ML20235V436
| ML20235V436 | |
| Person / Time | |
|---|---|
| Issue date: | 10/08/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1617, NUDOCS 8710150154 | |
| Download: ML20235V436 (192) | |
Text
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a TRANSCRIPT OF PROCEEDINGS t
i Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards In the Matter of:
330th General Meeting 1
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Pages: 1 through 169 Place:
Washington, D.C.
Date :
October 8, 1987 Heritage Reporting Corporation g
Official Reporters 1220 L Street, N.W.
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-1 PUBLIC NOTICE BY THE
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UNITED STATES NUCLEAR REGULATORY COMMISSIONS 3
ADVISORY COMMITTFE ON REACTOR SAFEGUARDS 4
i 5
(
6-7 The contents of this stenographic. transcript of the 8
proceedings of the United States Nuciear Regulatory 4
9 Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS Staff and no participant at 13 this. meeting accepts any responsibility for errors or
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inaccuracies of statement or data contained in this transcript.
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1 I) l' UNITED STATES NUCLEAR REGULATORY COMMISSION 2'
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
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5 In the Matter of:
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7 330th GENERAL MEETING
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- Thursday, 10 September 8, 1987 11 Room 1046 1717 H Street, N.W.
12 Washington, D.C.
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- , h The above-entitled matter came on for further 14 hearing, pursuant to notice, at 8:35 a.m.
15 BEFORE:
DR. WILLIAM KERR 16 Chairman Professor off Nuclear Engineering 17 Director, Office of Energy Research University of Michigan 18 Ann Arbor, Michigan 19 ACRS MEMBERS PRECENT:
20 DH, FORREST J.
REMICK Vice-Chairman 21 Associate Vice-President for Reaearch The Pennsylvania State University 22 University Park, Pennsylvania 23 MR. JESSE C.
EBERSOLE i
L Retired Head Nuclear Engineer i
24 Division of Engineering Design Tennessee Valley Authority
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25 Knoxville, Tennessee tO V
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1 ACRS pj,f;BERS PRESENT (CONTINUED):
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2 DR. HAROLD W.. LEWIS Professor of Physics 3
Department of Physics University of California 4
Santa Barbara, California 5
DR. CARSON MARK Retired Division Leader 6
Los Alamos Scientific Laboratory Los Alamos, New Mexico 7
MR..CARLYLE MICHELSON 8
Retired Principal Nuclear Engineer Tennessee Valley Authority 9
Knoxville, Tennessee, and, Retired Director, Office for Analysis and 10 Evaluation of_ Operational Data l
U.S. Nuclear Regulatory Commission i
11 Washington, D.C.
12 DR. DADE W. MOELLER Professor of Engineering in Environmental Health 13 Associate Dean for Continuing Education
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School of Public Health
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14 Harvard University Boston, Massachusetts 15 DR. DAVID OKRENT-16 Professor of Engineering and Applied Science Department of Mechanical, Aerospace and Nuclear 17 Engineering School of Engineering and Applied Science 18 University of California Los Angeles, California 19 MR. GLENN A.
REED l
20 Retired Plant Manager i
Point Beach Nuclear Power Plant
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21 Wisconsin Electric power Company
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Two Rivers, Wisconsin 22 I
DR. PAUL G.
SHEWMON 23 Professor, Metallurgical Engineering Department Ohio State University 24 Columbus, Ohio j
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ACRS-MEMBERS PRESENT (CONTINUED) -
2-DR. CHESTER P.
SIESS.
Professor Emeritus.of Civil Engineering
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University.of Illinois Urbana,-Illinois DR.. MARTIN J. STEINDLER-5 Director,-Chemical TechnologyJDivision Argonne National Laboratory.
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.Argonne,. Illinois
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-7 MR.. DAVID A. WARD
.Research; Manager on Special-Assignment
- Ch E.I. du Pont de.Nemours & Company.
Savannah River' Laboratory 9
'Aiken, South Carolina
.' 10 HR. CHARLES J.:WYLIE Retired Chief Engineer Hi l'
- Electrice.1 Division Duke Power Company!
121 Charlotte, North
- Carolina.
i-13 ACRS COGNIZANT STAFF MEMBER:
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Mr. Perkens 15
'Mr. McKenna 16 l'
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1 P R O C E'E D I N G S.
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.w) 2 CHAIRMAN KERR:
The meeting will come to order.
This 3
is the first day'of the 330th meeting of the Advisory Committee 4
on Reactor Safeguards.
5 During today's meeting, we will discuss or hear 6
-reports on the revised backfit rule, integrated. safety!
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assessment program, future activities, South Texas nuclear 8
station, Unit 1, matters dealing with nuclear waste,'and raport 9
on design' station full field exercise, some discussion of the
'10 implications of the Chernobyl, a discussion of the planning 11 subcommittee meeting agenda, and a discussion of the ACRS 12 subcommittee activities.
A portion of the meeting will be 13 closed to public attendance.
Items for discussion on
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14 tomorrow's agenda are listed on the bulletin board at the back 15 of the room.
The meeting is being conducted in accordance with 16 provisions of the Federal Advisory Committee Act, and the 17 government and the Sunshine Act.
Mr. Ray _Fraley is the 18 designated federal official.
19 We have received no written statements or requests to 20 make oral statements from members of the public regarding 21 today's meeting.
22 Items of interest that have developed since our last 23 meeting include an earthquake in California, which most of you 24 are aware.
There is a briefing on some details as they may 25 deal with opening nuclear plants scheduled for the operating
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events. session.
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-(Comments were made off the record.);
3 CHAIRMAN KERR:. Revised backfit rule, and Mr'. Okrent
'4 may want to make some preliminary remarks.
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5 DR. OKRENT:
I may.
I would recommend we"go directly 61 to hear what the staff las to say if the staff representative 1
- 7 is here, and then s.e what comments and so forth the> committee 0'
has or whether or what.
New.
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MR. NEWBERRY:
Good morning, gentlemen.- Mylname is 10.
Scott Newberry.
I work in the-EDO's office and.have'been
'11 involved in the preparation of the proposed backfit rule.
.I am 12 here.to discuss with you that change that was-proposed!in the, 13 Federal Register I believe on September 10th.
With'me are-
,,b 14 members of the staf f to help answer any questions that' 1 'am 15 unabletto handle.
16 What Irreally'would like to do is several things.
I 17, will' discuss'a few of the major points of the court' decision 10 that led to the proposed change.
I'll go through the major 19 elements of the change and describe why we are making them, and 20 then I'll touch on what I believe the impacts of the change, 21 change are.
I should probably point out that while as you 22 know, that this is a proposed rule chantce, it is still out for 23 comment.
The comment period has not yet expired, so the change 24 is not final.
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1 MR. NEWBERRY:
On August 4th, the U.S. Court of 2
Appeals for the District of Columbia Circuit issued its 3
decision in a case between the. Union of Concerned Scientists
- 4 and the NRC.
The assertion of the UCS was that the Atomic 5
Energy Act forbids the NRC from ever considering economic costs 6
in the backfitting process.
I have made a vugraph heret that, 7
that points out the major conclusions of the court as I.see 8
them.
9 They rejected the fundamental position of'the,UCS in 10 terms of cost never being a factor in safety decisions under 11 the Act, but on the other hand, they did conclude that:the Rule 12 50.109 should be vacated along with the manual chapter that i
13 describes the specific procedures that implement that rule due
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14 to the ambiguity and some of the background information 15 published in the Federal Register uhen the rule was issued and 16 also in some of the information in the Court brief for the 17 case, tha UCS and the NRC.
18 The court did conclude, point No.
2, that once, once j
19 you achieve an adequate level of protection, that the 20 Commission is authorized under the Act, and the details of 21 Judge McDaw's discussion of the court's decision go into the 22 basis for this, this conclusion, but the court did decide that 23 the Commission is authorized by the Act to consider and take 24 costs into account in ordering improvements beyond the level of 25 adequate.
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.1; DR.:; LEWIS:-.Are you open to questions as yoh'g6
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Lalong? (When:the' manual chapter:was.first: written I rbmember'-
3: i thinking that ~ it was: a strange. chapter.
I was told not"to
'4 worry because'it has;no legalLstanding anyway. It'isljust 5
- advisory.to the staff.
'6 Does.this mean'that the manual chapters:now1dothave; t7_
some legal force.behind them?
8 MR. NEWBERRY:
-I don't-think so. I am not atlawyer.
'9 DR.LLEWISt-How can the' court vacate something:that b
- 1.0 doesn't.have meaning?
ik 11 MR.-NEWBERRY - Let me try to answer it.
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12 the' court, I'believe the-Court' vacated it because^it wai
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challenged along with the rule,.and therefore, it was vacated.
13 brought up in the. court case'along with the' rule It was 15 along with it'.
.I. don't--
. 16
-DR.. LEWIS - Those people will explain it all.'
'17' MR. NEWBERRY:
That's about right.'
Steve?.
p 18 MR. CROCKETT:
-I think it,is a very good question.
'19-The really haven't considered that.
I guess one would think
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21 significance.
We had argued in the brief that the manual 22
' chapter in fact was without legal significance.
This suggests 23 that implicitly at least the court is saying a relatively-24-unprecedented thing, that such internal management guidance 25~
does in fact have' legal significance.
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1 DR. LEWIS:
If it does, the Commission is going.to 2
-have to be'a lot more careful about writing those things.
3' MR. CROCKETT:
That's right.
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MR. NEWBERRY:
That's a good question.
Well,:the 5
point of the manual chapter was brought up.
I should say that 6
as we stated in the Federal Register, it is our intent'to not 7
do anything officially with the manual chapter until the rule 8
is finalized, the comments are in, the rule is in place and we 9
know where we are before we march off and do anything with the 10 manual chapter so we don't do anything more than once.
11 The second vugraph I have prepared is something to 12 help me go through the major elements of the proposed rule.
13
.Okay.
And I will go through these one by one.
Some* carry over E-/
14 from the previous rule, and some, I think there is three points 15 that are changes as a result of the court decision.
16 The first two elements are really there.
They are 17 quotes directly out of the previous rule.
18 DR. OKRENT:
Question.
19 MR. NEWBERRY:
Yes.
20 DR. OKRENT:
Does the staff think it understands and L
21 can define the term substantial?
22 MR. NEWBERRY:
Well, Dr. Okrent, I don't know if I'm 23 the best person to, to address the definition of substantial.
24 I hadn't planned on doing that in this presentation.
It is 25 there in the previous rule and the scope of this change doesn't e
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2 DR. OKRENT:
I agree it was in the previous rule.
I
'3 made a couple of minor efforts to obtain a definition of 4
substantial.
I would not say with definitive success.
It 5
would seem to me since, as I understand it, the lawynes, it is 6
the staff who in small groups or one at a time or innsome way 7
will be making decisions.
This is a backfit.
Furthermore, it 8
is a cost / benefit backfit.
It almost behooves the staff one 9'
and all to understand what this is about, and maybe to try to 10 see if they agree sort of.
11 MR. NEWBERRY:
Tom, do you want to add anything on 12' substantial?
I would only make, attempt to make one comment, 13 and it is based on my experience as an engineer on a staff in 1
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14 this process, and that is, is that you know, there are 15 guidelines in the regulatory analysis documents that have been 16 published, you know, in terms-of the t:,ousand dollars: per man l
17 ram aspect of the cost / benefit rule, or the guidance used in 18 implementing the rule.
19 DR. OKRENT:
Excuse me.
But that I thought had be2n l
20 at least in question by a legal decision coming from the 21 staff's own OCG.
22 MR. NEWBERRY:
The thousand dollars per man ram?
I 23 DR. OKRENT:
Using only the thousand dollars per man 24 ram.
l 25 MR. NEWBERRY:
I am not familiar with that question.
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1 CHAIRMAN KERR:
There always is it seems to me r v
2 fairly significant difference between the place where that 3
originated which was in Appendix I of Part 50, was not 6nly the 4
one thousand dollars per man ram.
One has a very specific 5
recipe as to how one determines how many man ram.
Regulatory 6
guides, there is the method of calculation.
Whether one' agrees 7
with the results or not, the rule is fairly specific as to how 0
one goes about determining how many man ram are involved.' I 9
mean at least so it'seems to me.
10 DR. MARK:
Mr. Chairman, you are mentioning something 11.
which I probably should know but don't.
What is thathspecific 12 rule that determines how many man ram are involved?
Is it 13 integral of some sort, either in time or in distance or'in' 14 both; how does it go?
15 CHAIRMAN KERR:
Well, Appendix I describes the-16 permissible or maximum permissible exposure to populations due 17 to the emissions from normally operated power plants,.and it 18 gives, regulatory guides associated with it, give recipes for f
19 determining the calculated emission, the calculated' exposure 20 which one integrates over population, out to a 50 mile' radius.
21 DR. MARK:
I apologize for not knowing just how that 22 reads.
I should know, but those, you refer to one of the 23 questions I had in mind.
It reads out to a 50 mile radius, and 24 it' reads out to one year or a million years or what?
25 CHAIRMAN KERR:
It assumes that one has a' calculated i
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emission which is constant, so it is an exposure rate.
It is
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2 so much per year.
3 DR.~ MOELLER:
It is per year, and if I remember 4
correctly,'I don't think the 50 miles is key here.
It is to 5
the maximally exposed hypothetical individual at defense posts 6
and so forth.
It does not have a thyroid dose greater.than ten 7
millirams per year or whole body greater than, 345, somewhere 8
in that ballpark.
9 CHAIRMAN KERR:
It is only in the area that the 10 thousand dollars per man ram comes in. There is a maximum 11 exposure.
12 DR. MOELLER:
You are right.
13 CHAIRMAN KERR:
The numbers are in the rule.. The way 14 in which one arrives at the numbers, the recipe, is in the 15 regulatory guide.
16 DR. MOELLER:
Dr. Kerr is correct.
You calculate the 17 total collective dose out to 50 miles and if by spending a 18 thousand dollars you can reduce that dose by one person, you 19 must do so on an annual basis.
20 DR. MARK:
That 50 miles one might estimate that the 21 dose was a milliram, or tenth of a milliram.
It doesn't l
22 matter.
23 CHAIRMAN KERR:
The point here is there is a fairly j
24 unambiguous recipe which one has to make a determine.cion.
I 25 mean whether you agree with the physical reality or the logic.
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1 DR. MARK:
I am very much involved in wondering about 2-that.
Are,they using the:three linear quadradic. extrapolation-3 or using some previous. linear extrapolation?
Who knows?> I 4
can't tell.
5 DR. MOELLER:
'It is a formula,.as Dr. Kerr points 6
out.
And you are correct, It does not matter what:thei" 7
individual person's dose is.
If you had a nuclear power plant-8 with a population ten times the densities of another1one, then 9
that one would have to act upon a dose rate one tenth as much.
10 DR. MARK:
- Sure, i
11 CHAIRMAN KERR:
Mr. Okrent?
12 DR. OKRENT:
I think sort of the all-agreed rule did 13 have1what I consider to be an informative what is known
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14 discussion with the legal group last night, and I had hoped we 15 would get an informative insight as it can be discussion from 16 the EDO today.concerning those things that are on the technical 17 side of this rather complex little issue.
It seems like we are 18 going to get sort of a what you call an outline discussion of 19 the thing.
20 If that's the case, I almost have the suggestion that i
21 we make sure it is not too long; secondly, that we notify EDO 22 that we really want to get the benefit of their insight as to 23 how difficult the problems are and how they think we should j
i 24 approach it.
That's really it seems to me the intent;of a
.f 25 meeting like this.
I consider having EDO send someone down and r~(-)
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MR'.NEWBERRY:~ IfmI-understand'yoErLcomment,JI had a
'4 little trouble hearing allfof it,.but your concerns:are' focused
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.on.the-aspectstof the rule that were there before and'are'still 6
there:and are'not really, were not really addressed by.Lthe-
.7-court.
Is that correct?
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DR. OKRENT:.That is part of it,-but we are' going to
- 9 come to a question of what'is adequate.
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Yes, sir.
I respect;that; I respect'
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.DRv-OKRENT:.But we never.did get anLanswer asito, at least in-my own opinion, as to just what is a. substantial, what i
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.14' is.the" word, increase, and I have readfCommissioner-nzenstein a
-15 reviewing-what he thought.the Commissioners had done'in~that a
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.16 regard on Indian Point.
.I must say what he said was true.
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18 but I didn't.get.something like that when:I tried to' discuss 19 the matter with high-level members of the staff, but-I must.say 20 I don't have a clear picture in my mind of what is, what is 21' substantial from a technical point of view,_ and if somebody; 22
'around the table thinks he does, I would appreciate him telling q
23 me what it is.
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- 4 MR. EBERSOLE:
I am learning nothing from these two 4
25 sheets of paper.
I wrote rings around a half a dozen wdrds,
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1 adequate, further improvements, analysis, what is an. analysis,
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substantial increase,-'and other--adequate, redefining adequate:.
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I can get nothing out of this.
This is hogwash to me.
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MR. NEWBERRY:
Well, the--
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CHAIRMAN KERR:
Why don't we listen to the 6
presentation then?
Maybe we will. learn something.
- Whytdon't 7
you continue?
8 MR. NEWBERRY:
Okay.
The, let me point out the 9
changes that were made as a result of the court decision.
10 There is a change made on the second exception, that is this, 11 the second situation where backfit analysis is not required.
j 12 It is a wording change to line up with the Atomic Energy Act.
13 The term is now adequate protection rather than no undue risk.
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k-14 The most significant change is the third exception, which 15
. addresses the ambiguity in the' wording, that the court was 16' concerned.about, and it has to do with actions involving a 17 redefinition on the level of protection judged to be adequate.
I 18 The court was concerned about ambiguities in:the 19 briefing, the court brief, and in the Federal Register notice 20 of, promulgating the rule.
21 Now the last paragraph on the vugraph responded to 22 the court's concern that there was nothing in the rule, I 23 believe they termed it there was nothing positive in the rule 24 that would require or tell the Commission what to do if in 25 their judgment, adequate protection did not exist, and that i
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1 change was made to respond to that specific concern-of the 1
2 court.
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Now Mr. Ebersole's comment is not, I don't take 4
offense at your comment about, you know, that the meat or lack 5
of meat that is in those vugraphs.
I think maybe I. tend to 6
have that, a little bit of that feeling myself when I look at 7
them.
8 MR. EBERSOLE:
To say this is unambiguous isistrictly 9
to the imagination to experience.
10 MR. NEWBERRY:
Okay.
It certainly doesn't, the court 11 decision certainly doesn't clear up many of the questions that 12 we deal with every day in terms of when we deal with the 13 regulatory analysis, argue about levels of what is substantial,
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14 what is the question of adequate protection that engineers deal 15 with.
The court decision did nothing to clear up those 1
16 specific questions, as I see it, i
17 What I wanted to get into next is what is the impact 18 on the way we do business with the court decision?
I don't see 19 a significant impact.
I mean there is no, there is nothing 20 there that would change the way that we are doing business in 21 terms of clearing up all these questions that are on the' table 22 right here.
23 The question of adequate protection say, in the 24 process that we go through every day to determine whether those 25 plants out there are safe enough to operate today or tomorrow, i
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I don't see being changed, and the only other comment'I'would 2
make there is the decisions being made~on Peach Bottom or 3
whoever in terms of adequate protection, whether that' plant' 4
should be allowed to operate, it has been my experience the 5
cost hasn't entered into those day-to-day decisions, and I 6
think to some degree that, you know, that the court cases is, 7
maybe brought that out.
I. received some comments on this third 8
excepticn that would indicate that it would provide a ' basis for 9
more arguments or a stronger argument for more requirements, 10 for doing more to plants.
11 MR. EBERSOLE:
I thought it might at least' invite 12 less rigidity in the, based on doses that you are speculating 13 in the first place.
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14 MR. NEWBERRY:
It takes the argument right'to what in i
15 your judgment is adequate?
i 16 MR. EBERSOLE:
It has to be composite form of some 17 sort.
I believe the framework for that composite informed 18 judgment, some methodicity, I' don't see expressed anywdy.
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19 MR. NEWBERRY:
That is correct.
Certainly no
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20 specificity came out of this decision.
21 MR. EBERSOLE:
Not the rigid mathematics which turn 22 out to be ridiculous half the time.
23 CHAIRMAN KERR:
Would you judge that the court's 24 principal concern with the rule and annual chapter being-l
-25 whatever it considered, was ambiguity?
That it wanted to O
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1 remove ambiguity, in order to consider the rule appropa3 ate?
2 MR. NEWBERRY:
I, read the decision.
I certainly 3
haven't reviewed all of the court cases referenced in the 4
decision, but I think the court had two concerns.
One was the s
5 ambiguity, and I.know judge McLaughlin mentioned in the court
'6 decision that, that he thought that the ambiguity may have been 7
intentional, but so I don't want to read the judge's mind, but l
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it appeared that the ambiguity was primary concern based on my 9
reading.
10 CHAIRMAN KERR:
It might therefore follow that one 11 can make a modification, want to come up with something that is 12 somewhat less ambiguous.
Or perhaps the judge felt.it was not 13 ambiguous enough.
Is that a possibility?
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NEWBERRY:
Well, the ambiguity I thought., and I 15 will let Steve follow up here, what I thought the court was 16 trying to get at was this situation, you know, the distinction 17 between case number,' exception 2 and 3, two being a situation 16 where in your mind, you have a standard of adequate protection 19 or a judgment on what adequate protection is and you find out 20 that a facility doesn't measure up and in that case, you aren't 21 required to do a backfit analysis.
i 22 What the court was getting at, and I think it was l
23 some words that we had written or stated on the record,'was 24 that the situation about our thought process and our definition 25 of what is adequate, that is in that thought process, and here
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(it isicalled' defining or-redefining'a' level-of. adequate;.
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protection, herelin our minds, that costs were not to be-a
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' consideration.-
It is a little bit different.
.It is hard1for-s me in practice--you'can think'about this--it is hardofor.me in 4
5; practice to'separat'e the two.
But that was ' the aspect of-it, I 6
think whatLthe court was driving at.. ' Steve?
Do you have 7
anything to add?
8 MR. CROCKETT:
Scott and I are in basic ~ agreement but l
'9 put sli.htly another.way,'let's be careful to distinguish two 10 kinds ~of, let's be careful to distinguish two kinds of-11 ambiguity here.
There is the fundamental ambiguities of, of 12 the: key terms like adequate protection, substantial increase, n
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'and all the.other things that you circled there.
The court did
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14 not touch that ambiguity, did not criticize that ambiguity, 15
'indeed could not have becautie it is all in the Atomict Energy 16 Act, most of it.
I think Congress thought and I think'the l-17 courts thought that you all as informed technical' people would 18-
-know what those words meant at any particular case.
.o 19 Now the ambiguity that the court went off,at, the 20
~ ambiguity caused by a single sentence or maybe two sentences 21 because one was nearly a copy of the other which said that we 22 would apply the backfit rule, cost / benefit analysis section of 23 the backfit rule, even redefining what adequate protection
-24 meant,' they said that's forbidden under the Atomic Energy Act.
-25 They did not say tell us what adequate protection means or Heritage Reporting Corporation (202) 628-4888
4 k
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/
.1 you're arbitrary and. capricious.
I1could never figure out why.
2 UCS.didn't'come in and.say this rule is silly because.it never 3
says what substantial means,.but-they.didn't.
That^ ambiguity 4
-was' untouched.
5.
They simply wanted us to clarify, and proposed l rule 6
goes no further than to clarify the single point that'we will
- c 7
not apply the cost / benefit part of the backfit rule when 8.
redefining what' adequate protection means.
We were' called upon-9 to do no more.
Indeed I don't think we could have been 10 expected..to do'any more.
These fundamental ambiguities..have 11-been there since 1946.
They were reinforced in 1954 'and; have 12' not been touched since.
13 LDR. LEWIS:
It's'hsrd to remove ambiguities that were
- 14 really never there in the first place.
i 15 MR. CROCKETT:
I would like to say,' backed by'the 16 OGC, I.think Scott has been trying to tell you this and'i would 17' want.to make sure you are understanding what we wouldilike to 18 say--we don't'see that this, that the staff ever applied the 19 backfit rule in accord with this pending sentence.
We,can 20 think of no case in which that happened.
In fact, we' don't 21 know what the hell that sentence was talking about or how it i
22 even got in there. Nonetheless, it became the the tail that 4
23 wagged the dog, became occasion for the court to toss the whole 24 rule out without consideration for any of its other things.
)
25 DR. LEWIS:
You could have appealed it.
Heritage Reporting Corporation f
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1 MR. CROCKETT:
Since it has such a simple fix,<there 2
was no point in going back to the court.
There was, 3
quarrel--one of the other reasons I pointed out to thei
'4 subcommittee last night, there had been four days before this i
S decision, 11 to.zero decision in the Court of Appeals, despite 6
enormous division in that court right now between recent t
7 appointees and earlier appointees that the EPA when considering 8
what safe meant, could not take costs into consideration, but 9
when considering what margin of safety it wanted, could take 10 costs into consideration.
