15 became a very hot place when'you dumped it.
1 16 By the way, does Nine Mile have tailpipes on the j i
17 safeties now? l l
18 MR. KACICH: I don't know. j l
19 MR. EBERSOLE: Does anybody know that? I'm l 20 talking about the safeties, the safety safeties, you know, 1
21 not the pilot job, but the --- ]
1 22 MR. BICKEL: Jesse? I l
23 MR. EBERSOLE: Yes. )
24 MR. BICKEL: John Bickel with Northeast !
O 25 oti ittee- The a"esti " v "'re eexiao is retetea e e me I
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5940 02 02 70 of the very early BWRs had their safety relief valves that
)
Cnrysimons1 2 potentially vented direct to the dry well.
3 MR. EBERSOLE: That's right.
4 MR. BICKEL: Millstone 1 has the discharge of ,
i 5 those safeties vented directly to quenchers submerged in i 6 the torus.
7 MR. EBERSOLE: Was that the original design?
8 MR. BICKEL: No, I don't believe it was. It was 9 changed several years after the plant started operating.
10 MR. EBERSOLE: But that was a specific change and 11 not under any programmatic ---
12 MR. KACICH: That was quite a number of yearb 13 ago.
14 MR. EBERSOLE: Okay.
15 MR. KACICH: Just to finish up on this overhead 4 16 here, I think the six items on the right-hand side 17 identifying what were the intended end products have in 18 large measure been accomplished with respect to Millstone 1 19 and Haddam Neck as we see it. I don't know that they are 20 necessarily in any particular order, but we mentioned 21 before about the living schedule.
22 We do intend to formalize both the process, the i
23 process by which we will evaluate new projects and make 24 decisions and tie it to the license in some fashion. We 25 are in the midst of working with the staff about how i
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5940 02 02 71 )
rysimons 1 actually to do that. j 2 I do think that we are 99 percent done or 95 3 percent done on having a decision on all the topics in the i i
4 program. That's something that will be resolved as part of j 5 getting the draft NUREG into its final form, but the 6 differences that we have with the staff at this stage are j i
7 pretty minimal and I'm optimistic that we will work those 8 out.
9 We did have a fair amount of backlog. Eighty 10 topics was a substantial amount of work, and we think that I
11 by the time we have this program done and we have our i
12 current outage completed that that backlog will be reduced 13 considerably from what it had been historically.
14 The four item, improve safety, is an extremely 15 important one in that obviously that is what this process 16 is all about, to make sure that we identify dominant risk 17 contributors and do something about it.
18 We have already talked about having a better ,
19 understanding of the plant. Having gone through this 20 process and all the other studies that Millstone 1 in 21 particular has seen, it probably represents one of the more 22 studied units in the Nation with respect to participation 23 in the various programs that we've talked about.
24 MR. EBERSOLE: I don't know when it's appropriate 25 to take up specific engineering problems that prevailed at ace. FEDERAL REPORTERS, }NC.
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5940 02 02 72 rysimons 1 these plants. Is it now or later or any time? '
1 CHAIRMAN WARD: I don't think it's now. I think i
3 we'll hear more detail later. i 4 MR. EBERSOLE: Okay.
a 5 MR. KACICH: Then, lastly, having a framework for 6 future decisions, there has been a lot of frontend work l
7 that was done here in terms of developing the models and 8 other things that you will have described to you in more 9 detail later that set the stage for addressing new issues )
1 10 or new requirements in a much more efficient way.
11 So having gotten to this point, although it did 12 involve a significant expenditure of resources, I think the O 13 time aee come waeo the verdecx wi11 de there e"a there wi11 14 be a more resource efficient way to get the job done in the 15 future and maintain the level of safety and improve upon 16 it.
17 So going back to something that was prepared four ;
18 years ago and trying to reflect on how we did, I think we 19 would represent it as a reasonably successful process and 1
20 more of the particulars as to why we think that is the case 21 will come out in the succeeding presentations.
22 That's really all I have to say, i
23 CHAIRMAN WARD: Rich, I guess we 'll hear about 24 this, but the severe accident issues weren't -- well, O 25 there wasn't much focus on what we now call the severe ACE-FEDERAL REPORTERS, INC.
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5940 02 02 73 ysimons 1 accident issues and containment performance issues four 2 years ago. So your program really hasn't focused on those ;
I 3 either apparently. !
4 Why isn't that -- I mean I see that as sort of an 5 incompleteness in your program and why isn't it? -l k
6 MR. KACICH: Well, your statement is correct in j 7 that the program to date hasn't provided the solution, if l
8 you will, to the severe accident policy statement, and i 9 you'll hear more detail later, but we intend to move in 1
10 that direction and the ultimate objective th'at we have for l 11 all four of our units is to get level three PRAs in place 12 which I think no matter how the ITE thing comes out,.I=
13 don't think there will be any dispute that that would be a 14 solution.
15 Why it hasn't been done thus far represents our 16 judgment about given the limited number of people that we 17 have and what we can do, where should we look first? We 18 have looked at the older plants sooner than the newer 19 plants, such as Millstone 2 and we started with the level 20 one and the internal events work in preventing the accident 21 before we get into dealing with the consequences of it.
22 So we have mo,re work to do, but we think that we 23 have taken it in the right sequence.
24 MR. DAVIS: But you already have a level three 25 for Millstone Unit 3, which is your most recent unit.
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/ rysimons 1 MR. KACICH: That's correct, and basically the 2 reason for that I would say is that we were made an offer l 3 we couldn't refuse at the time of license.
4 (Laughter.) l l
5 CHAIRMAN WARD: Those seem to be good answers. )
1 6 Thank you.
7 MR. KACICH: Thank you. ;
8 With that I want to introduce John Bickel.
9 MR. BICKEL: Good morning, Mr. Chairman and 10 members of the ACRS.
11 I am John Bickel, the Supervisor of Probabilistic 1
12 Risk Assessment at Northeast Utilities.
()
13 I'll be discussing this morning in abbreviated 14 form the scope, content and results of the Millstone Unit 1
)
15 probabilistic safety study.
16 I will also address kind of where we stand on i
17 Millstone 1 and what our future plans are in that area. !
l 18 (Slide.)
19 Let me first begin with the desired end products 20 which we wish following the completion of our activities on 21 Millstone Unit 1. .
22 First of all, we were very interested in the 23 identification of plant specific significant safety 24 issues. In other words, are there any items out there that
() 25 are waiting to bite us that if we sit around and ignore and ace. FEDERAL REPORTERS, INC.
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1 l
5940 02 02 75 !
rysimons 1- wait for somebody else to solve could come up out of 2 nowhere and give us some trouble. ,
3 Our PRA models are basically built or put I i
4 together by the engineers within our own company for the 5 purpose of identifying on our own issues that may not have 6 been identified through other processes like the normal 7 regulation licensing activities.
8 We additionally wish to obtain enginering and 9 operational insights on critical safety issues. By this I 10 mean we wish to obtain information about the relative i 11 importance of one system versus another and various 12 different types of safety concerns.
() 13 We additionally wish to have a living PRA model, 14 one which is capable of being updated on a frequent 15 interval and is capable of evaluating in a fairly rapid 16 form the safety impact of proposed plant changes. By 17 proposed plant changes I include both the hardware and the 18 procedural type modifications that would'be going on over 19 the life of the plant.
20 We additionally wanted the model capable of being 21 expanded and extended into other areas such as to cover 22 future external events modeling.
23 And, additionally, we wanted to lay the framework 24 in the construction of the model so that we could add the 25 future containment and consequence modeling when we got to
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5940 02 02 76 ysimons 1 that phase of our program.
2 What I want to emphasize, and then we'll talk 3 about a little bit this afternoon is that the modeling 4 activities related to Millstone Unit I are but one phase of 5 an overall living PRA program which our company is carrying 6 out for all four of our operating nuclear units.
7 (Slide.)
l 8 CHAIRMAN WARD: John, I have a question. Your i 9 title is "The Probabilistic Safety Study."
10 MR. BICKEL: That is correct.
11 CHAIRMAN WARD: Do you mean by that something 12 different from a PSA or a PRA?
O 23 an 8 cxe'= heve beea to2a that the 14 distinction between PRA and PSA is something that the )
15 lawyers like, and I'll leave it at that.
16 (Laughter.)
17 I mean the same thing. j l
18 CHAIRMAN WARD: Okay. But you've introduced a !
19 third term now. 1 1
20 MR. BICKEL: The study is the writeup of the I 21 lsafetyanalysis,yes. !
l 22 l MR. EBERSOLE: Is there some place a compendium 23 of identification of significant safety issues? Are we 24 going to take up sometime may just a half a dozen or a 25 dozen specific cases?
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I 5940 02 02 77 f wrysimons 1 MR. BICKEL: Yes. I will bring that up later in O
2 my talk.
3 MR. EBERSOLE: Okay. f 4 MR. BICKEL: Tiiis slide briefly captures the 5 scope of kind of where we stand right now with the modeling 6 to date on Millstone Unit 1.
7 The level one internal events protion was 8 completed and submitted to the staff in July of 1985. Now 9 that was the basic big -- and I see some very familiar 10 cartons sitting over there. That was the bulk of the work 11 and it was submitted, like I say, in July of '85, two years 12 ago. !
l 13 We subsequently at that same time were initiating
({}
14 level one models of Connecticut Yankee, but we continued 15 our pursuit in the area of the external events focusing 16 first on fires because of the need to gain insights to 17 address remaining and residual Appendix R issues. That 18 effort was completed in March of 1986.
19 We than began work on the flooding analysis 20 immediately following that activity, and the internal 21 flooding anlaysis was in turn completed this past January.
22 And, also, I would point out that just abcut that time we 23 had completed the first major update of the PSS. So the f
24 PRA that I'm talking about today is up through Rev. 1.
() 25 The internal scope of the model, if you've ACE FEDERAL REPORTERS, INC.
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l 5940 02 02 78 rysimons 1 followed a lot of the PRAs or PSAs or PSSs or whatever the 2 jargon is that have been submitted, you will find that 3 there are generally two different approaches that people l 4 have tended to take.
5 One, is they use a large event tree small fault 6 tree approach which tends to accentuate critical operator i
7 decisions. It tends to play down the system 8 interdependencies.
9 An alternate approach is the use of a large fault l 10 tree small event tree approch which tends to focus very 11 heavily on the systems and their interdependencies.
12 The approach that we have adopted is some might Q 13 say a somewhere in between. We like facets of both and I
14 therefore our models basically could be described as large 15 event tree and large fault tree. We want to try and get 16 the best of both worlds.
17 MR. EBERSOLE: John, may I ask you a question l
18 about the first bullet. l l
19 MR. BICKEL: Yes.
20 MR. EBERSOLE: If you look at that thing in an j l
21 integrated context, which is what we are trying to do here, !
22 you could say that's intrusion of undesired influence in l
23 places where it shouldn't occur, and it happens to be fire 24 and flood.
25 There are other kinds. Just recently at Surry we !
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5940 02 02 79 had steam.
[}pysimonsI 2 MR. BICKEL: Yes.
3 MR. EBERSOLE: Where is your steam?
4 MR. BICKEL: Steam would be -- the event at Surry 5 was basically what you would call like a steam line break 6 on the secondary side of.the plant.
7 MR. EBERSOLE: Suppose that were to occur ---
8 MR. BICKEL: Steam would be like a system 9 interaction effect following the initiating event.
10 MR. EBERSOLE: You have steam driven HPCIs and 11 RCICs, don't you?
12 MR. BICKEL: No, we don't.
() 13 MR. EBERSOLE: What drives them?
14 MR. BICKEL: We have an electrically driven 15 emergency feedwater coolant injection system powered by a 16 four or five megawatt gas turbine, snd we additionally have !
i 17 a pretty much very simple isolation condenser. Both of 18 those, they perform functions equivalent to the HPCI and 19 RCIC.
I 20 MR. EBERSOLE: Okay. What about reactor water 21 cleanup?
22 MR. BICKEL: We have a reactor water cleanup 23 system, i i
24 MR. EBERSOLE: Does that penetrate machinery
() 25 spaces and has a potential for valve failure in the event i i
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Y(**ysimons 1 2 MR. BICKEL: The reactor water cleanup system 3 does penetrate a number of areas and was specifically 4 evaluated in the PRA for various break locations.
5 MR. EBERSOLE: In the evaluation did you claim 6 that the valves would always shut,'and what was the valid 7 basis for so claiming?
8 MR. BICKEL: In the area of the reactor water 9 cleanup system there are redundant isolation valves. What 10 we basically looked at was we assumed that the break 11 ocurred in an area near one of the valves, and we just said 12 the valve is mixed and we could only credit the valve that
(]) 13 was on the other side of a wall that would not be affected 14 by the adverse environment.
15 MR. EBERSOLE: Have those valves been tested to 16 1 close under duress the dynamic loads associated with 17 blowdown to an open discharge?
18 MR. BICKEL: Obviously nobody has ever checked 19 the valves in that type of condition.
20 MR. EBERSOLE: Then how can you claim a 21 statistical reliability number for it? I'll put it this 22 way. What would happen if they don't close?
23 MR. BICKEL: Well, obviously, you are going to 24 get a lot of water going through the walls.
() 25 MR. EBERSOLE: And what will that do to your ace FEDERAI. REPORTERS, INC.
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l 5940 02 02 81 ysimons 1 apparatus that you have to have to keep water on the core?
2 MR. BICKEL: They are going to have to come up 1 3 with an awful lot of water. !
4 CHAIRMAN WARD: But that sequence is in an event 5 tree.
]
6 MR. BICKEL: That is a sequence that is analyzed 7 in the PRA. Yes, it will lead to core melt if you don't --- "
8 MR. EBERSOLE: Does it result in a core melt?
9 MR. BICKEL: That is correct.
10 MR. EBERSOLE: Against some probabilistic number, 11 but I'm asking you really what is your basis for claiming 12 the valve will shut?
O 13 an 81cxe': rae beete taet ene velve wou1a enut 14 is -- well, first of all, there are a couple of 15 conservatisms. What you are postulating is like a worst 16 through wall bust out of a pipe system that's going to give 17 you full scale depressurization on maximum flows.
18 MR. EBERSOLE: Right, on low probability.
19 MR. BICKEL: It's much, much lower probability; f 20 that's correct.
l 21 MR. EBERSOLE: It's the valve that's the problem. l 22 MR. BICKEL: Yes. I won't argue with you on j l
23 that. You're right. l l
24 Let's see where I was talking, the last bullet on l l
25 this slide addresses the fact that our analysis is based l l
1 i
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5940 02 02 82 rysimons 1 extensively on a best estimate safety analysis. The reason
[
2 we do this is that when PRAs or PRAs, or whatever you want 3 to call it, are based on conservative licensing type 4 assumptions, you can very often get yourself into a trap of 5 trying to define what is conservative in a particular case.
6 So our approach is to take a realistic analysis 7 and understand the realistic timing requirements and factor 8 that into our PRA models.
9 (Slide.)
10 CHAIRMAN WARD: The bullet you just talked about, 11 that seemed to be the essence of the PRA, but I'm surprised 12 that you -- well, I guess I'm not really surprised that you
() 13 single it out as a strong point of your approach. I mean I 14 hope that all PRAs took a best estimate approach. I 15 realize they don't.
c 16 MR. BICKEL: They don't. I think if I had to 17 characterize it, and if one looked in particular at 18 programs like maybe IREP you would find examples where 19 there wasn't available budget to do that type of analysis 20 and obviously if you don't have the analysis you can't 21 i credit things that you don't know. So you rely on what is 22 in the FSAR.
23 CHAIRMAN WARD: That was a tactic that was used 24 several years ago, and I don't think it is being used any
() 25 more.
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5940 02 02 83 MR. BICY.EL: I would say that the more modern up-( {ysimons 1 2 to-date PRAs, the ones being done in the last three or four 3 years arc in general all to the maximum extent possible 4 utilizing the best estimate analysis where they can get 5 their hands on it. In some cases it is very expensive to 6 procure because like if you were looking at situations like 7 long-term cooling, which is a classic example, you're 8 talking about running expensive computer programs. Like 9 for a PWR, you're talking about running RELAP for time 10 periods of, you know, 10 or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> out into the very, 11 very long-term effects. That is not a cheap thing to do.
12 So the majority of the people tend to truncate the analysis
() 13 and fall back on the SAR.
14 I think in some of the areas where we have looked 15 we find some very interesting insights by, you know, if you 16 can find a way of making the computer run quicker.
17 CHAIRMAN WARD: As far as the scope and the 18 approach to external events -- I mean as I understand what 19 has been said here, your plan is go back and complete the 20 analysis and include a comprehensive look at external 21 events. But.you have included the fire and floods so far, 22 and why did you single those out? Was that a response to 23 some licensing questions or because you had some insight 24 there were particular problems there?
() 25 MR. BICKEL: What we were doing is -- one of the ACE-FEDERAL REPORTERS, INC.
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fysimons 1 things that my organization is charged with and is
[
2 accountable to produce is we have to support not one unit, 3 but four. I have a limited staff and a finite budget.
i 4 What was done is we did basically a major planning study i
5 some time ago that said given the people we've got and l
6 keeping our budget about the same how do we get the biggest 7 bang for the buck? l l
8 Our conclusion basically was, and I think Rick l
9 alluded to it earlier, was that we felt it was most i 10 important to focus on getting at a minimum level one PRAs 1
11 for all four of the units and with smaller amounts of 12 people we could devote to some of the external events. I
() 13 As an example, putting together a level one PRA i 14 based on our experience and the way we are doin' it, which 15 some may say is efficient or inefficient, consumes about :
16 150 man-months. That's basically eight to ten people 4
17 working a year or a year and a half, over that type of a 18 time frame. That is the biggest consumer of the resources l
19 that I have to try and get done. I can get the internal l l
20 fire / flooding type analysis done using maybe one person l 21 working about a year or half a year, in that type of time 22 frame. j i
23 So our focus was to stagger the level one j 24 analysis one after the other and with one or two extra j i
() 25 people start focusing in on the external events. In doing i
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5940 02 02 85 this we could get the maximum coverage in terms of events
{yysimons1 2 that we thought were fairly -- they were clearly in the f 3 realm of possibility.
4 If we look at the experience base out there we 5 know that, No. 1, there have been fires in nuclear power 6 plants and some of them have been severe. We also know 7 that there have been flood events and some of those events 8 have been very severe. .
i 9 Again using our internal policy of let's find the 10 damn thing and fix before it happens, we f elt that the 11 level one in addressing the fire and flood PRAs gave us the 12 maximum bang for the buck when we looked at it.
() 13 Now if we had I guess what I would call an 14 unlimited charge account and an unlimited space for lots 15 more people, we would have probably said let's do, you 16 know, let's do four level three's and just get the whole 17 thing done. That just was not a viable option.
18 (Slide.)
19 I'll continue on with the scope, and this may 20 address some of your qeustions in the area of the type of ,
1 21 things that we have considered and continue to add in with 22 passing years.
23 The initiators we considered are the classical i i
24 anticipated transients. These are the type of things that
() 25 I looked at in the FSAR. Obviously the differences are we ACE-FEDERAL REPORTERS, INC.
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fysimons 1 are compounding those initiating events with subsequent
[
2 failures.
3 MR. EBERSOLE: Does that infer you also look at I 4 them without scram?
i 5 MR. BICKEL: Yes, that is correct.
6 MR. EBERSOLE: Well, now your design preceded the I l
7 Browns Ferry design.
i 8 MR. BICKEL: Yes.
9 MR. EBERSOLE: It had some problems. It had a 10 potential for plugging. That was the old days when they f
11 had a singular vent and drain, and it had a potential both 12 remaining open when it shouldn't and then opening when it
() 13 shouldn't.
14 MR. BICKEL: Yes. That was modified -- I think i
15 what you're talking about is the scram vent and drain ----
16 MR. EBERSOLE: Yes. Now they have compounded the 17 problem by putting these valves in series which means the 18 failure of either one will guarantee you it won't do its 19 function.
20 MR. BICKEL: We had some discussions with the 21 staff when they were originally talking about what they ,
1 22 wanted us to modify in that whole scram discharging piping 23 area. We have completed the scram discharge volume 24 modification and in the area of the valving we didn't fully I 25 go along with all the things they had suggested.
[}
1 ACE-FEDERAL REPORTERS, INC.
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( {ysimons 1 It's kind of interesting that you bring up the 2 issue that when you double it that sometimes you double the l i
3 chance of creating other problems. You're absolutely ]
i 4 correct. We kind of took issue with the staff I believe in 1
5 about February of 1981 based on a PRA type argument. We l l
6 wanted to modify our discharge volume in our own way, and 7 we did an analysis which was subitted to the staff and they l
8 reviewed it and they said, yes, that we had addressed their 9 concern, but it wasn't exactly what came out in all the i
10 letters and recommended paperwork.
11 MR. EBERSOLE: Well, you would appear to be the 12 type of organization that would look at the root logic of
() 13 why (oes it make sense to close the dump volume before the i 14 rods are home, and that's a fundamental type of thing I 15 would expect a company of your stature to look at.
16 Where is the rationality that says I must not let 17 any modest radioactive release into the suppression pool l
18 until the rods are home? That's a critical question. j.
19 MR. BICKEL: Yes.
20 MR. EBERSOLE: What did you do with it? ,
I 21 MR. BICKEL: The particular way that that was 1 1
1 22 address, I myself am not fully familiar with. I do 23 recollect that there was a very extensive evaluation of )
24 that subject.
() 25 MR. EBERSOLE: I know GE probably as well as ACE-FEDERAL REPORTERS, INC.
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5940 02 02 88 rysimons 1 anybody having worked with them for 25 years, and if.they
[
2 have a policy, it's don't change anything because it makes 3 the others look bad.
4 (Laughter.)
5 MR. BICKEL: They've been known to be independent 6 on occasion I guess.
7 MR. EBERSOLE: But that's an issue that would be 8 interesting to pursue as to how you eventually satisfied 9 yourself.
10 Did you by any chance have loop selection logic 11 in your ---
12 MR. BICKEL: Yes, we did.
() 13 MR. EBERSOLE: Do you still?
14 MR. BICKEL: Well, let me put it this way. We 15 started off with initial loop selection logic as a result 16 of the PRA. It was a bunch of wiring, and I guess I would 17 call them problems identified, and I believe they were the 18 subject of an LER I think in the fall of 1985.
19 Basically the more thorough you look at it, the 20 stranger it gets.
21 (Laughter.)
22 As a result of the PRA, it identified that there 23 was some criss-crossing in the control logic that defied 24 common sense. You know, they appeared to be crossed. We
() 25 evaluated and went through all our regular internal ACE. FEDERAL REPORTERS, INC.
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5940 02 02. 89 ysimons 1 processes and filed an LER and modified it in the fall '85 2 outage. l 3 MR. EBERSOLE: Did you get rid of it?
4 MR. BICKEL: We cannot get rid of the overall j l
5 separation because it's part of the licensing basis.
I 6 MR. EBERSOLE: Yes, but you know it had impulse 7 lines were destroyed by the accident that it was supposed 8 to recognize.
9 MR. BICKEL: That has been hypothesized. l 10 MR. EBERSOLE: And it also had in recent reports 11 an ability to choke off minimum flows I think with a single 12 failure.
13 MR. BICKEL: Yes. The other point though is that 14 we are not totally reliant on the LPCI. We do have a two-15 train core spray system which is full capacity which could l
16 also handle --- '
17 MR. EBERSOLE: I thought the flooding capability j 18 of the core spray system made up for the absence of l
19 sufficient water from the low pressure injection if you 20 invoked it as a flooding system. I 21 MR. BICKEL: The biggest thing I would point out ;
22 that is a little bit hard is that my group and the majority 1
23 of the work I do is basically done in the best estimate, 24 you know, the realistic type world where we don't use the l J
oc' v " x" * ^99e"aix x eve 2" 't a = ae -
O 25 l
l ACE FEDERAL REPORTERS, INC.
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J
5940 02 02 90 O ysimons 1 Y I think that many of the problems that you talk l l
2 about are more related to the licensing grade cales. When j 3 we take a look at the best estimate response, one core 4 spray will do the whole darn job. So any perceived i
1 5 deficiencies in the LPCI would be more than made up by the 6 actual realistic capacity. j 7 MR. EBERSOLE: 'Did you solve the thermal uplift
.)
8 problem in the presence of core spray?
9 MR. BICKEL: 'Are you talking about the steam 10 holding the water up? My recollection is that when that 11 was analyzed based on the test data in GE's new best 12 estimate methodology that that uplift actually serves a )
O 3 co 9 1e bemeticie1 vervoeee- e te"ae to ao a more weter ia l
14 the core.
15 MR. EBERSOLE: At the time you were building your 16 plant GE was using core spray trajectory analysis with open l
17 sprays and sprays running into buckets on the ground i 18 without consideration of the increased density of the j 19 trajectory environment.
20 Do you know where your spray goes and do you have 21 to know?
22 MR. BICKEL: I don't know what they did in the 23 1960's ---
24 (Laughter.) ,
O 25 "a 88caso'e There te $ue' e ree "eet or ACE. FEDERAL REPORTERS, }NC.
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{7ysimons1 2 MR. BICKEL: Yes.
3 MR. EBERSOLE: Well, we can't hold up on this.
4 CHAIRMAN WARD: I think a lot of those have been 5 considered in the ECCS context.
6 MR. EBERSOLE: They still stand in shadows.
7 CHAIRMAN WARD: Well, I'm not sure. I think the 8 core spray trajectory, for example ---
9 MR. EBERSOLE: Well, it was denied that you 10 needed a trajectory in the long run because it ran across 11 the top and drew it on down anyway.
12 MR. DAVIS: John, as I recall in your PRA for l
() 13 steam line breaks you assume that the core spray is i 14 ineffective because of that reason. You split your brakeE, 15 into two different ---
16 MR. BICKEL: That was an IREP position I believe.
I 17 MR. DAVIS: I thought it was the other way l 18 around. Well, anyway, that was considered.
19 MR. BICKEL: Let's see, the other scope !
l 20 initiators. !
21 We do consider explicitly system interaction 22 primarily in the control system failure area where we are 23 looking at like say critical uninterruptible buses being 24 interrupted and uninterruptible cooling systems being
() 25 interrupted and that type of thing.
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5940 02 02 92 yysimons 1 MR. EBERSOLE: As a root sort of a logic do you 2 depend on fusible links to execute the isolation of your 3 damper isolation system in single HVAC ductwork design 4 which is surely what you had in those years?
5 MR. LICKEL: Yes.
6 MR. EBERSOLE: You do depend on fusible links?
7 MR. BICKEL: Excuse me, you're talking about the 8 thinks to close dampers for fires and things like that?
9 MR. EBERSOLE: Correct, I am, and so protect 10 solid state equipment because you're talking about control 11 system failures.
12 MR. BICKEL: Well, one of the things that
() 13 Millstone 1 does not have an awful lot of is solid state 14 equipment. It's primarily -- I think there are only two or 15 three systems, and correct me if I'm wrong, on the ATWS i
16 panel that are solid state. The majority of it is still l 17 relay.
18 MR. EBERSOLE: Okay. So that you have a more j l'
19 generous ---
20 MR. BICKEL: Forg iving .
21 MR. EBERSOLE: Yes, forgiving set of old 22 electromagnetic systems.
23 MR. BICKEL: That 's correct.
24 MR. EBERSOLE: Even so, do you depend on fusible
() 25 links to accomplish isolation before transport of ACE FEDERAL REPORTERS, INC.
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5940 02 02 93 ysimons 1 atmospheric temperatures which are in excess of those which l
2 will cause the local overload trips to occur on 3 switchboards or malfunctions of control apparatus? l 4 MR. BICKEL: Right now I couldn't answer that 5 question.
6 MR. EBERSOLE: Well, you know, you've got to get 7 those links pretty hot, John.
8 MR. BICKEL: Probably, yes.
9 MR. EBERSOLE: And by that time things are gone 10 on the other side. Those were originally designed for 11 warehouses so the cotton wouldn't burn up in the next 12 warehouse, and I think we have used those over the years to l l
O 23 protect reect r ea#1 9me"t- t $uet e" extrepo1etto" or 14 the experience that is inappropriate. You might look at ,
i 15 whether you depend on in a invalid way fusible links.
16 CHAIRMAN WARD: Are you talking about in a fire I
17 or in a LOCA or what? I 18 MR. EBERSOLE: Yes, whatever, like a low-class 19 fire which now has a transport capability to run across and 20 do system interactive effects. But even so it can go in 21 and tell the switchboards that, gee whiz, all your motors 22 are 40 percent overloaded because they depend on overload 23 intelligence from the local ambient in the switchboard j 24 room.
25 CHAIRMAN WARD: Well, you've done a fire ACE-FEDERAL REPORTERS, INC.
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l yysimons 1 analysis.
[
2 MR. BICKEL: That's correct. l 3 CHAIRMAN WARD: How did you deal with that?
4 MR. BICKEL: I think the issue of the effects in 5 the control room was alluded to a little bit earlier. i l
6 Millstone 1 has a lot of capabilities, and some of it are {
j 7 as a result of its age. It can be shut down relatively l l
8 safety primarily because of the isolation _ ondenser. If 9 you could bottle the plant up and go on the isolation j l
10 condenser, you remove the dependence on that you've got to 11 absolutely, you know, run all these switches and controls i
12 for lots and lots of different systems. It's one simple
() 13 system that, hey, I've heard people say that if they didn't 14 have power or anything they could just manually control it 15 if they have site gauges and what-not. )
16 MR. EBERSOLE: It has one big vulnerability. You 4
l 17 had better keep it pressurized. l 18 MR. BICKEL: Yes. Well, that's what I'm saying.
19 You have to have the system bottled up and it'll work ;
l 20 pretty good. j l
21 MR. EBERSOLE: So you can't have an inadvertent '
22 safety sticking open.
23 MR. BICKEL: That's correct.
24 CHAIRMAN WARD: Did that answer your question?
() 25 MR. EBERSOLE: Not really because he hasn't told ACE FEDERAL REPORTERS, INC.
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I 1
I 5940 02 02 95 me how he interpreted his fusible links.
(/ysimons
\s r
1 \
2 MR. BICKEL: At this point I'm really not a 3 hundred percent certain and somebody would have to look )
l 4 into it. !
I 1
5 CHAIRMAN WARD: Do you want to get an answer-to ]
l 6 that?
4 7 MR. EBERSOLE: Well, I think it's an answer that 8 I want to get. A fusible link is a ---
9 MR. BICKEL: I think I see Jack Quinn from our 10 Engineering Organization at the site.
11 , MR. EBERSOLE: A temperature trigger of some sort-12 that would execute closure by some other means other than
() 13 simple melting would do the job.
14 MR. QUINN: My name is Jack Quinn and I'm the i l
15 Engineering Supervisor at Millstone. Unit 1. I i
16 I can't give you the specifics of where exactly 17 all the dampers are located in the system, but-I do know i 18 the control room and in the computer room and in the cable 1
19 spreading vault and there are probably other places in the I 20 plant ---
l 21 MR. EBERSOLE: How about electrical equipment l 22 switchboards, MOVs and so forth, and what about valve rooms 23 and so forth?
24 MR. QUINN: There are areas of the plant that the
(} 25 dampers do get actuated by the smoke detection system and ACE FEDERAL REPORTERS, INC.
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\. 1 j 2 MR. EBERSOLE: By smoke detection? l 3 MR. QUINN: Yes, and not just by the fusible 4 links.