11 We saw the handwriting on the wall.
We were.in 12 analogous situation, no foothold anywhere in the court.
There 13 was simply no point in going back when the whole thingicould be
\\-
14 cured by a single sentence which reflected our practice and set
.15 things straight.
16 DR. LEWIS:
Thank you.
.i 17 DR. OKRENT:
Excuse me.
My only problem is Iidon't 18 really think what has been occurring, what you call.our!
19 practice, is in accord with this new version of the rule.
20 MR. CROCKETT:
Well, we had a brief discussion-like 21 this on the phone, and I may have gone too far.
As far as I 22 know, the practice has been that, but I deferred to you'in that 23 say case as one who would know our practice better.
At least 24 we know of no case since 1985 in watching the rulemakings come L
25 up, we would know less than plant specific backgrounds, but in fleritage Reporting Corporation (202) 628-4888 j
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2
- 1. M R. f N E W B E R R Y :- I would be--if-you want to pursue 3
that, Dr. Okrent put an example out, your comment was that n
x 4.
=currentipractice is not in line with the proposed rule,:right?-
E 5
DR. OKRENT:
I gave the example last night.-of.:the St.
6:
LucyLhearing board which judged that station blackout 7
. provisions at.that plant, even.though.they met the staff's-I
.8 standard SRP, et cetera, did not provide adequate protectionLof; 9
.the,public, and I believe.when the staff under pressure'took up 10 that USI.because they had no choice, they applied it back to
~11 ~
the rule'with. costs involved, although the ASLP opinion which:
12-was'not' overridden by the Commission, said we are not'getting adequate safety, so as I understand the situation, that was-a.
13 14' clear case.
I haven't looked for.many.
It is one that sticks o
.15 out'in my mind.
16 MR. NEWBERRY:
I'm not familiar with that, but based 17 on what you say, on the face, I can't disagree.
I think.:all I 18 would say in summary for my brief presentation is that,'that 19 the court decision is really in line with what our practice'has 20 been.
This is an interesting comment that Dr. Okrent makes.
I 21 am not familiar with it.
And therefore, we don't see a 22 significant impact.
I mean all the difficult questions dealing 23 with regulatory analysis are still there, are outside of the 24
- scope of the court decision.
Are there any other questions?
25 MR. MICHELSON:
Yes.
I have a question.
I am trying p
V Heritage Reporting Corporation (202) 628-4888
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I to understand how this applies in the context of the' resolution 2
of generic' issues as an example.
3 Generic issues often come up because the original 4
regulations were perhaps not fully clear and somebody 5
postulates a situation, and then we go back and we read the 6
regulations, a;>.d we work through a generic issue res6lution 7
which in many cases involves a cost / benefit decision'in'part to 8
decide whether to fix the plant or not, as a part of the 9
resolution.
10 It appears that fundamentally we have got to go back 11 to the regulation, and if we are in compliance with the i
i 12 regulation, we are adequate I guess is the word, but 13 regulations have to be interpreted and that's a part'of the O-14 p'rocess of generic issue business, so my real question' is' do we
\\
15 do a strict reading of the regulations and if we are not 16 strictly in compliance, then there is no backfit, no :
17 cost / benefit involved in the analysis?
That's what'I'g6t last 18 night I thought.
Is that you are adequate only if yohic6mply 19 with the regulations?
Is that correct?
20 DR. SIESS:
Unless you want to redefine it'.
21 MR. NEWBERRY:
Let me try and answer that.
For a 22 couple of reasons, I would say that's not, not correct.
One is 23 compliance with the regulation, regulations alone does'not, it 24 is my understanding, does not necessarily provide adequate 25 protection.
I make that statement based on both discussions
( )-
Heritage tieporting Corporation (202) 628-4888 l
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1 23
()
1-with lawyers and my understanding of and experience with the 2
regulations and sometimes being very general and the-fact that 3
you can have safety concerns even in. situation whereethe plant 4
meets.the regulations.
5 MR. MICHELSON:
You said that could be, that icould 6
be--
7 DR. SIESS:
Can you meet the regulations and be 8
unsafe?
Is the converse true?
'i 9
MR. MICl!ELSON:
It is possible I think he is saying.
10 11 MR. NEWDERRY:
I think--
12 DR. SIESS:
To meet everything in here and still be 13 unsafe?-
4
.O l
14 DR. OKRENT:
Let me comment on that.
My--in 15 regulation we are not thinking about what we now callosevere 16 accidents when they are prepared.
There is no reason to think 17 that they are. adequate to deal with severe accidentstexcept i
18 like some miracle, quite a miracle, and so to say that a plant 19 meets the existing requirements on containment if it has 1
20 arrived at par 100 or something else, and therefore have an 21 adequate containment flies in the face of any mature judgment I 22' would say.
23 I think that has been clear for twenty years at 24 least.
25 MR. MICllELSON:
Let me ask my question differently Heritage Reporting Corporation (202) 628-4888 i
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CHAIRMAN KERR:
Just a minute.
.I think theispeaker y
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'4 MR. NEWBERRY:
I: wanted-to make another comment.
I.
R. don't!know if it.directly answers your question, but certainly.
- g. -
'6' is'related, and'it' involves the process'you referred to in,
- 7f ~with respect to. generic issues or'any. generic. concern.
Maybe
^
0-it,is'not a generic issue, a concern that was,' lead to the
- 9.
. Issuance of a generic letter or something.that needs:to be done 10 rather near term, and'it has been my experience with the staff 11) and:in dealing'.with the:CRGR, for example, that the first-thing.
112-that'is' addressed and sometimes at length in heated' debate, is
. 13.
whether,;you know, this concern is significant enough to such 7gbf
- 14 that adequate protection or whatever you want'to call.it is not 15 provided,-and that we should just go ahead and do something.
l 16:
MR. MICHELSON:
That's a different definition of 17 a'dequate protection than'I think I have heard before; 18 MR. NEWBERRY:
You--
i i
19
' CHAIRMAN KERR:
He was not describing a definition.20-11e was describing a process, and I think maybe we should let 21' him get to the end.
' 2 2.
MR..NEWBERRY:
I just am pretty much near the end.
I i
23 just wanted to, to mention that that process, my experience has i
24 been that the process is like two steps. The first one is to 25 get, get'the judgments on the table and deal with the, the 1
- OT lleritage Reporting Corporation i
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1 issue of how significant is the issue?
Do you need to do
=
2 something rather quickly because the safety concern would i
3 question whether adequate protection exists?
4 MR. MICIIELSON:
That is tacF;1ed from the 5
probabalistic or some other kind of a viewpoint.
t 6
MR. NEWBERRY:
If those arguments are what got you 7
there, there is information available that you can use to make l
8 that decision certainly.
9
-MR. MICHELSON:
I am somewhat at a loss.
If you have 10 a plant which does not meet the regulations, you have' found for l~
11 some reason it rates a generic issue then let's say,'lt 1
12 can't--what happens, we identify a generic issue--wait' a' 13 minute.
Let me finish.
We identify a generic issue f6r 14 whatever. reason, then we go back and look carefully at'the 15 regulations and find well gee, maybe we didn't really meet the 16 regulations'to,begin with.
And that has happened thatwell, we 17 really don't need a strict reading of regulations, yet we L
18' proceed on through this generic issue with cost / benefit 19 calculations, so forth, trying to decide whether to do' 20 something about it.
8 21 If it doesn't meet the regulations, don't we go back 22 and say that part of the fix at least has to be done'without 23 cost / benefit?
We have to at least bring the plant up'to 24 meeting the regulation.
I think, that part I think we do
~25 without cost / benefit.
Now if we want to take it beyond'the
)
lieritage Reporting Corporation (202) 628-4888
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1 regulations, then we start doing some kind.of a costtdecision, i
2 but.isn't, there isn't even a question of cost in bringing.it 3
back into compliance.
I 4
MR. NEWBERRY:
That-is correct.
\\
5 MR. MICHELSON:
Now the only problem I have with that
- j i
6 is that' regulations, unfortunately, aren't that well written f
7 and there is a lot of judgments involved, in deciding whether 8
or not we meet'it, a lot of interpretations and so forth.
I 9
guess that's a, process that we can't afford anymore somehow.
1 10 But bringing it back into what appears to be compliance is not 11 a cost consideration.
Is--that is correct, isn't it?,'I will 12 keep that in mind in the future.
13 CHAIRMAN KERR:
What I heard, and it is not'quite kJ 14 what you are saying, is that to bring it back into whattyou 15 think-is adequate or safe, this may or--
16 MR. MICHELSON:
That by definitien is back.into 17 compliance with the regulation as a minimum I think..'
18 DR. SIESS:
It is a two-step process.
If it'doesn't 19 meet the regulations, you make it meet it.
Staff never has any 20 problem with what you are doing if it doesn't meet the q
21 regulations.
At least the regulations that affect you at the 22 time of the license; there is a problem if it doesn't meet the 23 current regulations when it was licensed twenty years ago.
24 MR. MICHELSON:
Then that is without consideration of 25 cost.
Then we start thinking about cost, that we believe it O
Ileritage Reporting Corporation (202) 628-4888
27
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1 should go further.*
a 2-
' CHAIRMAN KERR:
I misunderstood because I thought I I
3 was hearing that there could be a situation in which a plant j
4 would presumably meet the regulation, but would be deemed not 5
adequately safe, and getting from the regulations to adquately 6
safe one does not apply cost / benefit.
7 MR. MICHELSON:
That's another aspect, that's'right.
8 MR. NEWBERRY:
That is correct.
9 MR.-MICHELSON:
There is two ways you look at it and 10 that's the other way you look at it.
I was trying to make sure 11 I understood the first way.
I have got to get to, back'into 12 compliance with the regulation and I don't have to consider 13-cost in doing that.
k-14 CHAIRMAN KERR:
You don't have to consider cost in 15 going from regulations to adequately safe, either.
16 MR. MICHELSON:
That's right.
That's the other part 17 of it.
18 DR. LEWIS:
My understanding, I think an Act, that is 19 a separate relation automatically.
I think that an agency that 20 makes a set of regulations which it didn't conclude made a 21 plant adequately safe would be in a very tenuous logical-22 position.
The issue is that the rule I think says defining and i
23 redefining the--when you redefine the regulations, you are in 24 effect redefining the term adequately safe.
I would assume 25 that you cannot consider costs at that point, but is that going O
Heritage Reporting Corporation (202) 628-4888
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1 to be a problem?
I don't know who I am asking.
~-
(f 2
CHAIRMAN KERR:
What.is it that you are asking?
Is 3
there--
4-DR. LEWIS:
You see, the issue has always been if you 5
change the regulations, and require a plant to meet the 6-
. regulations of the day instead of regulations'of the time it' 7
was licensed, is that or is that not a backfit, and'if when you 8
change the regulations, you are automatically redefining what 9
is meant by adequately safe, then that would appear to'me as a 10 lawyer, of course, to be something in which you are~not allowed l
11 to consider costs so that would be an ambiguity in the' i
12 application of even the new backfit rule.
Am I wrong? 'Of 13 course I'm wrongt f
14 MR. CROCKETT:
If redoing of the regulation'is'on the 15 Lasis of information which indicates that regulation as it 16' stands does not secure adequate protection, then no, none of 17 the cost justifications judgments required by the rule should 18 be implied.
19 However, if the redoing of the regulation is because 20 you see that you can take care of a very large portion 'of the 21 residual risk here, although what you have in place you'think 22 is adequate, then the cost justification judgments called for i
23 by the rule are permitted.
In other words, there are'two 24 circumstances in which you might redo the regulation, and 25 depending on whether adequate protection is in the judhment of
(
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- i. '
- 2-justification standard or not.
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- 3 DR.eLEWIS:
I'am a lawyer and I recognize it, that
~
^ he. moment you break!the link between the regulations and'the
- 4.:
t M
5
, definition of adequately safe, you are in a'--
6
.MR.
CROCKETT:
I agree.'I should have'acknowle'dged n
7; that a little bit more at the.beginning.
I think. Tom'and I 8
would agree,that you are in. hot water then,.and that'those; 9
situations occur only on the~ basis of"information which shows H
- 10 that what:you thought, the level cf protection you. thought you 11 had, was.in fact.not secured by compliance with that',
12
' regulation.
Those' situations.I don't think. occur very often.
13 DR.. LEWIS:
.No, no, I wouldn't think so.
- O-14
.MR..CROCKETT:
And they are troublesome situations 15 that s'ays your' original judgment about.what it required as'a 16 matter of, engineering to achieve a certain vaguely underatood 17_
' level.bf adequate protection, was not good. Judgment,cyou.have-18.
since on the basis of better information, come to a different-19 judgment about what is required.
20 DR. LEWIS:
But if you take that position, then you 21
.are retaining the link between regulation and adequately' safe, 22 that I can see as logic.
23 MR. CROCKETT:
The link may be broken in another way.
24 I am not sure whether this should cause discomfort or not.
25 That is you could have regulations which required more than Heritage Reporting Corporation (202) 628-4888 i
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adequate protection, and they are justified on the giounds of 2
cost effectiveness.
3 DR. LEWIS:
I would have a problem with that because 4
then if I were a plant owner who got turned down because'I s
5 didn't meet the regulations, I would say that the NRS has 6
exceeded its authority because my plant is still adequately 7
safe because.then NRC is saying that the regulations' guarantee
/
0 more than adequate safety.
I wouldn't get into that hole.
9
-MR.'CROCKETT:
That's a good point.
And it has in 10 effect for the time being been resolved by the court decision.
11 The court said for the.first time as far as we'can'tell, that 12 any court said.it, that we have the authority to require, we 13 had the discretion to require more than adequate protection-and
\\~
14 that the sole. justification for ever considering cost"whs as 15 because we were in the discretionary area.
It was the 'most 16 curious thing to see Atomic' Industrial Board--that was' its at 17 the time--and the Union'of Concerned Scientists on the'same 10
' side of the issue, both saying we can never require more than 19 adequate protection, each for its own reasons saying that; each 20 for the reasons that you just gave.
21 DR. SIESS:
If this is a measure of adequate' I
22 protection.
23 MR. CROCKETT:
It is presumptively a measure'of 24 adequate protection.
25 DR. SIESS:
There is not more than a dozen plants l
l lieritage Reporting Corporation (202) 628-4880 l
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'l-that provide' adequate protection, because this is made in 1987,.
2-and an awful-lot of plants out that there were licensed under 3
the previous version and therefore they are not providing 4
adequate protection.
There is something wrong in the time
'S domain of using this as the definition.
6 MR. CROCKETT:
Well, I'm sorry.
Were7you through?
7 DR. SIESS:
Yes, I'm through.
8 DR. LEWIS:
.I hope.these guys are as good engineers 9
as we are lawyers!
10 MR. CROCKETT:
'I started out--
'll DR. SIESS:
The SEP program which was exactly what I 12-am talking about.
13 MR.-CROCKETT:
I started out saying last night this O-N 14 is your problem, not ours.
Congress turned over to you the 15 judgment about adequate protection, but that legal co9straints 16 can, can be drawn around your judgment in this case.,
l h
17 Now'there is an easy way in which one can' reconcile 18 the plants.
Most plants don't meet 10 CFR.
The first is that 19 maybe some of the regulations already require more than l
20 adequate protection.
Don't ask me which ones, all right?
- 21 Second, this is the harder, and this is the, like 22 trying to figure out how many backfits sit on the head of a pin 23 apparently because engineering judgments about what is adequate 24 do, as far as I can tell as the curbstone engineer, change over 25 time, and tend to become more severe.
Somehow there is a I
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I temporal aspect to adequate protection.
Adequate protection is l
2 going to vary according to circumstances.
Part of the!
3 circumstances.will be the time at which the plant is. licensed.
4 I,
at the moment I don't know quite how to get around 5
that, or even.whether it needs to be gotten around.
6 MR. MICHELSON:
Clarification on your statement 7
should there be the regulations in effect at the time of
.8 licensing, or should it be the regulations in effect today that 9
you use as.the measure of adequate protection--I am not sure 10
.you have quite answered it.
He didn't answer that question 11-specifically.
That is the question, though.
Is it really the 12 adequate, I meant mecsur 4 by the regulations in effect at time 13 of the operating license or construction license or just what?
14 MR. CROCKETT:
The court didn't touch on this. I 15 would think that it is presumptively, well, depends on what you 16 say in each new upgrading of the rule.
Whose plant have you 17 grandfathered and whose have you not.
10 MR. MICHELSON:
Assume you remained silent on:the 19 issue'in the regulation.
Then what regulation pertains?
20 MR. CROCKETT:
I hope we don't remain silent' too 21 often.
22 MR. MICHELSON:
Some of these upgradings, some'of 23 them are.
i 24 MR. CROCKETT:
You may be right.
I am too new:to the i
25 whole business to know the history well enough of which j
Heritage Reporting Corporation l
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1 regulations'have been cleared and grandfathered, which have not 1
2 been.
l 3
MR. MICHELSON:
If they remain silent, would you go i
4 back to the regulation at the time of the construction permit 1
d 5
or the operating license, or--
1 1
6 MR. CROCKETT:
If indeed the industry allowed us to f
i 7
remain silent, I -- off the top of.my. head--
8 MR. MICHELSON:
Let me get the answer.
9 MR. CROCKETT:
Off the top of my head, I would say 10 that the regulation has to apply to everybody.
4 e
11 DR. SIESS:
He doesn't know the answer because'there l
12 are times.when there are changes in the regulation, not really 13 backfits, but the next time a plant comes in'for reload' they 14
~make it.
'15 MR. MICHELSON:
Just trying to determine--
16 DR. SIESS:
Has nothing to do with the rule.
l 17 MR. MICHELSON:
Somewhat literally then the question 18 is in compliance, does that mean compliance with the current 19 regulation or the regulations in effect at the time the l
20 construction permit or what?
1 l
21 MR. CROCKETT:
The lawyer hopes that rule never gets 22 out of the staff until it says this rule applies to all plants 23 licensed after such and such a date.
l 1
i 24 MR. MICHELSON:
Those licensed before that date?- What i
I 25 regulation?
l Heritage Reporting Corporation (202) 628-4888
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1 MR. CROCKETT:
No, sir, does not' apply.
2 MR. MICHELSON:
What regulation does apply to them?
3 MR. CROCKETT:
One in effect at the. time they were 4
licensed or--
5
'MR.
MICHELSON:
Licensed for construction or 6
operation?
7 MR. CROCKETT:
Depends.
8 MR. MICHELSON:
Generally it is operation I guess.
9 Okay.
Just trying to understand what all this means.
10 MR. CROCKETT:
So am I.
11 DR. SIESS:
Lawyers don't make backfits.
The 12 engineers do.
13 MR. MICHELSON:
Then they keep throwing cost / benefit t
14 at us.
15 MR. CROCKETT:
Lawyers didn't throw that at you'.
16 This wasn't our idea.
17 MR. MICHELSON:
No.
I realize -- I have got-'my 18 answer.
19 CHAIRMAN KERR:
Further questions or comment?
Did 20 you finish your presentation?
21 MR. NEWBERRY:
Yes, sir, that's it.
22 CHAIRMAN KERR:
Well, thank you very much for 23 clarifying the situation for us.
24 MR. WARD:
I hear a lot of chuckles. I think'it has 25 been clarified.
}
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1 DR. SIESS:
It was clear to me before.we started.
- v-2 CHAIRMAN ~KERR:
We have scheduled a 9:45 break.
We 3
have ten minutes, therefore,.to discuss what we havehjustebeen 4
doing.
Mr. Okrent, do you have any recommendation as to 5
whether we are, are you proposing that we write something as a 6
result of this discussion or that we--my impression is that the 7
approach is going to be used to try to get a rule apreoved.
8 Once it is approved, then we will try to find out whatilt 9
means, but that we really shouldn't worry too much about what 10 it means until it has been approved.
I am not sure one ever 11 finds out what a rule means until one tries to apply.it, so I 12 am not sure this.is all bad.
13 DR. OKRENT:
Unless requested by somebody, Congress
,~\\
(l
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14 and others, I would myself not' recommend as a volunteer, an 15 opinion of the change.
I like the newer one better.than the 16 old one, although it still leaves open some questions on 17 substantial, but I do suggest that the committee ask some 18 subcommittee to think about how--the committee should not, not 19 just follow what is happening here, but see whether it wishes 20 to be active in shaping what develops.
21 DR. SIESS:
What develops legally or.what develops --
22 DR. OKRENT:
No.
Let me assume that this is passed 23 and so forth. Nrhere may be some questions concerning whether 24 some prior actions have to be re-examined; just the way the 25 staff in the future defines substantial.
O 4
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'DR.
SIESS:
Case by case, look at cases.
2 DR..OKRENT:
You can try that, but I'm just saying I 3-think the committee should consciously take this up as a matter 4
that it let's say not only follows,'but has interacted <in 5
.because I think it is an important issue.
6 CHAIRMAN KERR:
Further comments?
Questions?:'
7 Ten-minute break that ends at ten o' clock.
-8 (A brief recess was taken.)
9 CHAIRMAN KERR:
Safety assessment program open --
10 MR. FRALEY:
You have enough for a quorum, Mr.
11 Chairman, but I will round some people up.
l 12-CHAIRMAN KERR:- The question of a quorum did not 13 arise unless somebody raises it.
Nobody raised it.
Mr. Ward?
\\
14 MR. WARD:
Do we have a quorum?
g 15-CHAIRMAN KERR:
A quorum is present.
16 MR. WARD:
The topic is the continuing our review of 17 the ISAP, the staff's integrated safety asuessment program.
18 There is some material on this under Tab 3 in your book,'and we 19 will-have a staff presentation on developments sinceilast time 20 in just a minute, but first I will remind you what this is all 21 about, make a couple of comments.
22 Back after our July meetings, we reviewed the,ISAP 23 program that had been carried out to date, and t, hat involved i
24 two particular plants, Haddam Neck and Millstone I.
And we 25 issued the, a report to the chairman, the chairman after that 1
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)
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meeting.on July 15.
A copy of that is in the book; and I think 2
the letter.was quite supportive of the ISAP process.
3 We expressed the opinion that this was-a good, seemed j
l
]
4 to have.been-successful program.
It was a good idea to, that 5
it should be extended in some way to plants beyond just these 6
two that was. involved in the pilot program, and we asked the 7
staff when they are ready to come in and tell us about their 8
plans for future use of the ISAP process or whatever would grow 9
out of ISAP.
10 Now the staff has issued a SECY paper which is also 11 attached which provides their recommendations for continued use 12 of the ISAP methodology.
That was issued at the end of' August, i
13-and in this paper, they recommend--we are going to hear about
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14 this from the staff, but they recommend that the ISAP approach 15 be' extended to all licensees.
I don't think, it should not be l
16 required of all licensees but be extended to all licensees as 17 the opportunity for them to use, and but specifically as an 18 element of the implementation program for the, under the severe j
i 19 accident policy statement, the so-called IPE or individual plan j
20 examination program, and I think we had recommended in'our 21 letter that, that, that some' sort of integration of these 22 things be considered.
23 You described the IPE program--there is also a copy 24 of the draft generic letter of what an IPE is supposed to be 25 about that was issued last spring.
That's in the folder, too.
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1 We are going to' hear about this from the staff now, but I have 2
got a couple of comments in that I think what they say their-3 plans on the SECY, they have kind of got it backwards..It 4
seems to me that the strength of the ISAP process is that it 5
can be a method by which a staff, the staff and licensee in 6
cooperation can treat all of the licensing regulatory; issues 7
that might require action by the liceneee at a particular plant 8
and treat them all in an the integrated manner, and when you 9-look at it in that way, it seems to me that the, whatever is 10 done as far as an IPE process should, should become subordinate 11 to an overall ISAP program rather than the other way..around, 12 and that in fact although I don't think we really covered this 13 very well in our letter, that in fact other evolving responses
'l O
14 coming out. for example, of the resolution of USIs, and: other 15 generic issues, should also, licensing should also be'given the 16
' opportunity to treat those requirements as part of an overall 17 envelope in the ISAP. process.
18 I'm not sure that that's at all what the staff has in 19 mind.
Ne will give them an opportunity to say what;they have 20 in mind and why they are proposing something different from 21 that, that sort of model.
So unless there are comments from 22 other members, I would like to go ahead now with the staff 23 presentation.
24 MR. EDERSOLE:
I would like to ask you if ydu'have l
25 any observations to make about the ISAP program in light of our l
($)
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regulations.
i 1
previous discussion and, regulatory deficiencies,
.jJ-2 Are they going to take out--
3 DR. REMICK:
The court reporter cannot hear you.
41 MR. EBERSOLE:
Outside:-- I don't see any procedural 5
approach.
Do you follow me?
I 6-MR. hARD:
I guess I don't see quite what the 7-connection is.
I can see the issue you are talking about, may 8
develop some, some requirements for a licensee and those might 9
be, could be considered along with everything else that is 10 going to resolve through the ISAP process.