5 MR. EBERSOLE: I see.
l 6 MR. QUINN: I know there are some places in the 7 plant where you have fusible links.
8 MR. EBERSOLE: Well, they tell you, you know, 9 that you have looked at this thing about the inadequacy of 10 the fusible link mechanical release and done something 3 I
11 about it. I 12 MR. QUINN: In the fire hazards analysis the
() 13 specifics were reviewed to make sure that they would 14 operate and specific areas were upgraded to actuate on ---
15 MR. EBERSOLE: Did you say they must operate !
16 before I have unacceptable ambient temperatures in the j l
17 wrong places? I'm just talking about a fundamental root 18 logic, you know, a design basis. I must have them closed 19 before I have unacceptable ambience in the wrong places.
l 20 MP. QUINN: Most of the time they work off the 21 smoke detectors and the heat detectors. The setpoints of 22 the heat detectors, I'm not sure that that would cover --- )
i 23 MR. EBERSOLE: It's the origin of the setpoint 24 that I 'm trying to find.
25 MR. QUINN: Most of the critical components such
({}
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5940 02 02 97 as the control room work on smoke detectors and therefore
{7ysimons1 2 they would going long before the temperature would rise to 3 a critical temperature.
4 MR. EBERSOLE: Right, but maybe not in a 5 switchboard room damper where there are no people. See, 6 you were looking for the operators so that they wouldn't 7 suffocate, and I'm looking for the machinery so it won't 8 fail.
9 MR. QUINN: Well, the switch gear area is right lu outside the control room. I'm not sure there are specific 11 dampers for that large area.
12 MR. EBERSOLE: Okay. Thank you.
() 13 CHAIRMAN WARD: Well, let's see, could you direct 14 us to where in the fire analysis these questions are 15 addressed?
16 MR. EBERSOLE: Just an example.
17 MR. BICKEL: The fire PRA to my recollection is 18 in Section 5 or 6 or something of the ---
19 MR. EBERSOLE: Could you just state what the 20 basic criteria for zone protection was?
21 MR. BICKEL: Okay. Every utility that has done 22 an Appendix R compliance has done a fire hazards 23 investigation which basically breaks the plant up into fire 24 zones. We went one step further for the purposes of PRA in
() 25 subdividiing some of those very, very large zones. In l
/\CE. FEDERAL REPORTERS, INC.
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ysimons 1 other words, it is not realistic to assume that the whole 2 control room, if you have a fire in one corner, that it
]
i 3 consumes everything in the far opposite corner. It's more I l
4 realistic to break up the control room into subzones that 5 you can treat initiation and ask questions about does the )
6 fire propagate across the zone. The reason being is that 7 again this is try and be realistic.
8 Somebody trying to be conservative would say that l l
9 the fire here takes out the entire thing and I don't have 10 to worry about it because the room is dead and everything 11 is just one molten pile of plastic or something like that.
l 12 What we realistically look at was a small fire is j i
13 more likely -- in other words, a small localized fire l 14 compounded by, you know, maybe smoke or fire damage or heat 15 without absc,1utely destroying something in the opposite l l
16 corner, and then to get to core damage one would hava fail l 17 additional systems on top of that.
18 So our analysis started off kind of by subzoning 19 all the various areas in the plant that were assessed to 20 have combustible loadings and, yes, we also looked at 21 transient combustibles based on experience and said, you l
22 know, there is always some small probability that you have 23 a ignition source and transient combustibles and you get to 24 a fire.
I 25 The area of propagation was addressed by focusing ,
ACE FEDERAL REPORTERS, INC.
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5940 02 02 99 on an area such as barriers, what are the barriers rated
{yysimons1 2 for and realistically how long was it going to take for the 3 plant fire brigate to respond and start doing something 4 about the fire. At certain points you don't have to carry 5 the analysis very far because one of the purposes of fire 6 PRA is to identify, you know, are there places where you 7 can do enough damage just ine one area and you try and 8 single those things out and see if they exist and what you 9 should be doing about them.
10 MR. EBERSOLE: There are places where you have.a 11 focused vulnerability.
12 MR. BICKEL: That's correct. The real purpose is
() 13 to focus in on issues, and like you say, some focus on i
14 vulnerability if you've got a place that's really a soft ;
15 spot.
16 MR. EBERSOLE: Do you have some nodes in the 17 plant, for instance, that are subject to that sort of 18 thing?
19 MR. BICKEL: Well, I think in the analysis one of I
20 the areas that came up that was recently addressed was in ,
21 the area of the controls for MSIVs and SRVs.
22 MR. EBERSOLE: What about the spreading room, 23 that's a big node and it's usually under the control room.
24 MR. BICKEL: That was one of the areas that did
() 25 come up. I'll get into the fire analysis a little bit 1
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2 MR. EBERSOLE: Well, I don't think we have time 3 to go into these individually.
4 CHAIRMAN WARD: Jessie's bigger question is there 5 is a certain let's say class of propagation of fire or the 6 effects of a fire. You've got a localized fire, but the 7 HVAC system then transports hot gases from that fire to 8 other subzones or zones or something, and in those subzones 9 there might be some, for example, INC equipment which just 10 the hot gases would be enough to render inoperable, and 11 does your fire anlaysis take that sort of interaction into 12 account, and in particular there might be dampers in the O 13 HVAC system which are supposed to reduce the likelihood of 14 that happening. I think in looking at other fire analyses 15 that Jesse's got'the suspicion that sometimes those dampers 16 might not be as effective because they don't close until 17 temperatures are much higher than those required to effect 18 certain INC equipment.
19 MR. EBERSOLE: If even then because they are 20 rusted in place.
21 MR. BICKEL: I think I understand his question.
22 The point I would'like to make is the fact that when you do 23 the zoning analysis, the reason for concern about the fire 24 propagation from one zone to the other goes back to the 25 theory that I can separate the plant and I can always ACE. FEDERAL REPORTERS, INC.
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5940 03 03 101 fysimons 1 keep one train protected. That issue is very true,
[
2 particularly in plants that have two identical trains that 3 you can take a red line and divide the plant right down the 1
4 middle. !
1 5 Millstone 1 is not basically built that way.
6 You've got kind of overlapping areas. You've got an l l
7 isolation condenser in part of it and then you 've got a 8 feedwater coolant injection system. You've got a diversity j l
9 of -- well, several diverse type systems that can be called i
10 into play.
11 So the issue of propagation from one fire zone to l 12 another I think is more germane to like a very recent PWR
() 13 type plant. It would be far more of an issue in those 14 types of plants.
15 Basically what the fire analysis did was it tried 16 to zero in on those areas where if you have a fire and it i
17 does the damage and it's compounded by a single system 18 maybe being out of service for maintenance or something ,
19 like that in one of the diverse areas that you get into I
20 trouble.
I 21 At least from what we did there is not a need to 1 22 study more catastrophic things of fire dampera. There are 23 other ways. In other words, it would be more likely that j 24 something is out of service in a redundant train than the
() 25 fire propagates through a duct and a damper fails to close.
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^ MR. EBERSOLE: Well, you picked the worst case brysimons1 2 and so you shield at least the worse case, but the least 3 worse case is still significant.
4 MR. BICKEL: That's correct.
5 MR. EBERSOLE: That's an obscuring process to 6 find something worse than that and then brush the other 7 ones away.
8 CHAIRMAN WARD: You referred to the isolation 9 condenser as sort of a f all-back for probably a number of 10 sequences to prevent core melt and you haven't done a 11 seismic analysis yet. Do you think the isolation condenser 12 system will have some particular vulnerability to seismic !
O 13 or e t2 i 14 MR. BICKEL: As a part cf SEP there was an 15 overall seismic analysis. It's not what you would call
)
16 like a fragility analysis that you would use to support a 17 PRA, but the individual key systems were kind of piece by 18 piece looked at and beefed up. The isolation condenser is 19 in particular one that was very heavily upgraded primarily 20 because of the fact that it's a very large tank and it's ;
l 21 very high up in the building.
22 If you look at photographs of the way it looked l 23 originally and you look at it now and it's got a lot of "I" 24 beams around it and things like that, it has been 25 significantly upgraded in it's capability to take the ACE-FEDERAL REPORTERS, INC.
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5940 02 02 103 rysimons 1 shaking at the high level of the buildings.
2 MR. EBERSOLE: John, that's the inverse case in 3 point. You've just spent millions of dollars to upgrade 4 the seismic, but it only takes one SRV sticking to ,
i 5 invalidate its function. {
6 MR. BICKEL: As a matter of fact, we have started 7 to look at exactly that whole issue as part of the long- j 8 term cooling studies about how much of it do you totally i
9_ wreck if you have an open relief valve, and we are at the- j l
10 point of concluding that in combination, you know, one LPCI 11 heat exchanger with a LPCI relief plus the isolation j 12 condenser is a success path.
13 MR. EBERSOLE: What about the more simple concept
(])
14 introduced in GESSAR 27 15 MR. BICKEL: I'm not familiar with GESSAR 2.
16 MR. EBERSOLE: Well, okay, it's a very simple and 17 you must look at it I would think if you've got Millstone 18 1. If you have that stuck relief, so what, you get rid of i
19 the energy in the core via the dry well. It goes to the i
20 suppression pool and then in order to further get rid of it l i
21 you can vent the containment and eventually all you are 22 doing is pumping a little cold water with a jockey pump !
i 23 into the reactor vessel and you're going home with the 24 steam blown outside the containment.
25 MR. BICKEL: Currently our procedures don't go
(])
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into that type of thing yet.
[ pysimons 1 2 MR. EBERSOLE: I've been told by the staff on 3 other occasions that every BWR has a back door exit to open 4 cycle boiling through the suppression pool when it is above 5 the boiling point. That's the home run from everything.
6 MR. BICKEL: I think what you are referring to is !
i 7 there is analyses and activities supporting I guess some 8 recent revisions ---
9 MR. EBERSOLE: Pre-core damage venting process.
10 MR. BICKEL: Correct. What they are 11 impleme nting, and that is something that is being done by 12 the EPG, emergency procedure guideline working group for
() 13 the BWR owners group.
14 MR. EBERSOLE: The comforting thing is, John, all I
15 you need is a jockey pump some place run by a gasoline i
16 engine in the gauge class, and that is not much equipment 17 that you are protected from fire and earthquakes and 14,000 18 other influences. A boiler can do it, and any boiler that 19 doesn't take privilege of that advantage I think is a 20 little bit shortsighted. You can't do it with a PWR.
21 MR. BICKEL: Amen. I 22 Continuing on with this slide, one of the other 23 facets I think of our scope is our desires to make maximum I l
24 use of plant experience, and with that I poin, out the use i
() 25 of the actaal event frequencies component reliability, the ACE. FEDERAL REPORTERS, INC.
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i ysimons 1 actual system reliabilities, statistics and system 2 downtime.
3 These again are issues that would be updated on a 1'
4- periodic basis as part of the living PRA activities.
l 5 (Slide.) !
6 CHAIRMAN WARD: John, is there some way to l 7 characterize the fraction,of -- I don't know quite how to 8 ask the question -- some PRAs, particularly early PRAs and 9 maybe even some of the later ones used-almost exclusively 10 generic data'about their equipment and subsystems and I
11 systems. As you get experience you move toward using a 12 hundred percent.
l O 13 waere ere vou o# the co#ti#uu or zero to 1oo 14 percent?
15 MR. BICKEL: We utilize actual plant experience 16 for all except the LOCAs. We do not have statistical 1
17 experience on LOCAs. We have used it for lifted relief j
18 valves, loss of offsite power and all the types of events j i
19 that are, you know, there is a wealth of experience out 20 there that is waiting to be used.
21 CHAIRMAN WARD: Your own experience.
22 MR. BICKEL: Yes, that's correct. We do not 23 utilize plant specific experience from things like relays, I 24 the reason being is that the program necessary to collect !
O 25 statistics n the relays would be monumental, and the other ACE FEDERAL REPORTERS, INC.
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5940 02 02 106 rTrysimons 1 thing is that we tend to find that the main components that U 2 are really worth trying to track and put into the PRA are 3 things like your MOVs, SRVs, diesels, gas turbines, big 4 pumps and things that are large mechanical devices. Their J 5 reliability we tend to find plays very heavily in some of 6 the results you can from the PRA.
7 If I wanted to set up a program to capture all of 8 it, I would probably need more people and it probably i
9 wouldn't yield a heck of a let more useful information. It i 10 would probably confirm that WASH-1400 numbers for contacts j 11 probably aren't so bad.
l 12 CHAIRMAN WARD: What about operator performance?
(} 13 MR. BICKEL: Operator performance we have been 14 moving towards the use of the human cognitive reliability )
I 15 model, which is kind of the state of the art, and we are l
16 actively supporting the activities of EPRI which is trying ,
l 17 to gather actual -- they are trying to benchmark the model )
18 against simulator experiments. And we recognize that, yes, l
19 there are differences between a simulator drill and the 20 real thing. 1 21 However, the way they have structured the model )
22 is more related to the decision-making process than the I l
23 stresses on the people to perform in a full pipe-break LOCA 24 type of thing.
25 Our intent in that area is to follow that
[}
l 1
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i 5940 02 02 107 activity, keep it current and if we learn new things as a fysimons1 2 result of that program, they get factored in in a future 3 update.
4 We have used in some areas operator experience as 5 a source of initiating events. Some scrams are caused by 6 operator errors and they get factored into the initiating f I
7 event frequency. J l
8 CHAIRMAN WARD: Is any of that Millstone 9 experience?
10 MR. BICKEL: Yes, that'is correct, that is other 11 plants including our plants. g 12 MR. EBERSOLE: John, the issue of ATWS came up in
() 13 about '68. When did you put pump trips on?
14 MR. BICKEL: Oh, we put them in quite a while 15 ago. I couldn't give you an exact date. They were in 16 there at least as early as, what, '81 or '82.
17 MR. EBERSOLE: Well, that's after '68. S.i that's .
18 14 years.
l 19 MR. BLASIOLI: It was 1980. It was during an 20 outr.ge in 1980.
21 MR. BICKEL: I have included in the handout 22 material just for kind of some clarification a comparison 23 between the reactor safety study, what was originally done j l
24 in the Millstone IREP and a comparison with the 1985 ;
25 version of the Unit 1 PSS that we performed as part of
[}
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5940 02 02 108 rysimons 1 ISAP.
2 What this comparison shows is where we changed 3 some of the basic pieces that go into it like the success 4 criteria and initiating events that were used.
5 The changes in the success criteria were due to 6 the availability of our best estimate analysis of these 7 type of issues and system performance. We factored that in 8 where we had changes.
9 Additionally, we utilized as much plant specific 10 data, and that resulted in changes.
11 One of the areas I would draw attention to was in 12 the performance of the LPCI heat exchangers. We identified
() 13 a more conservative requirement being actually required for 14 long-term cooling than was used in the IREP, and that was 15 one of the key differences between what we submitted in 16 July of '85 and what was a result of the IREP program.
17 MR. EBERSOLE: Can you get the main steam 18 isolation valves open to use the condenser without 19 difficulty?
20 MR. BICKEL: Yes. As a matter of fact, they have a
21 operating procedures and they have done it on several 22 occasions. The plant's preference for obvious reasons is 23 to use the main condenser.
24 (Slide.)
25 This slide here shows I guesr what was obtained
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5940 02 02 109 rynimons 1 in the Peach Bottom study, the results from the Millstone 2 Unit 1 IREP PRA and two versions of the Millstone 1 PSS.
3 The first original result in July of '85 was 8 !
4 times 10 to the minus 4, which exceeded our corporate 5 safety goal and initiated a number of activities to begin q I
6 investigating what we had to do knowing what we know to '
1 7 reduce that number.
8 The subsequent investigations and focusing in on i i
9 what was perceived at the time to be the issues to be 10 working on has resulted in a reduction down to 5.2. This {
11 reduction still does not fully reflect what we know as of a l 12 week ago in the long-term cooling area.
13 MR. DAVIS: Excuse me, John, before you leave 14 that one I have a question. Is your 1987 number a mean 15 also?
16 MR. BICKEL: That is correct. i 17 MR. DAVIS: So to compare with medians you would 18 need to multiply that by a factor of like two and a half?
19 CHAIRMAN WARD: You don't really mean that, do 20 you?
21 MR. BICKEL: He said it, not me. j 22 (Laughter.)
23 MR. DAVIS: Yes, I do, )
l 24 MR. EHERSOLE: You know, there is kind of an I 25 interesting trend there. The more you know about a plant l
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.1 5940 02 02 110 ysimons 1 the higher the probability gets.
2 MR. DAVIS: I'm not so sure that's the case, l 3 Jesse, because if you compare the NUREG 11-50 number for !
i 4 Peach Bottom, it's even lower than WASH-1400, clear down to i I
5 8 times 10 to the minus 6th which means Millstone 1 is ]
6 about 100 times higher when you compare means.
7 What is your corporate goal, John?
8 MR. BICKEL: Our corporate goal right now is to 9 get all our plants below 10 to the minus 4.
10 MR. DAVIS: Median or mean?
11 MR. BICKEL: Mean.
12 CHAIRMAN WARD: Well, Pete, I've heard an awful O 13 or criticie ebout the eeeu 9tioas meae in re1 tiao meaiea 14 and mean values in a simple way as.you describe. Do you 15 have some confidence that that's a useful thing to do? j 16 MR. DAVIS: No. l 17 (Laughter.) .
1 18 MR. BICKEL: I think the means and medians 19 becomes more important I guess the fuzzier the numbers are, 20 but I think if the purpose of the program we have is to 21 identify issues and to try and judge which plant deserves !
l 22 the attention and to focus the activities and resources on 23 that plant, then it's probably not as critical. I mean our 24 intent is to identify where the issues are and begin work Q 25 on them and with time knock the number down as a result of 1
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4 5940 02 02 111 ysimons 1 changes to the plant.
2 CHAIRMAN WARD: That's valid as long as you have 3 an active program.
4 MR. BICKEL: That's correct.
1 5 CHAIRMAN WARD: But at some point you're going to ;
l 6 quit I guess, hypothetically anyway.
7 MR. BICKEL: We like to think so, yes.
8 CHAIRMAN WARD: When you went from 8 to 5.2 of 9 the mean, there are some pluses and minuses.
10 MR. BICKEL: That's correct.
i 11 CHAIRMAN WARD: You added in a couple of external i 12 events.
O 23 "a 8 cxe': " - 1et me cterity thet- The au ber 14 that I was showing was just the internal events only 15 because in 1985 we did not have the fire and flooding l l
16 completed.
17 CHAIRMAN WARD: Yes, but you did in '87. l ll 18 MR. BICKEL: In '87, yes. You would have to take 19 the overall number and add to that the -- this was just to 20 show internal events. Let me point out that if I added the I l
21 overall I would end up for the Millstone Unit I with an '
i 22 overall total right now of about 5.7 times 10 to the minus i 23 4, the reason being was the internal flooding and the fire ,
24 did not add -- they were not as likely as what you get from Q 25 the internal events. So it would.go from 5.2 to 5.7.
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5940 02 02 112 !
rysimons'l (Slide.)
2 I'm showing here a breakdown, and there are i
3 several slides that show the comparison of how the results 4 shifted as a result of the update in '87.
5 I think one of the key things to note here is ;
J 6 that a majority of the changes that occurred were very, :
7 very small and were very subtle. l 8 I think Jesse had asked the question did you 9 consider things about RBCCW and service water losses and 10 this type of thing. Yes, we did, and the percentages are l l
11 as shown.
12 MR. EBERSOLE: Why do you say loss of normal 3
() 13 power rather than station blackout?
14 MR. BICKEL: Station blackout would imply that 15 you have a loss of normal power compounded by the failure 16 of the two emergency onsite power systems.
l 17 MR. EBERSOLE: That's when you get into trouble. j 18 MR. BICKEL: That's correct. This is just losing 19 normal power and having f ailures other than station 20 blackout.
]
i 21 CHAIRMAN WARD: John, loss of normal power is the l l
22 initiating event. I 23 MR. BICKEL: Yes. ,
24 CHAIRMAN WARD: In some cases that leads to I
(} 25 station blackout and in some cases that leads to core melt, 1
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5940 02 02 113 and that's what your 30 percent is, right?
[}rysimons1 2 MR. BICKEL: No. This is a loss of normal power 3 in which there is a scram of the reactor and some 4 subsequent other failure on top of the loss of normal power 5 occurs and then you get the core melt.
6 MR. EBERSOLE: When you say feedwater, what kind 7 of feedwater? There are lots of kinds of feedwater.
8 MR. BICKEL: It's the feedwater coolant injection 9 system.
10 MR. EBERSOLE: Now is that the main feedwater ,
11 system?
12 MR. BICKEL: Yes. I guess what we call the FWCI
() 13 system is one of the two feedwater strings that has an 14 emergency mode of operation. In other words, it's like a 15 category one feedwater system.
16 MR. DAVIS: And that's hooked to your gas turbine 17 generator?
18 MR. BICKEL: That it correct.
I 19 (Slide.)
l 20 We looked at LOCAs. As you can see, there was a l
21 change in the small LOCA contribution. Again this was 22 refinements and changes to the model as a result of I
23 procedures, upgrades and things like that. j l
I 24 (Slide.)
() 25 You mentioned earlier unisolated cleanup system i
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5940 02 02 114 rysimons 1 LOCAs. It was considered. These are like interfacing 2 system type LOCAs. They are very small and again a lot of 3 it is a combination of there are multiple valves and things 4 like that.
5 (Slide.)
I 6 This shows what we call the breakdown of the CMF 7 in terms of safety issues. This was the station blackout 8 contribution and was.12 percent in '85.
9 Now as a result of our original finding about the 10 dominance of the long-term decay heat removal a number of 11 procedural things were initially done focusing on what 12 could we change immediately to try and get this number 13 under control, and that is reflected in the drop somewhat 14 in the contribution of this.
15 Of course, as you drop one something else is 16 going to start' rising. So of course the next one right l 17 behind it is the station blackout.
18 I have shown the breakdown of the station 19 blackout. We found that there are two causes. A unique 20 finding was that the gas turbine service water system 21 failure was a little bit'more dominant than the gas turbine 22 failing in the diesel. Losing service water or a failure 23 of that will of course Icad to that, but we found that to I 24 to be a little bit rare likely than the failure of the two i
25 power sources.
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ysimons 1 (Slide.)
2 This slide summarizes the results of the external 3 analysis. I mentioned the fire analysis was completed in i
4 March of '86 and the internal flooding was completed )
I 5 recently. !
l 6 I think one of the other issues that was brought 7 up a little bit was Appendix R issues, you know, have we 8 really looked at all of them. Well, the PRA model that was I 9 developed reflected what e.tisted in the plant at that time, {
10 and we were then able to use this type of analysis to look 11 at the remaining Appendix R fixes that were out there to be 12 completed recently.
O 13 ^11 eti11tiee ia comotvimo with ^reeaaix a sea to 14 develop similar type procedures. We view the isolation 15 condenser as a real ace in the hole for coping with a 16 considerable number of fire scenarios. j 17 Internal flooding, the fire protection system 18 turns out to be the dominant source. Again, a lot of 19 people say that isn't too big a surprise because there is a 1 20 l lot of industry experience and that's a good way to have it j 21 go.
22 (Slide.)
23 This slide summarizes the actions taken 24 immediately after the '85 upgrade or the completion of the O 25 1985 etudy.
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5940 02 02 116 I
ysimons 1 I would say some of the key ones were upon j 2 finding that the decay heat removal issue dominated-because {
l 3 of the small heat exchangers, we of course immediately j 4 began the legalistic type evauation of is this a reportable 5 type of event. 1 6 I think the unusual thing you come up with is 7 here again you have a PRA finding that indicates a 8 vulnerability and yet it isn't really an issue that the 9 plant doesn't comply with its licensing basis. It's within 10 it.
11 We immediately investigated what were the areas 12 in the long-term cooling area that we could have some O 13 effect n. In ther words, if we have to live with a 14 requirement of having two trains of LPCI heat exchangers 1
15 running, what wuuld i>e the limiting type of problems that '
16 would come and get you. One of them was the lube oil 17 cooling. So we upgraded our LPCI pump surveillance to 18 better focus in on that area. 1 i
19 Additionally, we made some improvements to the l
20 containment control IEOP to correct what were perceived as 21 errors of pump throttling instructions. We felt that they 22 needed some changes in that area.
23 You mentioned I think earlier LPCI loop l 24 selection. We found one and it was corrected.
25 MR. EBERSOLE: That was found to be a deficiency r
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5940 02 02 117
~
g irysimons 1 in design in the beginning and it was compensatory to !
v l 2' invent that system so that you would spill all the water on 3 the floor, but it brought with it the potential of dumping 4 all the water on the floor because now you must select 5 which pipe is not burst and orient your available pumping 6 capacity to the one that is still there. So you lose all I 1
7 the low pressure flooding functions. I i
8 MR. BICKEL: Well, you lose all of the LPCI 9 flow. You would still have the core spray flow. There are 10 other ways you could put water in. We have, you know, as a 11 result of the emergency procedure guidelines activities, 12 there are still other ways even if you knock those out.
13 I won't go through all of these.
i 14 Very quickly, we have made some changes to i l
15 procedures addressing an HVAC lockout to the RBCCW 16 problems. We have made some changes to the isolation l 1
17 condenser, one of the critical flow control valves that 18 turns the IC on.
19 We initiated in 1985 a major engineering project !
20 to reinvestigate the whole issue of long-term decay heat 21 removal by analysis and consideration of possible and even 22 major hardware backfits. We were actively pursuing 23 basicaly ripping out the existing heat exchangers and 24 putting in bigger ones and newer ones and we had a very 25 active program in trying to come to a resolution of what Ace FEDERAL REPORTERS, INC.
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{59400202 l I the problem was.
()Fysimons1 2 The key problem in this area was that this moves 1
3 into an area where you need an awful lot of information on ]
l 4 the long-term performance of the ECCS and the cooling 5 systems, and it's very difficult and you've pretty much got 6 to do it c'n your own.
7 MR. EBERSOLE: With respect to that long-term 8 business and the single failure criterion, one of the 9 original peculiarities of the single-failure criterion is 10 it had no time sense. Where is your time sense in the 11 single-failure criterion? How long must you operate before 12 the first failure or the second failure gets you?
() 13 MR. BICKEL: The specific failure we were looking 14 at was related to the success criteria. I want to point 15 that you only get into this problem as a result of not I
16 having the main condenser and the isolation condenser in 17 the shutdown cooling system. If you can come up with a 18 scenario that knocks those three out, you are now reliant 19 on your kind of RHR mode, you now, flood up the vessel and i
20 get a water flow path through a relief into the torus. l l
21 We determined that you needed two out of two i
22 trains. You could maintain injection for quite a while, 23 but at some point you've got to start taking the heat out i
24 of the torus. Our initial calculations, which were very 25 simplified, did not have the benefit of a full-scale
(]) l l
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I 5940 02 02 119 ysimons 1 computer model indicated that the torus would heat up-to a 2 level that the LPCI pumps would cavidate. So at about -
1 3 seven or eight hours into the event you couldn't keep those j
\
I 4 pumps running.
l 5 Your alternative then was to switch to pumps that didn't take suction from the torus, but you know at some 6
7 point you can't fill the containment solid with water. So 8 that is where the problem area was. ;
I 9 Now bear in mind that this is a living PRA l 10 program that uses the PRA. If it develops an issue that 11 you just don't have the information to solve, we take the 12 approach that it's a problem. If it makes the number go up O 13 taet issue te ootno to become the recue or eaaitio e1 work.
14 MR. EBERSOLE: You cannot pump water than from an 15 external source and just pour the whole thing full of 16 water?
1 17 MR. BICKEL: Well, to an extent.
18 If I can have the next slide.
19 (Slide.) !
i 20 In '87 we just recently completed the long-term 21 cooling study which we went back to study that, and the 22 ultimate resolution with I guess better anaysis is that if 1
23 the operators get confronted with a situation that they are 24 down to using those heat exchangers, our recommendation is Q 25 within two hours that they transfer for 40 minutes over to ace. FEDERAL REPORTERS, INC.
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l 5940 02 02 120 rysimons 1 the CST. 'That will raise.the water level, and we only need 2 about four feet of additional water level. It buys them 3 time and adds level to give better NPSH and it also gives )
I 4 ti.em a little bit of a pressure rise. All three of those !
5 effects will help to maintain a good margin on the NPSH.
6 Therefore, we can run those LPCI pumps indefinitely.
I 7 CHAIRMAN WARD: On this switchover to get a j l
8 higher water level in the torus, is that now in the EOP?
9 MR. BICKEL: No. I want to point out that the i
10 study that I'm referring to was literally completed about i 11 one week ago and I only had about five minutes to talk with l J
12 the staff on the fact that we own them a report on the O 3 resoluti n of this. This was one of the ISAP issues that 14 was prioritized as a very hot topic to get into and study. {
l 15 It was a 64 percent contributor to what we 16 perceived a a bad number and we felt we had to really work 17 on it.
18 MR. EBERSOLE: Does that design have a torus with 19 a suction pipe at the bottom of it?
20 MR. BICKEL: It has a ring header at the bottom.
21 MR. EBERSOLE: Were you required to justify how 22 you would operate if that were burst, or if that ring 23 header failed and you lost the suppression pool?
24 MR. BICKEL: I don't know the answer to that.
25 MR. EBERSOLE: You know, it makes for an ACE-FEDERAL REPORTERS, INC.
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5940 02 02 121 j rysimons 1 interesting state of affairs with that pipe. If it fails 2 under even modest pressures, then it does produce some i
3 spectacular effects. l 4 CHAIRMAN WARD: In the long-term cooling study 5 were you aware of or did you find useful, if you were, the I
6 A-45 studies?
7 MR. BICKEL: We were focusing basically on 8 analyzing in great detail what mechanisms you had available i
9 for decay heat removal generally in the beyond two hour 10 time frame. In other words, if you look at your FSAR, you !
11 know, you inject all the water and the peak clad 12 temperature comes down and it looks like the game is all O 13 over- ^ a whee we were beeice11v 1ooxiao et ie net 14 happens in the two-hour time, you know, beyond two hours 15 when you get out into the 10,000 and 20,000 seconds and 16 some kind of a simulation.
17 CHAIRMAN WARD: Well, the Sandia studies'in 18 support of the A-4 5 program looked at that sort of thing. ;
I 19 MR. BICKEL: I'm not familiar with those because !
20 we were not really apprised of them. We were looking j i
21 mainly at what I guess we would call our plant specific 22 sizing of heat exchangers and things like that options and 23 what procedures they would be attempting to follow.
24 In '87 one of the other areas that was initiated 25 was at the request of our station personnel who requested 1
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5940 02 02- 122 (hrysimonsI like a system specific reliability evalation. They wanted 1
2 us to look at the gas turbine and develop like a fault tree i I
i 3 type of model, reconcile it with the actual failure !
.l 4 experience and try to address the effectiveness of our H I
5 testing and maintenance and modification programs on the l
6 gas turbine. In other words, are we getting all we should ;
i 7 for what we are doing with testing. j 8 The intent of this thing is to basically sit back l
9 and say well, we've tried it-a couple of times and every i
10 time there is a ne~w failure we haven't thought of, you j l
11 know, we add another test or maintenance program and is !
)
12 this really the most effective thing to be doing. Maybe we
( 13 are overtesting some areas and undertesting others. They J
14 wanted like essentially an outside independent review of 15 the effectiveness of the program.
^
l 16 That study also is nearing completion, and this 17 addresses one of the issues that we feel is a very i
18 significant core melt contributor. l l
19 Two other areas that we have initiated in '87.
1 20 We have a pilot program on using the results of the PRA 21 program for focusing what we will call the discretionary 22 time of our quality assurance OC personnel at the site.
23 There is always some fraction of their time that in the 24 past they would just randomly go out and start looking at
( 25 design packages.
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l 1
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5940 02 02 123 arysimons 1 What we are doing now is that that discretionary i 2 time is being prioritized into the systems and particular 3 changes which the PRA indicates are sensitive. This again 4 focuses back on I guess what I would call one of our 5 original objectives, to become fully aware of the sensitive l I
6 safety and engineering issues and that when you have a l 7 discretionary item, you know, go for the bang for the buck.
8 Another area ---
4 9 CHAIRMAN WARD: I have a question about that. l l
10 Have you looked at the other side of that? In quantifying i 11 your plant experience to put into the PRA is there a ,
i 12 difference among the plant systems that are on the "0" list 13 or aren't on the "O" list?
14 MR. BICKEL: A PRA, like what we would do, j 15 credits all sytems that they call out in the EOPs. If the i
16 people have access to it, are trained in it and they have i 17 something written down or they have a pretty clear idea how 18 they would align it, we would credit it.
19 There is basically only I think one system -- I 20 mean there are a lot of systems I should say, like cleanup 21 systems, and it's definitely something that is not ---
22 CHAIRMAN WARD: I recognize that, but as far as 23 what you assume about the reliability of a system, what you 24 assume is somehow based on what you've experienced with O 25 that system.
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5940 02 02 124 rysimons 1 MR. BICKEL: Yes.
2 CHAIRMAN WARD: What I want to know is ---
3 MR. BICKEL: Are there significant differences?
4 CHAIRMAN WARD: Yes. Does your experience 1
5 indicate that GA does any good?
6 MR. BICKEL: It sounds like somebody is trying to 7 get me to say that OA is worthless. I don't think I want 8 to say that.
9 (Laughter.)
10 CHAIRMAN WARD: I would like to have your 11 objective opinion. As a PRA guy what is your observation 12 about it?
O 13 MR. BICKEL: I would say that quality assurance 14 addresses one issue. Reliability is probably not the issue j 15 that it addresses. I think the QA program is geared to, 16 what do you call it, 10 CFR 50 Appendix B. If you're 17 installing something and maintaining it and it's for !
18 protecting the public, according to the law your QA/0C i 19 program, it's function is to assure that you have in fact 20 done all of the things that you claim you have done.
21 You can have a quality assured system that meets 22 all the intent of the laws and you have followed all the 23 sign-offs and you've had 27 discipline reviews, and yet it 24 doesn't fully run very well because it is just too O 25 complicated. ;
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5940 02 02- 125 rysimons 1 OA and OC does not guarantee reliability of 2 equipment. It's function is different.
3 MR. EBERSOLE: You're saying that 0A/0C can't be
'4 put into a PRA except as a broad statistcal base.
5 MR. BICKEL: I don't think you can even put it in 6 as that. It's a separate issue.
7 MR. EBERSOLE: So what Mr. White is doing at TVA 8 can't be put into a PRA at all.
9 MR. BICKEL: I don't know what Mr White is doing.
10 (Laughter.)
11 MR. EBERSOLE: That's what he's doing.
12 MR. BICKEL: What I'm trying to say is that we 13 have some systems that are cearly quality, you know, OA Cat 14 1, and every time you want to touch them you've got to do 15 all the signoffs.
16 CHAIRMAN WARD: Well, I guess sort of naievly I 17 would expect if OA was worth anything that if I went out 18 and looked at a plant that had a lot of experience and the 19 experience had been analyzed carefully like at Millstone 1, 20 I would expect to find that those systems were parforming 21 up through the years more reliably than another system.
22 Now you're saying -- and that's what I'm asking --
23 you're saying it's not clear when you've analyzed the data 24 to put into your PRA that that's the case.
25 MR. BICKEL: Let me give you an example. I'll ACE-FEDERAL REPORTERS, INC.
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5940 02 02 126 rysimons 1 take a OA Cat 1 system, our ECCS. It has pumps and -
2 valves. Let's take another example, a shutdown cooling 3 system. The shutdown cooling system on Unit 1 is not an They use l 4 ECCS system, but it's like'an auxiliary system. '
i 5 it for refueling and they both have pumps.
6 Is the reliability of the ECCS pumps different l 7 than the shutdown cooling pumps? No, they aren't. As a 8 matter of fact, the shutdown cooling pumps themselves 9 happen to run better because they get run quite often.
10 Those are pumps that, you know, they have a bigger. duty 11 cycle.
12 CHAIRMAN WARD: It sounds like you might be O 13 better off to just'let the OA inspectors, you know ---
14 MR. BICKEL: Well, let me explain what we are 15 doing here.
16 (Laughter.)
l 17 You can recognize the fact that if we turn in a l l
18 PRA that says that a particular sytsem is hot, in other i 19 wordsd, that this is a very important system, we are also 20 aware of course of the fact that the regional inspectors ;
21 are now beginning to use PRA to help focus their 1
22 activities. They do the same type of compliance' checks.
23 I think we would be in a very bad light to have 1
24 done a PRA study and to have_obtained insights that certain i O 25 systems were critical to the to the safety of the plant and 1
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5940 02 02 127 l
O-rysimons1 we had a OA program that was running around looking for the 2 color we painted switches in a really non-critical area and )
l I
3 they were looling at, hey, this thing-here does not have 4 all the signoffs yet. So we are going to reject it. J 5 What we are saying is if it's important, it ought 6 to be important at all levels.
7 MR. SIESS: Well, what does the QA program look 8 at'once it has identified an important system? Do they q 9 look at that system to see how reliable it is, or do they 10 simply look at that system to see whether you've got the 11 paper that says you did the things you said you were going i
12 to do?
O 13 MR. BICKEL: There are a lot of things that go
)
t 14 into the things they_would inspect. One of the types of 15 things is the discipline of evaluations and were the codes 16 followed. In other words, if a particular system is 17 critical to safety, has it been thoroughly analyzed and 18 have all the steps been done, have you got the safety 19 analysis and have you got the safety evaluations, you know, 20 the compliance with all the things.
l 21 We would hate to find, like I say, that a system )
1 22 important to risk had had a deficiency in it. I l
23 MR. SIESS: Well, they do find it all the time.
24 Diesel generators are certainly important to risk and they O 25 break it down every other week.b ACE-FEDERAL REPORTERS, lNC.
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\_Arysimons 1 MR. BICKEL: Well, we don't break ours down that 2 often.
3 MR. SIESS: Presumably the OA program is uniform 4 throughout the agency.
5 MR. EBERSOLE: But the Japanese experience where 6 they take their plants apart and keep them dead for three 7 or four months and then run flat out w!thout without any 8 break in continuity does illustrate that some QA and 9 discipline brings them ---
10 MR. BICKEL: They have a different operating 11 philosophy. 1 12 MR. EBERSOLE: I like to think when I get on.an
(:) 13 airplane that the pieces of machinery have been looked at 14 before they fail.
15 CHAIRMAN WARD: Well, I think what you're doing, 16 and your bullet 3 there is sensible, but it's based on a I 17 l certain faith that the sorts of things that QA inspectors 18 do has some positive impact on reliability and safety.
19 MR. BICKEL: Yes.
20 CHAIRMAN WARD: And when I asked you the question 21 what about your bigger data base and is there evidence ---
22 MR. BICKEL: It's not conclusive that it's 23 there. The reason it's being done is from our viewpoint it 24 is prudent, and we expect that we are going to be ---
25 CHAIRMAN WARD: Okay, I understand.
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5940 02 02 129 rysimons 1 MR. BICKEL: That's kind of where we are at.
I '
2 The other things is we responded in this area i
3 with this pilot erogram primarily because of a request from 4 our own quality assurance organization, and I think'this is l 5 the thing that's different. This is not something imposed 6 from outside.
7 Our Manager of Quality Assurance at the time said 8 am I sending my inspectors to look at the right things.
9 You know, there is a tendency sometimes just to be nit-10 _ pickers with a check list and shouldn't we be looking at j 11 the most important systems, and I think that is what we are j 12 really focusing on. ,
O 13 MR. EBERSOLE: How do you know the plant is j l
14 mostly valves and pumps?
15 MR. BICKEL: Pardon?
16 MR. EBERSOLE: The plant is mostly valves and 17 pumps when you look at the trouble spots.
18 MR. BICKEL: Yes.
19 MR. EBERSOLE: Are you using Movats?
20 MR. BICKEL: Yes.
21 MR. EBERSOLE: I think that was a major step 22 forward. Movats is really monitoring of on-line 23 performance and then I presume preventative maintenance to 24 intersept what would otherwise be a costly shutdown. So 25 you're doing that. Is that cost effective? I think it i
4
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l (hrysimons 1 is. It would have to be.
l 2 MR. BICKEL: Jack Quinn from Millstone Unit 1 3 could better address that. i l
4 MR. EBERSOLE: Valves are a complex thir.g.
5 MR. QUINN: We don't have a data base of 6 experience on Movats. The plant is in an outage at this i
7 time and this is the first time that we have Movats to come 8 down to look at the valves. They are looking at both of 9 Toledyne operators and the limitorque operators.-
10 MR. EBERSOLE: I've got to believe that Movats is l
11 long overdue.
12 MR. QUINN: We will have to develop a dath base 13 and experience base with this system.
14 MR. EBERSOLE: Right. J 15 MR. QUINN: We are looking at it to look at t'Ae 16 results and see what develops.
17 MR. EBERSOLE: It really is the start of kind of i
18 a root logic anyway, refined on-line monitoring and 19 preventive maintenance.
20 MR. QUINN: Hopefully it will tell us something 21 about the valves prior to ---
22 MR. EBERSOLE: Well, not merely valves, but 23 anything else, any other kind of equipment. You can extend i
24 the logic in Movats to other kinds of equipment. l O 25 MR. QUINN: We are starting out with the valve !
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1 2 MR. EBERSOLE: Well, I think that is the best 3 place to start. I l
4 MR. BICKEL: To take the bottom bullet in my 5 conclusions ---
6 CHAIRMAN WARD: Before you do that, and I know 7 we're digressing a little bit, but I want to ask you a 8 little bit more about your plant experience data base that 9 you've used, and I think you apparently have done a good !
10 job at using your actual plant experience.
11 Now we often hear that specific plants come in' 12 with a PRA or some sort of probabilistic argument and they '
() 13 say that well, for this system we are not using the nuclear 4 1
14 idustry generic failure rates, let's say, but we're using 15 our failure rates which are better, and we have better 16 experience, and that affects the conclusions you make about 17 a certain issue and so forth.
18 Now if there are some plants or units'that have 19 failure experience better than the average, o0viously there 20 have got to be some that have experience poorer than l 21 average, and I've never heard of anybody coming in and 22 saying we have corrected our PRA by using our failure 23 experience which is worse than generic. Have you in any of 24 your cases?
O 25 MR. BICKEL: Yes.
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l 5940 02 02 132 rysimons 1 CHAIRMAN WARD: Is it worse than the industry l 2 average?
3 MR. BICKEL: Yes.- As an example, in the data 4 analysis section one of the things that we've pointed out 5 and did utilize throughout it was the fact that our 6 reliability motor operated valves we find are not as. good ]
l 7 as what people call, you know, generic experience.
8 Have a living PRA program which is focusing on j 9 where we want to go in the future and using data that isn't i
10 real to what we have could in some cases end up in 11 directing us oin the wrong path. So we see no benefit in 12 playing around and picking and choosing.
O 13 What we did is we took the that data we had for 14 pumps and valves and critical large components and used all 15 of it as we had it. The type of things we found was that 16 diesels, pumps and breakers were a lot more reliable than )
17 the generic data indicated and MOVs tended to be worse, and 18 those types of things were factored into the models. i I
19 We found also that you could separate the 20 reliability of the MOVs, the ones that were in the dry well 21 versus the ones that were outside the dry well in a 22 different environment. There is a statistically 23 significant difference in the observed failure frequencies i 24 between them. Now that type of thing is directly put into O 25 the model.
i l'
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5940 02 02 133 rysimons 1 The I guess concluding bullet here, and there 2 have been questions about what are we doing about level 3 three and containment consequence analysis. We have on the 4 books within my shop plans to extend all three of the 5 remaining plants that do not yet have the containment 6 consequence evaluation up to level three over the coming 7 years.
8 Millstone 1 being a Mark 1 containment boiling 9 water reactor, we recognize would be a logical first choice 10 to begin the containment consequence modeling. Those 11 activities were initiated earlier this summer. We have 12 taken the MAPP Code and we have converted it to our system O 13 and we have constructed a Millstone Unit 1 model for that 14 and we are in the phases right now of checking that out.
15 We will be beginning the actual containment 16 simulations for core degradation and beyond early this 17 fall. So we would anticipate having the containment and 18 consequence analysis in a matter of a bunch of months.
19 It't going to take.some time and we do have competing needs 20 that we have to address, but we are pursuing this at this f 21 k time. ;
22 CHAIRMAN WARD: Does that include external ,
23 events?
I 24 MR. BICKEL: We have additional externals on our i
() 25 schedule right now as part of a fi.e-year plan, but again I
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5940 02 02 134 (brysimons1 come back to the fact that we've got four plants. Unit 2 2 right now, that PRA has been underway since Janaury. That 3 is where the bulk of our resources in our group are going.
4 That concludes my presentation.
5 MR. EBERSOLE: John, could you give me just a 6 little bit more description about this gas turbine. How 7 big is it and how quick doea it start and what is the 8 failure frequency to start and the failure frequency to 9 run?
10 MR. BICKEL: The failure frequency to start runs 11 at about four percent, and the failure to run is now in the 12 10 to the minus 3 range is my recollection with a given
() 13 demand that is about one in a thousand chances. It's 14 dominated by start / failure. The exact sizing I'm not a 15 hundred percent clear on, but its function right now it 16 that it's part of the ECCS type requirements. It's one of 17 the two emergency power systems. It has to start and I 18 believe the tech specs require at 48 seconds.
19 MR. QUINN: Yes.
20 MR. EBERSOLE: What is it, an airplane engine?
21 MR. BICKEL: It's a GE jet engine; that's I 22 correct.
23 MR. EBERSOLE: And it runs a shaft that which has I i
24 a generator on it? i 25 MR. BICKEL: That's correct.
I
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i 5940 02 02 135 rysimons 1 CHAIRMAN WARD: It's 48 seconds to full load?
2 MR. BICKEL: That's correct.
3 MR. EBERSOLE: So you find that's not a. penalty 4 against the 10-second duty on the diesels?
5 MR. BICKEL: Well, let me put it this way.
6 Having to start that gas turbine in 48 seconds is something 7 that is a reliability issue.
8 MR. EBERSOLE: How many diesels do you have?
9 MR. BICKEL: Well, Millstone Unit I has a diesel 10 and a gas turbine. Also at' that site are two other units, I 11 two PWRs. l l
12 MR. EBERSOLE: Oh, you can invoke now, and I O 13 think it's popular to say ---
14 MR. BICKEL: A possible LOCA.
15 MR. EBERSOLE: And a LOCA is not going to be 16 coincidental with an offsite power failure.
17 MR. BICKEL: That is correct.
18 MR. EBERSOLE: So your rational seems to be good 19 enough to me.
20 MR. BICKEL: There are activities ongoing right 21 now that are proposed as an example to use the new GE LOCA 22 evaluation models. One of the impacts of that would be 23 much, much lower peak clad temperatures and other things 24 and one could seek relaxation of the 48 seconds. We O 25 perceive that from investigations so far as something that i l
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5940 02 02 136 (hrysimons1 would probably be useful. i 2 My example is that say the gas turbine right now 3 starts in 49 seconds, we have to by our tech specs say 4 well, shut it down, we've got to go fix it and let's tear 5 it apart. That's the law. If would be very convenient if 6 we have an analysis that said well, we'll fix it in the 7 future, but don't declare the thing inop and start .
8 stripping it down to work on it.
9 MR. EBERSOLE: That's a terrible imposition when 10 the accuracy of that number was not justified in the first 11 place.
12 MR. BICKEL: It's very conservative, I would 13 agree.
14 CHAIRMAN WARD: On the gas turbine is the problem 15 with the 48 seconds that you have a different start-up 16 procedure or start-up mode in order to meet the 48 seconds?
17 MR. BICKEL: It's all automatic. It's a 18 completely automatic system.
19 CHAIRMAN WARD: What I'm driving at is what if I l
20 the ECCS analysis under revised Appendix K tells you that l 21 you've really got three minutes or something like that, 22 would you still run the gas turbine the same way you're 23 running it today?
24 MR. BICKEL: I really couldn't answer that right I 25 now. What I'm saying is that if you had a lot more time, ACE-FEDERAL REPORTERS, lNC. I 202 347-3700 Nationwide Coverage 800-33M646
5940 02 02 137 rysimons 1 you know, you could start to think about coming up with a 2 much more I guess I would call it a risk effective tech 3 spec statement.
4 I think from my position right now declaring it 5 inoperable and sending mechanics in there on a some kind of 6 an action to stop the window to fix it is not ---
7 CHAIRMAN WARD: So other.than the legalistic 8 angle there is a more practical engineering angle. If you 9 had more time would you have a different startup procedure, 10 mode or something?
11 MR. QUINN: The answer to the question is j 12 definitely yes.
O 13 CHAIRMAN WARD: I see.
14 MR. QUINN: It's very hard on the gas turbine to 15 come up in that amount of time. They call it a black 16 start. They sustem is all primed and ready to go, but it 17 is very harsh on the equipment to come up in that short 18 amount of time.
19 MR. EBERSOLE: Is it preheated?
20 MR. QUINN: Yes, it is.
21 MR. EBERSOLE: So it's not the temperature, but 22 it's something else.
23 MR. QUINN: Well, the lube oil system is 24 preheated, not the engine itself.
25 MR. EBERSOLE: But the blades are not.
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.5940 02 02 138 arysimons 1 MR. QUINN: No, sir.
2 MR. EBERSOLE: Is there damage to the blading?
I 3 MR. QUINN: No, we have never experienced damage 1 4 to the blading. It's taken apart during each of the i 5 outages for inspection.
6 CHAIRMAN WARD: It's obvious, but I think this is 7 important, if I understand this, that this is one place 8 where a so-called conservative regulatory requirement, 9 which is Appendix K may very well be giving you a plant 10 that is less safe.
11 MR. SIESS: John, what do you expect to gain in 12 going to a level three PRA in terms of insights, increased O 13 safety or whatever?
14 MR. BICKEL: Right now we have a couple of areas 15 that we are explicitly planning to focus on. I think we 16 mentioned earlier that we have a corporate safe goal. It f
17 goes clearly beyond prevention of core damage, which is 18 perceived by many to be a economic issue.
19 Well, obviously to get to large-scale releases 20 you've got to pass through that point somehow, but we l
21 currently have only developed insights in the area of i 1
22 preventing the accident. We believe that as a result of 23 carrying out the level three that we might be able to 24 identify areas to improve the Mark I containment response O 25 specifically at Millstone. We are of course aware of the 1
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5940 02 02 139 rysimons 1 BWR owners group activities in that area.
2 As an example, there have been suggested changes 3 which some believe would have a major impact on the risk 4 reduction on Mark I containments. As an example,.the 5 capabiltiy to have a non-electric power driven pump that 6 could put water in the dry well or maybe an existing dry-7 well spray connection during a blackout. Is that a good 8 things to do? We don't know. We would like to have the 9 level three model to look at that type of question.
10 People have suggested that certain types of 11 venting could help certain scenarios. That of course 12 raises a question that we are going to deliberately vent O 13 following some accident under the idea that to hold the 14 pressure down will prevent an event bigger release. That 15 is a very close call and we would like to have a very good 16 model available to help us make that type of a decision, 17 and would we want to make a procedure to do that.
18 MR. SIESS: Does that model have to be 19 probabilistic, or are we simply talking about a severe 20 accident scenario?
21 MR. BICKEL: As an example, you can do a PRA in 22 the level three area and you can identify issues, and again 23 the same way we go after the issues that are what I guess 24 we call a big core melt contributor. We would also go at 25 the issues that are driving maybe public exposure.
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5940 02 02 140 rysimons 1 That concludes our presentation.
2 CHAIRMAN WARD: Well, John, you seem to have )
l 3 gotten us back on schedule.
4 (Laughter.)
5 CHAIRMAN WARD: Do you have a question, Pete.
l 6 MR. DAVIS: I want to correct something I said 7 earlier before the statisticians get after me. 'I 8 (Laughter.)
9 The conversion of means to medians is explained 10 in Appendix C of the ISAR. It is indeed a factor of two, ;
I 11 but it goes the opposite way as I suggested.- To convert i 12 medians to means you multiply by a factor of 2 rather than
} 13 the other way around. So it's not the PSS number that 14 needs to be multiplied by a factor of 2, but it's the other 15 numbers which would bring them all closer together.
i 16 MR. EBERSOLE: It sounds like a universal J 17 multiplier and I thought it had to take into account j 18 individual distribution. I 19 MR. DAVIS: It does, but it's explained in 20 Appendix C as being an approximate universal multiplier.
21 It depends on what the uncertainty distributions are.
22 MR. EBERSOLE: Do you have to imagine a i 23 distribution?
24 MR. SIESS: Well, no. It depends on both the O 25 distribution and the dispersion, doesn't it?
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O 5940 02 02 141-154 marysimons 1 MR. DAVIS: I've said about all I know about it.
2 (Laughter.)
3 CHAIRMAN WARD: Okay. Let's break for lunch and 4 come back at a quarter of two.
5 (Whereupon, at 12:45 p.m., the subcommitteo 6 recessed, to reconvene at 1:45 p.m., the same day.)
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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.31594.0 i cox 155 l i
1 AFTERNOON SESSION (1:45) i
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2 MR. WARD: We will begin again. I think 3 Mr. Lederman is next.
4 MR. LEDERMAN: Thank you. Good afternoon. My )
5 name is Mitch Lederman. I am an engineer in the generation l 6 facilities licensing branch at Northeast Utilities. I would l
7 like to thank the ACRS for giving us the opportunity to come 8 down here and discuss the ISAP program at Northeast l i
9 Utilities. I am going to give you a brief discussion today l 10 on the ISAP methodology and processes that we have been 11 developing and implementing at Northeast Utilities over the ,
1 12 last several years. l
() 13 Before we get into a little bit of the details' of 14 the program, I would just like to give you an overview of the 15 objectives that Northeast Utilities hopes to get out of the 16 ISAP program. The first two bullets, namely to improve 17 safety in the most efficient manner, to responsively 18 disposition the large backlog of projects, comes out of our 19 being a public utility and having to answer to both the NRC 20 as well as to public utility commissions. We have to take a 21 critical look at the money we spend on the plant to make sure 22 we are running it in the most efficient manners.
23 Another objective we wanted to get out of the
() 24 program was to have a more effective utility /NRC interface.
25 That is, we want to look at the plant in its entirety through l
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l 31594.0 cox 156 4 1 one organization in the NRC, rather than looking at specific i O 2 issues to the various branches. As we talked about this i
I 3 morning, to take the integrated look at the issues that were 4 pending on the the plant.
i 5 Fourth bullet and fifth bullet is to support our 6 cost containment initiatives as well as to improve our i
7 resource planning. Again, fallout of the first two bullets, 8 where we are a public utility and we do have to watch our 9 costs. We do have a limited amount of resources, so we 10 wanted to come up with a program whereby we could schedule j l
11 our backfits and other engineering studies in the most 12 efficient manner.
O 13 The next to last bullet, we talk about the ALARA 14 initiatives. NU as well as NRC, desires to keep our 15 occupational exposures as well as we can believe achievable.
16 One of these ways is through the integrated assessments when 17 we plan our backfits, to see exactly how much dose we are 18 going to be giving to our workers or to support craftspeople 19 on-site during the outages.
20 The last and one of the most important aspects of 21 the ISAP program is to facilitate our integrated project j 1
22 planning as a multi-unit utility, having four plants, 23 Millstone 1, 2, 3 and the Haddam Neck plant. The final O 24 objective of this program is going to be able to project our 25 resources across the board on the four plants. l ACE. FEDERAL REPORTERS, INC.
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31594.0 cox 157 1 What I am going to touch upon briefly will be the O 2 scope of the ISAP, which Frank Boyle of the NRC mentioned 3 this morning, as well as the methodology that we have 4 developed at Northeast Utilities. Methodology consists of 5 three phases. First, the analytical ranking methodology, 1 1
6 which is the prioritization and the ranking process that we I 7 have developed and are utilizing on both Millstone Unit 1 and 8 the Haddam Neck plant. ,
9 Second is the initial prioritization screening, 10 whereby we take the results coming out of the ARM, and we j 11 evaluate those before we put those into the integrated 12 implementation process. The integrated implementation O 13 schedule process, otherwise known as the IIS, is the final l 14 phase of the program whereby we combine the results of the 15 analytical ranking methodology as well as other factors, 16 which we will discuss a little bit later, to come up with the l
17 ultimate integrated schedule for the plant's T scope of l i
I 18 ISAP. Northeast Utilities proposed to the NRC to go with the j 19 integrated assessment'as a follow-up to the SEP program.
l 20 Subsequent, we had several meetings with the NRC as well as 21 correspondence on the docket, in which we negotiated and gave 22 the NRC our ideas on what we thought should go into the 23 ISAP.
O 4 Finally, n Ju y 31, 1985, the NRC completed their 25 screening review of the open issues for Millstone 1 and the ACE FEDERAL REPORTERS, INC.
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31594.0 cox 158 1 Haddam Neck plant and sent a formal docketed letter which 2 formalized the scope for Millstone Unit 1 and Haddam Neck.
3 This scope included the NU-initiated projects and safety 4 concerns. These included both hardware modifications as well 5 as engineering studies that we were tentatively planning to 6 pursue; included the NRC-initiated projects and safety 7 concerns; again, both hardware and engineering studies; and 8 these included unresolved SEP issues, the unresolved TMI 9 action plan issues for Haddam Neck and Millstone Unit 1, as 10 well as selected generic issues and unresolved safety issues 11 which the NRC Staff thought would be amenable to resolution 12 or further evaluation on a plant specific basis. All in all, O 13 there were approximately 80 topics on Millstone Unit 1 and 80 14 topics on the Haddam Neck project which were evaluated in the 15 ISAP.
16 The analytical ranking methodology -is the process 17 whereby we prioritize and rank our projects. Each project is 18 scored by four attributes. We have public safety, personnel 19 safety, economic performance, personnel productivity. I will 20 discuss each of these very briefly in a minute or two. Just 21 want to mention that we take the results coming out of the 22 prioritization and the scoring of each of these projects 23 relative to these attributes. We then combine them; we then
() 24 integrate them into an overall score for each of the 25 projects. This overall score is then utilized in the ranking ACE FEDERAL REPORTERS, INC.
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31594.0 l cox 159 1 that we come out for our projects. We also rank them by a 1 O 2 value, the integrated value, divided by the cost for a value l
l 3 of cost or cost benefit-type of analysis, and prioritized 4 them in that manner. So we look at it in two different 5 ways.
6 The first attribute which we considered was the 7 public safety attribute, and that was composed of three 8 characteristics. The first one being the radioactiva 9 material releases from the plant; the second being the 10 hazardous or nonradioactive material release from the plant 11 that would be -- for instance, at Millstone Unit 1 there used 12 to be chlorine tanks on-site, which were used for marine O 13 biofouling control. That was judged to have a significant
]
14 risk impact. Third, which is something we would plan to use .)
I 15 in the future when we do start getting into the realm of {
l 16 shipping fuel, both on-site or off-site, would be the hazards I 17 from the transportation accidents.
18 The impact is measured utilizing the PSS results 19 which John Bickel went into detail this morning, and were 20 applicable when using engineering judgment. We didn't have a 21 specific PSS quantification for a certain modification. If ;
i 22 we didn't have that, we would use engineering judgment or 23 comparison to other engineering data for those projects.
O 24 xa wino: e vo= ao have e ra^ 9" eat 151cetio=,
25 was that sometimes adjusted with engineering judgment or do ACE FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-336-6646
31594.0 cox 160 1 you always stick to using the raw output for the PRA?
O 2 MR. LEDERMAN: If we can quantify it in the PSS by 3 running a sensitivity study. For example, the project is 4 implementing or putting a new valve in the system and they 5 can run a sensitivity study on the PSS, they will come out 6 with a change in the core melt frequency based upon the 7 implementation of that project. That is then converted to an 8 equivalent man-rem risk to the public, which is then 9 integrated in with the other attributes. There may be a 10 project where we cannot directly quantify it. That is the 11 case where we would go to the engineering judgment. Where we 12 can, we use the direct quantification.
O 13 MR. DAVIS: Excuse me, question here. How did you 14 get your radioactive material release quantification, because 15 I don't think your PSS went that far. You didn't look at 16 containment failure modes or source terms; did you?
17 MR. LEDERMAN: I will let John Bickel answer that 18 one.
19 MR. BICKEL: John Bickel, Northeast Utilities.
20 What we did, we took the Sandia siting study and took the 21 man-rem dose calculations, did some scaling to equate that 22 Millstone unit, I think, 1. We also looked at the Millstone i
23 3 PRA results, also. We kind of developed a man-rem total
() 24 that would be expected for core damage and containment 25 failure event.
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, 1 What we did then was we used that as a consistent
(/ scale so that the shift in -- the benefit of implementing a 2
3 project that reduced man-rem were all calculated on a 4 consistent basis. But at this point right now, they mainly 5 are reflecting the effects of reduction in CMF. We did not 6 have any projects that directly addressed consequence 7 mitigation, so this was an effective way of getting it done, i 8 MR. DAVIS: Thank you.
9 MR. EBERSOLE: I would like to call up -- Mr. Ward 10 mentioned a while ago about undue conservatism on the part of 11 Staff requirements, leading to reduced safety of the plants.
12 He was referring to the fast-start requirements on the O 13 diesels to reduce the releases from fuel if it was without l l
14 coolant.
1 15 With a company as strong as you presumably are, so i
16 you can take your own position in the technical context 1
17 against GE, the Staff, and have your own viewpoint, I i
18 certainly would invite you to look at the arbitrary nature of 19 this matter of letting a little radiation go to prevent a l 20 catastrophe. Of course, that has to do with what you J
21 mentioned, but, again, I take up the matter of this business 22 of -- I will just take as a case in point, the stupid design i
23 which you have of the scram system. l
() 24 Why doesn't your company logically examine the 25 roots of this logic and what you are going to find is it's l I
/\CE. FEDERAL REPORTERS, INC. j 202-347-3700 Nationwide Coverage MX)-3364 M 6 ;
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y i
l 31594.0 )
cox 162 j 1
1 based upon that same conservatism; I will not let 1 micro O 2 curry loose, even though I increase heavy risk by a factor of l
j l
3 1000. It's a logical lock up that I am surprised a company j l
4 of your stature would allow to stand. My old company, TVA, 5 didn't have enough managerial guts to do anything with it, 6 but you could.