11 MR. EBERSOLE:
Carl mentioned the two viewpoints for 12 improvement of the deficiencies in the regulations.
It is a i
13 substantial improvement.
I don't soo any part of the ISAP --
'i 14 which viewpoint you will take or which course you willitake,
_l 1
15 but you do whatever you want to do.
It seems like we have got
'16 to consider what we just hear'.
Well, I don't want to discuss d
17 that and end up--keep it in the back of my mind.
There are two 10 viewpoints you can take.
19 MR. WARD:
Yes.
I don't know.
I don't know how that' 20 works out.
21 CHAIRMAN KERR:
Mr. Reed?
i 22 MR. REED:
I have the same concern that you have some 23 of.
I worry about the large number of inspections and reviews 24 and re-reviews that take place in plants and the diversion of 25 plant people away from their appropriate duties.
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1 Now.ISAP sounded to me like a good way totdo' things, 2
to bo'ttle things-together, coalesce, and come out'with a good 3
review.
4
.However, I would like to know that since you-5 mentioned IPE, that the IPE is folded in and you don't do IPE 6
'anymore.
You do ISEPs and also the OSTI, operationh1' safety 7
team inspections, and the IDI, the' integrated design 8
inspections and the RERI, regulatory effectiveness' review 9
inspections, are folded in.
I mean you keep building like laws 10 keep multiplying.
They keep building all these regulations and 11 inspections to more and more burden the people at the plants 12 and they won't have any time left for safety operations.
13 CHAIRMAN KERR:
So you are suggesting that we should kJ i
14 eliminate ISAP or--
15 MR. REED:
I think it is a good overall way of doing 16 it, but what are we going to do with all these other'that seem 17 to be part of, pieces.
18 CHAIRMAN KERR:
The man is going to make a 19 presentation.
He is going to answer that question I'111 bet.
]
20 MR. WARD:
I think that's an excellent point.
I 21 guess I don't see the ISAP perhaps as substituting.
I mean I 22 think the ISAP is a process by which the licensee can respond 23 to all the new requirements that might come out of all this, 24 policy statements, regulations, feedback from inspections, and 25 all that sort of thing, so he can respond to all of those in r^s
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1 some integrated manner.
I think that's good.
It doesntt 2
relieve'the burden of excess, you know, excess requirements.
I 3
mean partially it relieves it, but it isn't going to eliminate i
4 tini sort of problem we are talking about.
i 5
MR. REED:
I would like to see if these things can be 6
put into one overall inspection, namely, the ones that I 7
' listed.
8 DR. SIESS:
I don't understand how ISAP relates to i
9 inspections.
i 10 MR. REED:
Or reviews.
11 DR. SIESS:
Or reviews, either.
12 MR. REED:
Well, the individual' plant evaluation, we 13 understand that one.
O' '.
~14 DR. SIESS:
That has nothing to do with ISAP.
ISAP 15 is how you implement plant specific or generic backfits.
16 MR, REED:
Well, it was my opinion that ISAP'does a g
i 17 complete re-review of what is going on and how the plant is in-18 compliance, j
'19 DR. SIESS:
That has already been done.
Somebody 20 said do this, you do that, you do the other.
This is just the 21 way of scheduling them, and integrating them.
i-22 MR. MICHELSON:
You would need to hear about it.
23 CHAIRMAN KERR:
Any further comments?
i 24 DR. OKRENT:
I think certainly your consideration 25 should be given not only to holding ISAP in with the' systematic Heritage Reporting Corporation (202) 628-4888
42 s
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1 study of each plant, identified as being appropriate under the 2
severe 1 accident policy statement, but that some means.be worked j
3~
out of accomplishing the equivalent'of'a Level 2 PRA with i
4 regard to the. names available in this process, some means be 5
accomplished of assuring that there is a broad participation by 6
the personnel, and I don't'just mean the guys who look,: update 7
a, the guys who need to look at the broad import of the.
8 entries, to look at the, and to have a feel for the course of 9
severe accidents and think about what one could do to extend 10 current operating procedures within the utility so that in, in
'll this one process, one helps to achieve at least a, an improved i
12" technical knowledge within the utility, and in fact I think if.
13 a utility commits for putting in a substantial amount of effort h-14 to learn these different kinds of things they would.have taken 15 a big step toward--not the only step needed, but a big. step i
'16
'toward building management and operational quality,.and f
17 building a basis for maintaining it over the long-term, and it 18 doesn't strike me as being an impossible thing to pull these 19 things together, and I wouldn't ask that they all be done in 20 two years or some impossible time, but to try to lay out a 21 schedule which is practical and not forever.
I'll leave you
, ith that.
'I 22 w
23 MR. WARD:
Okay.
Thank you.
Let's go now to staff.
24 Mike, Mike Boyle is going to give the presentation.
25 MR. BOYLE:
My name is Michael Boyle.
I am a member 1
Heritage Reporting Corporation (202) 628-4888
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1 of the Integrated Assessment Project Directorate but I"have, 2
what I would like to do first this morning is give you'a 3
briefing on what is in the SECY paper itself, and some'of that 4
.was explained to you last time in July at our meeting. "A 5
little bit has changed.
The SECY paper was written to:
6 accomplish two requests for the Commission.
7 The first request was to report to them on'bhe 8
progress that had been made in the program.
The second' request 9
was to try to make.some kind of recommendation to the 10 Commissioners as to what future course of action that lSAP 11 should take.
12 ISAP started a few. years ago with a concept in SECY 13 04-133.
The Commission looked at that and okayed the staff
(-
14 issuing an ISAP policy statement to the public encouraging 15 licensees to perform integrated safety assessments of:the 16 plants.
For various number of reasons, budget being olie of 17 them, that policy statement was revised in SECY paper"85-160 18 which started a pilot program of two plants.
Northeast: Utility 19 volunteered the Haddam Neck and Millstone I to participate.
20 The major elements of ISAP would be integrated 21 assessment of the SEP lessons learned, the pending regulatory I
22 requirements, those requirements which they are not yet 23 formally issued, but the staff has a very good idea of what is 24 going to be required of licensees; current licensing actions 25 that are presently on the NRC's books, and actions that the
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1 licensee has on their books, usually plant improvement 2'
initiatives.
There'would also be an assessment of a plant 3
speuific PRA, and the staff would compile and perform an 4
' analysis of plant operating experience, l
5 MR. MICHELSON:
Is the PRA a full scope or including 6
external events?
7 MR. BOYLE:
That was not stipulated in the~ policy 8
statement, no.
The licensee that performed the PRAs fdr the j
9 two plants performed Level 1 PRAs and is now working up the 10 Level 3s and incorporating some external events.
11 From that integrated assessment the staff prepared a l
12 PRA and issued an integrated safety assessment report,;ISAR, 13 and from that.
The final ISAR would have the development 14 issuance of the integrated schedule.
15 DR. MOELLER:
The November '84 policy statement 16 apparently almost immediately.was found not to work out, I mean 17 if in May you issue then a suggested revision.
i 18 MR. BOYLE:
There was a suggested revision. 'One of 19 the basic reasons was because of resources throughout'the 20 statement.
They decided to try it on a pilot program first to 21 see.
22 DR. MOELLER:
Resources among the itilities?.
12 3 MR. BOYLE:
Basically from what I understand, the 24 staff.
I 25 DR. MOELLER:
NRC staff?
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.7 11 MR.'BOYLE:- 'Yes.
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!DR.<MOELLER:
IJ found ilt unusual they. would: have
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-5:
tMR'. BOYLE:,That is something-I am notiprivyito the-
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'6 reasons what happened there.
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7
'DR. MOELLER:
November. oft '84.
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8
.MR.
BOYLE:
As I previously said,-'the participants.in L
L 9.
the ISAP pilot program-were. Millstone. Unit-I and'Haddam Neck.
10-'
The program was.-implemented.by: separate project directorate-d 11 "within NRR, and'we also<had-the draft reports reviewed 1by-peer, j
'12 review group, and we.had submitted them to the ACRS-for ' their -
13-
. review if you so. desired.
, At this.. time, the-draft' reports for both Millstone I 14~
15' and.Haddam-Neck have been issued, and the' final' integrated
- i 16
safety' assessment reports for both plants are due-shortly.
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- 17D
' Listed here are a' few of the findings:.that we have'found'for-
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- 18 Millstone I and Haddam Neck.
. e discussed.these in. fair detail W
2
'19
'in~our' July meeting, and basically from the operating 1
'20 experience reports and from the PRA on Millstone I we'found~
21
' that there was, a failure to maintain adequate long-term decay I
l 22 removal capability was a major contributor to the CMF for the 23 plant.
The' licensee had taken steps as soon as that was F,
24-identified to help reduce that contribution in the short-term
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2 51 and they initiated studies for long-term reduction.
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MR..EBERSOLE:
Is that identified as a failure to 2
meet regulations?
3 MR. BOYLE:
No, not that I know of.
4 MR. EBERSOLE:
The regulations don't say you have to 5
maintain decay removal, or they do not say that you have to.
6 MR. BOYLE:
I'm sure they do, yes, but this is a, 7
they have ways of maintaining-long-term decay removal.
They 8
found vulnerabilities in their system.
9 MR. EBERSOLE:
Then they don't have ways that are j
1 10 adequate to go back to our earlier--
l 11 MR. BOYLE:
They do now.
They fixed it up right
~
12 away.
i 13 MR. EBERSOLE:
And is this failure supported by--
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14 CHAIRMAN KERR:
Mr. Ebersole, use the' microphone, j
i 15 MR. EBERSOLE:
Is this failure supported by'what we 16 were discussing earlier, some sort of mathematical analysis on 17 the PRA base or just a judgmental call?
l 18 MR. BOYLE:
It was PRA based, mathematically.
They 19 went out and took a look at failure mechanisms.
20 MR. EBERSOLE:
So this is a backfit then, regarded as 21 a backfit?
22 MR. BOYLE:
It is not backfit if the licensee 23 volunteers to make corrections to the plant themselves, and 24 they did so.
25 MR. EBERSOLE:
They volunteer so you don't have to Heritage Reporting Corporation (202) 628-4888 i
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makejthem.
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2 MR. BOYLE:
That is correct.'
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.3 MR. EBERSOLE:
That is interesting.
C 4
MR. MICHELSON:
Is fire among the external events 5
they did considered in their PRA?
6 MR. BOYLE:
Yes.
-7 MR. MICHELSON:
They have done a fire PRA in 8
determining minor contributor to risk?
Must have because it is 9
not highlighted here.
10 MR. BOYLE:
-Yes.
And also discussed last time the 11 degraded grid protection system designed deterministically to 12 meet the staff requirements for degraded grid protection. The
-13
. fact as. analyzed in ISAP under PRA space, showed
'V 14 vulnerabilities that weren't obvious before, and we went back-15 and the licensee has redesigned,'is now going to be 16
-implementing that in the next, I believe in the next refueling 17 outage.
18 DR. MOELLER:
Is the key to the first observation the 19 words long-term?
20 MR. BOYLE:
Yes.
21 MR. MICHELSON:
One other clarification -- to what 22 extent were systems interactions considered in doing their PRAs 23 and so forth?
That is, of course, an outstanding generic
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24 issue, but I assume to some extent they must have thought about 25 it in arriving at some conclusions.
To what extent did they pt)
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1-consider system interaction?
2 MR. BOYLE:
-I believe when the licensee did their-PRA 3
work they took a look at, when they were looking at an event, 4
they looked at everything that was going to be affecting that S
event.
6 MR. MICHELSON:
Rather encompassing statement--when 7
you say everything, because I am going to go look at their fire i
8 PRA to see how they handled migration of heat and smoke and so I
l 9
forth in terms of actuation of fire protection equipment that l
10 wasn't in the immediate vicinity of the fire.
I just wonder i
I 11 what kind of PRA they really did.
12 If they have included everything, I will be 13 pleasantly surprised.
.){ /'
1 14 MR. BOYLE:
We_have sent copies of both of Haddam 15 Neck and both the PRA down to the ACRS staff.
It is around 16 here someplace.
17 DR. MARK:
I have may have missed this.
I am sure 18 you said it.
Long-term, what does long-term mean?
More~than i
19 eight hours?
More than eight days?
More than eight weeks or 20 what?
21 MR. BOYLE:
Long-term is well, I haven't looked at 22 this in quite a while. Long-term is well after the initial 23 event has happened, and--
I i
24 DR. MARK:
Long-term is what?
25' MR. BOYLE:
Long-term is we are talking like years or
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months after a thing has happened.
2 DR. MARK:
Why are you going into that?
3 MR. BOYLE:
There is still going to be the decay heat 4
around.
5 DR. MARK:
There is going to be decay heat forever.
6 You stopped worrying about it about ten to the 9 seconds, or 7
ten to the 7th second, in less than a year.
I mean 16ng-term 8
11 you got yourself through the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, you are 9
through.
You are with it.
You are done.
Maybe 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.
10 What does long-term mean?
11 MR. BOYLE:
There comes a point when they no longer 12 can supply the cooling capabilities if one single failure 13 happens.
14 DR. MARK:
If you track after the thing for two days, 15 you are in.
16 MR. BOYLE:
For lladdam Neck, there was, they found 17 there was one motor control center that there was a single 10 failure there, they would lose the capability to provide safe 19 shutdown.
The licensee is now in the process of building a 20 separate system to provide redundancy.
21 MR. EBERSOLE:
Was this regarded as a regulatory 22 deficiency or after all, I think there is words to the effect 23 about not permitting single failures.
24 MR. BOYLE:
Yes, I believe you are correct.
25 MR. EBERSOLE:
So this escapes the original review O
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l and there was a single point failure?
2 MR. BOYLE:
I believe so, but I-would like to qualify 3
that that people knew about it, but I think the staff for one 4
reason or-another a long time ago--this is a very old 5'
plant--wrote this off.
6 MR. EBERSOLE:
MCC was not a single point and I would 7
have no grounds legally to say it wasn't.
O CHAIRMAN KERR:
I thought we were supposed to get a 9
picture of ISAP and how it'was going to be extended.- If we 10 want to' review these individue.1 ISAP, which we have already 11 reviewed I think once, I guess that is okay, but we may miss 12 what they have to say.
13 MR. MICHELSON:
We are trying to understand the scope O-14 of what is being involved here.
Let me ask one clarification 15-
-- 11addam Neck also did a fire PRA?
16 MR. BOYLE:
I believe so, yes.
17 MR. REED:
The shutdown on Haddam Neck, was it cold 18 or hot?
Do you know?
19 MR. BOYLE:
I think it is hot.
I believe it'is.
I 20 didn't review that plant myself, but I believe it was.
21 MR. REED:
Perhaps it was shifted to cold tt'ere when 22 the motor control center became a problem.
23 MR. BOYLE:
It is in the report that he supplied to 24 you.
Some of the conclusions we found from conducting the 25 pilot program were that the performance of the probabalistic
()
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I safety assessment or-risk assessment, whatever you want to call 2
it,;and operating experience reviews provided, identified 3
significant areas of risk, and we also found that they'could be 4.
used very well as a tool in performing the integrated 5
assessment und supplying relative rankings for trying to l
6 develop an' integrated schedule for implementing actions.
ISAP 7
provided both the staff and the licensees with a much better 8
understanding of the plant design and its capabilities and its 9
vulnerabilities.
10 CilAIRMAN KERR:
Is the PRA performed in the course of i
11 an ISAP, or is that the new nomenclature being used?
l 12 MR. DOYLE:
ISAP is nomenclature for PRA 13 CHAIRMAN KERR:
Thank you.
14 MR. BOYLE:
They wanted to put the word safety into 15 it for some reason instead of risk.
Integrated assessment had 16 the potential to identify separate review areas, and find 17 common elements between them in order to find ~an integrated 18 resolution, which would provide a basis and provide a basis for 19 elimination of low significant actions.
The licensee >has made 20 comments on the draft integrated assessment for Millstone I, 21 and has proposed the identification of some of those low 22 significant actions to drop from their integrated schedule.
23 The staff hasn't reviewed all those yet.
24 In other words, ISAP provided the opportunity'for 25 both the staff and the licensee to identify areas which O
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a2L 'aren"'t: worth doing;-also idenhified areas which either' party H
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had known about1which are-significantfand should be done.
The.
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4:
!1ntegrated' implementation. schedule provided a stable" basis for s
5J -both licensee'and-the staff to man' age,a. current workload.'and-to-
.6:
estimate resources:for future.regnirements.
z7
'Another finding or conclusion"from;ISAP which'isn't 8:
listed here:came from the staff in Region 1.
They conducted
. hatithey* call risk. based. inspections and they1 ound that 9
w f
i10' findings'6fJISAP fpr'those two plants to be greatly helpful in 1:
'11~-
their program.
12 TheJ1ast part of the SECY paper dealt with'the 13' recommendation for the future of ISAP,and it should be noted
/f~)
~
14
'now-thatithe'SECY paper itself is not a. paper entitisd'to 15:
implement a new ISAP program but rather a recommendation for 16 the' concept of:a' future ISAP program.
l 17
- The staff. recommended that the benefits of ISAP-18 should be available to any licensee, and they said that the 19.
.most effective way would be to combine ISAP with the severe 20 accident policy statement, because both programs would require-
' 2:1 some sort of plant examination'or-PRA and IPE or whatever you 22 would call it in order to conduct the programs, and the results-L 23 of'the combined ISAP severe accident program could be used to l
'24 identify and'prioritize vulnerabilities in licensing actions, 25
.and ultimately could be used to develop integrated schedules q_.
y lieritage Reporting Corporation (202) 628-4888 1
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for the licensees.
V 2
After our July meeting on ISAP, the ACRS wrote a 3'
letter making comments on the program, and in the letter, there 4
were three areas that the ACRS wanted clarified.
Those'had'to 5
do with the application of the process to plants that weren't 6
in SEP.
Second was the coordination of the IPE program under 7
severe accidents.
And the third was the appropriate scope for 8
risk analyses to be used as part of ISAP.
I think today we can 9
make some general answers to those questions, but not' specific because the s'aff really is waiting for the Commission'to 10 t
11 review the concept before they start in earnest to develop the 12_
implementation, although the staff has been meeting with 13~
research recently to get a leg up on the integration of,-
i}.
7
\\
14 interaction of ISAP and the severe accident.
The application 15 of the process to plants.that weren't in SEP, took that to 16 interpret meaning how are we going to deal with future plants 17 with the SEP lessons learned?
And that's a good question.
18 Tho staff thinks the SEP lessons learned are' 19 important.
They identified a number of deficiencies in plants 20 that were fixed in SEP.
The question now is how to implement 21 those lessons learned when in ISAP severe accident space or as 22 a separate generic program or as a generic letter or'some other 23 program.
We aren't just going to drop them.
l 24 MR. EBERSOLE:
I would like to ask you a question 25 about this integration process.
I rather hoped ISAP would be J
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- 1[ : a, reallyLa broad ~ scope detailed integration process as it 2
2
.says'.
- It.:is an integrated safety assessment' program. ' What. I--
v3 have.here.in hand'is.a letter dated September 30, 1987, about
.4; ifireiprotection' safety; capability of Haddam Neck.
And it 5
refers in--this-letter;to letters coming to NRC from September 6
16, '85'and. April 1986,5 June 1986,. September 1986.
This-is tan.
?
7 answer to those: letters, the last'of which was
'86.-
This is 8
'87, and'a number of highly. detailed requests for clarification ~
9 onifire: protection.
- 10.
Well, in the middle of this time span,.'ISAP is coming 11 along doing part'of or all of or similar--I can't integrate-12:
this.-
It is the problem that I-think--
13 MR. MICHELSON:
Fire protection apparently 1st, t.even V-
- 14-a problem or at least.it is not highlighted.
15 MR. EBERSOLE:
I don't see a true-integral process 16 taking place.
It.is a muddle to me.
-17 MRi BOYLE:
When ISAP first started for the two 11Ef
~ plants, a. decision was made as to what issues, actions'or 19 initiatives were going to be-included in the ISAP process, and 20-a number of them were not included because there were routine 21
. licensing work such as reload action that was going to get done 22:
.when the' plant'came down for reload. They needed.a reload
'23
. r e v.i e w. d o n e, so we didn't' include it.
24 MR. EBERSOLE:
They left the term integral in the 25 title.
Should be partial.
.O Heritage Reporting Corporation (202) 628-4888
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1 MR. DOYLE:
Partial, integral.
Y.,/
2 MR. MICHELSON:
i sort of was led to believe fire 3
protection was included in your consideration from your earlier 4
replies.
Is that true or not true?
5 MR. BOYLE:
Yes.
Fire protection was an ISAP' issue.
6 MR. MICHELSON:
Even after looking at it on an 7
integrated basis, you concluded that it is not a significant 8
contributor to risk at that plant.
9 MR. BOYLE:
However, there is still items that the 10 plant needed to do to show full compliance with the fire 11 protection regulations.
That's where the letter is coming.
12 MR. MICHELSON:
Significant contributor, is that 13 correct?
O k'
14 MR. BOYLE:
That is my understanding.
15 MR. THOMAS:
Cecil Thomas--the letter I think Jesse 16 referred to was the one that submitted to final fire protection 17 report for Haddam Neck.
And we are still wrapping up our 10 review of that and have yet to integrate it in the final 19 results if I recall.
I am not sure we know the exact answer.
20 MR. MICHELSON:
Your answer is quite different than 21 the earlier one I heard then.
Which one is, which one is 22 right?
23 MR. DOYLE:
I think my answer is based on my reading 24 or looking at the licensee's fire protection or fire risk i
25 analysis. Cecil is saying that fire risk analysis was under O
Heritage Reporting Corporation (202) 628-4888 i
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1 review by.the staff.
- v 2
MR. MICHELSON: -There are real serious questions 3
about' control room area of fire protection and, you know,_the 4
rooms immediately surrounding it.
It was quite serious, and I 5
just wondered if it had all been worked out.
The PRA says it 6
is a non-contributor now.
I was going to go back and look at 7
the PRA before I pursued it further with you.
L 8
MR. THOMAS:
It is my understanding that we are now 9
integrating the results of both of those reviews, and we have j
10 not given the final word on fire yet.
11 MR. MICHELSON:
So we may hear a different version 12
.later.
13 MR. THOMAS:
The final ISAR report that will bo
(\\~
14 issued on Haddam Neck is intended to address that integration.
15 MR. MICHELSON:
Okay.
16 MR. BOYLE:
Your second point was the coordination of
-17 the IPA program under severe accidents with the ISAP program.
18 Mr. Stello has recently directed research to do just such a 19 thing and research and NRR initiating have already met'to 20 discuss this integration.
21 CHAIRMAN KERR:
I'm sorry.
Integrate what?
22 MR. BOYLE:
The IPE under the severe accident program 23 with whatever is required with the integrated, integrating ISAP 24 into this severe accident.
Both would require some kind of 25 risk analysis, and the question is how does this, the staff Heritage Reporting Corporation (202) 628-4888 a
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)-
I want to frame the risk analysis to satisfy both programs?
2 The last point has to do with.the appropriate scope 3-for risk analysis to be used as part of ISAP.
4 MR. EBERSOLE:
Would it be appropriate that I looked 5-at ISAN when'it is finally integrated--Cecil, if.you say it l
6' will be--as really a supplement to the FSA which you picked up 7
deficiencies and ambiguities and problems in the FSA, but it is 8
a new, clean sheet, says the plant is safe to whatever degree 9
it says it is safe, and I can look at it only as a superior 10 document to the FSA?
11-MR. BOYLE:
I think it should be a document used with 12-
~the FSAR.
13 MR. EBERSOLEskIt is bound to show deficiencies in
]\\
14 the FSAR. I had identified those discretely all culled :out with 15 the FSAR, has been ambitious or deficient or which is going to 16 be the historical document of safety quoi ;fication.
17 MR. BOYLE:
Under the integrated a assessment program 18 a deficiency was found in a plant,.that deficiency was 19 corrected by the licensee.
There are FSAR description of that 20 system component or whatever should be updated within the 21 next--
22 MR. EBERSOLE:
Go back and rewrite.
i 23 MR. BOYLE:
The staff requirements, regulation 24 require the FSAR to be updated.
The FSAR hould not be a living y
25 document.
()
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1 MR. EBERSOLE:
Yes.
It is our opinion along:with 2
research if ISAP and severe accidents were integrated' that the 3
scope of the~ risk analysis should at least be a Level 2, i
l 4
probably Level 3, but that would is still.being worked out, and 5
let the entire scope, how much of the external events are going 6
to be incorporated is still under consideration.
7 MR. MICHELSON:
How can you ignore the external 8
events and call it integrated safety assessment?,
If'I-read the 9-words. I think about'what those words ought to mean.
It means-10 that I have kind of pulled together all the possible 11 challenges, and made a final judgment on safety.
And if I am 12 going to ignore pipe breaks inside the plant, pipes inside the
.13 plant and so forth, if I were to, that's not integrated k
14 anymore.