7 Let me tell you how that is. The rationale for )
8 that system is to lock up the effluent from a primary loop l
9 and close the system before the rods start to move. In so l 10 doing -- in that sign, they have a common mode potential 11 which stands square in their face and produces the loss 12 potential. If that had kept open until the boom rods had O 13 closed home, you wouldn't have that problem. Then, on a 14 judicious basis, you could follow that and be done. Do you 15 follow me. You tell me on a pure route engineering logic 16 basis how you can so placidly and selfishly stand on the 17 basis of an irrational concepts as that and run it. Is it 18 because -- you have to tell me, you know, what forces you 19 into this curious corner?
20 MR. KACICH: I am not sure that we can produce 21 today an answer that you would find satisfactory.
22 MR. EBERSOLE: I didn't expect you to.
23 MR. KACICH: What I think we can say is that O 24 philosophically, we certainly agree that we don't want to get 25 into situations where we cut off our nose to spite our face, ACE FEDERAL REPORTERS, INC.
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31594.0 cox 163 1 if that is what we are doing. It's a question of coming up 2 with the resources and establishing a priority to address 3 something like that. The real world constraint that we all 4 live in is that there are requirements which we either have 5 to meet, absent some compelling justification such as the one 6 you are' offering, that we can put together and stand behind 7 as a right way to go.
8 MR. EBERSOLE: It's often said that the industry 9 needs more guts, more independence and more personal 10 rationalization of what is safe and not safe. So here is a 11 chance to state your company corporate technical position.
12 MR. KACICH: If you reflect back on different O 13 things over the years, historically, we haven't been shy as a l l
14 company to do that if we felt that was the case.
15 MR. EBERSOLE: That's why I mention it here, 16 whereas I would not in other cases.
17 MR. KACICH: I think your whole philosophy is 18 understood. Let me put it that way.
19 MR. LEDERMAN: The second attribute that'we look 20 at is the personnel safety attribute. That is composed of 21 two main characteristics; the occupational radiation exposure 22 as well as the industrial safety. It should be pointed out 23 at this point that the occupational radiation exposure does
() 24 not consider the exposure during the implementation or the 25 construction of a project. That is picked up as a constraint ACE FEDERAL REPORTERS, INC.
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31594.0 cox 164 1 in the development of the IIS, the integrated schedule.
O 2 Rather, we look at the before and the after of 3 implementing a project if there is going to be an increase or 4 a decrease in the radiation exposure to the plant personnel.
5 For instance, if you move a valve from inside the dry well to 6 outside the dry well, you are going to reduce your exposure 7 from being able to do surveillances in a lower radiation 8 area. {
9 We also look at the industrial safety aspects of 10 the projects. This impact is measured by the combination of 11 quantitative and qualitative factors. We used the standard 12 $1000 per man-rem in converting the potential man-rem 13 savings. We also use industry data for cost per lost workday 14 to integrate the two into an overall value for personnel 15 safety from implementing a project.
16 MR. EBERSOLE: I just recall, you don't have a 17 design feature that I was about to mention -- As it were, 18 fair enough.
19 MR. LEDERMAN: The third attribute we look at is 20 the economic performance attribute as composed of four major 21 characteristics, which are the availability, the efficiency 22 of the plant, the electrical output, albeit if you are losing i
23 generation on the secondary -- on the balance of plant site
() 24 and the effects on core power rating, if you are going to 25 lose power on the nuclear side in the reactor core. These ACE-FEDERAL REPORTERS, INC.
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cox 165 I 1 impacts are measured by the plant specific reliability O 2 model. We have the reliability, availability, 3 maintainabilities or remodel, which is a computerized model .
4 of the plant similar to the way a PRA is conducted, where you .
5 have success paths and entries with the overall result being 6 the effect on the megawatts coming out of the plant, or on 7 the efficiency and output of the plant from specific design 8 changes. The quantitative measure that we utilize is the 9 equivalent unavailability or the gain in plant output for --
10 in megawatt hours or megawatt days, depending upon the 11 magnitude of the project.
12 The last attribute that we consider is the effect O 13 on personnel productivity. Specifically, we look at the 14 effects on people, the effects'on equipment and on the work 15 environment from the proposed modifications or regulations.
16 This impact is very subjective judgment. It is supplemented 17 when there is quantitative data available, as if someone else 18 done a backfit of a similar nature and had found that there 19 was a large improvement or negative effect from that 20 backfit.
21 As I mentioned earlier, these four_ attributes are 22 integrated together to come out with the ranking. For each 23 of the projects -- we scored approximately 50 projects for
(]) 24 Millstone 1 and Haddam Neck, came out with prioritization 25 ranking, which was then submitted to the Staff.
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1 Following the development of the prioritization -l O 2 ranking, you go to the initial prioritization screening. The 3 first three bullets are really done in parallel. We have 4 what is known as the ISAP working group at Northeast j 5 Utilities, which consists of members of the various 6 disciplines including the engineering; the plant is 7 represented, reactor engineering, facilities licensing, 8 generation projects. This working group has developed the 9 ISAP program. They do the scoring with assistance from the 10 discipline representatives. Then they go through the 11 projects to make sure each of the projects are scored on a 12 consistent basis. That is, that each of the attribute scores 13 -- we are looking at the project in the same light.
14 Following that, we have what is known as the 15 discipline plant review, which is a more broad review of the 16 ranking. Again, it's a sanity check to make sure that 17 someone didn't miss a major aspect of a project, if a project 18 had been in the early stages of design. Someone might have 19 gone in one direction, whereas the other attribute, people 20 may have reviewed it in a slightly different direction. So, 21 again, it's a consistency check. They simultaneously have a 22 cost-benefit review going on where we are looking again at 23 the ARM ranking, which is the value to cost as well as Q 24 internal accounting of pay-back period reviews.
25 Finally, the results go to management for a ACE-FEDERAL REPORTERS, INC.
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l 1 management review. This review is more of an overall check O 2 that the process has been developed and is working in a I 3 manner that is consistent with the company's corporate goals, {
I 4 objectives and our mission statement. That concludes the 1 5 initial prioritization screening, which goes into the --
6 MR. WARD: Mitch, looking through now, you are not 7 going to tell us anymore about the details of this 8 methodology; is that right?
9 MR. LEDERMAN: Unless you have specific 10 questions.
11 MR. WARD: In a cost-benefit review, what sort of 12 costs do you consider?
( 13 MR. LEDERMAN: We consider the remaining cost to 1 i
14 implement the project. That could be construction, as well l
15 as engineering, as well as design. That-is used in the !
i 16 denominator, the value to cost.
17 MR. WARD: What do you use in the numerator?
18 MR. LEDERMAN: Integrated value, which is the 19 integration of the four attributes into a unique value for 20 each of the projects.
21 MR. WARD: This is based on -- for the public 22 safety attribute, you didn't tell us -- you have averted 23 health risks. How do you value those?
() 24 MR. LEDERMAN: When you run the sensitivity study 25 on the PSS, it is converted to change in core melt, that is, ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 167 1 1 management review. This review is more of an overall check
() 2 that the process has been developed and is working in a j 3 manner that is consistent with the company's corporate goals, I 4 objectives and our mission statement. That concludes the 5 initial prioritization screening, which goes into the --
6 MR. WARD: Mitch, looking through now, you are not ;
I 7 going to tell us anymore about the details of this 8 methodology; is that right? ;
I 9 MR. LEDERMAN: Unless you have specific j 10 questions.
11 MR. WARD: In a cost-benefit review, what sort of 12 costs do you consider?
O 13 MR. LEDERMAN: We consider the remaining cost to l l
14 implement the project. That could be' construction, as well j 4
)
15 as engineering, as well as design. That is used in the l l
16 denominator, the value to cost.
l 17 MR. WARD: What do you use in the numerator?
4 18 MR. LEDERMAN: Integrated value, which is the 19 integration of the four attributes into a unique value for l I
20 each of the projects.
21 MR. WARD: This is based on -- for the public l 22 safety attribute, you didn't tell us -- you have averted 23 health risks. How do you value those?
() 24 MR. LEDERMAN: When you run the sensitivity study l l
25 on the PSS, it is converted to change in core melt, that is, ACE. FEDERAL REPORTERS, INC.
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31594.0 l cox 168 1 converted into a probabilistic man-rem savings or exposure to O 2 the public. That number is then converted, using the 3 standard $1000 per man-rem -- to a dollar value, which is 4 then weighted, weighted factor, and then integrated with the 5 other three attributes into a combined total value. I 6 MR. WARD: That's the only value that the averted 7 dose of $1000 a man-rem, is the only value you put in a 8 numerator? What about other off-site costs or on-site costs 9 from an accident, that sort of thing? How do those get 10 factored in? i 11 MR. LEDERMAN: To this date, we have not 12 explicitly factored in the averted on-site costs into the 13 ISAP process.
14 MR. WARD: The loss of the unit for X years or X 15 days or something doesn't get factored in?
16 MR. LEDERMAN: It partially would get factored 17 into the economic performance in terms of the lost 18 megawatt-days, but in terms of the accident scenarios, that 19 is something we noted in our final reports for both Millstone ,
l 20 1 and Haddam Neck. As an action item that we are I 21 investigating internally is how to incorporate, if necessary i 22 or prudent, to incorporate converted on-site processes into 1 i
23 the methodology. That's currently being studied internally.
l 24 Bob, do you want to add something?
(])
25 MR. FACTORA: If I may have an answer to the ]
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1 question. When you talk about costs for a project, the cost O 2 that is the result of the analytical ranking model is a 3 value-to-cost ratio. The costs that we are talking about 4 there is the implementation cost. How much is it going to 5 cost to install it with the engineering, the craft, so 6 forth. When Mitch was talking about the cost-benefit 7 analysis or the break even point for implementing a project 8 -- if you don't do a project, how much is it going to cost 9 you for maintenance of a particular item; if you have an 10 increase, say, radiological burial involved with some resin 11 contamination of things you have to pay for off-site burial.
12 The ALARA costs are factored in also.
O 13 We have a financial model in the company which 14 factors in maintenance costs, the operation cost, the cost of 15 replacement power and all other factors which come into what 16 we call a breakeven point.
17 MR. WARD: Is, for example, the cost replacement 18 power only on the project site or is it also on the averted 19 -- do you credit the averted costs?
20 MR. FACTORA: It's basically on the project site, 21 like for a megawatt change, or a new system that you are 22 going to install. If there's additional megawatts involved, 23 if you don't have that system, how much is it going to cost
() 24 you for not having that power available? It's all factored 25 into the breakeven point. We take that analysis, along with Ace-FEDERAL REPORTERS, INC.
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l 31594.0 cox 170 1 the analytical ranking model, and take it the next step prior 2 to factoring that project into the IIS.
3 MR. WARD: Thank you.
4 MR. LEDERMAN: The last phase of the ISAP process i
5 will be the development of the integrated implementation i 6 schedule, which is the -- in this phase, consists of the 7 evaluation of the scheduling for the potential plant 8 modifications and engineering studies.
9 We factor in many things into the development of 10 the IAS. We have listed the major ones here. We have 11 external impacts. You must consider the source of the 12 project, whether it's a requirement or an NRC regulation, O 13 whether it's something your public utility commission might 14 be wanting you to put in, INPO commitment. These are all 15 factored in. ARM rankings, major output. ALARA goals and 16 occupational exposures. How close are we to our yearly ALARA 17 goals on the plant. What are the expected doses from the 18 implementation of the project. We also have to look at our 19 capital and our expense budgets. As we mentioned earlier, we 20 have to answer not only to the NRC, but to the public utility 21 commissions who very closely scrutinize our expenditures on 22 our plants.
23 We have to consider the equipment and the material O 24 eve 11ed111tv- with aucteer coa tructioa a 1=a11a2 aow=, it 25 is not easy to acquire nuclear-grade material on a short ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 171 1 turnaround time. Sometimes you have to factor that in when O 2 you have to implement a project.
3 MR. EBERSOLE: Let me ask a question about the PUC 4 matters. You find if you want to put in a safety feature 5 which is not on the books as a rule, or a regulation by NRC, 6 that the public utilities commission will refuse to put it in 7 the rate base?
8 MR. KACICH: Richard Kacich. Historically, this 9 has not been a problem in Connecticut as a matter of 10 routine.
11 MR. EBERSOLE: Thank you.
12 MR. LEDERMAN: We were talking about personnel 13 resources. John alluded to this morning, we do have a 14 limited number of personnel. It's apparent in the PRA group 15 that we could not be conducting level 3s on all four plants 16 at one time. That stretches across engineering and 17 construction.
18 But the final two go together, which is the outage 19 duration and the regional power needs. That is something 20 that we have to look at what the regional needs are going to 21 be. For instance, this summer we are finding there will be 22 several overlapping outages, several utilities,' nuclear 23 plants. So that is another constraint in-developing the Q 24 implementation schedule.
25 The end product, which we want to come out with is ace. FEDERAL REPORTERS, }NC.
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31594.0 cox 172 1 the unit implementation schedule for each of the fewer plants 2 respectively, and then ultimately come out with an integrated 3 schedule for all four plants across the board where we are 4 applying our resources in the best manner to meet the 5 facilities run by Northeast Utilities.
6 MR. EBERSOLE: Let me ask a little bit about the 7 -- in running an investigation like this, the classical way 8 of doing it has been to say, I have, for instance, an AC 9 power problem. I treat it as a separate compartmentalized 10 issue. I work like anything to reduce the probability of 11 total station blackout. There may be a simple solution that 12 says I don't need any power anyway, but who works on that.
O 13 It hasn't been entitled yet as a solution to that particular 14 problem. It hasn't been identified. But it might be 15 infinitely cheaper and not carry with it the burden of 16 maintenance over the years, and adherence to all this 17 high-grade protective design, operation of vulnerable 18 subfeatures.
19 Of course, I am getting around to decay heat 20 removal itself, and the simple mode that is possible in the 21 boiler that is not in the PWR. I don't know what will happen 22 with the TAP-45, but surely it will have to be in contest 23 with the simple configuration of the boiler versus the PWR,
() 24 and say, aha, I have a long-term heat removal function which 25 is extremely central, but it has a price of a modest amount-ace-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-3364M6
1 31594.0 cox 173 1 of release of radiation.
(} 2 Do you all do this, are you looking at this and j l
3 attempting to save lots of money in the long run by adopting i 4 solutions to problems which are common defensive !
I 5 characteristics against a whole host of insults?
6 MR. KACICH: Richard Kacich. Again, this is a 7 little bit of a case where we had to walk before we could run 8 in terms of trying to go about doing our job, if you will.
9 We needed to deal with a rather significant number of things 10 that we absolutely had to do without any discretion. I think 11 as we move away from'the stage where we are dealing with a 12 large backlog, we now have a lot of tools in place with plant O 13 specific PRA.
14 I think we will talk a little bit more later today 15 about the fact that on your particular point, we are -- this 16 outage that is in progress now, tying in a backfeed so we can 17 utilize the emergency power sources at Millstone 2 to power 18 Millstone 1 equipment. We are adding another measure of 19 protection in that regard. We feel we will be in pretty good )
20 shape when we have to address an A-45 on a plant specific 1
21 basis.
22 MR. EBERSOLE: What you are doing is you are 23 !
killing, step by step, by reenforcing the individual
() 24 tentacles of vulnerabilities. By making them stronger, you 25 will eventually have an old structure that is so strong by ACE-FEDERAL REPORTERS, INC.
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1 the patches that you put on it that you will never get a new O' 2 one, and it makes a lot of sense. You have an in-built 3 investment which is now going to be invested. We have that 4 problem all right. The individual patching of 5 compartmentalism contributes to safety. We have a structure 6 which is extremely complex, made extremely strong by efforts 7 to make the parts atrong, until it looks like you might 8 believe in it a little bit.
9 MR. KACICH: I don't think we would dispute the 10 fact if we could turn back the clock 15 years and spend all 11 the money we spent, we would probably do it differently, for 12 sure.
13 But given that we are %here we are, the best way 14 to deal with today's environment that we know is.the program ;
15 we are describing. And John's discussion earlier about the 15 insights in a PRA that it gives us -- when the individual 17 problems that have surfaced and were very readily fixed, 18 that's exactly what we did. We don't want to invoke all this ]
19 machinery when all we have to do is change a procedure or do i
20 something relatively simple. That's what we have been 21 doing. It's an evolving process. As I say, it's the best we 22 know how to do right now. l 23 MR. LEDERMAN: That concludes my presentation.
24 Paul Blasioli will be next to discuss Northeast Utilities' 25 experience with the ISAP.
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1 MR. WARD: Thank you, Mr. Lederman. l 2 Mr. Blasioli. I I
3 MR. BLASIOLI: Thank you, Mitch. My name is Paul !
i u
4 Blasioli. I am here to summarize Northeast Utilities's j
'S experiences with ISAP today. I would like to briefly discuss 6 the program costs; which are the costs that we have incurred 7 in developing the ISAP methodology. Briefly discuss capital 8 construction costs; even though we have been actively 9 participating in ISAP, we have been expending financial 10 resources at the plants in plant improvements over the last 1
1 11 several years.
12 I am going to get into some discussion on those !
O 13 costs. Cost savings. I would like to briefly discuss what 14 we expect to save in terms of costs by implementing the ISAP I
15 methodology. The NU, NRC interface. We believe that we have j i
I 16 experienced an improved and more effective interface with the 17 NRC by virtue of our participation in TSAP.
18 Lastly, I would like to get into some general 19 technical insights that we have obtained by virtue of the PSS 20 and the ISAP methodology. j 21 Next line, please. Program costs for Millstone i
22 Unit 1. ISAP activities, $260,000.. That involves basically 23 the developmental cost for the ISAP methodology, both
() 24 in-house and external support cost. Reliability, 25 availability, maintainability model. That's essentially what ACE-FEDERAL REPORTERS, }NC.
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31594.0 cox 176 1 was used for the economic performance attribute.
O 2 MR. EBERSOLE: To have a scale understanding of 3 these costs, what is the net profit of running Millstone 1 a 4 day?
5 MR. BLASIOLI: I think I will turn that over to Ed 6 or Rick.
7 MR. KACICH: Would you repeat that, please.
8 MR. EBERSOLE: What is the net profit of running 9 Millstone 1, one day, in corporate profits? I am just trying 10 to get a scale factor on this thing. Is it that amount, 11 $260,000, two times that, four times that? Is that worth a 12 day's operation?
O 13 MR. BLASIOLI: Isn't it roughly $500,000?
14 MR. MROCZKA: That's replacement power, that's 15 not --
16 MR. EBERSOLE: Isn't that what you have to buy?
17 It would be the difference between running Millstone 1 day 18 and the purchased power, 19 MR. MROCZKA: This is Ed Mroczka. Getting down to 20 that, price of oil is low, it's much lower than it was a year 21 or so ago.
22 MR. EBERSOLE: So that's one day's operation, 23 maybe.
() 24 MR. BLASIOLI: As I was saying the reliability, 25 avellability, maintainability model was developed for that, ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 177 1 that represents $350. PRA development for Millstone 1, j O 2 $580,000. Which, as John alluded to before, it's 3 approximately 150 man-months of effort. For Haddam Neck 4 plant, ISAP activities, we were able to contain those a 5 little better than Unit 1 from lessons learned on Unit 1.
6 Costs were $150,000.
7 Again, reliability, availability, maintainability 8 model, $270,000. PRA development for Haddam Neck, $1.4 9 million. Again, represents 150 man-months of effort. We had 10 to initiate the Haddam Neck PSS at the same time we were i
11 still developing and implementing the Millstone 1 PSS. We 12 had to use some higher level of external support. That's the O 13 primary difference between the cost for the two PSSs. The 14 other major element of program cost is level of efforts of 15 engineering, plant support. That's roughly 10 percent of the i
16 overall plant cost.
17 Capital construction cost during the conduct of 1
18 ISAP. Even though we were actively participating in ISAP, as j i
19 you can tell on this slide and next slide, which is for l 20 Haddam Neck, we were still expending large amounts of 21 financial resources over the last several years. To address )
22 the point Mike Boyle brought up before, we definitely had 23 plenty to do. ISAP was not a mechanism for us to defer plant j i
() 24 modifications. As you will tell by this slide and the next 25 slide, we made significant plant modifications.
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31594.0 cox 178 1 MR. EBERSOLE: You referred to these costs as O 2 costs, but as sort of public utilities, you are agents of the 3 public, and these are passed to the public. They are not 4 costs in the contexts of corporate costs; are they?
i 5 MR. BLASIOLI; They are costs to implement to 6 various plant modifications, yes.
7 MR. EBERSOLE: They come out of the ratepayers in 8 the long run.
1 9 MR. BLASIOLI: I believe most, if not'all, I 10 MR. EBERSOLE: You are their agent?
11 MR. BLASIOLI: Yes. As a matter of fact, that's 12 an interesting point we would like to make. Since we are a O 13 public service organization, we are obviously held 14 accountable to our expenditures at the plants. We fully ,
15 intend to utilize ISAP to help us make better decisions in 16 the future to contain costs properly, but to do so at the I 17 same time without compromising plant safety. That is the l
18 real reason, j 19 MR. EBERSOLE: Does the PUC, are they involved in 20 understanding this in your efforts to do this?
21 MR. BLASIOLI: I don't know if we have actually el 22 presented this to the PUC.
23 MR. EBERSOLE: But eventually you will have to.
() 24 MR. MROCZKA: DPUC, Massachusetts, Connecticut, 25 two DPUCs that we interact with, each rate case, each ACE. FEDERAL REPORTERS, INC.
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cox 179 l 1 hearing, they become more and more involved in our
() 2 operations. Essentially, as far as cost, prudency, l
i 3 justification for cost, as to whether or not -- even though J
4 we have expended a' cost, should it be passed on to the 5 ratepayer or should it be borne by our shareholders? ,
6 MR. EBERSOLE: Do you view them as technically 7 competent?
8 MR. MROCZKA: Increasingly becoming more 9 technically competent, yes.
10 MR. WARD: At what point do you just let them take ;
11 it over?
12 MR. EBERSOLE: Or their insurance companies.
O 13 MR. BLASIOLI: I think I will continue. Again, 14 1985, refueling outage year, approximately $10 million; 1986, 15 nonoutage year, was $16 million. What happened there, about 16 $4- to $5 million was actually carryover from 1985, 17 end-of-year outage, some of the costs actually accounted for 1
1 18 in 1986.
19 1987, we are in an outage right now, we are 20 anticipating expenditures of about $44 million. Just briefly l 21 going through some of the major projects we are doing, 22 replacing the low pressure turbine rotor, process computer 23 replacement, various seismic upgrades to piping systems,
() 24 extraction steem piping replacement, interim spent fuel i
25 storage racks to allow us to have full-core off-location. )
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31594.0 cox 180 1 MR. EBERSOLE: The janitor hit with a broom a O 2 level switch on a heater, a feedwater heater, and the plant 3 tripped for that reason. We get reports of that type. Have 4 you taken steps to cage these things or taken steps that will 5 stop this stoppage of a PWR for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or longer.
6 MR. QUINN: My name is Jack Quinn. Our heater bay 7 is off limits because it's a radiological area. Basically, 8 the only people that go in are the operators. There's no 9 routine maintenance or building services in those areas. As 10 far as reactor building, the safety-related instrument racks 11 a long time ago were caged. Because of environmental l
12 concerns, they now have steel enclosures around them. That O 13 dissuades people from going in there. They need shift 14 supervisor's permission to go into that. In our history, we l 15 had somebody that hit it with a broom. That led us to cage 16 these a long time ago.
17 MR. EBERSOLE: So that's been accommodated. Thank 18 you.
19 MR. BLASIOLI: Again, briefly going over the cost 20 for the Haddam Neck plant, 1985, nonoutage, $14 million.
21 1986, which was an outage year, $32 million. Some of the 22 major plant modifications were the RCS loop temperature 23 elements for environmental qualification reasons, core
() 24 cooling instrumentation, post-TMI fix. Again, process 25 computer replacement. That was done in two phases at Haddam ACE FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Cmcrape 8(n336-6646
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31594.0 cox 181 1 Neck. We are going to continue that during this outage.
2 Again, additional seismic upgrades for piping 3 systems. The outage that will start in about a couple of 4 weeks, several weeks, at Haddam Neck. Again, we are 5 expecting to spend about $52 million; turbine rotary 6 replacements, new switch gear room which will resolve some 7 fire protection, Appendix R issues, as well as some turbine 8 missile SEP topics, RPS replacement, partial replacement, 9 long-term ECCS mods, continuation with the process computer 10 replacement and some Appendix J modifications.
11 Again, between Millstone 1 and Haddam Neck, about 12 $150 million worth of expenditures over the last couple of O 13 years, while we were still participating in ISAP.
14 Cost savings. We anticipate some cost savings 15 that are several times developmental cost of ISAP. One real 16 good example of that is a recent justification that we made 17 to the NRC using the ISAP methodology to be able to request a 18 permanent exemption from the EQ rule for motor-operated 19 valves. NRC has granted us those exemptions. That alone is 20 saving us anywhere from $1 million to $1.5 million.
2A l What we hope will happen in the future, as we get 22 better at this, as we institutionalize ISAP, is that we hope 23 more projects will be implemented at the plants based upon
() 24 the merits of the project's safety significance and less on 25 the origin of the projects, as has been the case in the ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 182 1 past.
O 2 One good example of that would be Appendix R 3 mods. I think that there are some of Appendix R mods that 4 both us and the NRC rated as fairly low in overall benefit to 5 the plant. Had ISAP been implemented a couple of years ago, 6 we may not have made some of the Appendix R modifications 7 that we did, in fact, make.
8 Next slide, please. We might get to 9 Dr. Ebersole's comment --
10 MR. EBERSOLE: If you invoke a development and 11 polishing of a system, you don't need much fire protection at 12 all, except for industrial protection.
13 MR. BLASIOLI: Just briefly discuss the NU/NRC 14 interface. As I said before, we have more effective and 15 approved interface with the NRC. Some of the items, briefly, 16 are that we think ISAP has established a framework for 17 enhanced communication between ourselves and the NRC. I 18 think we definitely get into much more detail about the 19 project. We each learn a little more about where each other 20 is coming from. I think that definitely helps. We believe 21 we are moving towards a regulatory interface where our 22 priorities and the NRC priorities are converging. I will bet 23 back to that in a second. We also think ISAP provides for a 24 forum for technical resolution of all safety issues. As we
(])
25 go through this process, we are getting better and the ACE. FEDERAL REPORTERS, INC.
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31594.0 cox 183 1 interface is improving.
2 I think the bottom line is we have taken 3 NU-initiated topics, NRC topics, USIs, the whole scope. We 4 put them through a common methodology and we both rated them 5 in terms of overall benefits. We found out that we are 6 really not that far apart. In most cases, we are very 7 consistent; I think Mike Boyle alluded to that before. A 8 good example: We had a meeting with the NRC Staff about 9 three weeks ago where we went over each and every individual 10 Millstone 1 topic, as well as Haddam Neck topics. I think 11 it's safe to say for the large majority of topics, we were in 12 general agreement on what the overall benefit of doing that O 13 particular project was. That includes our initiated topics 14 as well as NRC-required.
15 From our viewpoint, we also believe there are some 16 benefits from the NRC side in terms of the ISAP and interface 17 with us. Some of those are, again, similar to ours, but 18 consist of a methodology to address new regulatory issues. I 19 think as a new topic comes up, it would go through the ISAP i 1
20 methodology; it would get ranked. You would be able to know i
21 on a relative basis, how does it stack up to things we are ]
22 already working in. ,
23 Safety issues addressed in proper sequence.
() 24 That's self-explanatory. Enhanced communication on technical 25 issues. We would certainly envision continuation of the ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 184 1 enhanced communication, getting into details, learning more O 2 about our priorities and we would learn more of their 3 priorities.
4 Next slide.
5 Some of the technical insights that were obtained 6 through ISAP, some of these John Bickel got into before. I f I
7 am just going to go through them real briefly. Basically, we l 8 think that by developing a PSS and, in fact, going through 9 ISAP and evaluating some of the significant risk 10 contributors, not only have we identified and evaluated, and 11 we have certainly proposed appropriate modifications, some of 12 the very specific issues -- just to give you some examples, 13 Millstone Unit 1. Long-term cooling issue, I think John 14 discussed that at lengths this morning. Degraded grid 15 voltage issues. We were planning on implementing plant mods 16 in response to NRC requirement. Had we gone down the path we 17 were going, we would have increased the probability of a ,
i 18 station blackout. We discovered that through PSS, we further )
19 evaluated it in ISAP. We have since redesigned those l
20 particular modifications.
21 I think -- I believe it was Mitch who alluded to 22 the fact that we used to have liquid chlorine tank cars 23 on-site. That turned out to be the number 1 reactor ISAP 24 topic on our behalf. We have since replaced the chlorine 25 tank cars with a sodium hypochlorite system.
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31594.0 cox 185 1 Two issues that came out of the PSS and further O 2 evaluated in ISAP; loss of MCC-5 issue. That's a case where 3 we have only one motor control center. It is not redundant.
4 It does have a significant impact on the core melt 5 frequency. That was evident to the PSS. We are further 6 evaluating fixes to that. The new switch gear room I alluded 7 to before will go a long ways to help solve that problem.
8 Demineralized water storage tank, another case 9 again where we were going to make modifications; by doing an 10 evaluation through ISAP, discovered that those modifications 11 would increase the reliabil Ly of the feedwater systems.
12 Since, we have changed the plants to implement that {
() 13 modification.
14 We have PCB oil fill transformers on-site at 15 Haddam Neck. Those are being replaced this upcoming outage.
16 That turned out to be the Number 1 ranked item for the Haddam 17 Neck.
18 l Additional analyses, I believe John alluded to 19 these before as well.
20 MR. WARD: Could I ask you that, on the PCB oil, l
l 21 how did you rank that one quantitatively as far as public j 22 health risk. Was there an attempt to quantify that, or is it 23 a judgment call?
() 24 MR. BLASIOLI: I think I will leave that to John.
l 25 MR. BICKEL: John Bickel, Northeast Utilities. l ACE-FEDERAL REPORTERS, INC.
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1 The issue there that was involved in that, Dr. Ward, was the O 2 PCB oil fill transformers are located inside in the switch 3 gear room. If one were to have a severe overheating of the 4 transformer, certain temperature, you can ignite the PCB 5 oil. It will spread and disperse flaming oil throughout the 6 switch gear room, where you have essentially one switch gear 7 room. They are not two redundant rooms. You can take out 8 all the switch gear.
9 The other problems with it'is that when you have a 10 PCB fire, it's a lot different than a regular oil fire. It's 11 a little bit more difficult. You have more requirements 12 about fire fighting and all of-that, b
\- 13 The public safety-related aspects being studied in I 14 that was a potential PCB oil fire in the switch gear room, 15 putting the plant through a pretty bad event.
16 MR. EBERSOLE: That was adjacent to the control 17 room too, wasn't it?
18 MR. BICKEL: It's got some pathway between it.
i 19 They are both part of the service building. There is some l 20 footage between the two areas.
21 MR. WARD: Let me ask, John, what I was driving 22 at, with the PCB threat to the off-site population, did you 23 make any attempt to quantify that?
24 MR. BICKEL: No. The threat we were looking at
(])
25 was an internal fire source. It was the fact that it was an Act FEDERAI REPORTERS,INC.
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31594.0 cox 187 1 oil fill transformer in the switch gear room. If you were O 2 referring to the public health risk of the PCBs, that, in l
3 fact, was studied as a part of the personnel safety issue. /
4 In other words, the fact that you have PCB oil anywhere, 5 people will have to work around it. If there is a leak, you 6 have got to have people -- air packs, what have yaq, cleaning 7 it up.
8 MR. WARD: Thank you.
9 MR. BLASIOLI: 'The point I like to make with the 10 slide in general, the PSS part of ISAP allows us to resolve 11 and discover various risk contributors, and that the ISAP 12 methodology allows us to have -- to evaluate them and to O 13 prioritize them in the proper sequence, and to look to see 14 how they stack up against everything else. A new item comes 15 in, you find a problem, you have to resolve it; if you have a 16 process in the methodology, to rank it relative to everything 17 else we are working.
18 MR. EBERSOLE: Could you mention your approach to (
19 system direction studies at large. There have been a couple 20 of major shots at that. It was a design that took a shot at 21 the -- at the operational -- LERs and other matters, as a 22 source for looking at these things. Indian Point went at it 23 more f t:ndamentally. How did you satisfy yourself you had
() 24 properly dug around in a potential for system interactive 25 effects? How did you approach it, sectionalize the plant for ,
l ACE-FEDERAL REPORTERS, INC. I 202-347-3700 Nationwide Coverage 800-336 6646
I 31594.0 cox 188 1 implementation flow?
2 MR. BICKEL: What we did -- John Bickel, Northeast 3 Utilities. Jesse, what we did, we focused on the most likely 4 areas, the ones we concentrated on, key one being electrical l
5 and support system. A good system's interaction to propagate ]
6 has got to have a clear pathway to get it across multiple 7 trains of equipment.
8 MR. EBERSOLE: We just found some leaking 9 equipment off in a turbine hole someplace, where the water 10 had run down and off into the control room and down on the 11 scram channels.
12 MR. BICKEL: We look at that in the flooding l
( 13 analysis. The key area where we found system potential 14 interection on Connecticut Yankee, we didn't have to go that l
15 deep. We were looking at motor control center number 5 when 16 we did kind of a system level failure mode effects and 17 analyses; if you propagate where it can go and you 18 deenergize, I believe it was something like 23 additional ;
l 19 system failures. That's a very high number. Obviously that 20 really was something that commanded some very immediate i
21 attention.
22 We basically did the study with system level 23 FMEAs. We propagated it through, tried to see what it would )
24 do, made attempts to confirm how the plant people would
[}
25 cope. We went as far as running a simulator drill, put a ace-FEDERAL REPORTL (S, INC. )
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1 crew in the CY simulator. While they were drilling on the o
V <
i 2 EOPs, deenergized MCC-5. It helped us to confirm that we j i
3 have got to do something immec'iately hardwarewise because 4 there was too much going on. Our approach has been to 5 address electrical and support system -- related system 6 interaction, because, in fact, those are the most likely to l l
7 occur. j l
8 MR. EBERSOLE: But'you didn't go so far as to 9 break it down into cubic spaces and look at transporter 10 influence and damage to equipment?
11 MR. BICKEL: I guess not. I don't think we did it i
12 the way you are p;oposing. !
O 13 MR. BLASIOLI: Some additional insights obtained j i
14 through ISAP. We have talked a lot today about the ;
I 15 integration of issues and how we could come up with a more !
l 16 optimum resolution of issues that are related to each other.
17 We have some specific examples of things that did occur at 18 Millstone 1. That's definitely a strong suit of the ISAP 19 process that allows us to do that very nicely.
20 In the case of Millstone 1, we had several 21 containment purge and vent issues. Some of those were NRC 22 post-TMI follow up items. We looked at them collectively in 23 an integrated fashion, came up with one or two fixes that we O 24 felt would resolve all issues and did not have to implement a 25 fix for each one of the separate issues.
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31594.0 cox 190 1 MR. EBERSOLE: Did you satisfy yourself that the
.O 2 purging and vent valves would operate under the high duress 3 of vent flows?
4 MR. BLASIOLI: We did a fairly lengthy study in 5 the early '80 time frame, responding to some specific NRC 6 questions. We, in fact, did a study to show that they would 7 work in the conditions they had to work.
8 MR. EBERSOLE: They would work?
9 MR. BLASIOLI: Yes, and against the low 10 compression. The next one is the BWR vessel water level 11 instrumentation, SPDS. We had initially ranked the vessel 12 water level high because they were not able to reference O 13 flashing. We designed the SPDS to provide that information 14 to the operator so he would able to realize whether the 15 reference light is flashing.
I 16 l MR. EBERSOLE: On those higher nodes, 4, 5, 6, are 17 there any problems pertinent to ambiguity in water level 18 conditions? Well, let's get early on. Let's say you are in 19 a hurry to get a bad stick of fuel out. You trip off the 20 plant, you run as fast as you can to get the lid off, which i
21 means you have got to take the water down. As you get down 22 to the parting surface, you lose all AC power. You don't 23 have a condenser anymore, low level of power. You haven't
() 24 got a lot of water. You can get water, maybe, by manual 25 valve action, storage pools, et cetera. l l
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i 31594.0 l cox 191 1 Have you looked at the emergency conditions, O, l 2 including level control, and available reservoirs of cooling, i 3 when you don't have any electrical power under those l 4 operating modes? It's a coming-up issue precipitated by the 5 finding that the water level had to be reduced so low at 6 Diablo Canyon that there wasn't much overhead to cope with I
7 boil off. In a matter of a few hours, they would be dry.
8 MR. BLASIOLI: What I am familiar with only is the 9 issue of proposed LOCA, proposed steamline break environment l
10 causing some reference-like flashing issues. Other than j l
11 that, I not aware of any problem.
l 12 MR. EBERSOLE: Especially with BWR, look at what O 13 you can do in the higher modes where you regulated the thing l
J 14 off the RHR, which wasn't safety grade. Now it's performing 15 the only heat removal function there is. It's interesting.
16 Somehow, there's been a kind of a -- I don't know, an 17 assumption, that when you get that low, and everything has 18 cooled off a little bit, there's no problem, but there is.
19 At least -- somebody correct me if I am wrong, I 20 heard they were finding a substantial contribution to core 21 melt in the presence of the higher levels of operational 22 modes. What was it, 10 percent? Looking at Diablo Canyon, l
23 if you want to look at a specific plant; it's under the gun.
O 24 In those conditions, I might add they find 25 everybody is using make-shift level of tubing, whatever, new ACE-FEDERAL REPonTEns. INC.
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l l 31594.0 i cox 192 1 tubes, whatever. They don't have any formalized approach.to lO 2 maintaining level cover.
4 3 MR. KACICH: This is Richard Kacich. From what I 4 understand of what is to come as a result of the Diablo -l 5 Canyon thing, I have a feeling we will be looking at that in 6- a bulletin. One theme, although not your case in point 7 specifically, concerns the work that we did following the 8 cavity seal problem at Connecticut Yankee that did result in 9 a bulletin, 8503. I can.tell you, our company in particular 10 played very close attention to expanding the pressure 11 boundary to encompass the refueling area. That resulted in 12 some improvements at all of our units.
O 13 MR. EBERSOLE: Apparently there's been a feeling 14 which was largely expressed in the beginning; once you trip 15 the reactor, everything is okay. But that's really when life 16 begins. It extended on down in saying the entire mode of 17 operation is no big deal.
18 MR. WARD: Does your PRA even address modes other 19 than 1 and 2, I guess?
20 MR. EBERSOLE: No it does not.
21 MR. KACICH: No, does not.
22 MR. BLASIOLI: Lastly, the item I would like to 23 briefly discuss the tornado missile issue, which is SEP O 24 togic, e etter or rect- rnet's the ce e where we aia not 25 have -- do not have a missile of protected makeup water ACE-FEDERAL REPORTERS, INC.
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a
} 31594.0 l CoX 193 I 1 supply to condenser system. Again, initially ranked fairly ;
f l t 2 high in the rankings, that did not take any credit for 1 l
3 electrical back feed connection between Millstone 2 and {
l 4 Millstone 1, which we are putting in this outage right now, 5 for Appendix R fire protection reasons. When we go back and 6 evaluate the tornado missile issue, given that we have the 7 backfit issue, we are reducing the backfit on tornado 8 missile.
I 9 MR. EBERSOLE: How did you come out when you look 10 at the loss of direct current on which all AC distribution is 11 dependent. Did you find any vulnerabilities in the direct 12 current networks?
O 13 MR. BLASIOLI: The answer is no.
i 14 MR. EBERSOLE: What of a better capacity, prolong 15 loss of power -- well, let me ask you -- by the way, it just 16 occurred to me, we were shocked to find out, at least I was, 17 a few weeks ago, that there was no blanket response from 18 anybody. I can ask you the question against that 19 background.
20 If I suffer a total AC power outage, a blackout, i i
1 21 what is the first thing that is going to irreversibly fail i I
22 that will lead to core melt. How long will it take to fail.
23 You know you plant that well. I don't know what it could
() 24 be. It could be over temperature on solid states. It might 25 be -- you find it first. Just take the parameter of no ACE-FEDERAL REPORTERS, INC.
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31594.0 f cox 194 1 electric power and a rise in ambient temperature due to heat
)
l i]' 2 leakage in the dry well, wherever. You are not going to do l i
1 3 anything except by steam transport. What fails first that 4 you can't fix that will subsequently be needed to prevent-5 core melt. It won't be the core itself. It will be l l
6 something that supports the core cooling function. It has a l 7 high, shorter response time than the core proper. What is I 1
5 8 it; do you follow me?
l 9 MR. BICKEL: Yes, John Bickel, Northeast 10 Utilities. I guess as a response to an internal request from i
11 our units, had carried out -- I think we should call them -- l 12 have you done coping studies for station blackouts. The
() 13 answer is yes, i
14 Millstone Unit 1, if you have a station blackout 15 and.if you have bottled up the steam system, the isolation 16 condenser works, there is no cope forever.
17 MR. EBERSOLE: Which puts water into the secondary !
i 18 isolation condenser.
19 MR. BICKEL: You can fill it in several ways, 20 primary is through water connection system.
21 MR. EBERSOLE: Diesel driven?
22 MR. BICKEL: As a matter of fact, it is. The fire 23 system would depend on a diesel driven -- very, very small
{} 24 diesel pump that is tested the statistics and reliability of 25 that, we are analyzing the PRA.
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31594.0 cox 195 1 MR. EBERSOLE: In a blackout you are going through C:) 1 2 a transient. There is a coincident probability of a stuck l 3 valve.
4 MR. BICKEL: If you go through the change. Like I 5 am trying to say, if you just ask the question, if I take 6 another failure, yes. If you have a chanca like 1 la 100 or 7 something that a relief valve sticks in cycles and n <n stays 8 open, that's -- yes, you have some probabilities that the 9 coping time is less. Under that scenario, I believe my 10 recollection was, if it occurs very early on in the event --
11 in other words, if it depends on when it sticks, you are 12 going to boil off the inventory top of the core. That's 0 13 going to bring it down to about 25 minutes. Other scenarios 14 that could limit you: If you totally lost the capability of 15 restoring makeup to the isolation condenser. That means your 16 coping time is roughly about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 15 minutes, to boil dry 17 j the inventory there. Then you will cycle something over 25 18 minutes.
19 MR. EBERSOLE: I am pleased to hear you have a 1
20 coping time. I didn't think anybody had a coping time nor 21 did our NRC --
22 MR. BICKEL: It was done basically as a request 23 from -- our plant people were curious. They wanted to know
() 24 for training reasons.
25 MR. EBERSOLE: Good for them. Coping time.
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31594.0 cox 196 1 MR. BLASIOLI: As a matter of fact, that concludes 2 my presentation. Thanks, John. With that, I think John 3 Bickel is next on the agenda.
4 MR. WARD: John, a quick question before you 5 start. What fraction of your total technical effort on PRA 6 is conducted by in-house personnel, what fraction by 7 contract?
8 MR. BICKEL: We currently have no out-of-house 9 personnel working for us. A period of about three years ago, 10 at that time, I had a staffing of 10 people. We coald not 11 simultaneously do Millstone 1 PRA, Millstone 1 ISAP, 12 simultaneously, to complete the development of the PRA. We O 13 had four temporary engineers which we brought in for a period 14 of a year and a half, very expensive.
15 Right now,,all PRA activities except for things 4 16 that we participated in as part of the owners's group are 17 done by my staff.
18 MR. DAVIS: How large is your staff now, John?
19 MR. BICKEL: My staff now is 14. I would like to 20 begin my opening. I have been asked to give some discussion ;
21 about the probabilistic risk assessment activities, or PRA 22 program in general. This covers not only Millstone 1, but i
23 all the units that were responsible for providing support l O 4 - !
25 What I am going to discuss are the program ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage H(Kb3364M6 j
31594.0 cox 197 1 objectives, how we got into it, developed to where we are O 2 today. Where we utilized PRA on a day-to-day basis at NU, 3 how it factors in with our workings, with our licensing 4 organization. Some of the significant findings we have had 5 recently. What our planned future activities are.
6 The overall objectives of our PRA program was 7 directed at improving safety i:. the most efficient, cost 8 effective manner. We are doing this primarily because we 9 recognize the fact that we are accountable for prudent 10 decisionmaking. It is one thing to be able to say we can 11 solve everything in the world by throwing enough money at it, 12 hiring gobs and gobs of people and carrying out a lot of O 13 programs. However, if we were to do that, we would 14 undoubtedly reach some point where our utility commission 15 would be very upset, wpuld be calling us in on the carpet; is 16 it really prudent to do this type of thing.
17 The thing is we look at the fact we have to make 18 decisions, we are accountable for those decisions. In some 19 cases, we are having to make those decisions with a very 20 limited failure data base. He clearly recognize we don't 21 know everything. We have to make extrapolations, in some 22 cases, with limited information. Our position is that PRA 23 provides us a very effective tool to learn frcm the limited
() 24 experience from both our units and similar units, make a 25 rational extrapolation of where we should be going and the ACE FEDERAL REPORTERS, INC.
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31594.0 cox 198 1 types of problems we should be addressing. 1 2 As an example, we very clearly have had, with many 3 other utilities, the situation of having to cope with many, 4 many generic backfits, some of which had plant specific 5 detrimental factors that were not fully recognized. When 6 they come down the pike, we have to respond. PRA, we have 1
7 found to be an effective way to develop a dialogue with the 8 regulatory Staff in explaining in some cases why we have got 9 some legitimate concerns about the nature of some of the.
10 backfits.
11 Another area we have had to cope with, I think, 12 has been alluded to ceveral times, is the fact that we O 13 clearly have limited manpower to carry out the projects. We 14 have limited time available to get the work done, and we 15 clearly have limitations on money. Yet we still have to run 16 the plant safely and generate electricity for our customers.
17 Another area, which I think is very important, is 18 the overall issue of management control. If one expands the 19 work scope to do everything, you can get to a point to where 20 you begin to lose control for your work for us. Obviously we 21 do not want to see that type of thing happen. That goes as i
22 far as managing the outages, all the craft people on the 23 site, avoiding too many people in rad area, overexposures, O 24 that type of thing. We initiated the PRA program. The iden 25 was better decisionmaking, better control for our resources.
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3 31594.0 cox 199 1 This, chronologically, I don't probably --
0 2 probably shouldn't go through all of it, shows the 3 development of how PRA came to be where it is at NU. I would 4 say some of the key highlights were, I think -- probably the 5 one incident that probably brought PRA to Northeast Utilities 6 was the occurrence of Hurricane Belle.
7 We had a hurricane pass over our site and cause a 8 loss of on-site power due to salt spray in the switchyard, 9 also churned up the waters in Long Island Sound. There were 10 some observed problems in keeping the diesels running.
11 We basically asked ourselves the classic PRA 12 question, what if things had gotten worse. As a result of 13 that, it led to an in-house decision to carry out decay heat 14 removal study on Millstone 1. It was the first PRA activity 15 that our company had ever undertaken. Limited study, looked i
16 primarily at decay heat removal systems and focused heavily i 17 on loss of power scenarics. This was carried out in 1977; 18 '78 it was completed.
19 MR. EBERSOLE: John, you mentioned the diesels 20 were influenced by the hurricane. That suggests to me 21 something that I have thought about. These plants that are 22 on the coast that own diesels and are facing hurricane winds, j l
23 they are going to face a salt spray problem that will invade I 24 the air take ups. Do you sweep through the diesel rooms?
({}
25 MR. BICKEL: No. The problem that we experienced ACE FEDERAL REPORTERS, INC.
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1 31594.0 cox 200 1 had to do with the fact that the storm, as it had progressed 2 for a number of hours, kind of churned up the seaweed, 3 kelp -- !
4 MR. EBERSOLE: Plugged it up?
5 MR. BICKEL: Didn't completely plug it up but they j 6 were getting a hefty delta P across the strainers. It was 7 something to keep watching.
8 MR. EBERSOLE: Each thing you bring up like that 9 has a generic color to it.
I 10 MR. BICKEL: Yes.
i 11 MR. EBERSOLE: Are you satisfied with the problem 12 of rust, corrosion, moisture, whatever, oysters, clams.
O 13 MR. BICKEL: Biologics?
14 MR. EBERSOLE: Yea, whatever gradually lays it 15 down in pipes. Then sudden injection of chlorine, earthquake 16 shake-up, uncontrollably plugs up the fine structure fueling 17 systems.
18 MR. BICKEL: Could I refer that to inother person 19 from engineering?
20 MR. EBERSOLE: Not a slow problem, it's the i
21 impending disaster when you can shake all that stuff loose at 22 once.
23 MR. QUINN: We have a problem with continuous O 24 ch1 r1=etio= or the vete - no- it'e u 1#9 oasu-i 25 hypochlorite. We found there's a definite trend in the life l l
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1 cycle of biofouling. When there is a definite need to O 2 increase the concentrations of sodium hypochlorite and to I
3 keep that under control. What we found is there are two or j 4 three seasons during the year where we have a heavy influx.
5 We wind up cleaning the heat exchanges fairlysoften. We do 6 have a good handle on the problem, and routinely have a t
7 system of continuous chlorination so that tends to keep that 8 problem to a minimum, where you get a large release all of a 9 sudden. I think we are on top of that problem.
10 MR. EBERSOLE: Duke plant have had a problem with 11 suction uptake. Sedimentation, besides being a gradual 12 process, might'be a sudden onslaught of heavy sedimentation 1 0 13 fallout from big storms, seismic events. You are in trouble 14 and you don't have any water. Do you have any problem like 15 l that?
1 16 MR. BICKEL: One of the side advantages of 17 Millstone 1 is we do have a diversity in the power sources. ,
l 18 We are working pretty heavily right now to try to exploit j 39 that. As an example, the gas turbine on Unit 1 has no sea 20 water.
21 MR. EBERSOLE: What about cooling water, per se, 22 for other cooling purposes?
23 MR. QUINN: Excuse me, John, maybe if I can add
() 24 one more thing, Jack Quinn. We do have a routine process 25 where we send divers into the intake structure, and last ACE-FEDERAL . REPORTERS, INC.
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31594.0 cox 202 1 outage, when they do that, they look for debris build up in
'O 2 the base themselves and in the intake of the base.
3 Typically, for example, last outage, we did some dredging 4 work out in front of our intake structure and took out a 5 sizable amount of debris buildup that was considered 6 unacceptable.
7 MR. EBERSOLE: Is it possible for an earthquake to 8 send in debris at a rate you can't cope with?
9 MR. QUINN: If there is wind in the right
-10 direction on the bay, the debris in the bay can come and 11 cause a problem with the screens in front of the intake 12 structure. Long ago we made modifications to our traveling O 13 screen system to add an -- after, I believe it was Hurricane 14 Belle; fast speed through the screens to help them remove the 15 debris.
16 MR. EBERSOLE: Your convincing flow is taken as 17 well as the shutdown heat?
18 MR. QUINN: Yes.
19 MR. EBERSOLE: Larger flow -- I mean the fact that 20 you use it for the large flow for convincing protects your 21 vulnerability?
22 MR. QUINN: Yes, sir. We are taking off the bay, 23 basically Long Island Sound.
() 24 MR. EBERSOLE: Thank you.
25 MR. BICKEL: I will get back on track here. Decay ACE FEDERAL REPORTERS, INC.
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31594.0 cox 203 1 heat removal study made a number of recommendations that we 2 were actively ready to pursue. We initiated projects. I 3 think one of the problems that occurred with everybody was i
4 the Three Mile Island accident, which brought about a fairly 5 extensive laundry list of projects that were felt by many. i 6 that should be implemented to make the power plants in 7 general safer. We clearly got into a situation where we had 8 insights of a plant specific nature which we desired to 9 implement, which came up in direct competition with changes i i
10 which were, in fact, mandated by our regulators. We got into 11 a clear point where we had competition for limited 12 resources.
O 13 1981, PRA task force was formed by a management 14 personnel at Northeast Utilities to basically review the !
15 situation and make a recommendation of what should be done in 16 the area of PRA, where it was going, and what should the 17 company do about it. They recommended at that time that they 18 create a PRA organization within Northeast Utilities as part i I
19 of the safety analysis branch, staff it up. Its mission was 20 going to be to provide PRA-related support to all four of the 21 units. They were initially going to go out and develop the 22 PRA models in-house, and do them in the order based on the 23 age of the units. That would have resulted in Connecticut
() 24 Yankee first, followed by Millstone 1, 2 and then Millstone 3 l
25 in the latter part of the 1980s as we accumulated some 1
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31594.0 cox 204 1 limited amount of experience from the plant.
O 2 In 1981, later, though, we received, I guess Rick 3 Kacich referred to it this morning, an offer that was too 4 good to refuse. We needed to submit a PRA on Millstone 3 to 5 facilitate the operating license and FSAR views. This was l
6 done in August of '83. This particular PRA was called for at 7 a time far earlier than, I guess, our development of our 8 organization would have allowed us to do the whole thing on 9 our own.
10 Because of that, we contracted out with the 11 Westinghouse Electric Corporation to have the study done by 12 them with close fouling and participation by our staff in the O 13 study so that we could take over the study; its upkeep and 14 maintenance from the job was done. This, in fact, occurred.
15 Then the items which led to Millstone 1 done first i
16 was the recognition that we could get that into an ISAP 17 program. This is a -- jibing with the sriod that the ISAP 18 program was developing with the Staff. !
i 19 So the overall PRA program began to mesh very well !
l i
20 with the ideas of setting up an overall ISAP program. So we '
21 now proceeded then with additionally adding in Connecticut .
1 22 Yankee and then work on Millstone 2. l 23 Where we stand today, you can see in '86 and '87,
() 24 we completed the internal events on Unit 1 and CY; we have 25 completed fire PRAs, flooding PRA. This past January we ACE FEDERAL REPORTERS, INC.
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1 initiated the level 1 PRA work on Millstone unit 2, which is i 2 the last of the four plants we have to be analyzed. j 3 Additionally, later on in the summer, early fall, we'll be l 4 formally beginning the work of level 3 activities from l
5 Millstone Unit 1 plant.
6 We will talk a minute here about utilization of 7 PRA at Northeast Utilities. First of all, PRA is utilized in 8 a number of cases in the review and evaluation of plant 9 design change requests. Sometimes, on an informal basis, 10 when an engineer wants a quick reading about is this a good 11 way to do this, are we missing the picture, is there a better I 12 way, we will get involved in that area.
13 MR. EBERSOLE: John, let me ask you something, as 14 a PRA expert, does that mean he is a system interaction 15 expert; am I correct?
16 MR. BICKEL: Systems engineer, yes.
17 MR. EBERSOLE: Does_that mean he goes down in the 18 plant, he has a three-dimensional, real life perspective view 19 of a special and functional relationship of all of the guts 20 of the plant? That's a large order. l 21 MR. BICKEL: Obviously, people like that are 22 always hard to find. What we tend to do, our studies, when l i
23 they are done, are they actively -- you need certain l 24 disciplines to carry out the study. I think the majority of
({}
25 the people that do the work are reliability-type engineers ACE FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-3364(>46 l
31594.0 cox 206 1 with some grounding in nuclear safety. Some of them have ,
2 come from the classical safety analysis disciplines.
3 MR. EBERSOLE: Do they understand that the toilet 4 bowl over the scram channels is not a nice configuration?
5 MR. BICKEL: Yes, I would go so far to say that, 6 yes.
7 In the course of doing these studies, it is not 8 unexpected that the systems are very actively walked down to 9 the extent allowable by the radiation in the area. In other 10 words, like as an example, the auxiliary feedwater system in 11 Connecticut Yankee, in the course of developing the model --
12 and the engineer that did the model spent a lot of time with O 13 engineers in the plant looking it over. The first thing is 14 confirming they fully understand how it works, what is on the 15 prints is correct. There is nothing that ought to be 16 considered. That's a standard part of almost any PRA done by 17 any organization.
18 The PRAs have also been used in the area of design 19 optimization, which is a little bit different. That's when 20 you have multiple designs which are impossible to address, 21 and you have certain goals you are trying to achieve.
22 Sometimes you have a design that will make the plant safer, 23 but it's impossible to maintain. Sometimes you have a design
() 24 that would be more reliable, but it involves a lot of
. 25 man-rem. We are trying to keep it running. You have got to ACE FEDERAL REPORTERS, INC.
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31594.0 cox 207 1 reconcile some of these issues. We found PRA is one of the 2 mechanisms that can be used.
3 We have utilized PRA in identifying areas where 4 maybe the tech specs need to be changed. Requirements in 5 LCOs seem to confound common sense, surveillance intervals 6 are unrealistic or are causing other effects. As an example, 7 we found that certain tests required tech specs, put the 8 plant into operation where there is a high likelihood of 9 reactor scram, put stresses on people, decay heat removal 10 systems -- could be precursor to something more serious, i
11 It's our responsibility to try to reduce that chance. l
)
12 MR. EBERSOLE: Do you separate scrams into benign O 13 scrams and nonbenign scrams?
I 1
14 MR. BICKEL: I don't follow that. 1 1
15 MR. EBERSOLE: Benign scrams could be those that 16 do not invoke the required use of safety systems, feedwater 17 runs on, you have got modulated rundown, and you don't ask 18 the pedigreed safety systems to do anything. All you have 19 done is reduce reactivity. You have gone on to a safer 20 level. l 21 MR. BICKEL: When we do our studies, we do, of 1 22 course, utilize the actual events that occurred in our 23 statistical -- in our data bases, what have you, for what l O 24 ceeeed the eveet, ~ net were the immeatete outco ee- whet vo# !
25 are referring to, is, yes, we find that -- ny recollection is >
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1 on statistics, something like 93 to 96 percent of the scrams O 2 that have occurred on Millstone 1 have resulted in feedwater 3 ' remaining on line and running back down.
4 MR. EBERSOLE: What about Haddam Neck?
~
That's 1 l
5 Westinghouse, isn't it?
6 MR. BICKEL: That's Westinghouse. Frequency of 7 losing water in Haddam Neck is even lower.
8 MR. EBERSOLE: I thought that there, on the scram, 9 they always trip main feedwater?
10 MR. BICKEL: No. That is Millstone Unit 3. )
11 MR. EBERSOLE: That's the more modern design?
12 MR. BICKEL: That's correct. That's the new O 13 improved design.
14 MR. EBERSOLE: Yes, just like the commercial 15 automobiles. That guarantees loss of main feedwater.
16 MR. BICKEL: As a matter of fact, that was one of i
17 the issues that surfaced in the Millstone 3 PRA. We were a l I
18 little bit incredulous about it, I think even the folks at i
i 19 Westinghouse, that that was a designed-in feature.
20 MR. EBERSOLE: Stuff creeps in.
21 MR. BICKEL: At present there is a procedure to i
22 immediately restore main feedwater. Right now, it requires 23 opening a cabin, jumpering the isolation switch.
() 24 MR. EBERSOLE: I agree with you.
25 MR. BICKEL: I won't argue. Amen.
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31594.0 cox 209 1 MR. EBERSOLE: Yet GE makes a rundown. Why the 2 hell can't Westinghouse do this central thing?
3 MR. BICKEL: Part of it stems from the issue of --
4 my recollection is the overcooling issue, PWRs --
5 MR. EBERSOLE: Under pressure.
6 MR. BICKEL: Yes. You can crash the pressure. If 7 you bring it down and turn on the ECCS, it's pressurized 8 thermal shock.
9 MR. EBERSOLE: Sooner or later we will learn not 10 to build submarines.
11 MR. WARD: What about Millstone 2?
12 MR. BICKEL: The feed system is designed to stay O 13 on line. It's an older -- it's different criteria.
14 MR. EBERSOLE: Older and better.
15 MR. BICKEL: If you are asking me to make sense 16 out of it, I can't. i i
l 17 MR. EBERSOLE: It's strange, really. j i
18 MR. BICKEL: Continuing on, we do utilize the PRA 19 _xtensively in 50.59 safety evaluations. This occurs by the 20 fact that the PRA section is one of the three main sections i
21 in the safety analysis branch. Safety analysis branch at l 22 Northeast Utilities has line responsibilities for the 23 approval and performance of these safety evaluations. In
() 24 certain areas where we deal with certain things like changing i
25 level of redundancy, changing components, changing one ace-FEDERAL REPORTERS, INC.
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1 component to a completely different concept, our organization 2 would be an integral party that is involved in doing that 3 much. We utilize the PRA models as they exist -- maximum 4 extent possible.
5 We have recently, at the request of the Millstone 6 3 training organization, initiated a pilot program to try to 3 7 prioritize some of the training requirements. Again, this is l 8 based on utilizing PRA insights to see if we can -- see if we 9 would consider the way they spend the training hours. We 10 have a PRA that seems to say if this and this and this are 1 l
l 11 likely, are we training our operators in that area. We 12 clearly have requirements that they must absolutely be O 13 trained on each cycle if they go through there, but there is 14 always some additional time that is available. We want to 15 make sure that PRA-related insights factored into how they 16 use that time.
17 MR. EBERSOLE: Let me ask a simple question about 18 redundancy versus adversity. We have a few people that think <
19 if you find a good way to do it, stick with it. So I take 20 issue with the nonuse of diversity just because I found the 21 best system. What is your philosophy about the need for l
22 application of diversity?
23 MR. BICKEL: I think that, first of all, we do
() 24 collect a lot of statistics that in a lot of cases we have 25 seen common cause failures. Best way to get common cause I Acn FEDERAL REPORTERS, INC.
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1 failures, repetitious use of like components. Diversity has
( Its advantages are common 1
2 advantages and disadvantages.
3 cause failure? Its disadvantage is that you have to double l
4 the training, maintenance, all the other types of things. l 5 MR. EBERSOLE: You have an inferior system.
6 MR. BICKEL: I don't think I would feel 7 comfortable in making a blanket statement that diversity is 8 good or diversity is bad. It clearly has advantages and 9 applications. I think in the area of decay heat removal 10 systems, Unit 1, diversity isn't a bad idea. You have a lot 11 of overlapping areas. You can always find something. There 12 are other areas. I wish I had two of things. Kind much a O 13 mixed bag. ,
i 14 I talked about, earlier this morning, the fact 15 that we are -- with a pilot program attempting to focus the 16 use of QA inspector's time and the things which are really 17 more sensitive engineering systems. We have additionally 18 gotten involved in the area of optimizing emergency 19 procedures based on PRA insights. By that I mean we have a 20 lot of generic EOPs that are being produced by owners's 21 groups. We have a lot of plant specific information that 22 sometimes is not really reflected in those EOPs.
23 We have done a lot of work in the last few years
() 24 in trying to customize the EOPs to reflect some of the unique 25 issues. Connecticut Yankee, we have a single motor control ace.FEDE'RAL REPORTERS. INC.