It is partial safety assessment.
15.
MR. EBERSOLE:
That's right.
16 MR.. BOYLE:
I understand, though, there are some L
17 externals such as seismic which many--
l 18 MR. MICHELSON:
It is part of integration of your 19 safety.
l 20 MR. EBERSOLE:
Use the term integration without 21 integrating is--
22 MR. DOYLE:
I understand.
l f-23 DR. SHEWMON:
There are integrals that don't cover l
24 the wholo universe and are still called that in many' circles.
I 25 MR. THOHAd:
Integrated in the terms of ISAP meant
[)
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' exactly as was pointed out.
It was to.look at all the issues 2
that are on the plate for a particular plant in an integrated 3
sense'as opposed to putting blinders on and looking at each'one 4
of them out of context of the other.
It wasn't intended to be 5
- a. complete comprehensive re-review of the plant or review of.
6 how the plant meets today's criteria except through the SEP 7
lessons learned.
8 MR. MICIIELSON:
You are saying internal flooding is 9
not an' issue on the table for that plant somehow?
10 MR. BOYLE:
The lessons learned do cover quite.a few
~11 external. events.
They do it deterministically.
12 MR MICHELSON:
Don't do it in an integrated sense.
13 Itaven't gone back and studied systems interaction between the k#
14 various rystems and the flooding water and so forth and I 15 thought that is what you were getting at here.
I thought you
'16 were truly integrating and coming up with a f.inal conclusion.
17 MR. BOYLE:
Question comes as to how long this 10 program is. going to take.
19 MR. MICHELSON:
It is a limited scope integration.
20 MR. TilOMAS :
It deals with things that are already 21 known, Carl. It really doesn't, except for things that are 22 vulnerabilities, or common mode failures or where the PRA would t
23 show up; otherwise, it is dealing with at least known' topics.
]
-24 It is a starting point.
l 25 MR. MICllELSON:
Flooding is not a known topic I
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1 guess.
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MR. THOMAS:
Flooding is considered.
- 3 MR. MICHELSON:
You do include internal events such 4
as flood, internal flooding?
'S MR. THOMAS:
To some extent, yes.
Not to the extent 6
you are talking about.
'7 DR. SHEWMON:
May not cover everything that Carl 8
Michelson can think of on a good day.
9 MR. MICHELSON:
I am trying to find out what they 10 really are, 11 DR. SHEWMON:
He told you flooding is included for 12 some events.
13 MR. MICHELSON:
To some extent.
/ ~~
14 DR. SHEWMON:
Not for anything that everybody can 15 think of.
16 MR. EBERSOLE:
Just some of the latest edition.
17 MR. WARD:
Is that all, Mike?
18 MR. BOYLE:
That is more than enough, thank you.
19 MR. WARD:
Well, I guess I don't feel real well 20 satisfied.
I mean I think a lot of questions have I think 21 resulted from--I don't think the overall concept has been 22 described very well.
I don't know.
Maybe you need a logic i
23 chart or something to help us understand it, and I guess I'm 24 not absolutely sure you have thought it through yet.
Maybe you 25 have and perhaps I am being unfair, but you say you are waiting Q
y
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Heritage Reporting Corporation (202) 628-4888
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for the Commission input.
That worries me a little bit.
I w;
3 2
mean I am trying to figure out what the committee ought to do.
'3 I don't think we, I don't think we could draw a logic. chart for 4
you either, but we could work on it.
Maybe we ought to.
5 MR. THOMAS:
You asked--a point of clarification.
6 Are you asking about a logic chart attempting to depict the 7
ISAP process, or logic chart depicting where we go from now?
8 MR. WARD:
ISAP process.
9 MR. T110 MAS :
I guess we didn't come down here really 10 with that in mind.
We already talked about the process back in 11 June, and the purpose of, as I understood it, of this' meeting 1
12 and the Commission paper was to summarize experience today, 13 then to make recommendations, and that was primarily our
l 14 objective today as opposed to going over what we had presented 15 in June.
16 MR. WARD:
I think that was incomplete, and would.
17 hope that the recommendation was a little more specific, I-18 think.
i 19 MR. THOMAS:
It lu true we haven't, as Mike pointed 20 out, got into, got to the point that we can say these are the 21 specific ways that we think the program should proceed or the l
22 specific elements or whatever.
We, we have, as you know, 23 proposed to the Commission that ISAP be combined with the IPE 24 part of the severe accident program.
Because of our resource 25 limitations, we are, we feel we should only go so far until we O
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1 at least get to the preliminary feedback from the Commission, 2
they agree with that approach.
l 3
We have initiated discussions with Research.
4 Research has'been tasked to come up'with some_various' detailed 5
plans of how this is to be accomplished.
We are not there yet.
6 One thing that is very important to us, would be your input, 7
your_ suggestions, and I think the suggestions that were made in 8
your June letter are very important.
The staff generally I
9 agrees with them, suggestions we have heard today, like at i
.10 least the Level 2 PRA, consideration of external events and so 11 on, we think are very important.
And your views expressed to 12_
the Commission would go a long ways in heloing us develop this 13 program.
( s) 14 As you know, there is a great deal of work that has 15 to be done right now on how an IPA might be modified to be able 16 to accommodate an ISAP program.
The IPEs that have been 17 discussed in the past offer a range of options for itilities, 18 ranging from I guess the little more than the checklist that 19 built on PRA for surrogate product to a detail"4 Level 2 or 3 20 PRA.
In order to do a meaningful ISAP evaluat*
if the two 21 programs were married, you realJy need a pretty detailed PRA, 22 at least a Level 1.
We feel Level 2 would be better as far as 23 the staff goes, the ISAP people are concerned.
This is 24 important.
And your input would go a long ways toward helping l
25 us achieve that end, and I think if the Commission were made rm b
Heritage Reporting Corporation (202) 628-4888
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,( j-1 aware of your feelings on some of these issues, we could then 2
go ahead and develop a final program.
It is going to take some i
3 time to work out.
And we just haven't gotten there yet.
4 MR. WARD:
I think Paul, then Glen.
5 DR. SHEWMON:
I'm sorry.
I didn't get here for the 6
initial part of this discussion.
I sense something more 7
negative about the ISAP process than I had at least from my' o
i 8
experience with it in Millstone Unit I when it got from a 9
temporary to a permanent licensing.
There it seemed'11ke a 10 more rational way to try to weigh your various demands th$t the 11 different regulations of the NRC had and to establish a 12 relative weight and priority to them, and I think, you know, it 13 may not include everything that everybody can think of.
That i
'~'
14 really wasn't what it was intended to do.
Maybe it could be 15 modified to cover that.
Maybe it can't.
But there is a 16 decision process.
I think it uses PRA to do things in a more 17 logical fashion that makes a better contribution to safety.
18 And I think to me that is something I would like to see come 19 out of our letter.
Sometimes you have to say things four times 20 before people hear it.
21 MR. REED:
I am still interested in this folding in 22 process of other evaluations.
23 Dave made a very eloquent request on it I thought, 24 but who should say what can be folded in?
And I think that 25 will be very interesting to the itilities if they are going to i
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64 L;.<....hL 1; ido: this on a: voluntary basis... They would like to knowihow many
~
J i
21 reviews and evaluations do we fold inland how many~do1we get ridiof;as independent evaluations.
It seems to'me the staff-1
'4.
should writefsomething saying'how many, thing's-there could'or
'Sc would' fold into'ISAP.
Severe accident,-you said_IPE, but there-6 are a number'of other things, ICP.
I' guess there are other-
~
~
7,
. things'that could be' folded into that one integrated or h
8
' partially integrated evaluation?
'9 MR. WARD:
USI. recommendations,.for. example, is that 10.
wh'ati you.'have 'in mind?.
.11' MR. REED:
.IDI, which is integrated design-12'
' inspection.
13 MR. WARD:
Cecil; can you respond 1to that?.
14 MR. THOMAS:
I guess we go back to the discussion
'15 that you had' earlier at the outset of.the meeting, Dave, how 16 this relates to expansion activities.
17 We haven't thought a lot about that.
As Mike pointed 18 out, the' region made a lot of good use and thinks.very highly 19' of the work that was done in ISAP, and giving them'a sense of 20 guidance in what to look for in inspections, and certainly from 21 a resource point of view, that's very valuable.
From a safety 22 point of view, we think it is valuable, but we haven't--it is a 23' provocative thought.
We really haven't looked at it here in 24' Bethesda today.
At'that aspect of it.
It is something I think 25 we would like to think about.
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( J-1 DR. SIESS:
Can you answer my question?
Are we doing 2
IDIs on old plants?
3 MR. THOMAS:
I'm told we are not.
4.
MR. WARD:
He says no.
Well, Cecil, when, what sort 5
of schedule?
I guess what, I think that there needs to be mor,e 6
thought, you know, given to, you know, I think it is,. the ISAP 7
is a germ of a great idea idea.
I hate to see it lost'or 8
misdirected.
I think there needs to be more thought given to j
I 9
how it is going to be implemented.
You say you are working on i
10 it and you are working and you are expecting some Commission L
I 11 input again.
What sort of schedule are you on?
I don't think, j
12 I think the' committee here can, I think our letter of July was 13 kind of incomplete.
We hadn't thought it all out.
I think we
./_Tt
\\ ' '
14 can do better with that, and I propose that the chairman, that 15 we will do that, but I don't think we can develop a-letter for i
16 you at this meeting.
j 17 I think we are going to be, going to spend some more 10 time discussing it ourselves, and perhaps at the next meeting
)
1 19 present some of the work on that.
What sort of schedule are l
20 you on for--I would hate to see the Commission go off half 21 cocked or something without benefit of our wonderful advice.
22 MR. THOMAS:
We are scheduled to meet with the 1
l 23 Commission on the 4th of November on the paper.
With' regard to J
j 24 your comments on.the letter, the staff has not explicitly asked-25 the committee for a letter.
Nevertheless, we would certainly t
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1 encourage the committee to express its opinions and views to 2.
the Commission.
I think we would all find.it very useful.
3 Subsequent to the meeting with the Commission, 4
hopefully we will get some sort of indication from them that 5
they would approve us merging the two programs, the severe 6
accident program, and the ISAP approach, and the EDO,has 7
already instructed NRR and Research to begin working together, 8
and coming up with a plan for this, this marriage, and I would 9
guess'over the next several months, certainly by the end of the 10 year, the two offices have been asked to have a plan proposed 11 to the EDO for his consideration, so I think we are talking 12 about that timeframe for a preliminary plan.
Certainly the 13 details of something, that implementation plan that could p_
k/
14 actually be put in place, you are talking months after that 15 certainly.
16 MR. WARD:
Mr. Carson?
17-DR. MARK:
I am a little bit unclear on this.
Does 18 ISAP somewhere in some form, have an allocated specific budget, 19 so many FTEs or so many man months, and ISI have a different 20 allowance somewhere, namely you can only spend so long on it or 21 they have to be separated or added or anything of that sort?
22 Is this something that you guys who see the real words are 23 encouraged to go out and do?
24 MR. THOMAS:
The severe accident program has its own 1
25 budget.
The ISAP pilot program, which we have, Mike and I have O
IIeritage Reporting Corporation j
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1 been part of, had its budget.
The budget figures for the pilot 2
program are zero for FY '80 and beyond because we are---
3 DR. MARK:
We are in FY '88.
4 MR. THOMAS:
We are wrapping up the pilot program.
5 There are funds.
I am not sure under what particular category, 6
though, for.us to work to, to work with Research and marrying 7
these two programs together, but that will be done under a 8
different organization, but not with different people 9
necessarily than the pilot program.
10 DR. MARK:
I don't understand how it can be done at 11 all.
Here we are in FY
'88, there is no money, and you: fellows
.j 12 have to go and find something to.do I hope, but you can't do 13-ISAP because there is no charge account you can put your time.
14 on.
15 MR. THOMAS:
I hopefully emphasize the distinction 16 between the pilot program and developing a los -term program 17 that will be available to all the itilities.
It is the pilot 18 program that is, that has gone away.
It is the other program 19 that we are working with.
20 DR. MARK:
Thank you.
21 MR. WARD:
Jesse?
22 MR. EBERSOLE:
We, of course, from time to time 23 talking about documents, I guess all the rest of it, there must 24 be dead documents.
I would call this from what I am hearing 25 that dead documents as of a certain date, am I correct?
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'V Heritage Reporting Corporation (202) 628-4888 I
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' (J-1 MR '. THOMAS:
Which document are you referring to?
2-MR. EBERSOLE: 'ISAP report;.it will not be.kept up to 3
date, will not be integrated, separate program five years from 4
now.
You will go back to the FSAR and clean.it up although it 5
is always-ambiguous.
It is never really clear as to how: f ar it 6
went in detail at all.
It couldn't.be.
It is too massive j
7 already, but the only, this document is a temporal thing that 8
after.a certain day we go into other areas.
Am I orrect?
9 MR. THOMAS:
I would suggest that depends on how you 10 look-at'the living schedule that comes out of the program.
11 That's the bottom line you are-really looking for.
It is, a 12 schedule is indeed a living schedule, that is, the ktility is 13 allowed to continue to add subjects, topics, to it.
As:they.
,,i
~14 are identified, the utility has to go back and compare it with 15 something and they will compare it, what is on his plate at 16 that time and will review it that way.
To that extent, we will 17 still make use of this, this study, and the documentation, in 18 an integrated sense, that is, we will look at everything that 4
19 is on the utility's plate at any given time.
20 MR. EBERSOLE:
Each utility will have its own date on 21 its document and you will not have any standard requiring that 22 they bring it up to date or keep it up to date?
That will be 23 their option, is that correct?
24 MR. THOMAS:
That's true.
25 MR. EBERSOLE:
So there will be different time
(
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- ejj,
<l' schedules'on all'the documents?
They;are good as of'today or~.
'2
- whatever?
I3 MR.-THOMAS:
That.is.true.
There is~no requirement.
S 4
to-;go back Land reflect changes.
5 MR. EBERSOLE:
It will'always carry the ambiguous 16' uterms.
7 DR. SIESS: 'Are you; assuming-there will be another;
'8'
'ISAP?
9 MR. EBERSOLE:
No '.
We will. keep the one;we are 10 working.on now..
g.
11 DR. SIESS:
We have.got two' plants that have'done 12-ISAP.
13 MR. EBERSOLE:
..I am saying whether we keep that up as-7 l14 other things develop at the plant.
-15 DR. SIESS:
At these two' plants?
E 16 MR. EBERSOLE:
Yes.
l L
17 DR. MARK:
That is what he meant by that it'is a 18 111ving schedule.
'19 MR.-EBERSOLE:
.Okay.
-Are these t'o plants to keep w
20 this as a living, up-to-date record of safety assessment?
- 21 MR. THOMAS:
I-believe the utility has internal. plans 22 to do that.
We are certainly not going to require.it.
As they 23 add things to the schedule, they will have to somehow document 24; their bases for that, and those records will be available.
I 25-DR. SIESS:
Now ISAP is dead, is that right?
().
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1 MRd THOMAS:
The ISAP pilot program'is essentially; L2 complete..
il 3
.DR.
SIESS:' And.the Commission;hasLmade no? move.to.
14 fextendinglISAP?.
5 MR.' WARD:
Sure-they are.;
I mean.,they have got'thesei
.g'uys. developing,a proposal for it.
16.
4 7
.DR.
SIESS: 'They;are. prop losing to extend thewISAP-8-~
. concept toLthe'IPE-severe accident-process, but'ISAP.as_it was.
9.
?done.for-theitwo utilities--
' 10_.
.MR.
THOMAS:
The Commission has not.taken any. action u
- 11 to extend:the.ISAP pilot.'programpnor has-thel staff recommended-12 extending-the pilo't program.
- 13-DR.7SIESS:
Let me. explain"Ehat ILam' talking about..
'14' We'were talking:about extending the ISAP pilot program-which 15 would then not.be a pilot.
It would be" helpful to look at the-16 alternatives. 'How things were being done without'ISAP versus 17 how'they would be done with ISAP; now I thought.you had 18-proposed to try to integrate.the ISAP approa'ch into the I. pes.
19 Now to understand that, I think again we could profitably look
' 20 at how-the IPE would be done without that versus how.itlwould 21 be done with it-.
l
-;22 I would, I hoped that ISAP would just be a' continuing
~
12 3 -
. process, get things done in a more logical, more integrated
'24 manner, but apparently there have been no volunteers'from the
- 25 industry, and the NRC hasn't proposed to require them.
LO Heritage Reporting Corporation (202) 628-4888 L=____-_-
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1 CHAIRMAN KERR:
We are all hearing dif ferent' things.
2 It appears to me that what is being studied as a possibility of 3
combining what has been done under ISAP with what will be done 4
under IPE, whether you call.it IPE or ISAP, in the future it 5
will bo.an f.ntegrated look at plant safety which will I think 6
include the severe accident issues but include other issues as 7
well.
Is that--
8 MR. THOMAS:.That is correct.
9 DR. SIESS:
I don't understand how they can do that.
10 What, kind of regulation will require that?.
You are going to 11 have some requirement.
Under the severe accident' policy, there 12 is.a requirement, a generic letter out for an IPE.
13 CHAIRMAN KERR I thought what was said, this option'
{
14 was going to be made available to utilities, that if they 1
15 choose to carry out the IPE, under this, they could.
At least l
f 16 that's the tentative thinking.
l 17 MR. THOMAS:
That is correct.
18 DR. SIESS:
Would have all the features that we now 19 have?
20 CHAIRMAN KERR:
Which one?
21 DR. SIESS:
Whatever you do in the future for a l
22 plant; Millstone, Northeast Nuclear wanted ISAP extended-to 23 Millstone II and III, and the Commission has not done it.
They 24 offered to do it.
The Commission didn't accept their offer.
am 'rying to understand.
They are willing to 25 Now I t
l
("
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Heritage Reporting Corporation (202) 628-4888 E-
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do it..They have the PRA, they have to have something.' Is 2
.this--you supply the IPE for them.
What about for some other 3
plant?
What about Zion?
There was no offer from the' utility.
4 '-
This was'a voluntary process.
5 CHAIRMAN KERR:
Maybe you should answer this rather 6
than Mr. Thomas, but my impression would be that once RES and 7
NRR work out the details further than they now have, then a l
l 8
utility will have a choice.
This is a way I can go on-IPE or 9
'whatever.
10 DR. SIESS:
There would be a supplement or'something 11 to. replace the generic letter on IPE then?
l 12 MR. THOMAS:
Yes.
j 13 CHAIRMAN KERR:
Generic letter on IPE has never been
,_s'-)
i 14 released.
15 MR. THOMAS:
The requirement to do the IPE would be 16 mandatory, as mardatory as you can make a policy.
17 DR. SIESS:
The IPE will?
18 MR. TIIOMAS :
Yes.
19 DR. SIESS:
To what extent would the ISAP be an 20 alternative?
l 21 MR. WARD:
It seems to me that the staff has to j
22 provide some framework for doing the IPE and other things under 23 something called an ISAP process, and the utilities can 24 volunteer to approach it that way.
But the staff hasn't yet 25 defined that framework, and that's what needs to be done.
O lleritage Reporting Corporation (202) 628-4888
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'TStill would like to'get.'some feel for 2'
what the alternatives:are:for.doing that.
I think ' we z can i jtidge..
3~
.whether we want to--under the.old ISAP program,. alternatives
'4'
- were. clear.
You went along with the old way,=everything'had,tof 15' beldone. The OPR reg was required.- Generic issue was' generic-l 6'
l'ssue, you.did it.
Under ISAP, there was.a completely:
17~
different, more orderly, more' integrated rational process.
8 I don't see what'the alternatives are inLIPE SIMPLYL 1
y9 because nobody has worked them out yet.
They haven't gotian' 10 IPA. worked out.
l
. 11-MR. THOMAS:
It is kind:of useful maybe.to go back L
' 12-and just if you will permit me one minute to sy) back on how we 12 13 gotthere.
,fs.
1 14 One of the t ections that we have heard from 15 utilities to-doing an ISAP review"is gosh, we.have to do'this 36 expensive PRA, and we don't really want to spend the money on 17 it, and we observed that gee, a PRA of. sort in quotes is going 18 to be required by the severe accident. policy, and this could 19 range from something that is not much, that pretty much relies 20 on the surrogate PRA to a full-blown Level'3.or whatever PRA_
J 21-that you want to do.
Gosh, here is a way we all think the ISAP 22 ils a1 good program, maybe we could piggyback on that.
If PRA
-23 were otherwise required, then you, the utility, would have the 24 opportunity to use the ISAP approach to possibly drop some 25 issues that really weren't that important to safety, to develop D
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1 integrated schedule and so on.
So we viewed it as opportunity 2'
based on a quote requirement, so that's how we got to where we 3f are, and perhaps that is useful to you.
4
.MR. WARD:
Okay.
Thank'you.
~Mr. Chairman, we have 5
used up our time.
I guess what I would like to suggest is that-6 I will come back to the meeting next month, with a draft 7
letter, as a basis for discussion, and I would like to request 8
that we have, you know, I don't need an hour, or two hours, at' 9
the next meeting, to discuss this, and then the staff say that 10
. we.can expect next month or perhaps the month after that, a 11 comprehensive set of ACRS comments and hope in your discussion 12 with the Commission Commissioners before that you will reflect 13 that and so they will give us a chance to finish more comments i
'I I
14 before they discuss it and so on.
15 DR. SIESS:
We will still comment on their intent?
16 We won't have anything to look at.
17 MR. WARD:
I guess we will. comment on what our intent 18 would be for the program.
19 MR. FRALEY:
You have the SECY.
20 MR. WARD:
We have the SECY, yes.
21 MR. HERNAN:
Ron Hernan with NRR--I just want'to make 22 the coraittee aware that the generic letter on IPE has not 23 actually.yet been issued.
We are fervently trying to 24 incorporate the ACRS comments.
We are looking for issuance of 25 that within the next month or two, but it is still in quite a p)
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l1 stat'e.of.. flux.
.2 i
.DR.JOKRENTi ! We l l',
if the. committee by:some chance l3 thinksithere'is merit in theLrelatively broader encompassing i
4
- kind of program that I.was suggesting,-that would.' feed back ont l
!n and I!have no 1
,- 5 ~ ~ what the staffLguidance on'IPEs.as'well asDISAP,
' 6.'
. feel for what committee thinking on tlie matter. is, butiif. there j
7 is,any potential ~for that being the case, that it,would be.well" 8
.to have the. staff advised that:at least this is under=. serious:
- 9-consideration, and it is'useful for'them to hold up the release q
.. J
.10 '.of~the'IPE thing like.a_ year from now.
t 11'
'MR.. WARD:
Yes.
That's-a'. good point.
12
. CHAIRMAN KERR:
Well, thank'you, gentlemeni:for your l'3
> presentation.
We will now come to future activities.
14-(Future activities was discussdd'off'the record.)
15 CHAIRMAN KERR:
The schedule calls for the south L16
= Texas at at 1:35, so we'have time for'a break.
i
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17
.(A brief recess was taken.)
18-MR. KERR:
South Texas Nuclear Station, Unit 1, Mr.
.-19 Mark?
20 DR. MARK:
I believe that's mine already.
Very good.
]
~21 I have very little to say.
Something like a year ago,'the i
'22 committee sent forward a letter to South Texas in which we
{
23-flagged three items that we thought were receiving attention 24 and thought should receive attention on South Texas, and if 25 they were attended to, we said we thought the plant was ready PQ Heritage Reporting Corporation (202) 628-4888
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-76 1L toirun'or would-be ready to:run'.
And..I believe that by now, it
+
2 isiperhaps'about ready to run..
And it has been.given:a'five 3
percent'.' power-license if'I'm right'on that, a month or'six I
.l4:
weekscago.
15
.At the last meeting, as;you may recall,~several;
' -people,. Jesse,-and~Michelson and who'else? ~ Raised. ques 61ons
'i l
7 L which bore-on the South Texas plant,-but'may also have borne on:
8-Westinghouse house plants in general.
I am wondering'how South l
9
. Texas has atood on these points.
They were.wt-included in our?
-l
?10
. letter.
They weren't included:~1n our, thinking'about that 11 particular plant at that time.s 12.
Today we'gaveLsome thought to perhaps sending a-
- 0.
~13
. letter, perhaps' included comments on those points, and we
'14 decided.and I believe we decided mucli better, to have a littl'e 15 further com;.ent from the staff, and'perhaps South. Texas people 16 as well on their thinkirig and on their' actions at the moment.
?.
li 17 Mr. Kadambi of the staff.is.here, and will give us comments on 18 the points we raised a year ago'last June and Mr. Wisenburg
- 19 from South Texas is here to not necessarily say anything, but
- 5 '
20 at'least to respond to questions, where the South Texas people 21-
~ are, where they stand.
I believe that's all I am going'to say.
22 CllAIRMAN KERR:
Questions, comments?