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I center. If it fails, it causes a lot of problems. We found 2 it prudent to make a few hardware changes and also change our 3 -- I guess our symptom-oriented procedures to give us a leg 4 up on it. This is typically the type of thing that comes out 5 with PRA program. )
6 MR. EBERSOLE: This business came up pretty much j l
7 in the occurrence of the Salem. At long last but )
8 anticipated, thank heavens, the breakers failed to trip 9 coincidentally, because there were pivots, grease, absence of l
10 any studies on margins of force, or anything else.
l 11 Do you now invoke the concept of margins of force 12 to overcome static, thick grease, mall maintenance, tight O 13 seals. Do you examine the machinery to see what it does with 14 margin and maintain the margin in the face of maintenance?
i 15 MR. BICKEL: Jesse, that question I couldn't 16 answer.
I 17 MR. EBERSOLE: It's there, as well as our case in )
18 point. I would like to discuss the areas where our PRA has 19 been used directly in licensing activities. One of the main l 20 areas discussed earlier was in the area of exemption 21 requests. As a result of the ISAP program, there were a i
22 couple of areas which were originally very, very -- called 23 them hot regulatory issues, which were, upon completion of a O 24 PaA-type investigation, identified to de very, very limited 25 -- their ability to improve the safety of the plants. There ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 213 1 were targeted issues that might have been important at other O 2 plants, but didn't seem to do very much for our plant.
3 Based upon this type of information from our PRAs 4 and our reviews, we utilized PRA directly in seeking 5 exemption from a number of areas. One of the ones that was 6 mentioned this morning that we had obtained permanent 7 exemption on is for a number of motor operated valves at 8 Millstone Unit 1. The thrust of those exemption requests was 9 the additional benefit, in terms of making the plant safer as 10 a result of qualifying those valves, just wasn't there. A 11 lot of cases, there were issues of, you know, closing the 12 door after the cows have all gone out.
O 13 We have utilized PRA for justifications for 14 continued operation. PRA and Connecticut Yankee identified a 15 certain region of breaks in the loop tube with a charging 16 system connected; clearly indicated a need to modify and 17 upgrade our ECCS systems. Reported as an LER. We utilized 18 PRA-based arguments to justify continued operation until the 19 time we could get permanent modifications installed at the 20 plant.
21 We have additionally, as a n3jor activity in our 22 group, have been supporting the integrated safety assessment 23 program, which this meeting is about, by the generation of
() 24 public safety risk analysis. These are the public safety 25 inputs that go into the process that Mitch described ace-FEDERAL REPORTERS, INC. ,
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} 4 2 Doing a PRA on any plant results in general on ].
3 findings about what the soft spots are, areas in which you 4 concentrate effort; Connecticut Yankee, we identified these 5 issues, I have shown here, loss of MCC-5, which I mentioned 6 earlier, is a very severe system interaction type of event l
7 which is electrical in nature.
8 MR. EBERSOLE: You know the single failure 9 criterion is a longstanding thing. How did that escape the 10 initial review?
11 MR. BICKEL: What happened in there is a very 1
12 ancient story. 'I think Rick Kacich could tell you that.
O 13 This is a licensing issue, quite frankly.
14 MR. EBERSOLE: I can see that individuals are 15 looking at separata panels on the same board. I wouldn't be 16 surprised. What i.s it.
17 MR. BICKEL: They have all the motor-operated 18 valves. Just a quick question about the design. Rick can 19 answer the licensing issue related to it. Most plants, high 20 pressure injection systems, utilize check valves to isolate 21 the redundant trains from the RCS, Connecticut Yankee was a j l
22 very, very early PWR. If I am not mistaken, it was the 23 second or third commercial PWR built in the United States. l
() 24 It utilized motor-operated valves to connect the redundant i
25 trains from the piping instead of check valves. They needed l ACE-FEDERAL REPORTERS, INC.
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1 to get a highly reliable way of getting those valves to l O 2 open. What they did was they created a motor control center, 3 which is number 5, that has the power to the redundant trains 4 of motor-operated valves. The design, the way it was )
5 designed and built, it has ABTs to hunt for any available 6 power source. So the way they comply with the deviate LOCA, !
l l
7 loss is of off-site power and maybe a failure of a diesel is j 8 that that motor control center has logic to search for the 9 best available bus.
10 Now, there is some kind of a licensing -- what do i
11 we call it, Rick? 1 1
12 MR. KACICH: Well, this configuration -- Richard l 13 Kacich, I am sorry.
14 This didn't actually escape review. I am not 15 familiar with the particulars. It was a rather significant
.6 ECCS modification early in the plant's life that affected 17 this design to some extent. In any event, this was the l I
18 configuration from day 1. It was the subject of an exemption 19 that was issued in the early '70s, I think in 1971. !
20 Maybe a little bit off the point, but maybe worth 21 mentioning anyway, is that we had no obligation to disturb 22 that exemption. Everyone knew it was a point of single 23 failure and therefore significant. Intuitively you would
() 24 appreciate that. That didn't stop us from eventually, at 25 least, getting to the point where we took a closer look at ACE-FEDERAL REPORTERS, INC. >
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31594.0 cox 216 1 it, came to more quantitative grips with its significance.
2 Then we took short-term measures to improve it, long-term 3 measures that will be finished in '89.
4 MR. EBERSOLE: PRA brought it out of the darkness 5 to where you did something with it.
6 MR. KACICH: Right. Visible, but no one knew what 7 to do about it. Still the point is very valid. Given this 8 configuration with the ECCS, if we were to add a redundant 9 motor control center, here is a case where compliance might 10 not be the best approach because you would be, in effect, 11 relying on both motor control centers instead of just one.
12 MR. EBERSOLE: I take it it had a number of power O 13 inputs?
14 MR. BICKEL: That's correct. It has two off-line 15 to one. If that one happens to be dead, it has an ABT over 16 the redundant box.
17 MR. EBERSOLE: What did that do in applying 18 thoughts to the control center until you didn't know what to 19 do with all of them?
20 MR. BICKEL: That was explicitly analyzed in the 21 PRA. It turned out that the effects of the faults was 22 nowhere near as severe as if you just deenergized that bus 23 from the start. That was your initiating event.
(]) 24 MR. EBERSOLE: You searched, then, for a source?
25 MR. BICKEL: If you go to the output of that ABT, ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 217 1 put the fault there or open it or do something to deenergize O 2 it, what happened was that, basically, we had a motor control 3 center that licensing-wise could not fail. It's the old 4 issue, uninterruptible supplies. You interrupt it and all 5 hell breaks loose.
6 MR. EBERSOLE: But traveling arc or something of 7 that sort would take it all out?
8 MR. BICKEL: Yes. That issue was identified. We 9 took some very immediate actions. I recollect that I think 10 that was probably one of the fastest turn-arounds in a 11 hardware modification that ever occurred, at least since I 12 have been at NU. I think from the period we notified O' 13 management, we actually had something being installed i
14 something like four weeks later. It was a irery fast one. )
i 15 There were changes to the EOPs, everything. It was very 16 quick. It was very clear that this was not a good thing to 17 have there and have happen. j i
18 Additional item that was identified also turned 19 o'2t to be reportable when we evaluated it, was the -- we 20 identified in the course of the PRA that the two emergency 21 diesel generators had solenoid valves that opened up to admit 22 cooling water from the service water that were, in fact, 23 dependent through a series of -- going back through
() 24 transformers, circuit boxes, what have you, trace of about 25 six sets of drawings. They also ultimately went back to ACE-FEDERAL REPORTERS, INC.
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i 31594.0 cox 218 1 MCC-5. So if you postulated a loss of off-site power with a O 2 single failure, namely of MCC-5, both diesels would start but f I
3 would fail on high lube oil, lack of coolant. We immediately j 4 corrected that one also.
1 5 MR. EBERSOLE: But you said the valves were open, 6 loss of power.
7 MR. BICKEL: No.
8 MR. EBERSOLE: They closed? l 9 MR. BICKEL: Stayed as is. You needed power to 10 make them go to the correct position. I 11 MR. EBERSOLE: Flip-flops?
12 MR. BICKEL: Yes, something like a modulating i O 13 thing.
14 MR. EBERSOLE: Weren't spring loaded or anything 15 like that?
16 MR. BICKEL: No. We found that one and 17 immediately fixed that one.
18 MR. EBERSOLE: Let me bring up something with air 19 compressors. The concept of applying power to obtain water 20 is replaceable with the concept of having water in all the 21 time and closing it off with application of power. What do 22 you use as a logic?
23 MR. BICKEL: In this particular case, the reason O 24 that the valves are closed is that these valves supply 25 cooling water to a lube oil system. Lube oil system is kept )
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. I hot so that you have your hot lube oil for your diesels.
2 Basically, they are isolated from the water too.
3 If you had them plugged open, the water would tend to drop 4 the temperature of the lube oil; you are back to the cold 5 start issue.
6 MR. EBERSOLE: If you energize them to keep them 7 closed, their opening will reflect the warning of the loss of 8 temperature system.
9 MR. BICKEL: I think when they modified it,'that's 10 what they did. They kind of reversed all of those.
11 MR. EBERSOLE: Right.
12 MR. BICKEL: We identified -- I think I mentioned 0 13 earlier, some small lead break LOCAS, in the RCS loop 2 that 14 would never have been found if the PRA had not been 15 performed. Again, we identified with the PRA what was the
. 16 best solutions to implement. These are not inexpensive 17 ones. We are talking, I think, some fairly significant 18 modifications to the ECCS.
19 MR. EBERSOLE: Why do you say loop 2?
20 MR. BICKEL: Charging line is connected with the 21 RCS, It turned out the way the plant was originally designed 22 and analyzed; loop 2, the charging connection, was where you 23 went into high pressure recirculation. In other words, you
() 24 injected -- everything would be fine.
25 If you had a particular break that was located in ACE FEDERAL REPORTERS, INC.
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31594.0 cox 220 1 loop 2 near the charging header, you could end up with a 2 situation. If you went on high pressure recirculation, 3 directly following the procedures as in the plant at the 4 time, it would end up with peak clad temperature going down 5 as you inject it. Over the long term, you drain all the 6 water out of the RCS. When we recognize this, again, this 7 was a reportable item. We took immediate action to go in 8 there and change the procedures immediately. We committed to 9 changes to the ECCS piping.
10 MR. EBERSOLE: The pumping system would take it on 11 around to the whole.
I 12 MR. BICKEL: That's correct.
O 13 MR. EBERSOLE: I'll be darned.
14 MR. BICKEL: Bear in mind, we are talking in some 15 cases, vintage plants that were designed before we had many 16 of the system's engineering tools that were available now.
17 These were plants that were designed -- these were very early 18 plants we were talking about. l 19 MR. EBERSOLE: Do your plants have orifices or 20 dams in them to keep spillage at a limited rate out of the 21 supply lines from cooling systems which are broken? Some of 1
22 them are going to be poured on the floor.
23 MR. BICKEL: Flow-restricting orifices?
1
() 24 MR. EBERSOLE: Yes.
25 MR. BICKEL: I don't know the answer. Wouldn't i
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1 surprise me. I do take it back. I do know the answer. They O 2 have some throttable flow valves that were set.
3 MR. EBERSOLE: If you look at the matter of taking )
4 given pumps and running them dead headed with no flow because 5 some little bypass valve is locked shut, you get in trouble.
I 6 On the reverse context, if you run them flat open --
7 MR. BICKEL: Water runs around in cycles.
8 MR. EBERSOLE: No, you overload the pumps and they i
9 lock out. Where have you -- have you looked at this dead f
10 head flow?
11 MR. BICKEL: The issue of the bypass and the flow, 12 the operation of the pumps, I believe, is directly evaluated, 13 like in the HPSI and charging system.
14 MR. EBERSOLE: What about charging systems which 15 would be the condition of the LOCA?
16 MR. BICKEL: I would have to look.
17 MR. EBERSOLE: Might not be a bad place to look.
18 MR. BICKEL: We mentioned earlier, the DWST issue 19 surfaced because we had look at the project, concluded it was 20 pretty risky. Decided not to do it. We have talked about 21 Unit 1. I won't spend any more time on it.
22 I think the bottom line on this, we have a living 23 PRA program, it keeps up with the plants. Every time that we 24 have done these studies, we have found areas that we
[])
25 concluded we wanted to do something to make improvements. I Ace FEDERAL REPORTERS, INC.
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31594.0 cox 222 1 think that anybody that does a PRA comes to a similar 2 conclusion.
3 MR. EBERSOLE: John, let me take up one more 4 generic topic. Have you look at what I will call control 5 systems that provide modulation system, like voltage 6 deregulators on AC or DC and the context of their going.in 7 the positive direction too far than --
8 MR. BICKEL: Midscale failures?
9 MR. EBERSOLE: No. I am talking about failures 10 which are upscale in all context. Water flow, electricity, 11 whatever. Upscale flows. I have a particular' reason for 12 mentioning this, because I used to be in the airplane O 13 business. I saw one plane, several destroyed, because the DC i
14 system had a capacity of 85 volts instead of what should have j
)
15 been 28, which, when the regulators failed, took everything.
16 MR. BICKEL: We look at it to the extent that we i 17 have knowledge about the potential. I think one of the 18 classic examples where we have seen upscale failures is on 19 Millstone Unit 1 where the -- we build a solid state atlas 20 panel.
21 After it was installed, again, trying to be good 22 guys, quickly getting it in to making requirements, there was 23 a simple turbine trip, excuse me, a loss of load or something
() 24 like that. Turbine didn't trip, it goes through the -- it 25 accelerates while it tries to run back and what have you.
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31594.0 cox 223 1 That, of course, impressed higher voltages on the end plant O 2 buses. Charging went up, DC went up. Atlas panel went out.
li l
3 What should have been a load reject that the reactor was 4 going to attempt to accommodate without scramming, turned 5 into a spurious atlas system actuation. That is an example 6 of the type of high-scale fittings.
7 MR. EBERSOLE: We had that show up in the last 8 month or so where overpressurization of piping occurred, 9 where there was a valve arrangement where a pump could do.to 10 dead end pressures beyond the stress capacity of the pipes 11 that we see, and that showed up as, I think, as late as a 12 month or so ago. This is high-end failure.
O 13 By the way, do you have any plants among these 14 four that maintain, at least hold house load, after the 15 turbine is tripped off?
16 MR. BICKEL: Yes.
17 MR. EBERSOLE: When you hold house load, do you 18 recognize you compound or could compound the effects of 19 turbine runaway to involve all of the parallel connected i 20 equipment? Do you follow me? I 21 MR. BICKEL: I think I do.
22 MR. EBERSOLE: You carry up in frequency --
23 cooling pumps will carry on up with the turbine.
O 24 xR. B1CxEt= The 9 1 ent in eueetion 1e Mi11etone 1, 25 is designed to run back. That's the only one of the three.
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. 1 MR. EBERSOLE: Old-timer?
2 MR. BICKEL: Yes.
3 MR. EBERSOLE: Is there overfrequency trip 4 cleared? Jack.
5 MR. QUINN: I think, John, that answer may have 6 been misleading. When we have a turbine tripped, you do get )
7 generator lockout. That will trip the generator. You don't 8 try to pick up house loads as the turbine is tripping.
9 MR. EBERSOLE: Is that universal company 10 requirement or are you going to try to move into holding 11 house loads on the turbines?
12 MR. QUINN: I don't think there's any kind of O 13 logic.
14 MR. EBERSOLE: You know what you will inherit if l
15 you do.
16 MR. QUINN: If you get there. I agree.
17 MR. BICKEL: Future activities. I have summarized 18 here where we are headed right now. This is as a result of I
1 19 our overall five-year plan. We intend to complete the level l 20 1 portion of the unit 2 PSS, 1988. We currently have work +
21 ongoing on the other three. Millstone 3 BRA is getting its l
22 first update since the plant has gone into operation. Unit 3 23 went into operation last May, May of 1986, first rev. to that I 24
(]) PRA will be in August. Haddam Neck will be updated. That 25 will be rev. 1, completed by December. Millstone Unit 1 will !
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31594.0 cox 225 i 1 get its second update, that one is schedule for completion 2 February of '88.
3 We are planning over the coming number of years to 4 upgrade all of the PRAs to level 3. We will be utilizing 4 5 them for the resolution of severe accident policy statement.
6 We will be having- this information available fo2. use in 7 closing it out. We are, of course, like all the other 8 utilities, awaiting the forthcoming Staff guidance.
9 Additionally, the resolution of safety goals 10 policy.
11 MR. WARD: You don't say anything explicit about 12 external events here.
O 13 MR. BICKEL: We are adding, like I say, adding the 14 externals as we are going in. Right now, where I think we 15 are standing. I think I mentioned this morning, we had done 16 some evaluation of bang for the bucks.
17 MR. WARD: This isn't even in your five-year 1
18 plan? Even at the end of that five1-year plan, you haven't 19 gotten to external events?
20 MR. BICKEL: We have added flooding and fires.' We 21 have seismic on Millstone unit 3.
22 MR. WARD: You are not planning to go any farther 23 than that in the next five years?
O 24 MR. e1cxEL: 1 wou1dn.t say we aren't planning. I 25 think what the situation is, again, it's what we have with ACE. FEDERAL REPORTERS, INC.
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31594.0 cox 226 1 the extensiveness of the commitments that we seem to have on O 2 us right now, the likelihood of getting to those does not 3 look too promising. We clearly have urgent needs in terms of 4 the operating units to support a lot of the activities we 5 have ongoing.
6 One of the things, if I could leave with you, is 7 the issue of the payback. A seismic PRA is about one of the 8 most expensive items that you could come up with. There have 9 been a lot of acuivities out there trying to streamline the 10 process, works of groups like EPRI, seismic equipment quality 11 indication, trying to find ways to address the seismic 12 problems of nuclear power plants. In general, most plants
/
13 have found there is a specific list of items that tend to 14 dominate the sei smic risk. Rather than doing a full-blown 15 fragility analysis on a large plant, tying up a large portion 16 of our Staff, lots of resources involved, and payback that 17 would probably be fairly limited, I guess our choice right 18 now seems to be getting level 1, getting the containment 1
19 analysis that we need to support severe accidents, trying to 20 go in that direction. We recognize it would be nice to do l
21 everything, but we have to make our decisions and live with !
22 them. l 23 MR. WARD: But, on the other hand, if I look at 24 the sample of six plants that are analyzed by Sandia in the
[}
25 845 program, I think it ranges from 30 to 70 percent of the
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l 31594.0 cox 227 1 risk. I think that's probably core melt, that ranges from 30 0 2 to 70 percent, is from external events.
3 MR. BICKEL: When you say " external events," are 4 you implying anyone in particular or all of them added 5 together?
6 MR. WARD: I forgot what the breakdown was. All 7 of them added together, which includes seismic. They did --
8 in that program, they did develop a short-cut seismic 9 approach. I am not qualified to have an opinion on it 10 technically, but it is something that's been done.
11 MR. KACICH: Mr. Chairman, maybe I could augment 12 John's comments a little bit. If I interpret your question
( 13 properly, I think the most visible omission from the plants 14 that we have provided already concerns the seismic area. I 15 think John was alluding to the fact that at this point in 16 time, if you consider the resources required to do that, and 17 typically the amount of uncertainty associated with those 18 analyses, you kind of get the worst of both worlds.
19 Recognition of what we have done, if you look back 20 to the SEP process. the topic 3-6 was by far the single most 21 exhaustive and intensive resource process. It resulted in 22 modifications that, when coupled with bulletins from 79.2 and 23 14, is still going on in Millstone. Costs are being measured 24 in tens of millions of dollars. At least my hope would be
[}
25 before we get too far down the road, John has described ace. FEDERAL REPORTERS, }NC.
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31594.0 cox 228 1 USAI-46 would be along this way. We have a large investment 2 in the seismic area already. So, again, in reaching a 3 judgment about what to do with PRA resources, where we are 4 right now, is influenced by some of the history we already 5 had at Millstone.
6 MR. WARD: But the SEP program, I guess A-46, are 7 really go-rounds that brought the seismic resistance up to 8 the design basis level. They don't really say, I guess --
9 they are going to contribute to the resistance of the plant 10 beyond design basis. But you don't have any quantification 11 of that or any estimate.
12 MR. KACICH: No disputing that. I won't represent O 13 myself as a seismic expert as a long shot. But I recollect 14 there was a fairly significant amount of probabilistic 15 treatment of seismic events in the course of dealing with 16 3-6, to the extent that it was the best we could all do at 17 the time, if you will, trying to see to what extent there 18 were upgrades to current criteria justified. I am not saying 19 it's a home run ball, but we haven't ignored the seismic 20 area.
21 MR. WARD: I think you don't want to be misled by 22 the proposals on the severe accident policy, where the IPEM 23 does not include an external event. I think in some circles
() 24 that's looked at as a rather serious flaw of that effort.
25 Rather than an example, I don't think it necessarily means ACE. FEDERAL REPORTERS, INC.
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y 31594.0 cox 229 1 that we are going to be going on for a long time without j
(:) 2 wanting to consider seismic or other external events.
1 1
3 MR. DAVIS: John, I think it might be worthwhile 4 to point out that for Millstone 3, which did look at external 5 events, they were not found to be significant contributors to l
6 either core melt or risk, for that matter. But I recognize J 7 there was a lot of controversy about the seismic curve as I
8 well as fragilities, but we do have that data for this site. l 9 MR. BICKEL: I think to amplify on that comment, 1
10 Pete, I agree with you. One of the areas we are looking at, 1 1
11 not only in our dealings with the Regulatory Staff, one of I 12 the key purposes of these models, quite honestly, is what we O 13 do internally. A seismic PRA, in all honesty, I would have a 14 heck of a lot of trouble in using my day-to-day work. We 15 don't always go out about making modifications that are in 16 the seismic area. You have got buried surface water piping.
17 We don't change that type of thing very often. The most 18 important thing that we need those models for in looking at 19 day-to-day type engineering decisions about changes in tech 20 specs, that type of thing. Seismic PRA, I guess my point is 21 now, that the bang for the buck is limited. We have, I 22 think, in the area of supporting needs from our plants, what 23 we perceive as very urgent areas that we would like to be 24
(]) pursuing. I think, as an example, the study of our gas j i
25 turbine on Unit 1, took time and we think it is money that is j ACE. FEDERAL REPORTERS, INC.
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1 very well spent.
O 2 I have been asked to also stand in for reliability 3 engineering organization at NU and give some highlights of 4 the objectives and the nature of the program in that area.
5 The reliability engineering activities at Northeast Utilities 6 are carried out by a separate branch, this is not the safety 7 analysis branch, there is a reliability engineering branch.
8 I am summarizing this slide. Some of the key objectives of 9 that reliability engineering organization. As noted here, 10 the first bullet, improving the reliability of plant systems, 11 components: a lot of them on the secondary side of the plant 12 and impact the generation of electricity. They provide 13 engineering and economic studies and root cause 14 investigations on request from the plant additionally provide 15 special examination and testing services. As an example, the 16 reliability engineering people coordinate leak rate, also 17 provide nuclear unit balance of plant, thermodynamic 18 performance, this is the PEPSI program and the heat balance 1
l 19 work. j 20 Some of the functions and programs carried out by 1
21 the reliability engineering branch: first of all, they have 1 1
22 an ongoing availability improvement program, also have a 23 reliability, availability and maintenance analysis. That's l
[} 24 one of the key items into the ISAP, economic performance 25 attribute. They have quantitative models that look at the I ACE. FEDERAL REPORTERS, INC.
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31594.0 cox 231 1 impact on the overall systems and units. Additionally, taken O 2 on the role of carrying out the requirements of the safety 3 system unavailability monitoring program. INPO initiative.
4 Part of it is also addressing station blackout. The 5 monitoring, essentially logging the overall unavailability of 6 systems like the emergency power units and the auxiliary 7 feedwater systems on our PWRs.
8 Reliability engineering group is also carrying out 9 programs in the area of equipment analysis. One of the key 10 areas there is vibration and monitoring of rotating pumps.
11 Taken a base line acoustical signatures. They have monitored 12 them periodically to see how they are trending.
() 13 Additionally involved in nondestructive 14 examination. They have got the personnel to do the ISI and 15 IST program supports. As an example, you have the people 16 that inspect wells, report through the liability results 17 engineering group that is involved in steam cycle 18 efficiency. They have carried out a lot of innovative 19 programs. I think one that stuck to my mind, using infrared 20 video cameras, trying to look for unnecessary heat losses and 21 piping on the secondary side of the plant of all of this is 22 related to the efficiency of the steam cycle.
23 Additionally, they are involved in performing
() 24 special tests, leak rate testing is an example of that.
25 That concludes my presentation on the PRA and ACE FEDERAL REPORTERS, INC.
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1 reliability engineering programs. I would now like to bring O 2 up Ed Mroczka, senior vice president of nuclear engineering 3 and operations for NU to conclude. l 4 MR. WARD: Thank you. Let's take a break. Let's l
5 come back at 4:00.
6 (Recess.)
7 MR. MROCZKA: Ed Mroczka, Northeast Utilities. I 8 would just like to take a few additional minutes to summarize 9 our future ISAP activities and conclusions. As a company, 10 Northeast Utilities is committed to ISAP. Our emphasis to 11 date has focused basically on our two oldest plants, 12 Connecticut Yankee, Millstone Unit 1. We plan to complete 13 the level 1 PRA from Millstone unit 2, then essentially 14 institutionalize the ISAP process in-house and apply it to 15 all four of our plants.
16 We will pick up Millstone unit 2 and 3, and I feel' 17 it's basically a prudent move to have all of our people kind 18 of use the same process for making determinations, especially 19 when we have people that do some work on one unit and then on 20 another unit and so forth. If they stick with one process, 21 and I don't know myself, as far as Northeast Utilities is 22 concerned, of any other process that really makes more sense 23 and provides a basic foundation for us to work with the NRC ]
I 24 and to come to some reasonable conclusions. We plan to 25 further develop the living PRA program, by completing the 4 ACE-FEDERAI, REPORTERS, INC.
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1 level 3 PRAs for all four units as John Bickel mentioned I C:) l 2 previously. Then, most importantly, I think, is to keep them 3 current. )
1 4 Our final objective is an integrated resource plan )
i 1
5 for all four of our nuclear units. What we are trying to do 6 here is -- our resources are not unlimited -- what we would 7 like to do is, when we have to utilize resources, to consider 8 all four plants and apply those resources to that specific 9 plant and that specific area, where we would get the most 10 return, as far as impact on safety, for those resources.
11 If we examine the objectives listed at the 1
12 beginning of the presentation, we believe we have essentially O 13 made some significant progress in achieving them with these 14 resulting benefits.
15 I think we have become more efficient utilizing 16 our limited resources to approve safety. We are integrating 17 the review of plant specific issues where, hopefully, we can l 18 take and consolidate so that one modification doesn't just 19 address one issue. But if there are other related issues, we 20 can make a modification that makes sense and resolve several 21 issues. Again, that is just prudent use of resources.
22 Our plant specific PRAs are providing specific 23 guidance for generic requirements on a plant-by-plant basis
() 24 for our four units. We believe the regulatory utility 25 interface has been made more effective with this process.
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31594.0 cox 234 1 I think ISAP provides a real logical basis to 2 resolve these types of issues; and, with time, it will 3 minimize inefficient resource management due to decisions 4 that are based on opinion, rather than on some logical 5 basis.
6 I think that is where we end up maybe not 7 effectively using resources on both sides, opinion tends to 8 dominate, und we end up having to do things where when we go 9 back and reflect and take the time to do the evaluations, we 10 find out we could have done something and made some better 11 use of those resources.
12 As far as the interface between us and the NRC, we 13 have mentioned this several times during our presentation.
14 We think that the NRC could potentially benefit from ISAP 15 implementation the following ways: in many cases, they are 16 no different than we are as a utility. Our resources are not i
17 unlimited. We are all judged for the prudent use of those 18 resources. Here we can have a consistent methodology to I
19 address regulatory issues and safety issues can be addressed 20 in proper sequence, where we can be putting the more 2 important things first, second and so forth, as far as our 22 prioritization process.
l 23 With that, and with the ISAP process, again, ]
24 communications on technical issues can be enhanced finally,
[]}
25 what it boils down is to two basic items. We plan to i
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31594.0 cox 235 1 continue and expand the integrated safety assessment program
'()' 2 to, essentially, include all four of our units. Again, I i
3 basically, I think the best process that we know of right now 1
I 4 to effectively utilize resources, and what time we are going 5 to see that, there will be additional pressures on all of us 6 to account for those resources and to insure that we do make 7 prudent judgments, we get the greatest safety impact that we 8 can from them.
9 Basically, what we are asking is that the NRC 10 continue to support the implementation of ISAP, and at this 11 point, are there any questions?
12 MR. WARD: Ed, what do you mean by the last point, O 13 " continue to support." It is my understanding that you want 14 to see the NRC credit you or permit you to use this problem 15 as a way to resolve all the issue resolutions that are on the 16 horizon, severe accident thing, A-45 loss, station blackout 17 and a whole list of generic issues?
18 MR. MROCZKA: We are on both sides, we can take 19 the issue, look at it logically. Have a common basis for 20 understanding and work together to come up, basically what we j 21 are looking for, is the prioritization. We just can't. I am j l
22 not sure if anyone else can do everything simultaneously. We 1 23 just don't have the resources to do that. We have to come up
() 24 with a system of prioritization and insuring that as we apply 25 those resources, we are getting the greatest positive i ace-FEDERAL REPORTERS, INC.
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, 1 benefit, as far as activity is concerned.
2 MR. WARD: If the NRC wraps up generic issue, 3 well, A-45, decay heat removal, with a resolution position 4 that says every operating plant has to backfit a dedicated 5 decay heat removal system, you would want to say, well, no, 6 let's look at that under the ISAP process and decide whether 7 it's really useful approach.
8 MR. MROCZKA: We can still address that issue, but 9 do it through the ISAP process, through the PRAs and so 10 forth. For us, anyways, look at each one of our four plants 11 and see what kinds of modifications actually come out and of 12 what significance those modifications would be.
(:) 13 In relationship to the other things that also have i
14 an impact on safety, just where do those items fall and in 15 what sequence, es far as priorities go?
16 MR. SIESS: I am getting confused.
17 MR. MROCZKA: Yes.
18 MR. SIESS: The ISAP program was set up as a pilot 19 for two plants. I don't have the slightest idea whether it 20 was intended that it would take the issues existing as of 21 such-and-such a date, and if they decided not to go ahead, 22 that would be the end of it. Did I hear you asking two 23 things, first that the ISAP approach, philosophy, be
() 24 continued for Haddam Neck and Millstone 1. Beyond the issues 25 that existed or were handled in this report. The other thing ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 237 1 you are asking is that the ISAP program of the NRC be O 2 extended and that as far as you are concerned, you will like 3 to have it extended to Millstone 2 and 3. You think it's a 4 good idea that if you had any other plant, you would want to 5 extend it to those; is that correct?
6 MR. MROCZKA: For Northeast Utilities, considering 7 what we have done at this point in time with our PRAs and so 8 forth, I don't know of any other better process to use.
9 MR. SIESS: Right now we don't know and you don't 10 know what the NRC's plans are. They may stop with this l 11 document and say that for new issues that come out tomorrow, 12 we go back and do it the old way. You don't know. You don't 13 know whether they will be at ISAP branch, division, or 14 whatever it is called, or not.
15 MR. MROCZKA: Right.
16 MR. SIESS: Let me follow up on something else:
17 You said you can't do everything at once. That's obvious._
18 It's equally obvious you haven't been doing everything at >
19 once. That is, you have been implementing generic issues, 20 USIs, TMI requirements, routine stuff, on some basis, 21 presumably negotiated with the Staff, and you haven't been 22 doing it all at once.
23 MR. MROCZKA: That's right.
24 MR. SIESS: Did you have an in-house, before you 25 went to the Staff, a prioritization process for that, or did ACE FEDERAL REPORTERS, INC.
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1 you just sort of play it by ear, day-by-day, and do what you O 2 could?
3 MR. MROCZKA: We tried to develop a prioritization 4 process with time. That's essentially what led us to the 5 ISAP process. But what I am basically asking, I guess, is 6 that even though we have had a process, it's extremely 7 important that we have a process that is mutually acceptable 8 by ourselves and the NRC, so that that can be the bridge of 9 logic, so that both the NRC and us, Northeast Utilities, can i 10 start from some common ground and work together. That has 11 not always been the case in the past. Even though we haven't 12 done everything simultaneously, I just think that at times, O 13 on both sides, that we have not utilized our resources 14 efficiently. f 15 MR. SIESS: In other words, if this particular j l
4 16 group, ISAP group, which was born from the SEP group, and was 17 trained, essentially, to look at risk, relative risk, and 18 look at the best way to do things rather arbitrarily, if that ,
19 group didn't exist, you could still take your PSA, go in and i 20 . argue branch by branch -- you would be arguing branch by I l
21 branch, all your project manager could do would be to refer 22 you to the technical reviewer, I guess. I don't know how 23 much authority he has got, but you could still go in and
() 24 argue branch by branch on risk, on internal priorities, but 25 you feel you wouldn't be on the same common ground you are, ACE FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 804336 4 46
31594.0 cox 239 1 where, here you have this group of people that know what you O 2 are doing, know what you have done, and they sort of stand 3 between you and the technical reviewers; is that right?
4 There are still technical reviewers out in NRR involved. But 5 you guys sort of do a translation, intermediary function. I 6 want to say referee, but -- getting back to doing everything 7 at once, or the impossibility of doing everything once, and I 6 certainly hope you wouldn't do everything at once, there is l 9 something called a "living schedule," which, as I recall, 10 involves a negotiated program for doing things.
11 Now, it doesn't have the word " integrated" in it, 12 as I stated it. I believe there's talk about an integrated 13 living schedule. But there is a provision now for doing 1
14 things in some agreed upon order -- negotiated order. Where 15 do you picture that in relation to the kind of thing you have {
l l
16 come up with here in ISAP?
17 MR. MROCZKA: I think that's essentially one step <
l 18 short of ISAP. What that does is allows you essentially to I i
19 take and utilize the resources that are available with time, ;
I 20 essentially, so that you have mutual agreement between '
21 ourselves, essentially, and the NRC as far as sequencing.
22 But I think what you lose, and the benefit that is l 23 lacking, is the assessment as to impact on safety. So that 24 not only do you have the living schedule, but what you should
(]) ;
25 be applying your resources in a shorter period of time, is on ACE FEDERAL REPORTERS, INC, i 202-347-3700 Nationwide Coverage 800-336-6646
31594.0 cox 240 1 those particular projects, where you are gaining for the n 2 resource you are putting in, the greatest increment and a 3 positive improvement on safety. But that's what' I see this 4 process allowing you, as a new issue comes up, you do a fair, 5 reasonable assessment, look at your living schedule, take 6 that new item, and be able to drop it in its proper place.
7 MR. SIESS: Not to leave something out completely, 8 because it isn't important.
9 MR. MROCZKA: If something has a lesser impact on i
10 safety, to me it seems reasonable that that item maybe could 1 11 slide out in time if it's being replaced by something that 12 has a greater impact.
O 13 MR. SIESS: You are, in effect, saying something, 14 and I don't want to disagree with it, but I think you are 15 saying that everything the Staff requires is not equally I 16 important for safety. l 17 MR. MROCZKA: Everything that we require also may i 18 not be equally important to safety unless you have some 19 system to make that judgment.
20 MR. SIESS: From your experience in the past, 21 would you say that the Staff would agree with what I just 22 said? Everything they require is not equally important to 23 safety?
24 MR. MROCZKA: I am giving you my opinion.
25 MR. SIESS: That's what I am asking for. When you ACE-FEDERAL REPORTERS, INC.
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i 1 talk to the Staff, outside of ISAP, before ISAP, or as far as 2 plants outside of ISAP, you believe that they think 3 everything they are requiring is if you talk to this man in 4 this branch, or this one in this branch, each one thinks what 5 he is doing is really important?
6 MR. MROCZKA: From his particular focal point, I 7 can't disagree with that.
8 MR. SIESS: What you get out of ISAP is somebody 9 in between that has a somewhat broader view.
10 MR. MROCZKA: A process that helps those 11 individuals appreciate what the significance of that 12 particular project has and the impact that it has on safety.
O 13 Some process where you can take opinions and put them aside, 14 and put projects aside, whatever things, and come up with 15 something that builds on logic. That's on both sides, I am 16 talking about my side as well as the NRC. I 17 MR. SIESS: We have been looking at the process of 1
18 resolving generic issues. Staff goes through a process of 19 prioritizing generic issues, in that process says some of 1
20 them are so unimportant, we will call them low and they have 21 essentially a high and medium level, but they don't make any 22 distinction of all generic issues, once they have been 1
23 prioritized, and resolved, and somebody decides your plant is I l
() 24 to implement it, nowhere in the process did anybody assign it 25 a rank.
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31594.0 cox 242 1 I guess if the Staff could do that, it would be O 2 nice. We would have a category 1 through 10 on generic 3 issues, and they would sort of automatically fit in. I am 4 just trying to idealize something in my mind. Assume it 5 wouldn't work because I expect the priority is plant 6 specific, about 99 times out of 100.
7 So, really what you are saying is if we are going 8 to not assign all items equal weight, it takes something like 9 ISAP to do it intelligently, with both NRC resources, utility 10 resources, cost to the public and so forth.
11 MR. MROCZKA: From our point of view, looking at 12 our four plants, that's the way it looks to me, yes.
13 MR. SIESS: But if every plant in the country.were 14 on ISAP, Staff would have to be reorganized again.
15 MR. WARD: Is that a problem?
16 MP. SIESS: Not to me, it isn't.
17 MR. MROCZKA: I am just looking for a logical 18 system to effectively put things in their proper perspective 19 so that we are working on the right thing at the right time, 20 basically.
21 MR. SIESS: I am convinced.
22 MR. MROCZKA: When you start looking at things 23 like taking things on a generic sense, as far as giving it a 24 pseudoranking of importance that you hope kind of catches all
(]}
25 of the plants, I am not sure how logical that approach is.
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31594.0 l cox 243 1 As far as saying here is an issue that we, Northeast O 2 Utilities, should consider as to potential impacts on our 3 plants, I think that that is a valid statement.
4 MR. SIESS: Let me raise another question --
5 MR. WARD: Let me say something, just on this 6 point. It seems to me that when a -- I guess it's a project 7 manager in the Staff, agrees with a licensee to an integrated 8 living schedule --
9 MR. SIESS: I am not sure -- do they call it 10 that?
11 MR. WARD: Yes.
12 MR. SIESS: By this, " integration" means doing O 13 everything including plant betterment items. You integrate 14 those, but not to the extent of throwing something else. Do 15 one fix, take care of three things partially. You can't 16 quite do what ISAP is doing in that sense.
17 MR. WARD: That's it.
18 MR. SIESS: You may not have a PRA to base it on.
19 MR. WARD: That's --
20 MR. SIESS: If somebody said it puts them in 21 different boxes, but it doesn't take anything out.
22 MR. WARD: But it agrees that some agreement 23 between the licensee and the Staff on the prioritization, but
() 24 in doing that, the Staff, I guess, has to have something in 25 mind about -- has to make some judgments or form some ACE-FEDERAL REPORTERS, INC.
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L 31594.0 cox 244 1 opinions, I guess, on priorities, presumably based on safety O 2 importance. I don't know what else. !
3 MR. SIESS: There has to be something wrong with 4 the integrated living schedule because nobody wants to do 5 it. How many plants --
6 MR. WANG: Staff wants a' formal commitment.
7 MR. SIESS: That's what I suspected. They don't 8 like the idea of having that. Why is something as simple as 9 that that would require a formal license requirement and ISAP 10 doesn't?
11 MR. BOYLE: We will require a formal licensing 12 amendment. Every time you add or subtract an item, you have
\- 13 to change your license, or to put the methodology for 14 maintaining and updating a license in the schedule or 15 documenting where that methodology could be found.
16 MR. SIESS: What is the advantage, and you can 17 choose where you applied, the advantage to you, advantage to 18 the licensee, advantage to the public health and safety, of 19 making it a formal license?
20 MR. BOYLE: The way I perceive it, at least 21 documenting methodology for ISAP process, each plant that 22 goes through ISAP may be a different utility. Each plant may 23 come up with a different methodology for prioritizing. It's 24 advantageous to go to Staff and licensee and have it formally
({}
25 documented somewhere so neither party can renege.
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1 MR. SIESS: Licensing amendment is a formality. 1 O 2 MR. BOYLE: It may state it's the methodology for i 3 the schedule.
4 MR. SIESS: Does this bother you?
5 MR. KACICH: I would say we shared some of the j 6 reservations Alan expressed about formalizing this to the 7 extent where we could be scrutinized more thoroughly than we 8 have about our own decisionmaking. There's tradeoffs and 9 leaps of faith that I think we would be inclined to be ready 10 to make at this point. As Mike described, we think that we 11 can structure an amendment in cooperation with the Staff that 12 would benefit both in terms of documenting the methodology O 13 that we would use. It would be some protection for both of 14 us, if you will, if you would not have to issue subsequent 15 license amendments that often, because methodology would not 16 be expected to change that often, then we could submit it to 17 the Staff and if they had any problems, so be it. j 18 MR. SIESS: It would be a descriptive list of what j I
19 you were going to do in what order and when --
20 MR. KACICH: I don't think we would sign up for 21 such an amendment.
22 MR. BOYLE: I don't think we would either.
23 MR. SIESS: Now may I go on to something else, O 24 oave?
25 MR. WARD: Yes.
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l 31594.0 cox 246 1 MR. SIESS: In the list of items by priorities, 2 4.1 and the one you had on the screen earlier, there are-3 particular groups of items that simply stand out, this batch 4 here, bottom of highs and bottom of mediums, doesn't have any 5 Northeast ratings on it. They all refer to section 4.1, 2.1, 6 something and something, which aren't in there.
7 MR. BOYLE: Let me explain --
8 MR. SIESS: That's just an introduction. Could 9 the Staff discuss just a little bit what you intend by 10 section 3.4 of the ISAR which talks about additional areas of 11 integration, which I believe are these areas, although I 12 can't get 1 to 1. It isn't clear whether these are things O 13 that were added by the Staff'in this report or whether they 14 are things that have been discussed and agreed to or what 15 they are. They are additional areas for consideration in the 16 PSA, as I can tell.
17 MR. BOYLE: Initial format of the ISAP was to take 18 a look at not only the licensee's initiatives, NRC 19 requirements, but pending requirements. Many of these are 20 pending requirements such as station blackout or severe 21 accidents, BWR, MARK-I containments.
22 We were only going to include those pending 23 requirements which were very well defined at the time ISAP
() 24 started. Some of these have become much more well defined, 25 as ISAP progressed. In discussions with the licensee, we ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 247 1 agreed to address these in the integrated assessment. As O 2 such, the Staff viewed these pending requirements and made 3 recommendations in section 3.4 and in more detail in appendix 4 D in the report. We put them in there for comments for the 5 licensee to comment on how they could address these, many of ,
6 them very descriptive recommendations.
7 MR. SIESS: Some of them look like they have been 8 discussed back and forth with the licensee. Some of them, I 9 am not so sure. Would you care to comment on that? 3.4 and 10 appendix D items.
11 MR. BLASIOLI: We are in the process of responding I
12 to appendix D items and we have had several phone calls with 13 the NRC. We are going to respond in somewhat more general 14 fashion than the descriptive items that the NRC has.
15 MR. SIESS: These are essentially new to you and 16 not something that's been under discussion for a couple of 17 years? I 18 MR. BLASIOLI: Probably not a couple of yeare.
19 Some we have known about for a little while in discussions
]
20 with Staff on ISAP. I believe this is the first time, in l
21 some cases, formally responding to. I 22 MR. SIESS: In what way are you going to respond 23 to the priority item?
24
(]) MR. BLASIOLI: Appendix D?
25 MR. SIESS: No, for others.
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31594.0 cox 248 1 MR. BLASIOLI: I am not sure I understand.
2 MR. SIESS: As I recall the last paragraph where 3 3 the report says that Northeast Utilities will comment on 4 these priorities.
5 MR. KACICH: I think I can answer your question.
l 6 The intended form of our response will be integrated s 7 implementation schedule. That will be the bottom line of 8 what we thought all the other factors and what work you can 9 do when, as well as the Staff comments about highs, mediums 10 and lows. If it's on the schedule early, that means it's 11 higher priority and we can do it. If it's on the schedule 12 later, that means given all those other factors, we would O 13 want to do it, but do it later. If it's not on the schedule, 14 that means we would want to drop it.
15 MR. SIESS: As I recall, the Staff pointed out 16 they don't expect all the high items be done first, but there 17 will he some lows dumped in there. It's easy to do, some 18 highs that will take three years. You expect to come back 19 now with a schedule and go through an additional iteration 20 with the Staff. j 21 MR. KACICH: Exactly right.
22 MR. SIESS: In that additional list there, one 23 item on containment lube break testing, I didn't understand, ,
l O 24 especially why it took six pages to view what we now think 25 about containment leakage and severe accident. But that one ACE FEDERAL REPORTERS, INC.
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31594.0 cox 249 1 is one I mentioned because it looked like that one has been O 2 discussed back and forth for two or three years.
3 MR. BOYLE: To put it simply, the answer is no, it 4 has not been discussed back and forth.
5 MR. THOMES: Number of issues in appendix D are 6 not new.
7 MR. SIESS: I am thinking about pages 3-87 through 8 3-91. Letter dated 1979, 1978. That's more than three or 9 four years.
10 MR. BOYLE: Let me retract. One issue has been 11 discussed in great detail over quite a number of years.
12 MR. SIESS: That's one they have been arguing with O 13 you about for 10 years.
14 MR. BOYLE: Yes.
15 MR. SIESS: Maybe in the context of ISAP, you can 16 settle it.
17 MR. KACICH: Just a point of clarification. When 18 Paul was giving a presentation earlier, he mentioned there 19 were some five- or six-person-event issues that had been 20 around for a long period of time. We took this opportunity 21 to look at them all at one point in time and state our 22 position about what is the best way to put them to bed. Out 23 of the five or six issues, there were two actions that we
() 24 thought we needed to take to put the whole thing to bed.
25 MR. SIESS: This whole thing relates to locals; ACE FEDERAL REPORTERS, INC.
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2 MR. BLASIOLI: If we were purging the contain --
3 venting or purging the containment in the LOCA --
4 MR. SIESS: This is not venting in the context of 5 severe accidents --
6 MR. BLASIOLI: No.
7 MR. EBERSOLE: -- or pre-accidents to allow heat 8 rejection from the containment?
9 MR. BLASIOLI: No. Primarily you would be venting 10 for one or two reasons. Both of which we are making go 11 away.
12 MR. EBERSOLE: PWR containment carries a penalty O 13 with it. PWR has that secondary steam to atmosphere. We 14 don't have it. That's one of the better aspects of the 15 design, but it carries a lot more degrading aspects along 16 with it to get it.
17 MR. SIESS: I read through this whole thing. It 18 reads like a novel, with a couple of flashbacks if you really 19 end up deciding that you can use your nitrogen supply to 20 check for gross rate leakage.
21 MR. BLASIOLI: We are in the process now of 22 actually coming up, hopefully, with an alternative plan that 23 will allow us to trend gross leakage.
() 24 MR. SIESS: How do you do that, what is gross 25 leakage, 10 percent a day?
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31594.0 cox 251 1 MR. BLASIOLI: It would have to be large enough
_O 2 that we could recognize it in the fairly easy fashion, yes.
3 MR. SIESS: When we get to severe accidents, I 4 don't know what it is for a small volume BWR containment.
5 But on a big PWR, 10 or 15 percent a day means you can't 6 overpressure the thing. That's really the kind of leaks you 7 are looking for.
8 MR. EBERSOLE: If you look at the case of a-9 relatively small radiation damage accident to the core, but 10 one that was associated with a containment failure, because 11 valves didn't shut or something -- somebody left the door 12 open, which results in emissions beyond the design basis and j O 13 in the context of control room vulnerability?
- 14 MR. SIESS: You can't leave a door open in a 15 boiler room, Jesse.
16 MR. EBERSOLE: I am talking about something like 17 Haddam Neck.
18 MR. SIESS: Haddam Neck --
19 MR. EBERSOLE: Anyway --
20 MR. SIESS: Get it straight, Jesse, I was talking 21 about the boiler.
22 MR. EBERSOLE: I am talking about the case where 23 you haven't had a big severe accident.
() 24 MR. SIESS: Haddam Neck operates under pressure.
25 MR. EBERSOLE: Does it?
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1 31594.0 i cox 252 1 MR. MROCZKA: Pound and a half of pressure.
O 2 MR. SIESS: I thought you could detect something 3 in a week.
4 MR. MROCZKA: I can't give you specific. It's 5 been years since I have been associated with CY in that kind 6 of detail. But I know that we were able to pick up some very 7 small leakages over a period of one to two weeks that would 8 give us an indication by our trending that something wasn't 9 quite right. We should start looking.
10 MR. SIESS; You have a leak at Haddam Neck of l 11 probably 2/10 percent a day; is that right?
12 MR. KACICH: Sounds about right.
13 MR. SIESS: That's what it usually is. How long 14 would it take you to detect a 1 percent a day leak? I don't 15 think it would take you a week, if somebody was looking.
16 That's a pretty good size leak.
i l
17 But, now, is that what brought this thing on as 1 18 far as Millstone 1, the idea of detecting gross leakt..ge, or 19 is that something that came out of NRC? Is there a 20 requirement to do that something?
21 MR. BLASIOLI: We have a tech spec condition that 22 requires gross monitoring for leakage.
23 MR. SIESS: That common for boilers?
() 24 MR. BLASIOLI: I don't really know what other 25 boilers have. I would think it was something that was around ACE. FEDERAL REPORTERS, INC.
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1 31594.0 cox 253-I when we first got licensed on Unit 1. Any boiler in that 2 time frame probably would have had it.
3 MR. SIESS: Anybody else remember?
4 MR. BLASIOLI: I don't know of any reason l
5 specifically why Unit I would have been singled out.
6 MR. SIESS: I don't either. All the discussion we 7 have been having about leak rates, preexisting leakage, 8 things of that sort. This is the first I have heard about 9 it.
10 MR. EBERSOLE: Speaking about challenges to 11 containment, what is your considered conclusion and terminal 12 viewpoint on sufficient bypass? Do you think you have it O 13 behind you? You know the Germans still require double wall 14 piping. You know, of course, the Brookhaven study that says 15 if you breach it with an SRV -- what is it, SAR, due to 16 resonance and vibrational fallure, if you break it off in the 17 wet wall space, you have had it. How do you feel about i 18 that? See, what you do, you lay down a film of hot water on 19 the compression pool, it will not condense.
20 MR. WARD: Your PSA says something about that, you j 21 have to use generic pipe break. l 22 MR. EBERSOLE: This time, over the long pendulum 23 crooked downcomers that hang there, potentially at least O 24 etert 1ew tree e ciee-25 MR. SIESS: Capacity or safety release valve?
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31594.0 cox 254 1 MR. EBERSOLE: In this case just the safeties, if 2 they stick. It proceeds to the low end regime of pressure 3 and you enter a resonant condensation mode. Everything i
4 starts shaking. A thing not revealed by the original test of I
5 Humboldt Bay because they didn't have enough purge volume in i 6 those reservoirs. They didn't enter the long low pressure i
7 regime and discharge.
8 So after 30 years of rusting up there at the roots i 9 where the pipe is held, once you break off and give you j 10 trouble, if so, you get out of it. I think containment '
11 venting is the answer, along with a lot of other answers like
, 12 fires are because it gives you an exit for thermal energy 13 that you don't now have.
14 MR. SIESS: I have another question.
15 MR. WARD: Chet -- were you going to respond to 16 that?
17 MR. BLASIOLI: I think the kinds of topics that 18 John was talking about before as part of the five-year game 19 plan and do a containment, response analysis, we will get 20 into a lot of stuff, I don't think we have the answers right 21 now.
22 MR. SIESS: Severe accident.
1 23 This is not severe accident, this is just a i
O 24 d1owao-a- ,
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1 failure that precedes core damage.
.O 2 MR. SIESS: Is that worth postulating?
3 MR. EBERSOLE: Does anybody not understand what I 4 am talking about?
5 MR. WARD: Presumably, that's part of your 6 internal events analysis now, I guess, isn't it, John Bickel, 7 can you answer that?
8 MR. EBERSOLE: Let me give it to you real quick.
9 MR. BICKEL: You break an SRV in the dry well, you 10 will pressurize the dry well. That's no different --
11 MR. EBERSOLE: No, no, no, John. You are home 12 free if you break in the dry well, because the discharge will 13 go to the compression cooling under the big --
14 MR. BICKEL: You are talking about breaking it in !
15 the section of bumper water where it comes in.
16 MR. EBERSOLE: Correct. Suppression bypass.
)
17 MR. BICKEL: That's a lot less likely than if a
]
l 18 vacuum breaker sticks. l 19 MR. EBERSOLE: It's in the family of things where 20 a vacuum breaker exists.
21 MR. BICKEL: I think it's bounded by what happens 22 if a vacuum breaker sticks.
23 MR. EBERSOLE: They have little micro switches on 24 them.
(])
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,- 1 the surveillance. I think a pipe breaking is going to be a k_
2 lot less. ;
3 MR. EBERSOLE: There has to be a suppression. I l
4 agree with you. As a matter of fact, one of the MARK-IIs I
5 found out that the resonant discharges in those pipes would 6 actually cause things to come back and forth and fling !
l 7 themselves open.
I 8 MR. BICKEL: I don't know that.
9 MR. WARD: Chet.
10 MR. SIESS: Yes, talk about license amendment, i
11 This may be immaterial. But there was an issue with l
12 Northeast Utilities a while back about whether there should 13 be a license amendment saying that you did something when the j 14 salt spray was blowing, a hurricane was coming. Was that l
15 Millstone 1 or was that one of the other?
16 hll MR. KACICH: You might be talking about Millstone 17 . 3 in station blackout issue.
I 18 MR. SIESS: Why, aren't they all, Millstone 3, 19 aren't they all in the same place?
l 20 MR. KACICH: We thought that was an excellent 21 question.
22 f MR, SIESS: Didn't that come up in the context of 23 Millstone 1?
() 24 MR. KACICH: Certainly seemed logical to us if it 25 hit 3 it would hit 1 and 2 also.
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31594.0 cox 257 1 MR. BICKEL: You wet one first.
2 MR. WARD: I guess I don't understand what the 3 bottom line of this discussion is.
4 MR. SIESS: It might not have been relevant to 5 what we were doing. Staff was arguing they should have a 6 license condition that requires them to shut down and take 7 precautions when a hurricane is coming because a hurricane is 8 almost surely going to take out the switchyard. It has done 9 it twice, I think. The argument is, by the licensee, yes, we !
I l
10 agree, but the last two hurricanes, we shut down. Why 11 doesn't the license amendment --
12 MR. WARD: I see.
O 13 MR. SIESS: I was trying to find out whether there 14 was a license amendment for the site for just one unit and my 15 recollection was it was just three.
16 MR. KACICH: That's right.
17 MR. SIESS: Looking for logic, I am just looking 18 for logic.
19 MR. KACICH: If I can take that opportunity, 20 that's such an excellent lead in. It's not kind of -- it is i
l 21 an example of why we have a greater interest in finding a 22 mechanism to interact with the Staff on a four-unit basis, if 1
23 you will. These things happened with, not often, but
() 24 regularly, where an action will be proposed, unique to one 25' unit, where, from a pragmatic standpoint, there's no !
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1 difference. It's happening now. ;
O 2 MR. EBERSOLE: That comes up at Browns Ferry. You 3 put this in three stalls of independence or an integral l
I 4 system. We elected 'o take it.
5 MR. SIESS: I gave you.a better example. Some of I
6 you may remember. Systematic evaluation program, Dresden 2 1
7 was included. Dresden 3 was not because it had a full-term j 8 license. Units were essentially identical. At least the 9 utilities said any changes we make in unit 2 we will also 10 make in unit 3. We volunteered those.
11 MR. EBERSOLE: You are doing things that are 12 interesting to me and I will be interested to see what they (b
s~/ 13 are. I recall a problem that two DC supplies were hardly 14 enough since they were on duty all the time. Failure of one 15 would precipitate the plant into a trend that required duty 16 on residual one. Failure of transient puts super demands on I
17 the other. It was possible to have three large DC power 18 supplies, really only one great big battery on a unit, which i
19 would traverse and fed the other -- do you follow me, had 20 three big sources. When the big fire came, guess what the 21 plant survived on, one DC source out of three. I thought 22 that was fascinating. It got two of them.
23 MR. WARD: Let me ask, to what extent is your 24 desire to have the Staff embrace continuing ISAP process
[}
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31594.0 cox 259 1 a more simplified or more singular interface with the Staff.
O 2 You are kind of a unique utility in that you have four 3 different kinds of units. I don't know to what extent that 4 has led you to problems where even if you try to integrate 5 things internally, it's nearly impossible to, because you are.
6 reacting with different people or different groups in the 7 Staff.
8 So has that -- even if you didn't have a program 9 here, an ISAP program that would sort of quantitatively, I
10 logically based as you have, would there still be a '
11 significant benefit in just having an interface with a 12 Staff?
13 MR. MROCZKA: Do you want to take that one, Rick.
14 MR. KACICH: Yes. I would say absolutely yes. We 15 have tried to make it clear throughout'the course of today 16 that when we make decisions as a company, it has to be with 17 the recognition of the activities on all four units if they, 18 in fact, are relevant. It's been particularly frustrating 19 when we will communicate our preference to the Staff, or 20 however we want to handle something, and the answer we get 21 back, geez, I hear you, it makes sense, but I am really not 22 in a position to do something like that. It's the 23 organizational setup at times, as much as anything else, that 24 has caused more inefficiencies and frustrations at both
(])
25 ends. It seems logical to us that that would be an
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31594.0 cox 260 1 improvement independent of ISAP.
2 MR. WARD: In a way, your organization, or setup, ,
l 3 kind of puts the Staff to a test, in a sense. You are 4 integrating on one side. If they are not integrating on the 5 other side, it becomes apparent. j 6 MR. EBERSOLE: At one time in the Staff, there was 7 a system called " Division of System Integration." I was 8 pleased to hear the name, if nothing else.
9 MR. SIESS: I disagree. There used to be cases 10 around 1968 or so, where we would run around and say we have 11 a composite problem involving five systems where we strike 12 the balances on all of them. To whom do we go and get help O 13 on striking the balance of the facets of considerations on 14 all of these. We can make one of them better. It's a 15 multisystem problem, like this is. Do you find that you have 16 got access to multisystem considerations in the Staff now?
17 And it is through this mechanism, the ISAP program?
18 MR. KACICH: I would say that there is no one 19 system that is perfect, but our experience to date, this is 20 the best that we know of, at both ends, as we see it.
21 MR. WARD: Well, I think we have got a pretty good 22 story from the Northeast side. Let me turn to the Staff 23 now.
() 24 What is wrong with this program? What don't you 25 like about it? Why isn't everybody embracing it?
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() 2 or so. If you look at IPE, A-44, A-45, maybe some other I
1 3 things, there seems to be a tremendous need for either the 4 Staff integrating its influence requirements, or mechanism 5 permitting the licensees to integrate their responses to 6 those requirements. This looks like a way to do it. Maybe 7 it isn't the world's only way to do it, but it is a way, but 8 yet there doesn't seem to be -- maybe there is. You are 9 working on a second paper. What do you expect? Do you 10 expect to get endorsement from the -- your management in the 11 Commission on this sort of approach?
12 MR. THOMES: I think those of us who have been 13 involved with the ISAP program really recognize its 14 benefits. Everybody I have talked to on the Staff, without 15 exception, thinks it's a really good thing. It not only 16 helps the utility allocate its resources, according to the 17 most important safety issues, but also the Staff. With time, 18 with our resources, it's going to be more and more important i 19 for the Staff, also.
20 I don't anticipate anyone being against the idea, 21 don't know of any negatives on the way up to the Commission.
22 That remains to be seen, and certainly will bring things out 23 in terms of ACRS recommendations, I think is going to be very
(} 24 impoa. tant, play an important role in how the EEO and 25 Commission would react, also.
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1 If I may, I would like to make a couple of 2 comments, kind of expand on what Chet was saying, l
t 3 First of all, when generic requirements are laid 4 on an industry, we tend to view them, at least in the ISAP, 5 as being a horizontal cut. The agency as a whole decides 6 that these issues are important across the board and lays the 7 requirements, all the utilities, without, for the most part, 8 without recognition of that specific circumstance, ISAP 9 allows you to cut that vertically. You can see what is 10 important with respect to a given plant, based on its unique 11 characteristics. We feel that's very important.
12 Another point that you made, I think, is also 13 important, is right now we have a very small staff, ISAP 14 project director consists of half a dozen people, normal 15 project managers, SEP project managers, technical review 16 folks and so on that were dedicated.
17 Obviously, we feel this is an important program.
18 We would like to see ISAP made available to everybody. To do 19 that would indeed result in a reorganization if it was done 20 in exactly the same way. That would be -- NRR would be one 21 big ISAP director, so to speak.
22 I would suggest there are other ways of 23 accomplishing the same end.
24 While we will be recommending to the Commission
(])
25 the continuation of the ISAP program, we will be prepared to ACE. FEDERAL REPORTERS, INC.
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1 discuss recommendations on how it could be implemented. The O 2 way the ISAP program was implemented, in our branch, we had 3 normal project manager, we integrated assessment project 4 manager, and certain specialists, either directly within the 5 branch or readily accessible, particularly in the areas of 6 PRA and operating experience.
7 Those organizations presently exist in the Staff.
8 There is no reason, if we couldn't, for example, spread the 9 word, now that we know that the pilot program has been 10 successful as it has, reorient these groups to look at the 11 issue as a whole from an integrated point of view. In other I 12 words, recalibrate the Staff. We feel this is a way we would O 13 like to see business done in the future and for everybody to I
14 have that opportunity.
15 MR. EBERSOLE: Just, though, as the big strike at 16 Martin Marietta, you have jurisdictional strength in the 17 compartmentalized context and you will have a problem with 18 them.
19 MR. SIESS: Couldn't you start by reprogramming 20 advantages?
21 MR. THOMES: That's exactly it. l 22 MR. SIESS: If one of you people that had the 23 experience were made a project manager for plant X', were O 24 9 1 vem the eethority es 1 seia, aoa't you entax vou oou1a 25 accomplish a great deal?