Mr.-Kadambi?-
ll 23' MR. KADAMBI:
Good morning.
My name is Presad' 24 Kadambi.
I'am the project manager of, assigned in NRR'to the 25 South Texas project.
I received intimation of the ACRS D)
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lieritage Reporting Corporation (202) 628-4888 L
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U 77
[v) 1 interest to cover South Texas about a month ago.
I then 2
informed the licensee that there was going to be some time set 3
aside during the October meeting to discuss South Texas, and I 4
requested their participation to address questions in some 5
detail if they arose.
6 They are present here as Dr. mark mentioned.
I have 7
not set aside any time for their presentations.
I hope I can 8
address the questions that I have received adequately.
9-I have a few staff members also available to address 10.
questions in some more detail, and representative from region 11 4, Les Constable, is also here in case there are questions 12 related to the region's conduct of the inspections, et' cetera.
13 I must point out before beginning that the review of 4' ')
14 South Texas, of the South Texas design, has spanned two major 15 reorganizations in NRR, and some of the, the reviewers who, who 16 were actively involved in the review are not as accessible now 17 as1they were some time ago, but I don't believe this is a 18 problem.
19 (Slide) 20 MR. KADAMBI:
The concerns that have been raised by 21-ACRS so far or the questions rather--I don't think any of them 22 arose to the level of concerns as I see it--were related in the 23 June 10th '86 letter to three items -- the qualification of RHR 24 pump at South Texas.
The RHR pumps are within containment, the 25 construction appraisal team inspection items, and the diesel
~Ih Heritage Reporting Corporation (202) 628-4888 i
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- -1 E igeneratorHfueloilpiping{vibrationtesting.
2 Of course,-prior to-issuing this letter,'therACRS had' 13 -
been?torthe site.
Subcommittee-meeting was. held in Bay. City.
4 L and the full committee' meeting.-was held here, and,these.three.
<5 items were. indicated'in the-letter of June 10th to be addressed' 6;
by:the staff,'and all these three have,.in. fact been completed.
-m 7.
11 will address.that shortly.
r 8;
Then_on September 18th, we heard from Mr. Fraley1that; 9
the ACRS had expressed an-interest.in four' topics;
?I wasn't
~10-quite sure about the interpretation of some of the topics:that?
11:
were' mentioned, so I have shown here what, the way.I; p
12 interpreted it,jand I wanted to make sure that this is.theLway; 13' in whichyI am going to address.it..Just to show everybody, I f
14 would like to display, you know, what the wording was'of the 15 questions as they came to.me..
- l 16 MR. EBERSOLE:
May I ask-just a reconsideration of 17 the.first three items?
I believe.the fuel oil vibration 18 testing was a part of a, some of the larger pictures.-.This-L 19 plant is built with the diesel plants, including'the fuel oil 20 system in a vertical configuration with the fuel oil storage 21 tank at the very top of the pile so to speak.
22 MR. KADAMBI:
That's right.
1 23 MR. EDERSOLE:
And the rather obvious consideration 24 that gravity, doing what it does, will carry fuel down, produce' I
25 a vertical fire of some sort, which you would argue is
)
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,n protected agadnst encroaching on the other side because of the
(_)f 1
2 presence of the walls.
I sort of think you may concede you l
3 might have something of a fire problem in the vertical context 4
but it won't translate to the sides.
5-interestingly enough, sometime after the ACRS visit to 6
that. plant, you in fact did.over-pump the tank or the tank was 7
pumped full: and the drains were plugged or some mal-1 l,
L 0
coordination, and I understand oil went all over the place, but 9
it didn't catch on fire.
10 I hoped you will elaborate on, a little on how you 11
' don't, you anticipate, you don't anticipate having that' sort.of
- 12 thing happen again in view of the fact of the fuel being on top 13 of the working machinery of the plant.
h' 14 MR. KADAMBI:
Well, I will address, you know,'what 15 was done as a consequence of that event which--
16 MR. EBERSOLE:
Had it ignited it would be an 17 interesting question.
18 MR. KADAMBI:
'Yes, right.
That was exquisite sense 19 of timing on the event.
It came exactly a month after you 20 issued the letter.
21 MR. EBERSOLE:
Yes.
22 MR. KADAMBI:
Anyway, these were the four items that 23 were sent to NRR to be addressed by the staff.
24 (Slide) 25 MR. KADAMBI:
And I will try to do that one by one l'~U Heritage Reporting Corporation (202) 620-4880
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3 MR..KADAMBI: 1: Regarding theiitems.left over:from,the g
[4' JuneJ'86 letter, the quall'ficationfof:the RHR. pumps was 5; ; addressed?in' supplement No. 4,to theLSouth Texas SER'..
This was 6
aissued'.in' July J.87 in support of the low power l license.,'The 7
pump motor itsel'f was explicitly reviewed las 'part' of: the
'a :
equipment;qualificationiaudit'which the staff' conducted at'the
.9.
site.
From'a' technical standpoint,~it was. essentially; resolved-f
~
10:
when the South' Texas project made the decision ~to qualifyEthe.
L 11-pumps for the harsh' environment it would see after a postulated 12.
accident..
So 1lbelieve that takes care of'this: item.
)
13-MR. WYLIE: Mas it qualified?-
- i. )
14 MR. KADAMBIs Yes, it was.
'15 MR.-EBERSOLE:
.It-is, created an ECCS pump.~in 16 essence?-
o 17 MR. KADAMBI As far as qualification is. concerned,
-l 18 yes.--
.19 MR. EBERSOLE:
Valves that go along with-it, the 20 uptake valves and so forth, they are treated the same way?
21 MR. KADAMBI:
I believe so.
22 MR. EBERSOLE:
Maintain RilR functions after a l m -.
l E23 contaminate'on heat-up of the containment?
24 MR. KADAMBI:
Yes.
25 MR..EBERSOLE:
Thank you.
7 lt Heritage Reporting Corporation (202) 628-4888
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1 MR. MICHELSON:
What temperature was.itLgualified to 2
operate?- In 325 degree Farenheit. environments.
Or 3
thereabouts?
Is that what you are'saying?
4 MR. KADAMBI I don't really know the particular 5
temperature.
6 MR. MICHELSON:
I am sure it is quite high.
7 CHAIRMAN KERR:
The information you want from the-8 South Texas representative?
9 MR. KADAMBI:
Yes.
If Mark Wisenburg, somebody knows 10 the answer to that, I would invite you to--
11 MR. WISENBURG:
Mark Wisenburg-- I am manager of 12 engineering and licensing for Houston Lighting and Power, South 13 Texas.
7
()
14 The RHR pumps valves, all of the safety-related
.15 equipment is qualified to be worse case containment. pressure 16 temperature, in this case, steam line break accident, 326 17 degrees.
18 MR. MICHELSON:
You are saying the RHR pump had 19 adequate air cooling, I guess it is air cooled pump, isn't it, 20 or. water cooled?
21 MR. WISENBURG:
It is air cooled, i
22 MR. MICHELSON:
Can operate with ambient of 325.
l 23-MR. WISENBURG:
For the time duration that we would 24 expect that temperature to be there, which is some time.
25 MR. MICHELSON:
That is a pretty good motor.
f~\\)
Q.
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MR. EBERSOLE:
Open air cool or secondary air. cooled?
2 There is two kinds.
Open air cooling or have air exchange?
3-MR. WISENBURG:
It is open air cooled by cooling in 4.
.the pump cubicle.
5 HR. MICHELSON:
Inside containment?
6 MR. WISENBURG:
Yes.
7 MR. EBERSOLE:
It injests the containment atmosphere 8
with, the other sttif f ?
9 MR. WISENBURG:
That is correct.
l 10 MR. MICHELSON:
That is quite an air cooler.
j 11 MR. EBERSOLE:
Can cope with the surface 12 contamination?.
I 13 MR. WISENBURG:
That is correct.
The real reason we Q~'
14 got into the situation we were in, we of course desired all 15 along to get these things qualified for that environment, but 16 we are somewhat hesitant to make flat-out commitment to do so 17 pending the outcome of application.
18' MR. MICl!ELSON:
The air cooling rate of that cooler 19 is based on inlet air to the cooler, at such duration and 325 20 degroes saturation?
Is that what the basis is then?
21 MR. WISENBURG:
Yes, sir.
22 MR. MICHELSON:
That's what the condition would be as i
23 a minimum.
Quite a condenser then to cool that air down below i
1 24 saturation and so forth.
It is a very large heat exchanger.
25 MR. WYLIE:
This is air cooler in the cubicle where Heritage Reporting Corporation (202) 628-4888
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1 the. motor'is located?
l MR. MICIIELSON:
Yes, but the environment in'the 2
3 cubicle'is fully saturated since it is not a sealed cubicle I i
4 gather.or would be designed for containment pressure.
]
5 MR. WYLIE:
Maybe he can explain it to us.
6 MR EBERSOLE:
Is it a sealed cubicle?
7 MR. WISENBURG:
Not completely sealed.
8 MR. EBERSOLE:
So the same pressure AREA, same 9
humidity level?
10 MR. MICHELSON:
This is a large condenser you have
'11 attempted to put inside that cubicle to cool the air down.
12 Because it is already at saturation--very large heat exchanger.
13
) '
14 MR. EBERSOLE:
Temperature differential inside the 15 cubicle versus outside--
16 CHAIRMAN KERR:
Jesse, remember the microphone.
17 MR. EBERSOLE:
Are you attempting to provide a
-18 somewhat different environment inside this so-called cubicle 19 in the containment?
20 MR. WISENBURG:
The cubicle in which the pump sits--
21 MR. EBERSOLE:
Yes.
22 MR. WISENBURG:
Is cooled, under normal operating 23 conditions.
So what we are dealing with here is the transient 24 increase in temperature outside versus the transient change in 25 temperature inside.
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'MR. EBERSOLE: LYou"normally cool this. cubicle w'ith
-2
.some sort of' external," internal-cooler.
Now it must assumeTa L34
~ condensation load and you;come to, I presume your-temperature-1 4-
'.with.the' air. temperature outside;'you;1ose your' control =of the 5'
' environment but that doesn't matter because thefduration, is-7 6
that correct?
-7 MR.=WISENBURG:
That is correct. ' You haveLthat' time tb history?outside and time history inside.
You reachLequilibrium:
9' at some point.
10-
- MR. MICHELSON
What duration roughly are we talking-ill about?' Hours?
Minutes?
12 MR. WISENBURG:
Getting'a little complicated.here.
13 MR. MICHELSON:
Didn't mean to get' complicated.
i.
-14, MR.-WISENBURG:
It qualified for the" environment it-15-would see.
During the course of the~ design basis loco, design
' 16
-based-line break without running for about ten to 14' hours,
-1 71 then pump. starts running, then'you use.that.asothe heatiinputs.
A 18 MR. MICHELSON:
Is this written up somewhere-.in the 19-FSAR where I can read it?
20 MR. WISENBURG:
The details of the qualification 21 program were.
22 MR. MICHELSON:
I said qualified.
I just want to 23 know the criteria for qualification.
24-MR. WISENBURG:
Criteria are in the SAR.
i
=25 MR. MICllELSON:
Thank you.
1 O
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1 CHAIRMAN KERR Further questions on this topic 7.
2 Please continue.
3 MR. KADAMBI:
Thank you.
The next item is', relates 4
to the construction appraisal team inspection items.
The 5
Region 4 inspection program followed up on all the findings of 6
the team.
There were eleven inspection reports written 7
subsequent to that which addressed the corrective action'on 8
those findings.
9 All the items were closed out adequately.
Any 10 questions?
l 11 MR. MICHELSON:
Just for a moment -- could the staff 12 provide me the description of this RHR pump cubicle and'so 13 forth that you reviewed in deciding this, this was an
(~')
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14 acceptable arrangement?
You must.have gotten some paper'.
It 15 is not many pages, I am sure.
Could you send me a copy?
16 MR. HERNAN:
The audit is normally done outside.
I 17 don't-know if we would have the paper here.
18.
MR. MICHELSON:
They can get it easily enough..
I 19 would like to see the--it is only a few pages I'm sure.
20 CHAIRMAN KERR:
Please continue.
21 MR. KADAMBI:
Okay.
The next item over here is the 22 diesel generator fuel oil piping vibration testing.
The 23 applicant submitted some guidelines that they were going to use 24 for the testing of the piping and response to the 25 recommendation made by the ACBS.
The staff approved these O
Heritage Reporting Corporation (202) 628-4888
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. guidelines in supplement 2 to the SER on, South Texas'.
The l
2 testing itself has been completed at Unit 1, and we~have a
~
l
'3-commitment from the licensee that they will conduct similar 4
testing at Unit 2.
L 5
DR. MARK:
Where is Unit 2 in a timeframe?.' Coming'up
'6 within the next'aix months or what?
7 MR. KADAMBI:
No.
They expect to load fuel in l
0 December of 1900.
That's the current schedule.
9 DR. MARK:
Little over a year.
Okay.
Thank you.
10 MR. WYLIE:
The scope of the testing of the fuel oil-l 11 piping, this was, what was the scope?
Was it all theipiping on l
12 the diesel and the piping to the tanks above?
13 MR. KADAMBI:
Again, I must say I don't know the
,s
' (-)
14 details on it.
15 CllAIRMAN KERR:
South Texas, could you repeat the 16 question, Mr. Wylie, so--
17 MR. WYLIE:
What was the scope of the testing of the 10 fuel oil piping on the diesels to the day tanks?
Up to the 19 storage tanks?
Is that the scope?
20 MR. WISENBURG:
The piping which was tested was all 21 other than engine mounted.
Engine mounted piping itself was 22 not instrumented specially for this.
23 MR. MICHELSON:
Why was that the case?
You must be, 24 you didn't think there was any problem with vibration on the 25 engine?
k Heritage Reporting Corporation (202) 620-4000 i
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1 MR. WISENBURG:
That is correct, sir.
2 MR. MICHELSON:
What made youLbelieve that-that was 3
the case?
4 MR. WISENBURG:. As I said, it was specially 5
instrumented--with the engine running, vibration was' observed, 6-or you were able'to observe vibration and we have subsequently 7
moved some of the engine mounted supports around, but that 8
piping itself wasn't especially instrumented for the test.
9 MR. MICHELSON:
I kind of thought that was a part of 10 the thrust of our concern was the engine mounted stuff'and if I
11 you get a failure there, you have got a potential for a good 12 fire.
And that's why I think we asked about the vibration.
I-13 thought, I thought we were clear what was meant.
.O 14 MR. WYLIE:
That was the. thrust of the question was 15 to. search out for resident vibrations and then to move supports 16 wherever necessary or counterbalance or whatever to subdue the 17 resident vibration.
i 18 MR. MICHELSON:
It all comes from the engine.
19 MR. WISENBURG:
Breaks down into two parts of the 20 fuel delivery system which is unique to South Texas since we do 21 have our fuel storage tank located above engine compartment and 22 that part of the system which is during normal operation 23 isolated to a degree from the fuel delivery system to the A 24 tank, and would be like any other diesel.
Certainly fire 25 expands in a vertical direction, but the part that was OO Heritage Reporting Corporation (202) 628-4888
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1 instrumented and tested was that which would directly 2
-communicate with the area above.
3' MR. EEERSOLE:
But isn't.there interactive effect 4
here?' I mean I guess the concern arises from the fact'you have i
5 got all this tanks structure above you, you may even invoke 6
gravity flow.
Do you have gravity flow?
7 MR. WISENBURG:
We use fravity flow to do the 8
tapping.
9 MR. EBERSOLE:
In the context of having flow 10' available under gravity, although fuel flows in the face of L
11 accidents, unless you turn it off.
You don't have pumps to 12 turn it off.
You are going to feed a fire.
And I:think this 13 probably precipitated Dan's inquiring as to the capability of a.
7_s b
14 fire on the engine, worrying that you had all this fuel above 1
15 your head which would come on and be introduced into the i
16 originally small controversion.
17 MR. WISENBURG:
I understand.
The point I am trying 18 to make is what we estimated and tested was that section of the 19 piping which would be subject to gravity, the problem you are 20 talking about, flow from up above.
21 MR. EBERSOLE:
I think Charlie's questions, he can 22 correct me, he was I think concerned about that small fire from 23 the engine piping propagating to larger ef fects due to: the 24 presence of the gravity fed flow above.
I don't knowtwhether 25 that is true or not.
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Heritage Reporting Corporation (202) 628-4888
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'l MR. WYLIE:
That.is part of it.
It is_the feed of
~2 the fuel oil piping on the machine invalidates the' machine'if 3
you needed it for one thing.
i 4
MR. EBERSOLE:
If you have a fire, do you have an 5
automatic valving that tripped off or what do you do?
I mean 6
you are facing a constant gravity flow supply.
You have get to 7
cut it off.
You just don't turn a pump off because you don't 8
have to have a pump.
9 MR. WYLIE:
If you--I didn't understand what.you 10 said.
Maybe you can say it again.
11 MR. WISENBURG:
I can't answer the other questions 12 specifically.
I will be happy to get back with you.
13 MR. MICliELSON:
Related to that question is the g
\\~#
14 question of what fire protection provisio'ns are actually in the 15 diesel compartment.
16 MR. EBERSOLE:
In the context of guaranteeing fuel 17 won't come down in your face.
18 MR. MICHELSON:
The fire protection will last j
19 indefinitely.
If you tell me CO 2, it doesn't last forever, i
20 MR. WISENBURG:
It is foam.
21 MR. MICHELSON:
It 'is foam, yes.
Now is that going 22 to be lasting, you know, if we do have interruption such that 23 you do continue to deliver fuel oil to the room, foam 24 protection isn't going to be a protection for,:ver.
So what 25 happened when it does ignite?
C Heritage Reporting Corporation (202) 628-4888 i
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-MRNEBERSOLE: 'Was thatLthe. original thought;behind:
. y:
L 12) theEdesign?
-3' MR. WISENBURG:
The original thought.-behind the G
J4 design was-'not to put the fuel oilr tapping in the locationithat 5'
it was, but throughlvarious-interactions with the staff, that turne'd out..to be the best
'6 involving other problems,
+
7' compromise,-yes,' sir.
- 8.
MR. REED:
I guess the remaining question here isi. whether you have' trip valves in:the gravity lines leading to
- 10.. the diesel generator?-
-11 MR. EBERSOLE:
Just don't have controls.
, 12 MR WISEN. BURG: ' Isolation valves after.the DAYTAK, r
13 but I unfortunately can't give you an answer which would:be i o '
14-specific enough'and I would like'to get back to you.
15 MR. MICHELSON:
1.think you need to tell-us how they 16I are actua'ted, whether or.not they are redundant, will they~even 17
~ be there.during a fire to isolate?-
18 MR. WISENBURG: -Yes, sir.
I understand.
1 19 CHAIRMAN KERR:
Further questions on this issue?
20' DR. REMICK:
You instrumented the piping to,.that you 21 thought was relevant, except for the piping on the engine which j
22 you observed the vibrations and made adjustments in supports, 23 is that what you are saying?
'24 MR. WISENBURG:
That is correct, sir.
25 MR. EDERSOLE:
It was just from a visual observation
- r Heritage Reporting Corporation (202) 628-4888 l
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1 that you needed to stabilize'the pipes I guess.
a MR. WISENBURG:
That is correct.
We have also run.
.i 3
these machines quite a long time at South Texas.
Eachimachine 4.
has by this point in time, gone through a normal work in test 5
program which culminated in a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> continuous run during 6
which time that piping was observed and any problems with 1
7 supports that you have asked.
8 MR. MICHELSON:
Is your foam system seismically 9
qualified for this plant, including the actuation of the foam 10 system?
11 MR. WISENBURG:
No.
Fire protection system is, needs l
12 the normal seismic qualification.
It is two over one.
It 13 doesn't fall down..
'-)
14 MR. MICHELSON:
I don't know what you mean by normal 15 but that's another whole issue.
This question of inadvertent 16 actuation of foam system on all your diesels once during a 17 seismic event wouldn't be very handy, for instance, and but it 18 is nother issue.
I won't pursue it further now.
19 MR. EBERSOLE:
On the other hand, if you do say that j
20 you--would you flood both in the rooms, the engine rooms with 21 foam, if you have a seismic upset, and would the diesel survive 22 that because the switch yard hypothetically ic gone.
Do you 23 follow me?
24 MR. WISENBURG:
I follow you.
Three engine rooms.
J 25 MR. EDERSOLE:
Common influence of the seismic Heritage Reporting Corporation (202) 628-4888
i 92
< ~ <
(_)
-1 shaking, would this result in potential flooding of'all the
-l l
2 rooms with foam?.
_j 3'
MR. WISENBURG:
I'm sure there is a small, but finite 4
probability of that.
l 5
MR. EBERSOLE:
I don't know.
I have no idea.
6 MR. WYLIE:
Let me see if I can get clarification.
)
7 That all piping subject to vibration, fuel oil piping subject
-8 to vibration external-to the machine you instrumented, that was-9 subject to vibration?
10 MR. WISENBURG:
That is correct, sir.
11 MR. WYLIE:
Okay.
And on the machine you manually 12 detected vibration and you moved supports to reduce it?
13 MR. WISENBURG:
That is correct, sir.
(2) 14' MR. WYLIE:
Okay.
15 MR. MICHELSON:
One other question--what provisions 16 are in there for fire protection in the tanks storage room 17 directly above the diesel?
10 MR. WISENBURG:
The tank storage room and diesel 19 compartment is separated by three-hour fire barriers, either 20 concrete wall or penetration.
The tank room itself is 21 continuously ventilated with a class one E seismically' 22 qualified fan.
This one is qualified.
The fire protection 23 provisions are foam in that room.
The access into that room is 24 water tight, submarine-type hatch.
l-25 MR. MICHELSON:
Maybe another key question--is it lLO Heritage Reporting Corporation l
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' automatiO: fr:m or manually actuated?;
L 2-
~Mu EISENBURG:'
Auto' foam.
1-I 3
MR. EBERSOLE:
If facility has auto foam, again.say y
54 the seismic event:will trip the foam, and cause it to be v
5 discharged'into;the engine room, is that right?
And that's a 6
blanket discharge--all of it.
.Now let me go t'o.the operation 7
ofithe' diesels, in the presence of foam.-
0 Are'they designed to be shut'off"when the foamnis-9
~sent into the' room or_ will: they_ attempt to run and cannot run?
l 10 MR. WISENBURG:
They will attempt to run.
1E 11 MR..EBERSOLE:
But the, but.the generator,. proper 12-use--the generator set is air cooled, isn't it?
13 MR'. WISENBURG:
It is air cooled.
'14-MR. EBERSOLE:
Will it continue'to'be. cooled in the 15.
presence of foam all over the place in the room?
Seems to me.
16.
to would upset the environment.
~
17 MR. WYLIE:
The question is outside air.
18 MR. WISBNBURG:
Without a fire in the room,' the 19
. engine running, and it would just blow us away through the 20:
foam.
21 MR. EBERSOLE:
In other words, the engine, the 22 generator cooling function would override the presence of the 23 foam?
What would it do with it? Throw it out the discharge?
24 MR. WISENDURG:
Flow to the far end of the room.
The 25 discharge, wouldn't get in the discharge because the discharge
!OL IIeritage Reporting Corporation (202) 628-4888
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19 4 -
1E isifrom the engine 11tself...
j 2'
lMR..EBERSOLE:- I'm sorry.
-I am: talking about the~ air:
3:
cooling 1 function of the generator.'1That's a' fan cooled 1
. 4..
generator, andLit will suck-the foam.in' eventually _I'would L
5-Ethink.and<just. recycle it'and you.will lose air circulation.in.
6 the room because of the. presence of the foam,-is'thaticorrect?
7 You' don't.have--
8 MR. WISENBURG To some degree, yes.
~
9 MR. EBERSOLE:
Well, all I am trying to doils get.you; 10
.to say theLengine is. going to run with a room full of foam.
~
l.
11
.MR.
WISENBURG:
The engine itself is going to.run 12.
with a room full of. foam.
13 MR. EBERSOLE:
Sorry--the diesel generator.
e 1
-14 MR. WISENBURG:
The generator is the problem.
15-MR. EBERSOLE:. Cooled and remain functional after.you zl6 have injested foam into it from the atmosphere?
17~
I want to have continuity of power in an earthquake.
'18 '
.You have lost the circulation.
19 MR. WISENBURG:
The answer to the' question:is'yes, it 20 will continue to generate for some period of time, depending 1
'21 on, you know.
22 MR. EBERSOLE:
I don't know how long that period--as 1
E
'23 far as'I am concerned, that time has to be indefinite.
I don't 24.
know.when you are going to get the owitch air tight.
25 MR. WISENBURG:
Or when you--
O:
l
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1 MR. EBERSOLE:
Or earthquake--a time long enough to 2
have a problem, hours and hours; after all, you have'got the 3
seven-day supply of oil I believe.
That was pulled out of the 4
air about 25 years ago.
You are going to need your diesel for 5
that long.
Start at seven days fuel.
6 MR. MICHELSON:
How deep a foam are you planning on?
7 You have got controlled injection.
How deep is the foam when 8
you shut off your injection?
Your injection rate is not the 9
seismically qualified either, so although you have set Jt up on 10 a timer for a few cycles of foam, I don't know where you are l
11 going to dump all the foam, or part of.it.
What are you.
l 12 planning on as the item for fire protection?
13 MR. WISBNBURG:
No, sir.
I will have to get back to 7
14 you on how deep you can discharge the whole, the whole capacity 15 MR. EBERSOLE:
May not be a solid.
16
'MR. WISENBURG:
No, sir.
17 MR. EBERSOLE:
Just the, blanket the walls and j
18 surfaces.
19 MR. WISENBURG:
Yes.
20 MR. EDERSOLE:
That brings up the question, are you j
21 going to parcel out a fraction of the foam content, the foam 22 storage, and are you going to be sure you inject just that 23 parcel and if so, what is your basis for doing, not injecting l
24 all of the foam?
Is the foam supplied on a per engine raom 25 basis?
1 1
Heritage Reporting Corporation
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>Per--engine room' basis?'.
m l'.
- MR. WYLIE:-
- 2, MR.':EBERSOLE:' Don't have a parceling' process?
.3
- MR.'WISENBURG ' That is correct.
F 4,
MR..MICHELSON:
h i
MayT ave 'commonistorageLout there.'-
I 5
Jdon'tLknow what your arrangement is.
6
~MR.:WISENBURG:
No, sir.
'7 MR. EBERSOLE:
'IEgather.this one does'not.
'8L CHAIRMAN KERR:
Further questions on'this issue?,.
.9
- Please continue.
10
.MR.-KADAMBI:
The first of the four items'from the Lil September 18th letter I believe is related.to the April'10th, 12 1987, meeting,'I mean. event at Diablo Canyon.
The wording
'13 indicatedEthat there was a concern about'the capability! to vent O_q 14 'fthe RHR pumps, especially since they aro. located withinE 15' containment.- Should the need arise, how would it be,done?: So 16 I, questioned the design features that are available for L
17 venting, and.whether there are procedures in place to perform-18 the venting, and whether operators are trained to perform these L.
19 procedures.
20 There is a design feature available.
There is a 21
' manual valve on top of the pump cooler for each of the pumps,.
22 which-is what would have to be manipulated in order to' vent the 23-line.
24 There are specific procedures.
u l
'25 CHAIRMAN KERR:
Excuse me.
There is a quest' ion.
O Heritage Reporting Corporation (202) 628-4888
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'2 1 MR. REED:' You said a manual valve. -That'is not as l
2l remote operating. valve, and you said it was on the cooler.
I.
.31 don'tLguite understand that.
-It is.not on the pump'itself?
4-MRs'KADAMBIs I believe it is connected by piping to 5
the' cooler'part of the pump b'dy.
You know, there is flood o
6 flow that.provides cooling through the component cooling water
'7 system to the pump; seals I believe.
-8 MR. MICHELSON:
Yes.
9 MR. KADAMBI It is in that portion that there11s a 10-manual valve I'm told.
l-11 MR. MICHELSON:.You can't vent back through the seals-12?
very'well, not the right part of.the. pump.
13 MR.LEDERSOLE.It is not vented into the pump casing _
O~
'14 >
at'the high point.
15 MR. KADAMBI I believe it connects with the' pump p
- 16.. casing. ~Maybe I will have to elicit the help of the-applicant 17-again.
18' MR. REED:
I think you do need help from the 19 applicants.
20 MR. MICHELSON:
Vertical or horizontal. pump?
21 MR. KADAMBI:
It is a vertical pump.
22 CHAIRMAN KERR:
Would you repeat the question, 23 please, Mr. Reed?
24 MR. REED:
I would like to know if it is a remote 25 operated valve for circuits of the pump casing at high point.
l O-Heritage Reporting Corporation (202) 628-4888
98 (m
y_)
1 MR. SCHLAZER:.My name-is Len Schlazer with the 2
Houston Lighting Power Engineering -- the valve is located.at 3
the high point of the pump casing.
It is located on.the 4
cooler.
It is located on the cooler and it is a manual 5
operated valve.
It is.not automatic.
t 6
MR. REED:
It is to be remotely operated?
7 MR. SCHLAZER:
Not really; the operator physically 8
has to go over there and open the' valve.
9 MR. MICHELSON:
What cooler is this?
10 MR. SCHLAZER:- The seal oil cooler.
11 MR. MICHELSON:
The seal cooler?
12 MR. SCHLAZER:
Just mounting part of the high point 13 of the pump casing does vent the pump casing.
I,h 14 MR. MICHELSON:
Directly, not through the seal?
15 MR. SCHLAZER:
No, no..
Through the valve.
16 MR. KADAMBI:
I'm sorry about that.
I misunderstood.
17 MR. REED:
It is located inside containment, in a 10 compartment within containment, I would think that access by
- 19 _.
operator being rather long and tedius.
20 MR. SCHLAZER:
We have estimated, we have actually 21 done the venting and the operations people estimated between
-22 ten and 15 minutes to vent the pump, vent the lines and vent 23 the system, from an air entrained system to operational system, 24 approximately 15 minutes.
25 MR. REED:
This is after you back inside containment O
Ileritage Reporting Corporation (202) 628-4888 j
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1 radioactive and you-have controls over containment entry?
2' MR. SCIILAZER:
Location of the pump is outside the 3
priming machine, the operator.
4 MR. REED:
It is, there is an envelope that has 5
certain activity build up in it, gaseous and'otherwise, and you.
6 will have rules and regulations to enter through the first lock 7-I assume.
O MR. SCl!LAZER:
That is correct.
~
9 MR. REED:
You think that you will have reasonable 10
. access to take care of this venting by just a manual valve?
11 MR. ' SCIILAZER:
We feel that for the conditions that 12 require venting, i.e.,
this particular scenario, that the 13 radiation inside containment would be low enough and time is
'~'
14
'available for the operator to get in there.
15 MR. EBERSOLE:
You invoke no argument.which defines a 1
16 radiation release into containment and venting, right?
I am l'
N 17 saying you have, you-argue that you won't, will not have'a 10 coincident of a need for venting, and activity in the
'19 containment.
'20 MR. SCl!LAZER:
Not simultaneously.
21 MR. EBERSOLE:
Or temperature or pressure?
MR.
22 SCIILAZER:
On RPR and emergency ECCS systems, our 23 units are two separate systems.
24-MR. EBERSOLE:
So you are invoking not coincidence 25 and you looked I guess at all aspects of that, you can'think of OO 11eritage Reporting Corporation (202) 620-4000 l
- =,
f, 100
.. g
- pJ
~1 in this case?-
4 2
MR. SCHLAZER: 1That is' correct.
I 3
MR.!EBERSOLE:
That doesn't include this little
'4
/ problem we had' at Diablo Canyon where they did it just' air.
~
5 JMR. SCHLAZER:
Does-include that event.
We feel at:
6 this'particular time, that'should we. lose RHR pumps, we feel 7'
there..is sufficient time without.the radiation levels of the 8
containment,: including high levels,ithat the operator can-'get' 9
in there and vent.the pumps land'get;the' system back in 10 operation.
.{
'll MR. EBERSOLE:-
I see.
l 12.
MR. REED: RHRs'is a strange acronym and it'means 13
- residual heat removal pumps, but you'are saying that your. pumps
.( )-
14
'do.not. work as low' pressure' safety injection. pumps?
They.only.
^
15-work for shutdown cooling?-
16' MR. SCHLAZER:
That's correct.
l' 117 MR.' REED:
Operations belowf350 degrees, and certain.
-18 pressure.
19 MR. SCHLAZER:
That is correct.
20 MR. REED:
So your occasions to have to vent would 21 fall below that 350 degree regime?
'22 MR. SCHLAZER: That is correct, for non-design basis 23 accidents.
24-MR. HERNAN:
Mr. Reed, the staff was a little bit.
25-uncertain as to what the situations they were postulating when li -
Heritage Reporting Corporation (202) 628-4888 L
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they' asked this question.
We couldn't postulate where the pump 2
would need venting at such time when people _would already be in
]
I 3-the containment.
In the case of Diablo Canyon, I believe the j
4 containment was occupied at the time of the operation.
.If that 1
5 situation were to occur at South Texas, it seems to us'that the I
6 people would already be in containment, all the containment
{
7 entry requirements would have been met.
It would be a matter 8
of walking over to the pump and venting it.
]
1 9
MR. REED:
Well, I think there have been a; number of
' 10 loss of shutdown cooling events and this is one that is--and l
11 some plants are designed by the RHR pumps function low pressure 12 safety injection,,and if they are in, you can have a more 13 severe problem, but if you are completely independent--.
14 HR. SCHLAZER:
We are not in that case, no.
15 MR. MICHELSON:
- Just for, to take care of my own 16 ignorance, we were discussing this same pump earlier relative 17 to the cooling capability.
You are telling me it will never_be 18 used during an accident in which'the containment is at high 19 temperature, whatever?
Or only, we are under adverse l
20 conditions, you will never see 325 on the pump when it is 21 needed?
You will not even be running it?
22 MR. SCIILAZER:
That is correct.
l 23 MR. MICHELSON:
You wait until everything cools way 24 down, back to normal, then you would just want to make sure 25 that during that exposure that you did not jeopardize-future lieritage Reporting Corporation (202) 628-4888
7,_____----
102 l
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1 use of the pump.
That's the onif-requirement, so you don't get.
4 2
into any questions of air cooling the pump under these very 1
l 3
adverse conditions because you are.not going to run it you tell j
1 H
4 me,.I thought?
Is that correct?
You can't vent it.
You explained 6
to me I don't need to vent because I am not going to use it so 7
you don't need to, qualification 1s not for dynamic operation, 8
it is only for withstanding static effects so to speak until l
9 later?
10 MR. HERNAN:
The qualification conditions were stated 11 in the SSA No. 4 I believe, which has been sent to you all, l
12 which is, as I read, 323 degrees, 48.4 psi and a hundred 13 percent.
~#
'14 MR. MICHELSON:
The question, question is does it-15 have to operate under those conditions or only withstanding 16 those conditions for subsequent operation when you are back to 17 cooler, much cooler conditions?
There is a big difference.
18.
MR. SCHLAZER:
Has to withstand those conditions, 19 operate under lower conditions later on.
Never be operated, therefore, never 21 has to be vented, but it does have to be, you must enter from 22 an event of that sort later to do this venting.
And I can 23 imagine the kind of steam leak, break or whatever.
It is kind f
24 of a tough condition in there at the time.
Might it even be a 25 steam tube rupture with it, which makes it even tougher and you
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Heritage Reporting Corporation (202) 628-4888 l
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(_yf-1 can do that subsequent venting a day later or something and 2
enter that' containment to do it?
That's what I think I hear.
3 That is kind of hard to believe that.
Now that I understand-L 4
how it is used, I still, the first problem we presented'I don't:
1 L
5 think is a problem.
This one is a problem, of trying to get in 6
~ there after such an event.
7 MR. HERNAN:
Mr. Michelson, what is-the scenario?
I-J B
guess'I am personally a little stymied.
What situation are i
9 you, requires the' pump to have to be vented?
10 MR. MICHELSON:
The situation that got you 325 degrees
~
11 Fahrenheit, 448 points of pressure, that scenario that got you 12 to those conditions, for which the pump had to' be desigried and 13 then subsequently you want to use the pump, you got the (5
lJ 14 conditions back down somehow, apparently about 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> lator 15 you want to use the pump and you are saying now I can enter the 16 containment if I have to at that point in time, to perform this 17 venting.
18 MR. HERNAN:
How did it become entrained in'the pump?
19 HR. MIC11ELSON:
I am not trying to name it.
Just 20 trying, a claim was made you could vent it I guess.
And I just 21 wanted to know how do you do it?
22 MR. IIERNAN:
Compared with the situation at'Diablo l
23 Canyon in which the RHR pump was intentionally starved of water 24 and vortex form--
25 MR. MICHELSON:
I wasn't intending to go back and l
("U) l Heritage Reporting Corporation (202) 620-4888 i
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speculate on the exact scenario that got you into it, but 2
rather that you have a design requirement that you be able to 3
vent it and you are claiming you can.
After, I guess'after 4
.this maybe you can't do it after this event.
j i
S:
MR. HERNAN:
Staff I don't believe has a requirement, 6
you know, to bind different unrelated events.
7-MR. EDERSOLE:
There'is no basis for believing you 8
will get air injection to an accident like this is what you are
'j 9
saying.
10 MR. MICHELSON:
That's the point.
11 MR. SCHLAZER:
That is correct.
12 MR. MICHELSON:
You are satisfied that is correct?
13 MR. REED:
1 might comment you may be adequately I
_s 14 protected--let me point out that there are incidents such as 15 wrong containment, wrong system, wrong valve, in two init 16 plants, where sometimes people might go and vent the wrong RHR l
17 pumps and the wrong containment, and if you think of those 18 things from a practical, practical point of view, operating 19 point of view, and the fact that you probably are subject to 20 vortex, I expect you have a half loop condition that you will 21 get cold in the shutdown operation.
22 MR. EBERSOLE:
Not post-accident.
23 MR. REED:
I am wondering would these wrong loop, 24 wrong things, are operators told to quicxly go up and find the 25 right containment, and vent the right pump?
I am just
- n. (j Heritage Reporting Corporation (202) 628-4000 i
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1 wondering if that all goes'together well enough?
2 MR..WISENBORG:- I understand your concern, sir.
I-3'
_ would point out'that South Texas is two separate, complete 4
separate nuclear' power plants situated side _by side, separated 5
by about 500 yards, so we are fairly immune to that type of 6-problem.
7' MR. REED:
You have. discrete operators for each?
8 MR. WISENBURG:
Discrete control room, discrete 9
operating ~ crew for these units.
10 CHAIRMAN KERR:
Paints one of the pumps blue.and the 11 other one red!
12 MR. EBERSOLE:
It is possible to inadvertently 13 introduce air into the suction uptake of these pumps by 14 operating one valve someplace, kill the pumps.
I am invoking,
.15 though, the: loop operation as a result of just a singular valve 16 operation.
And I walk up to the pumps.
What you are telling 17 me,-I don't need to, well, I do need, don't I?
After an 18 accident, I do need them later on.
19 MR. WISENBURG:
Under the accident scenario, the time 20 that you would use RHR is 14, 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after the accident.
21 MR. EBERSOLE:
Then you would have to have it, am I 22 correct?
23 MR. WISENBURG:
Depending upon the accident, yes.
24 Contain--the heat rejection mode at South Texas is fan coolers.
25 MR. EBERSOLE:
To get it out of the core, in the
()
s Heritage Reporting Corporation (202) 628-4888
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long-term?
2 MR. WISENBURG:
There are other ways to get~1t out of
'3 the' core.
4 MR. EBERSOLE:
I won't pursue that question.
5 CHAIRMAN KERR Further questions on this issue?
6 MR, KADAMBIs I just wanted to go down here and?
7 indicate where the staff stands on the follow-up to the biablo 8
Canyon events.
Wo issued a generic letter,87-112, tho' 9
licensee responses to those 50, 54 F started arriving the week 10 of September 21st.
The South Texas response was dated 11 September 22nd.
The staff review is, is not complete and 12 therefore we are not in-a position to state what the 13 concluulons of our review would be.
14 One thing we have seen is that the submittals of 15 almost all the plants so far anyway are subject to future work 16 being completed, analytical work, so right now, it appears that 17 the submittals are incomplete in terms of fully resolving all 18 the staff's questions.
19 At South Texas itself, I did want to list some of the 20 features which, you know, would tend to mitigate the concerns 21 related to the RHR system.
There are three trains of RHR 22 loops.
There are three separate trains of low head safety 23 injection loops.
There are three separate charging pumps.
The 24 Hi!H suction line has been built in such a way that it is free 25 of high points.
They have told na in response to the generic 0
lieritage Reporting Corporation (202) 628-4888
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. (3
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letter'07-12 that they will keep two_ core exit thermal couples 2
working when they are in mid-loop. operation.
The reactor 3
vessel level indication system uses the heat adjunction thermal 4
. couples so in addition to giving the indication of level, one 5
can also get temperature indications.
6 MR. EBERSOLE:
Does that mean this is a Westinghouse 7-plant?
They use the standard SDP cells, isn't it?
8 MR. KADAMBIs They use combustion engineering.
9 MR. EBERSOLE:
On a Westinghouse plant.
10 MR. KADAMBI:
Yes.
11 MR. EBERSOLE:
Interesting.
Never thought 12
. Westinghouse would agree to that.
13 MR. KADAMBI:
They have made a commitment again in 14 their response to the generic letter 87-12 that after the first 15 refueling outage, they will have when they are in miduloop 16
. operation, they will install control room indication of vessel 17 level.
10 MR. EBERSOLE:
They do not have the Westinghouse 19 level system at this time nor will they ever, is this correct?
20 MR. KADAMBI:
I believe they don't have it.
They 21 don't plan to, either.
22 MR. REED:
You mentioned that the R11R line.
You put 23 it singular.
Does that mean there is a single suction line for 24 RHR?
25 MR. KADAMBI:
There are separate suction line for
, 0( :
Heritage Reporting Corporation (202) 628-4800 l
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OUn separate line?
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tlMRy KA)p11F3It Yes, bet ause it is--
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, 31R. RSED:
You said there are-no high points on these 3
y '.
three#pss?
5 MR. KADAMP3:
That's right.
6 e
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MR. REED:
This is'not.tsafety related, but if there l
f 8
is no high points, it means7that the valves are all located
't t
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9 below the loops.
That is Q shut-off valves.
Suction shut-off a
valves, which will be interesting 3' diaintenance problem or 10
{
,);
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11 challenge sithout core unload, Lut'that's not a safety issue.
4 o
3 33 12 c
MR. WYLIE:
This -,
(
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MR. KADAM5I:
I gt%:ss I don't know how to address 13// l,0 (m) x' s
3 14 that.
15 MR. REED:
You don't have it.
I c
16 dR. WYLIF; These are 300 percent trains?
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17 MR. KADARBI:
Yes.
(
j' 10
MR. WYLIE:
So it is N plus 2 plant, in that right, 19 c:e to t.he safeguard?
20 MR. EBERSOLE:
Say,'yles, jl i 24 MI'. KADAMBI Yes.
l
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You also have generator circuit breakers l
. 2 ?h, f*on that plant, too, don't you?
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24 /
MR. KADAMBIr fYes.* There are circuit breakere.
1 s
26 MR. EBERSOLEi This is a high-class plant, man!
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'MR. MICHELSON:
The-three trainsof-RHR, two of?them
'2-
- were outside.of containment','a' third.one was in?
Theytare~all 3
.there, three?
~
=4' MR. KADAMBI:
All'three in.
=
.5.
.MR.
MICHELSON:..None.of'those are.needed.duringlthe:
i
-6*
first l4 hours of an accident?
.I thinkLthat's what..I heard.
~.7 Am1I misunderstanding something?
8 MR. WISENBURG:
No, you are-not, sir.
E 91 MR..MICHELSON:. Don't need RHRifor 14-hours, not 10'
' injection at all?
[
L 111 MR.,WISENBURG Notfinjection at all.
' 12 '.
.MR.
MICHELSON:
Any type of accident?
.13 MR. WISENBURG:
For any type of: accident; ECCS'for l
L 1* - >
14:
South. Texas =is three high head,Lthree low head located outside-15.
containment.
16 MR.-: MICHELSON : 'The heat removal is1through the
.17 conta'inment coolers?
18 MR. WISENBURG Same coolers for containment.-
'19-MR. EBERSOLE:
There is an answer to'the question of 20
'why you used CE level detectors versus Westinghouse.
I am not-21
.. going'to pursue that answer across the table here.
I suspect 22 what it is.
23 MR. KADAMBI Okay.
Can I continue?
l 24:
CHAIRMAN KERR:
Any further questions or comments?-
~25 L MR.~ MICHELSON:
One final clarification on RHR'-- do i
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1 you ever need RHR--got by for 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, and now what?
2 MR. REED:
You mean for save shutdown?
3 MR. MICHELSON:
For post-accident, only not for 4
cooldown or shutdown.
5 MR. SCHLAZER:
We use RHR for in the scenarios for 6
small break' load, long-term cooling, we use it for steam *1ine 7
break.
8 MR. MICHELSON:
Only after 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />?
9 MR. SCHLAZER:
After 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> for steam line break; 10 for the first 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> we would cool down on our active steam 11 generators.
12 MR. MICHELSON:
Small break?
13 MR. SCHLAZER:
Small break, the same way you cool
>J 14 down on active steam generators and depending upon the size you 15 would fill with our low head, you pump, keep inventory in, and 16 then if necessary, cool with RHR, depending upon break' size.
17 MR. MICHELSON:
Why do you ever need RHR?
At 14 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> why do you need it?
19 MR. SCHLAZER:
Long-term cooling, safety long-term 20 cooling.
21 MR. MICHELSON:
Can't do it through containment?
22 MR. SCHLAZER:
Depending upon the heat level, j
l 23 depending upon the size of the break.
i i
i 24 CHAIRMAN KERR:
Are we going to suggest they remove l
25 the RHR7 Heritage Reporting Corporation (202) 628-4888 l
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1 lMR. MICHELSON:E No. :Just. suggesting that I want'a 21 Eclarificat' ion'.-
That-one missed me completely when we looked at p.
3-South Texas..
4 4
MR. REED:
I just got1 confused.'now..
I thought.there 5-was no requirement for~an RHR,.for any break, Land.nowiyou are 6
saying for small break, there is a requirement?-
'7-
'MR. SCHLAZER:
For small break' loco,' depend 1hgLupon-8-
the break size.
For a very, very.small break, about less than-9 one square foot, I believe the number is--
i
'10 MR. REED:
Which contaminates the interior?
11 MR. SCHLAZER:
Contaminates the.interf.or, essen'tiallyc s
!12' what we would do.is provide a long-term cooling, all safety J
' 13 grade equipment.would be through RHR,'not'being more than 14 safety grade type' shutdown and for safety type scenario.
15 MR. REED:
The small break occurs, the interior of 16 the containment is. contaminated.
You.have activity in it.
17 Your vent valves are manual, in site containment.
+
18 MR. SCHLAZER:
There isuno cause for venting.
19 Inventory is maintained ~through.the I head pump.
+
20 MR. REED:
You'are saying.you are always sure your 21 laid-up pumps don't have air, that air doesn't separate the
- 22 hydrogen, doesn't separate in the pump or anything?
23 MR. SCHLAZER:
Not at that elevation.
24 MR. EBERSOLE:
Do you periodically check this?
5 MR. SCHLAZER:
Pumps are inspected once every 30 2
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-MR.
REED:
This adequate protection, quotes,' adequate
- 3
~by, if11'was the operating person there, I would certainly want-
'4
'the11ow operators on those valves for.the: scenarios and'the use 4
Se that'one.~you: told me about.
16:
MR.~EBERSOLE:
You don't'have any system to ensure'
.7~
' filing,1you just --
8.
MR. SCHLAZER:
We have aihead tank, above the heat 9
exchangers to ensure that the-level is maintained in the RHR 110 system.
There'is a head tank.
11-MR.- EBERSOLE:
And you have' evidence the operator can 12 see.outside conta.inment?
13 MR. SCHLAZER:
We have a level indication on the 1L 14 tank, on the tube.
15 MR. EBERSOLE:
Okay'.
So they run surveillance at l
16 some intervals then?
17 CHAIRMAN KERR:
My schedule shows we are supposed.to 18 be completed'at this Another five minutes, is that going to be-19 adequate to cover the issues?
20 MR. KADAMBI:
Let me try to hurry up through the rest 21 of my presentation.
22 The second item that was listed as lack of diversity L
23 in the control room, in the control rod scram holding circuits, 1'
24 I interpreted this to be tied to the July 2nd McGuire-event u
25
'where there was a broken weld in a breaker.
I believe the O
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J-1 concern is related to the possibilities that mechanical failure i
2 could affect redundant breakers, and perhaps that'the failure L
3' of this type was not covered by general letter, the salient 4
follow-up.
And also the Westinghouse response didn't really
.t address breakers.
6 The. current staff position on this is that, you know, 7
it is a random event.
A bulletin is going to be issued shortly 8
for all licensees to inspect this weld of concern.
We feel
-9 that there is no other safety issue involved in this,'and that 10 the staff evaluation of the Westinghouse submetals to the rule 11 50-62 still remain edequate.
i I2 The licensee's position is I guess they are still 13 being, they are still evaluating the recommendations in' g_
14 response to the information notice that was put out as a result 15 of the, this event.
16 MR. EBERSOLE:
I think I should comment on this.
I i
I 17 probably initiated it.