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31594.0 cox 264 1 MR. THOMES: Absolutely. I was getting to that O 2 point. One of the other things we are going to do is to see 3 3 how we can take the in-house expertise that we have gained 4 over the past several years, and make that available to the 5 branches, to the project managers, or whatever, with -- we j 6 could share the experience in a number of ways, and be able 1
7 to provide guidance and direction in carrying it out. There !
8 are a number of ways we are considering.
9 First, we have to get the Commission to agree that 10 ISAP should be continued. Then the question is how we have 11 -- the point I want to make is we thought a lot about it, 12 even more about it. But there are ways to do it. If we make 13 it available to everybody and a lot of people jump on the l
14 bandwagon, you are going to have an unwieldy organization. l 1
15 So there has to be some ways to deal with that. We are f 1
16 giving a lot of thought to it, but the how has to come after 17 whether.
i 18 MR. WARD: Is there any indication of interest on l 19 the part of other licensees?
20 MR. THOMES: We have purposefully not gone to 21 other licensees yet. There have been a couple -- clearly 22 Northeast has approached us at every opportunity with 23 Millstone 2 and 3. There has been some rumblings from one or
() 24 two others. It's not clear whether they were volunteers or 25 there was some arm-twisting there. This was several years ACE FEDERAL REPORTERS, INC.
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O 2 MR. WARD: Where would the arm-twisting come?
3 MR. BOYLE: In the initial ISAP program, we were 4 looking for four, six or eight plants to participate. We 5 didn't have quite enough. We knew some people were leaning 6 one way or another.
7 MR. SIESS: Excuse me, Northeast Utilities, I 8 would say, are enthusiastic. Have you made any attempt to 9 display that enthusiasm among your fellow utilities, have you 10 been keeping quiet so you could have the next two plants?
11 MR. KACICH: There have been a few instances where 12 we at workshops, seminars, what have you, made presentations O 13 in it. I daresay we stop short of recommending how other 14 people do their business are just as we would not like others 15 to tell us.
16 MR. EBERSOLE: Does Northeast Utilities have an 17 orientation, what I will call " project engineering," primary 18 control, versus what TVA did, total orientation towards 19 distribution or design duties and construction duties, 20 totally functionally oriented. Very weak, if any, project 21 control. All I see here is what I think is a long overdue 22 return to project engineering as a project, rather than just 23 an assembly of parts, which somehow, somebody couples, puts
() 24 together, without any interpretation to consideration of the 25 distillate effects of system 1 from system 14. How do you do ACE FEDERAL REPORTERS, INC.
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1 your work? Are you project-oriented on even coal burners, on O 2 what?
3 MR. KACICH: I think there is a mix.
4 MR. EBERSOLE: Mostly you can do a project on coal 5 burner because if it doesn't work, you fix it. All I see 6 really this is a long overdue return to project engineering 7 per se.
8 MR. WARD: Have you detected much interest in 9 other parts of the industry, I mean, other utilities, when 10 you say you have given presentations at workshops?
11 MR. KACICH: There has been some measure of 12 enthusiasm, but it's not been wholehearted and we definitely 13 want to go off and do this. There are clearly some buy-in 14 costs, including plant-specific PRA.
15 MR. WARD: Nobody has come to you asking for 16 briefs?
17 MR. SIESS: That leads to a que,stion I want to 18 ask. This was an experiment, pilot study. I have been 19 observing Northeast Utilities for some years. They have a 20 tendency to disagree with the Staff frequently, write long, 21 carefully thought-out, well documented letters telling the 22 Staff why they are wrong, and very convincing, I must admit.
1 23 They have a reputation of doing an awful lot, like they are ;
24 setting up a 12-man PSA organization sponsoring research at 25 MIT and things of that sort. Do you think it was a fair test ACE. FEDERAL REPORTERS, INC.
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1 31594.0 cox 267 1 either way? Are they likely to be easier to deal with than .
2 somebody else? Is the next company likely to be so much j 3 different, come in with a contracted PSA, for example?
4 MR. THOMES: Tom, that's a hard question to answer 5 on balance. Tney certainly have a lot of attributes, like 6 you say, they nave people doing their own work that certainly 7 enhances communication and one of the big b'enefits that 8 Northeast put up on a slide that we totally agree with, going 9 through this process helps them understand their plants 10 better. I don't think that benefit would accrue to the 11 extent that it has with Northeast Utilities with a utility 12 that farmed out a PRA. To that extent, they have been the O 13 exception.
14 On balance, I don't know. I think it would be !
l 15 difficult to generalize.
16 MR. SIESS: I would have judged, if I were picking 17 'omebody to do this, they would be one of the tough ones to l
18 work with. I think a lot of project managers will tell you '
19 they have been tough to deal with over the years.
20 MR. THOMES: I would hope to characterize it as we 21 kept each other honest.
22 MR. SIESS: I don't know what is a compliment, but 23 I never considered them typical of anything.
24 MR. EBERSOLE:
(]) How would you think this would 25 impact on the ABWR and APWR which is the only distant I see ACE. FEDERAL REPORTERS, INC.
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O 2 MR. THOMES: At this point, I don't see any 3 impact.
4 MR. EBERSOLE: I am talking about the integrating 5 picture. You would look at it in this case with the 6 . advantage of not having to deal with the physical plant in 7 place. I don't see -- I can see APWR and some contact.
8 MR. THOMES: Here we are talking about the end 9 product of the ISAP program for operating reactors, it says ]
I 10 what things are important, what order you do them. For a 11 plant that is not yet licensed, I would suggest an 12 integration, more of a systems integration.
13 MR. EBERSOLE: It would have a fix in it.
14 MR. THOMES: But this program is more 15 schedule-oriented. I can see the fix being slightly 16 different from that.
17 MR. EBERSOLE: It's an easier fix, it's a bigger 18 fix. But I don't really hear that coming out of the APWR.
19 MR. THOMES: I would view that as a subpart.
I 20 MR. EBERSOLE: The integral aspect of the ABWR, I 21 have yet to see. l 22 MR. THOMES: Strong project manager.
23 MR. EBERSOLE: With a technical staff.
() 24 MR. THOMES: Yes, strong project manager.
25 MR. EBERSOLE: Yes, right.
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31594.0 cox 269 1 MR. WARD: I guess this process, if you do O 2 encourage industrywide -- permit, encourage or require this 3 sort of process for vertical slices taken and a unique 4 solution is found in each plant to a whole covey of general 5 issues, that means each plant will become more unique from 6 all the other plants in the country that has been to start 7 with, and I guess that's okay, or inevitable. I mean in this 8 era, we seem to be thinking how wonderful it would be if 9 everybody was alike. This will definitely not be making the 10 plants more alike.
11 MR. THOMES: I am not sure you could generalize 12 that far. Let's say a generic issue came up, whatcver you O 13 would find it to be. If the schedule for all of the plants 14 to comply with the fix for that generic issue were fixed, 15 that would just mean everybody would have to have the fix in 16 place at such-and-such a time. It doesn't ensure that the 17 fix would be the same for all the plants or even the same for 18 all the groups of plants. I think the beauty of ISAP is that 19 it allows you to take into consideration plant-specific 20 differences and maybe, number one, tailor the fix in a way 21 with all the other issues that is best for that particular 22 plant. Maybe in a long run, for a number -- resolve a number 23 of issues. Secondly, to do it in a time frame that gives you
() 24 the maximum return on safety up front.
25 MR. EBERSOLE: Yes, in the ISAP program we looked ACE-FEDERAL REPORTERS, }NC, 202-347-3700 Nationwide Coverage 800-3364(>46
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l 31594.0 cox 270 i
1 at with your PWRs, I am trying to --
3 MR. EBERSOLE: One PWR. How do you interpret the 4 value of Mr. Glenn Reed's concept of primary blowdown and j 1
5 direct cooling? Do you invoke it as kind of a terminal 6 backup method of cooling?
7 Do you know what I mean? You have lost the 8 secondary coupling on a PWR. For the sake of argument, I 9 have just lost feedwater.
10 MR. WARD: You just mean, do you believe in feed 11 cooling of the core?
12 MR. EBERSOLE: That's what I mean.
13 MR. WARD: All right.
14 MR. EBERSOLE: Can you do it and would you require 15 it?
16 MR. KACICH: I would say at the Haddam Neck 17 specifically we have gone through quite a bit more work in 18 that area to substantiate that is not a desirable but an 19 available means of getting the job done.
20 MR. SIESS: Dave.
21 MR. WARD: Yes.
22 MR. SIESS: When we were talking with the Staff 23 about generic issues, when we got to what we called 24 implementation, which was a different group, they said that's
({}
25 NRR's job. Then somebody from NRR chose to divide ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 271 1 implementation into three stages, imposition, implementation l O 2 and verification, I guess. Imposition was deciding who had l
j I
3 to do it. Now, that, to some extent, gets vertical. The j I
4 implementation, they told us, was scheduling, among other l 5 things, and they said that the project manager has a certain l
l 6 amount of flexibility there. Is that really true outside of )
i 7 ISAP?
8 MR. THOMES: Could be true for the integrated 9 licensing schedule program.
10 MR. SIESS: I got the feeling we were being given 11 a little rosier picture than might have been the case. They 12 were starting to say, well, it isn't done across the board, sm 13 there is some vertical separation, maybe over and above what i
14 the generic --
15 MR. THOMES: I am reminded the project manager 16 does have latitude.
17 MR. BOYLE: Nor here what ISAP would allow, but 18 they are allowed in negotiating.
19 MR. WARD: Okay. Well, I would like to come back 20 to any people on the Staff for just a couple of minutes to 21 talk about what we would like to have in the presentation to 22 the full committee on Friday, I guess it is, no, on Thursday 23 morning.
O 24 8et riret 1et me ture to the oommittee ema eex vou 25 to comment on anything you would like to comment on, ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-33M/>46
, 31594.0 cox 272 1
1 including what course of action you think we ought to take O 2 right now with the full committee, and longer term, any i 3 thoughts? Jesse.
l 4 MR. EBERSOLE: I was bothered by ISAP being I 5 regarded as the third part, the first two parts being SEP and 6 another. I am trying to look at the whole book. ISAP ought l
7 to be included as an integral identified part. It rides on i 8 SEP or IREP, or both.
9 For a new plant that didn't have the benefit of 10 SEP or IREP, it was all three of these things.
11 Excessive verbiage all over the place --
12 MR. SIESS: What are you referring to?
O 13 MR. EBERSOLE: Somebody has a terrible urge to put 14 14 words where one would do.
15 MR. SIESS: That's where they get hired as Staff.
16 MR. WARD: Widespread disease.
17 MR. EBERSOLE: It's terrible to find what is the 18 line of truth and intent in this stuff. Somebody has got to 1 19 do something because this all over the place. ,
20 MR. SIESS: Someone has to document it.
21 MR. EBERSOLE: I have an obscene word that is 22 better, but I won't use it here. It's not easy to say what 23 this says you are going to do in this matter of integrating 24 the ISAP program. It's the integral safety assessment.
({)
25 Doesn't leave out the other parts.
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1 31594.0 cox 273 1 MR. WARD: Chet.
O 2 MR. SIESS: I guess my view of ISAP may be i
3 different from what Jesse's is. I have been in favor of it 4 from the beginning. I did every SEP plan, one subcommittee.
5 I was extremely impressed by what came out of SEP. I could j i
6 see ISAP as an extension of it. I think it probably 7 contributes more to safety for the' money than anything else 8 we are doing, including a lot of the things we have done in 9 the past.
10 I think one thing, that has got to focus better on !
1 I
11 the severe accident, which is the real threat of health and 12 safety to the public. By using PSA, PRA, it tends to put 13 some of the requirements we have got that are based simply on 14 LOCA and design basis accident, things of that sort, tends to 15 put them in perspective and maybe puts them out of the lower l
l 16 category.
]
17 To me, I think you are going to get a better 18 picture of the plant than you are going to get from this 19 individual plant examination or anything else that comes 20 under the severe accident policy. I just wish we could do a 21 follow-up. I think it's not just a process, it's a 22 philosophy.
23 MR. EBERSOLE: Yes, I agree with you.
() 24 MR, SIESS: It's a philosophy that fits in with 25 what the Commission says is the responsibility of the ace-FEDERAL REPORTERS, INC.
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31594.0 cox 274 1 licensee to operate the plant safely. This is at least O 2 sharing some of the responsibility of how you go about 3 operating it safely. Too much of saying do it this way and-4 this way and this way, but it's your responsibility if it 5 doesn't work. I am in favor of it. I think it would be the 6 greatest thing in the world if the NRC could go whole hog on 7 it and get the whole staff oriented towards this matter.
8 MR. EBERSOLE: I certainly agree with that.
9 MR. WARD: Pete.
10 MR. DAVIS: I am pretty much in agreement with 11 what Chet said. I am pretty enthusiastic about this 12 program. I have been concerned for some time about what O 13 appeared to me to be the fragmented and inconsistent program 14 that the NRC had to examine safety issues, particularly those 15 related to severe accidents. At one time there were five 16 different programs looking at auxiliary feedwater. They 17 seemed to be not talking with each other. All would 18 eventually come up with some kind of a requirement for a 19 modification.
20 Furthermore, I think we saw where this program can 21 identify plant-specific vulnerabilities just from doing the 22 PSA by itself, independent of any NRC requirements from 23 previous investigations. I think that Dr. Bickel indicated 24
(]) that he found some modifications that were been planned which 25 were actually detrimental to risk. I think we should be ACE-FEDERAL REPORTERS, INC.
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i 31594.0 cox 275 1 looking for those things too.
O 2 I see two weaknesses, at least in this pilot 3 program. One of them is a lack of a consistent approach to 4 evaluation of external events. I understand the reasons for I
5 that. I appreciate the difficulties and the possibility that 6 there may not be a pay off there. On the other hand, we have 7 found plants that have been particularly vulnerable to 8 external events. I think we need to keep looking at them.
9 The second concern is over the lack of an in-depth 10 assessment of the containment response and source terms.
11 Again, I understand the reasons for that particularly I
12 troublesome issue, and it would take some resources to derive l 1
13 that.
14 However, it seems to me that a good risk profile l
l 15 for the plant is necessary to make some of these decisions.
16 That doesn't exist unless you do a full level 3 PRA. That's l i
17 all I have, Mr. Chairman.
18 MR. WARD: Thank you, Pete. Well, I guess you 19 have -- Dick has informed you that we would like to have 20 discussion of this topic at the full committee meeting on 21 Thursday. That is scheduled for a two-hour slot from 10:45 22 to 12:45 Thursday morning, two days from now.
23 What I would like to do is split that two hours, O 24 merhe 9 1 ve northeeet ut111tiee eboet he1f of it, eed the 25 Staff and I will split up the other half. I will just take a ACE-FEDERAL REPORTERS, INC.
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31594.0 cox 276 1 very few minutes of that. If you can look at Staff, who has 2 got 50 minutes or so, and limit your presentations, I think 3 -- I really think you need to cover the -- more briefly, what 4 you covered today, but I think we particularly want to hear 5 about the directions you are going, your plans for writing a 6 second paper. If there are some positions elsewhere in the 7 Staff that are negative on the program, it would be one of 8 you -- I am not suggesting that you bring in some guy who l
9 hates ISAP or something. j l
10 MR. THOMES: None of us are aware of any, so that l l
11 may make it easier. I l
)
12 MR. WARD: All right.
13 MR. EBERSOLE: I just want to reinforce what I 14 said. I think it's unfortunate that you used the term i I 15 " integrated safety assessment program." Then you identified !
l 16 l residual issues.
I 17 MR. WARD: How about integrate the residual; is I
18 that all right?
19 MR. EBERSOLE: No. I don't think you are entitled 20 to use integrate if you incorporate the notion of residual.
21 Integrate is integrate. It starts at the plant beginnings 22 and goes to the plant ends. It's not a part of the 23 late-coming issues, is it?
24 MR. WARD: I would have to agree with you.
(])
25 MR. EBERSOLE: I have to go to the beginning of ACE FEDERAL REPORTERS, INC.
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I 1 the plant, old standards, old criteria, reassessment of l k,)
m l 2 those. It's not just the last two dozen issues. l l
l 3 MR. THOMES: Non-SEP plant, that would be pretty 4 close.
5 MR. EBERSOLE: Then make the differentiation if 6 you want to. Let's look at it without the prop that you have !
7 in SEP and IREP. That's the way you look at it.
8 MR. THOMES: If it's an SEP plant, then it was 9 already covered.
10 MR. EBERSOLE: But you don't say that and you 11 mislead people by thinking it's a non-SEP plant.
12 MR. THOMES: How about ISAP project or something 13 like that?
14 MR. EBERSOLE: I don't care. Integrated is i
15 integrated.
16 : MR. WARD: Well, as far as your hour, you probably 17 better figure on having about 30 minutes of presentation; and '
18 because there will be a lot of comment, questions from around 19 the table, you will have to trim it down. We don't want to j l
20 hear much about the !?RA itself. Let me come back to that. I 21 do think we want to hear a little bit, but a discussion of I l
22 ISAP applications, your experience, what you want to do with l 23 it. That's really what we would like to hear. l l
() 24 I think somewhere in there, maybe just the people 25 who present that can do it, maybe John Bickel who will need ACE FEDERAL REPORTERS, INC.
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- 1 to do it. I think we want to hear enough about the PRA so l V
2 that it's clear as to what the scope of your PRA is, the fact l 3 that you have done a level 1 for all plants. It doesn't yet j 4 include all external events and the reasons that you are 5 approaching it, the fact that you do have a level 3 for 6 whatever, Millstone 3 for a particular reason, so forth.
7 But instead of getting -- just so we understand
)
8 what the scope of the quantitative base for your ISAP program l l
9 is, it is neither more nor less than what you really have.
10 I think the full committee will find a program 11 very interesting.
i 12 MR. SIESS: We don't have to write a letter on the 13 Millstone ISAP, do we, like we did on the SEP?
14 MR. THOMES: We are not holding up our report for 15 you. We were more interested in your views on problematic 16 aspect.
17 MR. WARD: I think that is what the committee is i 18 going to be interested in.
19 MR. SIESS: We ought to have the presentation 20 towards the process, the philosophy, and not the individual !
21 items and how they got resolved. !
l 22 MR. WARD: Right, right.
l 23 MR. SIESS: Right now, there's not enough .
() 24 disagreement that you need a referee. Haven't reached that !
25 point yet.
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31594.0 cox 279 1 MR. WARD: I guess, Mike, in your part of the O 2 presentation, you don't have to make a big issue, but I think 3 you do need to make clear that the program consists of doing 4 that, looking at the individual issue, licensing sort of 5 requirement issues.
6 MR. THOMES: I guess to be consistent, let me ask 7 the subcommittee. If you did not address Millstone, we were l
8 talking about two to three months behind with Haddam Neck.
9 Would you want to review Haddam Neck?
I 10 MR. WARD: Let's wait and see; give us time to 11 chew over that. )
)
12 MR. THOMES: I think your decision will affect O 13 which way you go.
14 MR. WARD: That's an open question. We will 15 answer it, but not today.
16 Okay. Any other questions, comments? Okay, 17 gentlemen. I thank you very much. Appreciate your fine 18 presentations. Thank you.
19 (Whereupon, at 5:24 p.m., the meeting was 20 concluded.)
21 22 23 Q 24 25 ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6646
CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON INTEGRATED SAFETY ASSISSMENT PROGRAM (ISAP)
DOCKET NO.:
PLACE: WASHINGTON, D. C.
DATE: TUESDAY, JULY 7, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt M '
(TYPED)
MARY C. SIMONS Official Reporter ACE-FEDERAL REPOPgTERS, INC.
Reporter's Affiliation O
CERTIFICATE OF OFFICIAL REPORTER O
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCIMMITTEE ON INTEGRATED SAFETY ASSESSMNET PROGRAM (ISAP) i DOCKET NO.:
PLACE: NASHINGTON, D. C.
DATE: TUESDAY, JULY 7, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt) / g (TYPED) [
UENDY S. COX Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation O
NRR STAFF PRESENTATION TO THE O
SUBJECT:
Inte9 rated Safety Assessment Program DATE: July 7, 1987 PRESENTER: Michael L. Boyle
~
PRESENTER'S TITLE / BRANCH /DIV: Project Manager / Integrated Safety Assessment Project Directorate / Division of Reactor Projects III/IV/V and Special Projects I
PRESENTER'S NRC TEL. NO.: 492-7636 SUBCOMMITTEE: Subcommittee on ISAP.
O
1
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HISTORY OF ISAP l e SYSTEMATIC EVALUAT!ON PROGRAM (SEP) STARTED IN 1977 TO REVIEW OPERATING PLANTS AGAINST REGULATORY REQUIREMENTS THAT HAD EVOLVED SINCE THE MAJORITY OF REACTORS HAD BEEN LICENSED.
e INTERIM RELIABILITY EVALUATION PROGRAM (IREP) DEVELOPED FROM THE TMI ACTION PLAN (NUREG-0660).
e ONE OF THE SIGNIFICANT CONCLUSIONS DRAWN FROM SEP AND IREP IS THAT ISSUES RELATED TO SAFETY OF OPERATING NUCLEAR POWER PLAIJS CAN BE MORE EFFECTIVELY AND EFFICIENTLY IMPLEMENTED IN AN INTEGRATED, PLANT-SPECIFIC REVIEW.
e NRC DEVELOPED INTEGRATED SAFETY ASSESSMENT PROGRAM (ISAP) IN 1984 (49 FR 45112).
e ISAP PILOT PROGRAM REVISED IN 1985 TO INCLUDE TWO OPERATING PLANTS THAT WERE PREVIOUSLY EVALUATED IN SEP. (SECY 85-160).
O l
1
O OBJECTIVE OF ISAP INTEGRATED ASSESSMENTS OF OPERATING NUCLEAR POWER REACTORS ARE CONDUCTED ON A PLANT-SPECIFIC BASIS TO EVALUATE ALL LICENSING ACTIONS, LICENSEE INITIATED PLANT IMPROVEMENTS AND SELECTED UNRESOLVED GENERIC / SAFETY ISSUES TO ESTABLISH IMPLEMENTATION SCHEDULES FOR EACH ITEM. IN ADDITION, PROCEDURES ARE DEVELOPED TO ALLOW PERIODIC UPDATING OF THE IMPLEMENTATION SCHEDULES.
MAJOR ELEMENTS OF ISAP API:
REVIEW OF LESSONS LEARNED FROM SEP PERFORMANCE OF PLANT-SPECIFIC RISK ASSESSMENT ANALYSIS OF OPERATING EXPERIENCE INTEGRATED ASSESSMENT OF TOPICS INTEGRATED IMPLEMENTATION SCHEDULE O
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ISAP REVIEW e ISAP CONDUCTED BY AN INTEGRATED ASSESSMENT TEAM (IAT) e SCREENING REVIEW BY BOTH IAT AND LICENSEE TO DEVELOP TOPIC DEFINITIONS, SCOPE, REVIEW CRITERIA AND JUSTIFICATION FOR .
I CONTINUES OPERATION.
f e ISAP EVALUATION IS DIVIDED INTO THREE PARALLEL PHASES TOPIC EVALUATIONS (DETERMINISTIC AND PROBABILISTIC)
PERFORMANCE OF PROBABILISTIC SAFETY ASSESSMENT (PSA)
EVALUATION OF PLANT OPERATING EXPERIENCE e LICENSEE PERFORMS AN INTEGRATED ASSESSMENT OF TOPICS TO DETERMINE WHICH WARRANT CORRECTIVE ACTION BASED ON PERCEIVED SAFETY SIGNIFICANCE AND TO DEVELOP COST-EFFECTIVE ACTIONS TO RESOLVE MULTIPLE ISSUES, WHERE PRACTICAL.
e STAFF ISSUES DRAFT INTEGRATED SAFETY ASSESSMENT REPORT e DRAFT ISAR REVIEWED BY LICENSEE, PEER REVIEW GROUP AND ACRS e FINAL ISAR ISSUED; INTEGRATED IMPLEMENTATION SCHEDULE AND METHODOLOGY TO MAINTAIN SCHEDULE IS FORMALIZED.
I l
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4 4
O ISAP PILOT PROGRAM MILESTONES March 23, 1984 SECY 84-133 described a four plant ISAP pilot program in lieu of SEP Phase III and the National Reliability Evaluation Program.
November 15, 1984 ISAP policy statement was published in the Federal Register (49 FR 45112).
May 6, 1985 SECY 85-160 described a revised ISAP pilot program for two plants: Millstone Unit 1 and Haddam Neck.
May 17, 1985 Northeast Utilities (NU) submitted a proposed set of " topics" for both plants; the proposed scope was a revision and update to two previous proposals (June and December 1983).
June 1985 Meetings held with NU to discuss scope of topics, pending licensing actions, generic issues, and plant improvements.
July 10, 1985 Millstone 1 Probabilistic Safety Analysis (PSA) submitted; immediatecorrectiveaction(long-termcooling)and topic-related issues were defined in the forwarding letter.
July 31, 1985 Staff evaluation identified 80 topics-for Millstone 1 and -
70 topics for Haddam Neck, as well as projects that were to be completed independent of ISAP. Documentation requirements were defined for deterministic, probabilistic and plant improvement summaries.
August 13, 1985 to NU submitted individual topic safety analyses for Millstone 1 February 4, 1986 together with applicable topic probabilistic summaries.
August 19, 1985 NRC issues draft Millstone 1 operating experience report for comment.
September 23, 1985 Draft SAIC PSA evaluation report for Millstone 1 issued to NU for factual corrections and coments.
October 3, 1985 NU submitted comments on ISAP operating experience review analysis.
October 21, 1985 NU submitted comments on draft SAIC Millstone 1 PSA evaluation report.
November 20, 1985 Commission Memorandum and Order issued granting a schedular extension to 10 CFR 50.49 for the environmental qualification of eleven valve operators to be resolved under ISAP for Millstone 1 but not later than August 30, 1987.
Q 1
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O Final SAIC PSA evaluation report issued to NU for use in the January 3, 1986 Millstone 1 integrated assessment.
February 14, 1986 NU submitted a proposed ISAP schedule for Haddam Neck.
i February 19, 1986 Comission briefing on ISAP status. l March 3, 1986 Safety evaluation for Millstone 1 issued which describes the results of the topic reviews: (1) specific issues to be addressed in the integrated assessment, (2) resolved topics, ,
I and (3) three new topics and the related issues resulting from the PSA and operating experience review.
March 26, 1986 NU submitted the supplemental fire analysis for the Millstone 1 PSA.
March 31, 1986 Haddam Neck PSA submitted by NU; imediate corrective actions l (small break LOCA) and topic related issues were defined I in the forwarding letter.
I April 22, 1986 SECY 86-121 presented first annual ISAP progress report.
June 13, 1986 to NU submitted individual topic safety analyses for Haddam Neck November 18, 1986 together with applicable topic probabilistic sumaries.
July 3, 1986 Draft Haddam Neck operating experience report issued to NU for comment.
July 31, 1986 NU submitted their proposed resolution of the Millstone 1 integrated assessment issues together with a priority ,
ranking for each issue.
August 19, 1986 NU submitted coments on draft Haddam Neck operating experience report.
September 30, 1986 Staff issued final Haddam Neck operating experience l report.
November 16, 1986 Draft SAIC PSA evaluation report for Haddam Neck issued to NU for factual corrections and comment.
December 12, 1986 NU submitted their proposed resolution of the Haddam Neck integrated assessment issues together with a priority ranking for each issue.
January 14, 1987 NU submits coments on draft SAIC Haddam Neck PSA evaluation report.
April 14, 1987 Staff issued draft Millstone 1 Integrated Safety Assessment Report (NUREG-1184) for coment.
Q May 27, 1987 Final SAIC PSA evaluation report issued to NU for use in the Haddam Neck integrated assessment.
i 1
O May 26, 1987 Coments on Millstone 1 draft ISAP received from peer review group. Comments from NU due at end of month.
May 1987 Staff issues second ISAP progress report and recomendations ;
for future ISAP Actions.
- July 14, 1987 Staff to issue draft Haddam Neck ISAR to NU and peer review -
group.
- July 30, 1987 Staff to issue final Millstone 1 ISAR and start process for Millstone 1 license amendment to inccrporate integrated schedule plan.
- August 14, 1987 Coments on Haddam Neck draft ISAR due. .
- September 1987 Staff to present Haddam Neck ISAP to ACRS.
- 0ctober 1987 Staff to issue final Haddam Neck ISAR and start process for Haddam Neck license amendment to incorporate integrated schedule plan.
- Current completion schedule.
l l
l
O MAJOR ISAP FINDINGS MILLST0hI I 64% OF TOTAL CALCULATED CORE MELT FREQUENCY WAS DUE TO FAILURE TO MAINTAIN ADEQUATE LONG-TERM DECAY HEAT REMOVAL CAPABILITY HADDAM NECK LOSS OF MCC-5, IN THE SWITCHGEAR ROOM WOULD CAUSE A LOSS OF FUNCTION OF CRITICAL EQUIPMENT AND PREVENT SAFE SHUTDOWN ISAP ALSO IDENTIFIED AREAS THAT WHILE DEVELOPED TO INCREASE PLANT SAFETY OR AVAILABILITY, ACTUALLY INCREASED RISK.
MILLSTONE 1, DEGRADED GRID VOLTAGE PROTECTION HADDAM NECK, NITROGEN BLANKET FOR THE DEMINERALIZED WATER STORAGE TANK.
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ISAP CONCLUSIONS i
e PERFORMANCE OF PSA BY THE LICENSEE, AND REVIEW 0F THE PSA AND OPERATING EXPERIENCE BY THE STAFF HAS LED TO A BETTER UNDERSTANDING OF THE PLANT'S OPERATING CHARACTERISTICS AND CAPABILITIES BY BOTH THE LICENSEE AND TIE STAFF.
e INTEGRATED ASSESSMENT HAS THE POTENTIAL TO IDENTIFY COMMON ELEMENTS IN SEPARATE REVIEWS AND PROPOSE A SINGLE ACTION TO IFSOLVE THEM.
o INTEGRATED ASSESSMENT PROVIDES AN OPPORTUNITY FOR THE STAFF AND LICENSEE TO ADDRESS PENDING REQUIREMENTS ON A PLANT-SPECIFIC BASIS.
e ISAP PROVIDES A FORMAL PROCESS TO EVALUATE TIE PRIORITIZATION OF ALL PROPOSED ACTIONS.
e PILOT PROGRAM HAS DEMONSTRATED THE POTENTIAL BENEFITS TO LICENSEES, THE PUBLIC AND TIE NRC OF INTEGRATED ASSESSMENTS USING PLANT SPECIFIC PSAs AND OPERATING EXPERIENCE REVIEWS.
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Additional Information on NOTE (4)
(3 V
In IREP it was noted that Millstone Unit No.1 had never experienced a total loss of feedwater in 12 years of operation. Because of this, IFEP approximated the upper bound failure frequency at a 50%
confidence level by using a chi-squared sampling test, which yields an esticated frequency of .06/yr for feedwater system failure. IREP also noted that feedwater is lost whenever there is a total loss of TBSCCW system cooling to feedwater or service water cooling to TBSCCW.
Consequently, it can be implied that zero feedwater system failures equates to no TBSCCW or service water system failures as well. IREP then derived a total frequency for loss of feedwater by addin6 the {
chi-square approximations for no failures of the feedwater, TBCCW and j service water systems (e.g. 0.18 failures per year).
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