It is new, the fact we did find the l
18 McGuire failures indicating a mechanical defect because of I i
19 guess malfabrication, and it again emphasized the fact that I
20 there is no redundancy in the, or rather diversity in'the 1
21 Westinghouse concept, although great pains is taken to provide 22 a bit of diversity in signal generation and processing circuits 23 that go into the breakers, however this breaks down when you I
24 get into the mechanical breaker proper, and there it is simple i
25 redundancy.
I point out it is a mechanical device of high Heritage Reporting Corporation J
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' energy, really.not' designed for_ operational use-but rather for 2;. breaking! circuits under duress.
And'these breakers would 1:o ~
13 appear to present a problem with coincidence of failure;in-4
' simple _ redundancy:because of their' mechanical-complexity, as
'5 occurred at Salem,.but then.for!any other number o'f mechanical.-
6 causes,-and comp larative ease of'getting a; diverse;tripLgoing 7'
zinto the existing-system raises the question why don't.we have 8
true instead'of artificial diversity:where you.have strained to:
-9 claim'you have it..
It is a sensing _ circuit but you haven't-10l
' carried through.to the mechanical design.
cil The question was brought up here because:of:the 12.
realization that this was-a~ conservative utility that might be 13-giving some consideration to getting a_somewhat-better breaker j
or r.ather breaker, rather circuited interruption process:to the P'
14
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15' magnet.
16'.
By the way, we have run a little internal study.
We 17 found a,.I think a failure.of two out of a hundred of breakers, 18 but I don't yet know whether that's in the closing or opening 19 mode of the breakers.
I think it is in the closing mode, when 20
=you are trying to compress the springs, so we are going to 217 break that down and get a better picture of the actual 22-liability of these breakers.
23' In fact, my understanding is we wear these breakers 24-out testing them.
We need to have some place where we don't 25 wear out our circultbreaking equipment, but stand and wait for
( O Heritage Reporting Corporation (202) 628-4888 l
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1 an incident'when we only need it once, that blue moon. That
'2' would be an exciter interruption device.
Do you follow'me?
3 MR. KADAMBI:
I do, and I believe that.
4 MR. EBERSOLE:
South Texas is not unique.
I don't 5
want to. point to South Texas.
It is the whole Westinghouse 6
set.
7 MR. KADAMBI You are right, and on some of'these 8
questions, I believe the staff did consider these questions, in
'9 terms of what kind of follow-up actions, you know, are 10 appropriate to this event.
The conclusion is coming out that 11 you know, we are going to issue a bulletin to make sure that 12 everybody looks at this weld and that it is in fact okay.
13 MR. EBERSOLE:
I put that in the category of standard 14 generic approach to problems that the staff uses which I call 15 pettitis.
16 MR. KADAMBI:
Anyway, may I proceed?
17 CHAIRMAN KERR:
How much more did you have?
18 MR. KADAMBI:
Just two more such overheads.
19 CHAIRMAN KERR All right.
20 MR. KADAMBI:
I hope it will go faster.
21 (Slide) 22 MR. KADAMBI:
This one, it has to do with I believe a 23 concern that some of the older Westinghouse plants interrupt 24 the pump, the safety injection subsequent to an accident.
At 25 South Texas, the changeover from the RWSTT to the sump is O
Heritage Reporting Corporation (202) 628-4888 l
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)
1 automatic, so--and the calculations,.the analyses are performed s
2 with that assumption, so I believe the concern doesn't apply at 3
South Texas.
4 MR. EBERSOLE:
Is it independent automatic or single 5
automatic transfer function?
6 MR. KADAMBI:
When you say independent--
7 MR. EBERSOLE:
'When you make a transfer, what-8 executes the transfer. function?
Is it a--
9 MR. KADAMBI:
It is sensing of the low level in the 10 RWSTI.
11 MR. EBERSOLE:
Is that done in triplicate or 12 duplicate or redundant configuration?
?
13 MR. KADAMBI:
I be]ieve it is done, maybe.I'will j.,
14 invite the applicant--
15 MR. WISENBURG:
Each loop is done independently.
16 MR. EBERSOLE:
Carry on.
17 MR. KADAMBI:
Okay.
18 DR. MARK:
That related I believe to the report, 19 preliminary report, there was a ten-minute interval which might 20 lead to trouble.
I think the situation is that here, there 21 isn't such an interval.
22 MR. KADAMBI:
That's right.
23 MR. EBERSOLE:
Ron, you told me there was really only 24 one plant, 25 MR. HERNAN:
Turkey Point, the problem came up in b.
v Heritage Reporting Corporaulon (202) 628-4888
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.1 Turkey Point, in the design verification.
+
2 MR. EBERSOLE:
Other Westinghouse plants dch't have 3
.the problem either, not near South Texas 4
MR. HERNAN:
That's.my understanding.
5 MR. EBERSOLE:
Thank you.
6 MR. KADAMBI:
That brings me to the last of the 7
questions that was brought up, and I believe we have covered 8
this in some detail already.
9 MR. MICHELSON:
I thinking we haven't covered at all 10 much the actual event and what happened and what did they do to 11 correct it.
12 MR. KADAMBI That's right.
The concern I believe 13 was precipitated by an event on July 10th, 1986, in which fuel
.,,s 3
V 14 oil spilled into the diesel generator room.
The reason for 15 that spillage then was a combination of operator error;'and the 16 fact that the level indication was not properly calibrated.
17 The operator did not know when the fuel oil level went up to 18 the overflow, and continued'to fill and that's what caused the 19 spillage.
At that point, the plant was still under 20 construction, and some of the drains were not completed.
In 21 fact, some of the drains were actually clogged at the time.
22 And so the spillage did, some of the spillage did get into the 23 diesel generator room itself.
24 MR. MICHELSON:
How did that happen?
We were assured 25 that that, those rooms were sealed from each other.
Because we k
Heritage Reporting Corporation (202) 628-4888
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1 had talked about this at the time of the-licensing process, so 2
what was missing that allowed the water, I mean allowed the 3'
fuel oil to get into the diesel compartment?
4 MR. KADAMBI:
At the time the construction had not 5
been completed to the point where all these drains were fully 6
operational, and a drain plug I believe that separates 4the 7
upper chamber from the diesel generator cell was not in place, 8
and that's what led to--
9 MR. MICHELSON:
Where should there be a drain plug to 10 begin with through that barrier?
It is something fou can open 11 up now.
12 MR. WISENBURG:
If I might answer, I think I can 13 simplify this.
All the piping penetrations between the fuel j _)s L'
14 oil storage tank room and the engine compartment itself were 15 not sealed.
Seal job was not complete.
16 MR. MICHELSON:
Now you have done the seal' job?
17 MR. WISENBURG:
Now the seal job is completed.
18 MR. MICHELSON:
Now do you know the seal job will be 19 adequate if you should experience similar event for some 20 reason, whatever?
How good are the seals?
How much oil on the 21 floor will the seal withstand?
Those are fire barrier seals 22 normally and I want to know are these also really fuel oil 23 seals?
24 MR. EBERSOLE:
The gravity head.
l 25 MR. MICHELSON:
Not all fire barriers are O
Heritage Reporting Corporation (202) 628-4888 a
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-1 hydrostatically sound.
2 MR. WISENBURG:
These fire barriers are 3
hydrostatically sound.
I can't give you off the top of my head 4
-the-height of them.
5 MR. MICHELSON:
That is design requirement, that they 6
withstand certain hydrostatic levelof fuel oil on the floor.
7-Is that correct?
8 HR. WISENBURG:
.It is a design requirement.
9 Unfortunately, I am not familiar with the details of that.
10 MR. EBERSOLE:
In the filling of this tapping, you 11 fill it with transfer pumps upstairs?
12 MR. WISENDURG:
Yes, sir.
At the time of the event, 13 by the way, those pumps were not in, either.
(,)'s.
14 MR. EBERSOLE:
Well now they are in, you fill these 15 with pumps and they go up to certain level, automatic cut-off 16 then?
When you get the fuel oil so high?
l 17 MR. WISENBURG:
No, sir.
18 MR. EBERSOLE:
That's an operational procedural 19 controlled process.
He has level gauges to see where he is?
20 MR. WISENBURG:
Yes.
21 MR. EDERSOLE:
Not redundant I presume?
22 MR. WISBNBURG:
Yes, they are.
23 MR. EBERSOLE:
So--
24 MR. MICHELSON:
Not safety grade, are they?
25 MR. WISENBURG:
No, they aren't safety grade.
Heritage Reporting Corporation 4
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l' MR. EBERSOLE:
He fills them under normal 2
circumstances, so but they are checked and originally for 3
adequacy.
4
.MR. WISENBURG:
Calibrated and checked.
5 MR. EBERSOLE:
Should something unfortunate happen in 6
your overflow you would want to drain the oil away anyway.
7
- MR. WISENBURG
That is correct, sir.
8 MR. EBERSOLE:
Where does the oil go?
m 9
MR. WISENBURG:
To the plant's oily waste.
10 MR. EBERSOLE:
What is the capacity, full capacity of 11 transfer pumps?' What arbitracy' discharge rate through the 12 drains have you taken?
If it is less than the capacity of the 13 discharge pumps, I have a question for you.
Q_
14 MR. MICHELSON:
I thought you were going to pipe the 15 overflow in so it didn't dump into the room?
Maybe I 16 misunderstood.
You don't have to vent to the room.
There is a 17 lot of other more gaseous places to go.
I thought you were
'{
18 going to vent it somewhere else, so that you wouldn't flow over J
19 into the room, right above the diesel engines.
.20 MR. WISENBURG:
It overflows to the room.
21 MR. MICHELSON:
To the room.
22 MR. WISENBURG:
Yes, sir.
Then the room drains to 23 the waste system.
24 MR. MICHELSON:
You better ask about the quality of 25 those seals, too, relative to fuel oil getting them as opposed Heritage Reporting Corporation (202) 628-4888
121
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1 to moisture or water.
Are they really fuel oil seals?. Not 2
just fire barrier seals that you think will hold the 3
hydrostatic pressure?
You'may dissolve the material from the 4
-seal.right away.
Fuel oil is'really an aggressive agent.
I'
-j 5
don't'know how long it.will hold the seal unless.it has been-6 tested.
This doesn't sound like they.have done their --
7 DR. MARK:
That is all you had, Mr.Kadambi?
8 MR. KADAMBI:
That covers the actual presentation.
I 9
just wanted to state that we have completed the review on these-10 items, and from a licensing point of view, South Texas has met 11 the acceptance criteria, and I guess that's the conclusion.
12 MR. MICHELSON:
Have you looked at the seals' between 13 the two floors and satisfied yourself that if oil overflows the-14 tank which is a non-safety grade arrangement, that you can
'15 withstand, that the fuel oil will not penetrate through the 16 seals and into the room below.
17 MR. KADAMBI:
The way we did the review was'to 18 postulate the accident, the design basis accident, for'that 19
' cell was the spillage of the oil from the tank.
And you know, 20 did the design features meet this accident is tr.e way that it 21 was looked at, and the conclusion was that it does.
Now I 22
.can't tell you any detail.
23 MR. MICHELSON:
You did look at the effect of fuel 24 oil on the seals to be sure that they withstood some reasonable
]
1 25 length of time so you could get the place cleaned up before the j
l' h l
u/
l Heritage Reporting Corporation j
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122 lll-1 oil was getting into the engine compartment?
2 MR. KADAMBI:
I can't say for sure whether that 3
particular question was addressed or not, no, sir.
4 MR. EBERSOLE:
I can't quite remember the picture of 5
the gaseous space above the fuel in these tanks.
Did you do 6
that or n,ot?
Did you argue it was non-explosive?
I know it is 7
a common question.
Bury the tanks under the ground; as to 8
whether these'have enclosive vapor, they are --
b 9
MR. WISENBURG:
No, sir.
The tanks are vented to the 10 room and the room is ventilated.
11 MR. EBERSOLE:
You argue there is no ignition point?
12 MR. WISENBURG:
That is correct.
13 MR. EBERSOLE:
The vapor pressure is too low?
14 MR. WISENBURG:
That is correct.
15 MR. MICHELSON:
Ignition atmosphere, hopefully that 16 vent line so the fire doesn't blow the tank.
i 17 MR. WISENBURG:
Yes.
l 18 CHAIRMAN KERR:
Further questions or comments?
Thank 19 you, Mr. Kadambi.
20 MR. KADAMBI:
Thank you very much.
21 DR. MARK:
I have ten minutes to talk still.
i 22 CHAIRMAN KERR:
We will defer to my agenda.
23 DR. MARK:
There is ten minutes for discussion.
The 24 discussion which I have is really not worth ten minutes.
25 CHAIRMAN KERR:
My agenda shows this session ending O
Heritage Reporting Corporation (202) 628-4888
123 lh 1
at 12:30.
2 DR. MARK:
The question I have, sir, is there any 3
occasion for us to write or say anything else concerning South 4
We have already written a letter a year and athalf ago 5
saying we think it is okay to operate that plant.
I believe 6
that's the current situation, that there is nothing we need to 7
do.
8 CHAIRMAN KERR:
Comments?
9 MR. REED:
I would like to have somebody, perhaps the 10 staff, provide me with a non-conflicting discussion of the RHR 11 shutdown cooling pumps in use.
i 12 CHAIRMAN KERR Before--
13 MR. REED:
Sometime --
14 MR. EBERSOLE:
That is not a condition.
15 CHAIRMAN KERR:
You just want some information.
16 MR. REED:
There was some conflicts in the story and 17 I would like to hear it.
18 CIIAIRMAN KERR:
Are you proposing we try to' hold up 19 further action on licensing, or you just want this information?
20 MR. REED:
No, I am not.
21 MR. MICHELSON:
I would like to see the staff's 22 evaluation of whatever it was of the problem of overflowing a 23 tank in the storage room, and the qualification of the seals 24 and whatever to withhold the oil from the engine compartment l
25 for some reason at the time, and I think you have to answer O
Heritage Reporting Corporation (202) 628-4888
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L1 Lthat, question as:a'part of your. original'. evaluation'.-
.21
- CHAIRMAN KERR
- ' Do you-think,-however,. that we'need-
- 3-to write a-letter?'
41 MR. MICHELSON:
Not atLthis point.
- I-would;like.toL 5L 'see.the-evaluation.
It may'be perfectly' good.
6' CHAIRMAN.KERR:- Okay.
.7 DR. MARK:
There is'nothing:we needLdo unless we hear
'8
-something'in1particular.
And our original letter:which was, 9
had three' conditions, they-have-been met.
Further-questions 10, have been discussed. -Further questions.might or might hot.
7 11 arise, 'and if the.:staf f,is in a - position as I ' believe' it to be 4
12.'
'of.saying the full power license is. warranted,-you can move 13 forward from where you are, that's where we' leave it.
. s 14-
, CHAIRMAN-KERR:
Lunch break; back I'n an' hour.
1S' (Whereupon, at 12:45 p.m.,'the meeting was recessed,
- 16 to reconvene at approximately 1:30 p.m. the same day.)-
17 18 19 20 21 22' 23 L
- 24 l
25 L
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3 CHAIRMAN:KERR:
Okay.. Now we'will1. talk aboutithe j
'4 LZion Station. full field exercise.
4 Mr. Moeller,.whoLis the
- sj.
.. cognizant _ Chairman,,will introduce theJstaff member who'is w
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.6 going-to make the presentation.
7 DRS MOELLER: Gee.tlkhnks. :We?have.those on-the' r
Committee' who-rdc 11" tiiey held' a ful1-scale. field exercise -
8.
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.at St.. Lucie aboutethree years 7ago?.Lwhat,.1984?L Then the:
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secod full scals ' exercise.was ' held Et Zion roughly ' June, i
10; 11.
- several monthsyag'o.c a k L12
-And today we will hear.the lessons learned;
.13
.MR. PERKINS: 'If you don't mind,-I' wiil..'use'the 14 podium.
15 ~
.(Speaker moves to ' podium) 16 MR. PERKINS:
Good ' afternoon.
'I am-Ken Perkins.
- .17 Ic am Chief of the Incident Response Program;for.the Agency.
18 I was one of the management group members in planning for 19-the federal field exercise at St. Lucie,,the relocation 20)
. table-top-exercise that we had in '85lat Beaver Valley,.and-21 the federal field' exercise we had this year'at Zion Nuclear 22 '
Power Plant,
<a 23 (Slide) h 24 The federal field exercise goal was to test the 25 federal plans and procedures for providing timely and Heritoge Reporting Corporation m.
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This includsd licensee, two 5
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.We had'200 non-players.
These.were.the people-8' who.were responsible for the conduct'lof the exercise;-that
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the visitors duringithe exercise..
- ll' We had:a total of:175. visitors.
Of:that. number, 12-about.80 were foreign visitors.
He have had'a high' level' 33 of in'terest'in5the: international community'in!.o~ur response 34
. capabilities,'especially since Chernobyl.
15 But from'the Op Center I can tell you we have had.
16
.a rather= persistent international-interest.
The exercise--
17-DR. MARK:
Excuse me.
What is the wind rose like 18
- at Zion?
-19 MR. PERKINS:
It is a lake-front site.
20 DR. PARK:
I know that.
21 MR. PERKINS:
.'I'm sorry..I.cannot hear you.
22 DR. MARK:- Wind rose, distribution at 360 degrees.
23 MR. PERNINS:
.I.am afraid'that! I do not-have that
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25 DR. MARK:
The prevailing winds are from the west.
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I don' t know-.and I am sorry that I.cannot.
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In the scenario,.Ifcan,tell you that; 6
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The exercise took place over three days'but the 8
time frame that it' addressed--that is, the. problems that 9
.'it addressed--were.for a ten-day ~ time line.
So we did'
-10 get:.into. addressing some of.the recovery.and' reentry issues.
11 DRL SIIEWMON:
Which way did the wind bicw in your 12-test?
Are'you going to get to that?:
13
' tiR. PERKINS:
If that is of,60cial importance 3
-14 to you, sure.
15
.DR.
SHENMON:
Whether.there is any radioactivity
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.over land has.a large effect, you might realize.
That is 17 why we,are interested.
.j 18 MR. PERKINS:
It did blow over' land.
The. plume 19 went--well, let's go to the next slide.
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20 (Slide) 21 Actually'this map.does:not give us enough j
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But the plume'was, if you are 23 interested in meteorology, you are probably also familiar 24 with lake breeze effects' and...the fact that you'have diurnal
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For about 190-degrees then:we'had' a shift to about'45-dsgrees and then it. rained.-
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It essentially'came.into Illinois, D
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(Points " to map on slide) 10 gg:
l'P. - NEISS :.And'then it shifted down about the:
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-Oh, that's ri(fht.
It. shifted down.-
14
. CHAIRMAN KERR:
Are you describing'what.the 15 weather was like or--what it was hypothesized to be?'
16 MR. PERKINS:
What.the scenario was.
17 MR. WEISS:
No. It was hypothesized on' Day..l. On 18
. Day 2 and Day 10 we used real weather.
MR. PERKINS:
We used real meteorology on those 39 20 days.
But for the plume deposition, that is the meteorology-21' that we used in order to provide.the field measurements.
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.And to be able to provide the 23 MR. PERKINS:
24 footprint.
25 Okay.
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11!
So it'is-a close-in Emergency Operations Facility..
12
.We also had the licensee'sLJoint-Public Information Center.
13-located'down,here.
14 -
(Points'to point on slide) 15
. This is the place where the -licensee,: the two 16 states and the federal public affairs people went to c
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Other~ facilities tha' we had participating in
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20.
And'not shown on this map was also up in Wisconsin, the 21 Kenosha County Emergency Operation Center.
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N DR. MOELLER:
The.last'two, the FRMAC'and.th'e FRC,
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are they at that particular site or at that.particularLplant' v
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.or for~thatjparticular exercise at that particular plant?
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No, Dr.'Moeller,- That'is 'at good 10 -
question; Both'the Department'of Energy's facility and 11-the FEMA facility are not pre-designated.
They are 12 identified ~onia case-specific basis.
33 One of'the things that.we would like:to,see is a-14 little bit'more thoughton pre-designating those..It would 15 make.their be'ing set up occur more easily;.
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Remember, with respect to a radiological emergency-38 at a licensed power plant, there are two primary decision i
19 makers.
20 The Federal Government is not one of them.
21 The first primary decision maker is the licensee.
He has the ultimate and continuing responsibility for mitigating 22-23-the con' sequences of the accident; that means the in-plant 24 actions and recommendations to the offsite authorities.
25 Okay.
The other decision maker is the state or Heritage Reporting Corporation l
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role.is.primarily one of: supporting'the' licensee.'and the.
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and it may include just confirming that the licensee's 20 protective action and recommendation is appropriate.
21:
Fourth, another benefit under the federal plan is that the NPC is the single agency for capturing technical 22 information from the site and providing it to the other feds 23 p
so that,1f we have another-Three-Mile Island type of situation, 24 we do not have the same pitfallithat.we had where there were 25 Heritage Reporting Corporation non m
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8 How'does all this come together?
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that is the' Governor.
He has to de'ide'whether and'how to implement:
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Do,you know if he is using the
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(Laughter)
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That is probably the only one we will' 19-ever get.
20-(Laughter) 21 MR. PERKINS:
Okay. - What.I wanted to show next
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That'look's like a line' function
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The.processlis.
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It is going'_up. 'We!re going upfto wJ
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The decision making-is going up.c 14.
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So that is'just a, feed.to the top.
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Correct.
This is "a" recommendation.
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i 22 MR..EBERSOLE:
So the' decisions come out'of his l
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Yes, Sir.
Okay.
Next.
Remember I 3
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The first one that I should have up there is that 17 the Federal plan really did work. There are some areas that gg are going to need adjustment or modifications, but it did 39 work.
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exercises once every three years.
7 That is not often enough to make sure that all of 8
the states and licensees understand the capabilities that 9
are there.
In fact, their argument is that we are to negatively training states and licensees by not being Il there.
They learn not to expect us.
12 And then when we participate, we are a major n(v) 13 perturbation.
In my opinion, that is a valid criticism.
14 However, we have to find something that will enable us to 15 get our participation message or experience across that is 16 not so labor and dollar-intensive as the federal l field 17 exercises.
18 Okay.
Next, in this exercise, because we went 19 to Day 10, we did start addressing recovery and reentry 20 issues.
And we formed--Bert Davis,who is the Director of 21 Site Operations, formed a recovery and reentry work group.
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Okay...The next lesson learned was that start-ups;
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'you.did cause some interruption or some perturbation.
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The more agencies or an organization, exercised, the 9-better 'it'. performed.
10 And soLthe' message there was primarily to FEMA and 11 DOE. 'TheyEcught to exercise. setting up their FRMACs and 12~
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25 Okay.
He experimented with using electronic mail i
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What part of that,'was valuable?J
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You meanithe hardware.or the-fact that you only used~a-14 15 single communication?
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The' mechanism.
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CHAIRMAN KERR:
Thank you.
J 21 MR. PERKINS:
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kept' informed and will coordinate that.
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Congressional person in the field may be needed and we need to work-that out in detail.
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Next is one that I find particularly interesting 8
and I am particularly committed to myself.
NRC needs to 9
clarify NUREG 0654, Protective Action Guidance, to better 10 describe the Agency's intent, il The process that we went through in setting up 12 this exercise had us do a table top,.then a dry run, and o
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13 then the exercise.
During the dry run, we ran into a 14 situation where the licensee--I'm sorry--where the state is was not prepared to recommend protective action until they j
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They were waiting for actual 17 doses that would trigger their threshold or projected 18 doses that would trigger their threshold'.
19 The licensee, if I recall the situation correctly, i
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22 We have met with the state and the licensees.
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Would that action;have.been[to'geti
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- 15
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'I' expected ~that that might be I
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But,I would like--could~we hold
- 17
' pursuing that'until the end?y,
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18 DR. SHEWMON:
Yes.
I think'I only[hadea 19 MR. PERKINS:, Okay; S
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20 couple more slides anyhow.
Next I wanted to mention to you l
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24 (Slide) 25 And the first point was that the FRMAC, as we call l
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DR. MOELLER: These are what samples,:. Ken,-
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19 (Slide) l 20 Next with~ respect ~tocthe' federal rAsponse center, 21-
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16 (Slide)
'17 The last slide that I have speaks to--
-18 DR. STEINDLER:
.Let me ask a question.
Is there a 1
single document in which responsibilities, accountability 19 20-and functions have been integrated through NRC, DOE, the 21 state, FEMA-that?has;been;found'as,an' operational plan?
22 MR. PERKINS:
Yes.
That is in the federal JD 23.
response plan.
I can get'you a copy.
24' DR. STEINDLER:
Are not all the things that 25 are indicated here that seem to be unknown--for example, Heritage Reporting Corporation (302) nemos u_____L_____.
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- 17 one.
And we think, on that~1ast one that I just 18:
mentioned, that some detail needs to be developed there.
39 20 Okay.
The federal plan, in our opinion, needs 21' some modification with respect to the following.
First off, the plan should be modified to include the Department 22 0
- 23 of State.
That really became clear under Chernobyl, the 24 Cherneb"' event, when we were manning the OP Center 20 and guess 14-hour days and had the interaction with the Y
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6L So, too,-should'GSA.
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support capability that they can provide.through the 8L resources lthat GSA has.
9-As I mentioned before,Lwe need t'o-provide
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15 Under:the federal plan, NEC'becomes the'"stuckee"
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.19 Well, what we have found is.that is perfectly 1
20 appropriate for the period of time in which the event is un-21 folding, the period of time in which.the plant is unstable, 22
.and while.you are going through the process of deciding, p
23 is it now stable,'are there generic implications.
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2 But you reach.a pointirelatively1 guickly where'
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might.the' private citizen-do, even'if he.is allowed to go-10 int'o"the gray, area, to further_ reduce his' exposure?
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g g" Our" point ofl view'is.that NRC is not'the agency 12 with the greatest expertise for th'at.
It)is'more like.
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AndF so!weihave set up#a'mehting.with EDA.. It is 13 the EPA. ;
34 -
not a new. issue to us.
It is one we have been trying to 15 get EPA to,. ' bey more i ang'ressi've. on -.
16 But we now have done some ground work and' background l
37
._ work.
EPA is receptive to=taking a lead'for recovery and:
18-reentry.
The~NRC would still stay the cognizant federal u
39 agency, but EPA would be the lead and support the NRC in 20 the recovery and reentry aspect.
21 Yes, sir?
22 DR. SHEWMON:
Another interruption.
What if l
23 Grandpa Smith decides he is not going-to leave like the 24 guy up there by the mountain up in Washington?
Do the 25 police have the power to take him out forcibly?
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That,.according to my experience,:
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.MR. MICHELSON: 'Can I.go back to EPA?
Why;did(you-
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'7 pick EPA?. On an hi'storical basis, itJseems. to me ' that :tihn1 ll t-1 q-8 precursors of FEMA have many. fairly well-developed plans 9.
to. precisely address the-issues you are" talking about, based; I
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' handl'e' questions of what! kind'of'decontaminationishould-U
.15 private citizens get involvedjin.
On that basis, I won' der.
16 why you elected.to tag the EPA for that job?
17-MR.PERKINS:
It is our' observation that the 18-current FEMA organization does not have the radiological i
19 assessment expertise nor charter, really, for performing 20' that' kind of assessment.
l
.21 And EPA was the organization. after all, who had 1
-22 that role for Chernobyl.
And'it was based upon that 23 experience and the fact that EPA also further into an event I
Q 24 assumes responsibility or. takes over responsibil' v for the 25 FPJmC.
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we have;gone':a step further than..the' Vienna Convention
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8 If yoti remember,the Vienna Convention talks ? about 9'
trans-boundary impacts..Our-observation is that there are real impacts 'n'd there are'perceivedLimpacts. 'And the 10' a
. l
~11 Vienna' Convention really addresses the real impacts that the publicjhas:concernsjwhgnever there is'a. radiological.
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13 14
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'information as we can as early as we can.
'l 18 So what.we have said is that for any event for 1
i 19' which the NRC response organization activates, we will 20
-call in international programs and we will set up the 21 linkage'through the State' Department to provide information 22 on that event to other countires.
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,i 23 CHAIRMAN KERR:
What sort of information do you l
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24 have in mind?
25 MR. PERKINS:
The type of information that we put Heritage Reporting Corporation
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in the status summary, which talks to the plant conditions'
(
2 as we know them.
It is the same kind of information that 3
we would make public in this country.
4 We would not get into great detail,' great technical 5
detail in those documents but speak to overall plant 6
conditions'and magnitude of releases and projected health 7
effects.
8 CHAIRMAN KERR:
What will your representative do 9
who deals with the Press?
10 MR. PERKINS:
Yes.
11 CHAIRMAN KERR:
And the Press, of course, will not 12 stop.at what you give them.
They will start probing.
llll 13 Is it going to be illegal for individuals associated 14 with this to give additional information or perhaps even 15 information that has not been cleared to essential 16 organizations?
17 Because once this gets to the Press, it is 18 disseminated internationally rather widely.
19 20 (Continued on next page) 21 C:)
23
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25 Heritage Reporting Corporation
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MR. PERKINS:
That's a very good question.
Let me 2
give you an illustration of what we have done to try to make 3
sure that we've got a realistic response there.
First let me 4
tell you that we've been in our new operation center for about 5
30 months, and during that time we have run exercises in which 6
a commissioner, chairman or other, comes out and manages the 7
organization, about 14 times in 30 months.
That's about once 8
every 2 months.
It includes reactor exercises, transportation 9
exercises, fuel cycle or materials facility exercises.-
10 Okay.
Now, what do we do on press releases?
The 11 status summary is the official agency position.
We'd like to 1
12 have just one person speaking so we don't contradict ourselves.
13 We know we can't do that, but we do put out the status summary 14 to represent the Agency's official position on understanding 15 the conditions at the facility and the impacts off-site.
We do 16 also provide technical briefers who we train and exercise, with 17 a reactor engineering background and with a health effects 18 background, and their mission is to put what they're being told.
19 in the press release or in the status summary into some 20 technical context to help the media understand it.
21 Now initially, when we're operating out of the 22 operations center, we set up a news center in Bethesda at the 23 Phillips Building, where we deal with the media.
Once the 24 regional administrator arrives at the site and the baton is 25 passed to him, then the focus of interaction with the press is O
Heritage Reporting Corporation (202) 628-4888
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I transferred to the site and it's handled from that joint press 2
information center that I showed you.
But the basis, the main 3
document, that we rely on is the status summary, and press 4
releases are built off of that status summary.
5 Okay.
Are there any questions up to now?
I just want to 6
say that the one other lesson learned that's not up there is 7
we've got to do something to get the FFE experience out to 8
thop' other states and licensees.
If we don't, think about it, 9
it takes three years to do a licensee.
I don't know the number 10 of years it's going to take us to get around to everybody once, 11 but it's a bunch.
So we've got to find another mechanism.
12 We've tried capability conferences around the country where 13 Department of Energy comes and they set up their FRMAC, we talk kJ 14 about what we do, FMA and EPA talk about what they do.
But it 15 comes across as the Feds talking at the others, and then we 16 take them and we show them the equipment, and it looks more 17 like a May Day parade than it does a capabilities conference.
18 MR. REED:
You mentioned parade -- I notice there's 19 about 1400 people involved here, and if you price that out for 20 3 days, you're talking about a half a million dollars that this j
21 kind of activity costs.
I think you're doing it on a> pretty 22 frequent basis.
I wonder, on a cost benefit basis, is it all i
- 23 worth that compared to the fact that Chernobyl didn't have a l
24 plan at all, and was that okay or not?
versus half a million 25 dollars for exercise?
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153.
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lMR. PERKINS:
First off, the~ cost'was welliinlexcess-g l
2 of~whatiyou've stated.
3-
'MR-REED:' ' Well I ~ thought: lt 'would be. becadse' you --
4 MR. PERKINS:' 'And, but I appreciate,that.
I_ guess-5 lthe1 Federal government has decided -
it's'not my decision,fbut 6
I guess I would support it -'that making sure that the-Federal:
- 7 government is ready to respond if there is another Three Mile t
'8 Island, is worthLeome_ cost.
I think that had the Soviets'had a:
9
~ program.similar to our own emergency preparedness and emergency',
.10'
. response program, they could have saved themselves:from'some_of-11 the' problems that they had there, particularly with respect.to
-12 moving the people.
They did essentially the right_ thing,~but 13:
they were -
right thing according to our philosophy-- but-(
14 they.were behind by 24-36 hours in doing.it.L So'they could 15' havefdone it'more promptly'and reduced the dose' commitment.'
. r 16 MR. EBERSOLE:
May I ask a question?
I' wonder if~you
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- 10 MR. PERKINS:
Sure.
l 19 MR. EDERSOLE:
I got confused with that a-little bit.
20 You state that the governor doesn't go with the people'who will
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21 ultimately decide the critical movement action.
22 MR. PERKINS:
Yes.
I 23 MR. EBERSOLE:
And you' told me that, in essence, this i
1 24 so-called' support function is the generation of information for 25 such activity --
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I'sa'id.'it's not that these subordinate-7
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of people or personnel?.
They're generating information'.for.
9-action at-the top,-is that: correct?
-10' MR. PERKINS:
The only. people they're moving-are l~
'll. :their own people.
Oh, their own people.
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Yes.
13
- .14 MR. EDERSOLE:
But not the public?
~ 15 MR..PERKINS:
Correct.
16.
MR.' EDERSOLE:
That' takes place at the governor's 17 level?-
4 I18 MR. PERKINS:
Yes sir.
19' MR. EBERSOLE:
Well at this time, and withttheinew 20
'information coming out on sheltering, are you factoring 21-sheltering now into your action -- in this. exercise do you 22 refer to the merits of sheltering versus moving people around?
23' MR. PERKINS:
Yes, we.have always taken sheltering i ',
24
~into account.
In fact, Tom I know you've got --
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25 MR. EDERSOLE: I thought that was your other fluid p
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35 4.
Iintroduce Tom'McKenna.- I asked-Tom if he would be prepared --
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6 of prot'ective measures.
In. light of a recent-communication -~-
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8 some interest in what our. philosophy as an~ agency is in 1
3 9
. protective' action recommendations, so I asked Tom if he'd'be 1
q 10 prepared'to discuss that with you.
e 11 MR. MCKENNA:
I don't have any. actual hand-outs.
12 MR. PERI'. INS :
Okay.
1 13 1
MR. MCKENNA:
I' brought several slides'just to.
f 114 illustrate, but I think it's reallyfan importantipoint.to "15' realize'that the NRC's' fundamental policy on emergency 16 preparedness _and~public -- what is appropriate for theypublic 17-to do in response to a severe nuclear power plant-accident,-one 18.
involving core ~ damage -- hasn't changed since 0654 has 19
. published.
120 L Now, what has changed, possibly~in the minds of some 21-people, is -- it has changed in the minds of some people 22-because I have to admit when we originally published'the 23 guidance in the guidance document, we didn't do a very good job 24-of explaining it.
And we've been trying to explain it and make
. 25 it clearer ever since.
In fact, our latest attempt at this is
.O Heritage Reporting Corporation (202) 628-4888 dm2 m___m__.m...m.m
.4 156 (m) 1 in the form of a training manual'that has been published _for i
2 all the people that do_ respond to nuclear power plant:
31 accidents, from the NRC, and it explains it in greattdetail.
4 And.that's' basically what I'm going to be speaking from today, 5
is that document.
6 CHAIRMAN KERR:
We have on our schedule a rather j
7 limited amount of time.
Are you going to take how much time?
8 MR. MCKENNA:
Five minutes.
9 CHAIRMAN KERR:
Okay.
10 MR. MCKENNA:
Fundamentally, what we've been saying 11 now for a number of years -- ever.since I've been involved, and 12 I was one of the original people involved in writing the 13 original emergency preparedness guidances -- first of all,_for j,y kJ 14-a severe accident, you take action before the' release'if at all 15:
possible.
16 Two -- core damage -- evacuate near the plant in all 17 directions.
Shelter everyone else.
Near the plant can be any 18 place from 2 to 5 miles, and to a great extent is determined by j
19 the locals.
Don't evacuate in the event of an uncontrolled l
20 puff release that you -- in the event of a puff release that is 21 predictable and characterizable, i.e.,
the only place we think 22 that holds is venting.
Everything else is unpredictable.
l 23 Then finally, evacuate hot spots following
)
1 24 monitoring.
f 25 DR. SEISS:
Now this is NRC advice to whom?
($)
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MR. MCKENNA:
It's in our guidance to. state and 2
locals for the development of their' plans.
In other words, our 3
requirements say you should develop plans in accordance with 4
Federal guidance.
There are two parts.to Federal-guidance:
S-there are those numbers provided by EPA, and then there's 6
guidance based on how you respond based on plant conditions, 7
and that's what'I just stated.there.
8 We have made an intermediate attempt to explain the 9
guidances-in 0654 in terms of an information notice and a flow-I 10 chart which you see here, and you might have seen it somewhere 11 else.
I'm not going to attempt to explain this in detail, but 12 it follows the basic philosophy that we just outlined'there.
13 We feel that this strategy is' effective for very
\\/
14
' severe accidents in preventing health effects, and can be shown 15 to be effective, contrary to other statements that might be 16 made.
In fact, I think all the studies since 1978 have 17 consistently shown this.
And finally, I think we can show it 18 to be effective for lesser accident in keeping deSes'below 19
-PAGs.
And then if your final objective is just keeping doses 20 low, I think.it can be shown to be just as effective in keeping 21 doses low.
22 IIere is a chart that was done by Jim Martin for us, 23 and I don't know if people are familiar with Jim -- but Jim 24 went ahead and did a CRAC runs for us for a specific site -- it 25 happened to be Indian Point -- meteorology and they used (3
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1 Shoreham population.
And the reason they did that is it-was -
2 easy to do in the computer.
And what it shows is conditional 3
. probability of exceeding a certain number of fatalities.
- Now, 4
as you know, there are great uncertainties in doing this kind-l 5
of stuff, so what we really want to do is just look for big 6
changes between risk.
Here's the no action curve, and the:
7 graphics people put it on incorrectly -- it doesn't go up with 8
distance, it's just basically flat.
But, there's about an 9
order of magnitude drop on a category of action called'one mile 10 of early evacuation.
What this curve shows is that'for the I
11 worst possible accident we're willing to talk about now,:which
)
12 is an SST-1, or.probably equivalent to a PWR-1 or possibly-at
)
13 the top of what they think Chernobyl might have been if it had A-14 been a ground-level release, if you can' evacuate the people 15 within one mile starting shortly after the release starts, put 16 everybody else on shelter, which is out to 10 miles, and 17 evacuate the people that are on shelter within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />,'you get 18 this reduction.
i 19 This is the reduction if you evacuate everybody 20 starting a half hour after the release out to 2 miles, put 21 everybody else on shelter, and evacuate after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> on a hot 22 spot.
It just falls off the chart when you get down to three 23 miles.
This basic data has not changed, and there hasn't been 24 anything that I've seen that basically changes the fundamental 25 conclusions, to include zero, uh, 1150 which has similar types GV Heritage Reporting Corporation (202) 628-4888
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1 of:-findings in it.
So that's basically where.we --
2 MR. WARD:
Is that in a published report?
3.
MR. MCKENNA:
Yes.
It's in this document, explained j
4 in detail -- the foundation for it, and it's also been l.
5 published in things like Health Physics and such as a technical 6
article.
7 CHAIRMAN KERR:
Those results come from the CRAC 8
code?
9 MR. MCKENNA:
Those are CRAC code.
But that's just 10 zui illustration of an attempt to apply our strategy.
Our 11' strategy is core damage, and the reason we go on core damage 12 and not try to assess containments is we don't trust them.
We 13 feel that if you have a core. damage situation, it's low s-)
14 probability, you shouldn't have to do this very.often, let's go I
15 ahead and move the people close in.
So the recommendation on 16 core damage is get them out close in -- close in is up to the 17 locals -- then shelter everybody else, and then basically 18 hunker down and until the release and go look for the material 19 when it's deposited.
20 MR. EBERSOLE:
Core damage triggers the whole 21 process?
22 MR. MCKENNA:
Core damage triggers the process.
We 23 figure it's a low probability event, we shouldn't have to do it 24 again.
We would have done it at TMI if this guidance had been j
25 in place.
Once you have core damage nobody can assure us, and O
Heritage Reporting Corporation (202) 628-4888
160
,,;u) 1 research -- here again this seems to be.a new finding, but 2
we've been talking this way since 1978 -.that once you have 3
core damage you've-lost a lot of your confidence in the 4
operators'and the plant.
So, rather than trust the
~5 containment, hoping it will hold -- we realize it probably will 6-
-- but hoping it will hold, let's move the people as soon as we-7 get the first Indication and not wait for the containment.
8 Because if we wait and we made the wrong decision, it could 9
have been a tragic mistake.
If it does hold, we've'made the 10 wrong decision, and we move some people we don't need to, but 11 our chances or moving anybody are slim now.
12 DR. SEISS:
Ilow much more research do you think it 13 would take to make you change your approach?
sI 14 MR. MCKENNA:
All I can say is I've been seeing theso 15 reports -- I've been watching these reports come across my desk
-16 now since 1979.'since 1978, and they keep saying the same thing 17 over and aver again.
And let me just show you something, why I i
18 think it's not going to change.
4 19 DR. SEISS:
The more reports you see, the less 1
.20 confidence you have?
21 MR. MCFENNA:
The more confidence I have in the basic 22 approach, which is, if we get into a situation where we have 23 done major damage to the core -- realizing the only place that 24 probably there's enough inventory and energy to cause early 25 health effects is the core -- as soon as we start damaging it, Heritage Reporting Corporation (202) 628-4888 1
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q L
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.161 I
Q "I
and:weJhave'builtclots:-and-lots of systems-to protect;from; JU that, but once those have been' defeated, either by human'or n
3t mechanical. problems, then I've lost.my confidence.. We.should, 4L
.act then and -- our philosophy:is we should act then.. We have L
5 one barrier'left -- it.will.probably hold.
How many more. times-lL 6, should we have to apply this?
. e shouldn't have to use this W
D
- 7 criteria.
It only.gets pulled.out on core damage.
1; 8'
DR. OKRENT:
How-soon:after core damage occurs is.the' N
9
. operator supposed-to know that it has occurred to be.. efficient-
'10 so that he beats the point at which you.would trigger -
11 evacuation. nearby?
"12 MR. MCKENNA:
We have asked all the' licensees-to-
~13 festa'blish -- well we've required all the licensees to establish f
i
.14 a system of. emergency action levels'-- specific instrument-1 15 readings that would trigger a certain level of emergency..One 16 of those. levels of emergency.is al general emergency.
General 17 emergency immediately puts:this into place..Upon declaration 18 of a general, you make the recommendation to move people close in.
We have built the system so hopefully it'll catch it at a 20 series of points.
One, it can be triggered at the failure of a 21 critical safety function.
You no longer can keep it covered, 22 you no longer can keep it cool.
23 MR. EBERSOLE:I want to ask a question in that line.
24-DR. OKRENT:
Excuse me.
I'd haven't got an answer to 25 my question.
How long --
O Heritage Reporting Corporation (202) 628-4888 c
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162 1
MR. MCKENNA:
-It would depend on the scenario, I've 2
seen scenarios that -- the labs, Oak Ridge went ahead --
3 DR OKRENT:
I want to take the TMI-2 scenario.
4 MR. MCKENNA:
At a bare minimum, at a bare ttinimum '
o J
5 they should have caught it at 6:25 in the morning when they had-6
~ damage, based on radiological and thermocouple readings.-
7 Absolutely bare minimum.
No' excuse for not catching a. general 8
then.
Before then, if they had recognized that they had lost 9
inventory control, they would have regained it, so,'It 10 probably wouldn't have been caught until 6:25 in the morn:ing, 11 is when it would have happened.
lp 12 DR. OKRENT:
And what is it that was supposed toLtell
. O)..
13 them that they had damage?
(-
14 MR. MCKENNA:
Movement of radiological material.
If 15 you take a look at the traces on the monitors and such, they 16 started ramping up.
So sometime after 6:25 they would have 17 started seeing the radiological -- a movement of gap material 18 out.of the core, number one, and thermocouple, either one of 19 them would do it.
20 DR. OKRENT:
It was my impresalon that the 21 thermocouple were not reading out there actual temperature --
22 they went off scale at something above 600 F, so I'm not sure 23 what you're telling me.
24 MR. MCKENNA:
If you take a look at the matrix of the
(
I 25 thermocouple readings, they had some up into the 1400s.
But 1
(
Heritage Reporting Corporation (202) 628-4888 1
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()
1
-it's interesting, if you get the licensee to come in and he 2
gave us a course on their assessment procedures for core u
l 3
.,famage, it's almost incredible that they didn't spot it, now, 4
when you have.. hindsight, because there was the whole spectrum'-
5 of process'and area radiation monitors ramping up.
Sometimes en
.6 at different times, but they were all ramping up very rapidly.
7 They even sent someone down, if you remember, with a hand-held 8
instrument -- I don't remember when -- outside one of'the I JI4' hatches and basically the alarm went off and he h&d to-back 10 off.
That's good'enough for me.
My guess if -- well, if the 11 procedures were in place now, my guess would be they would've w'
l 12 picked it up at 6:25 or thereabouts in the morning, based on 13 movement of fission products, the gap fission products out of
_O tO 14 the core.
15 DR. OKRENT:
From what I read, I would have! expected 16 an answer like if they have reason to think there was' core l
17' damage they would try to take a sample of radioactivity!in the 18 primary system.
l 19 MR. MCKENNA:
Too slow.
That takes hours.
l 20 DR, OKRENT:
Well, you 21 MR. MCKENNA:
What I'm saying --
22.
DR. OKRENT:
I asked you the question, and in fact 23 that's what I seem to read in the view that was made of just 24 the plotting or the measures available and so forth.' It seems 25 to me you're defining some ad hoc observations that might be O
Heritage Reporting Corporation (202) 628-4888
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/'N'
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1 made'(in one plant to one. scenario and not be applicable 'for q
2
,another plant.or --
3 MR. MCKENNA:
No, just the opposite.
I l
4 i; 4, MR. PERKINS:
I think his point is where it's-a T
4 l
5*
detected.
He's not debating whether it's detectable'or what 1
ti,
time' frame it's' detectable in.
Im not sure what --
7 MR. MCKENNA:
They have license -- we establich very 8
/ strict guidance, giving'them examples of the situations.
They 9
have to go out and then determine what the instrument readings
.10
. would be in the plant that indicated this condition.
For o
l 11 instance, one.of them is containment monitors.
you go ahead 1
12 and go out and determine at your plant what the containment 113 monitor would read if you had movement of more than 20 percent k-}
(
14 of the gap material out of the reactor core.
What would your 15-instrument read if this condition happened?
if that condition
-16 happened?
Those are all written down.
Now, if the emergency 17 action system had been in place at the time of the TMI accident i
18
-- and I have to admit I haven't done this -- but if they had i
l 19 been at that accident at that time of the morning, it should l
I 20 have been triggered at around 6:25, 7:00 in the morning.
21 Because they would have seen the instruments in the containment 22 go up and that would have been it, they would have declared a l
23 general.
i 24 These are specific instrument readings at every 1
25.
plant.
They're in place.
Oak Ridge did a study at a-hope j
()
11eritage Reporting Corporation (202) 628-4888
.v 165 (f
i every time they did one of their severe accident sequence 2
studies they tipped when they. thought the emergency action 3
. levels should have been triggered for these sequences, and I 4
saw some being caught at the same time as core damage, which 5
would be a TMI case, and I saw some being triggered as much as 6
2, 3, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in advance.
7 MR. PERKINS:
I know -- go ahead'.
8 MR. EBERSOLE:
Let me ask a similar question'.
Before 9
you get.infor.mation that there's been a modest release of 10 primary fluid.and a containment, but the operator was unable to 11 maintain containment temperature and pressure and was on the l
12 verge of venting,~ assuming the NRC's going to let him do that, 13 what would you do with that?
You haven't damaged the core yet, ym.
(-
14' you have a modest amount of concentration in the containment, 15 you're going to have to let it go to preserve the core,.what 16 are you going to do with the evacuation?
17 MR. WARD:
Why would the operator want to vent 18 containment if you're saying there's been a modest release of 19 primary into the --
20 MR. EBERSOLE:
Because he's exceeding containment 21 temperature and pressure and he's jeopardizing the --
22 MR. WARD:
That sure wouldn't be a modest release.
23 MR. EBERSOLE:
It could be a modest release of 24 radiation but a --
25 MR. WARD:
That would be the whole inventory'of the O
Heritage Reporting Corporation (202) 628-4888
l.
O L
166' (5-t
,)
1 primary. system; o
l
~
2 LMR. EBERSOLE:
He could.have failed to' reject! feed u
L 3
from.the containment.
Period.
- 4 MR. MCKENNA
If it doesn't involve -- we've made a -
5-very distinct cut at core' damage.
If'it'doesn~'t involve, core f6 Edamage,.and.this' case really would not' involve core damage --
l-.
17' maybe there's a. spike in there, but people would, let's say
~
1:
8 were debating -- if it doesn't involve core damage we do'it:
9~
based on an assessment at the time basically based on dose 10.
' projections.
If it is core' damage,.then that's'got a' life of
-11 its own and we take this strategy.
12 MR. EBERSOLE: 'So you do it on doseLassessment --
13 MR.-MCKENNA:
At the time, at the tima.
That's when 5
14' your sample might become important.
You draw, you do your
~
15 calculation you say,' let's go.
16 Okay, thank you.
17 CHAIRMAN KERR:
Just one question.
I don't-need a 18 big, long answer.
You make recommendations to your state 19 agencies?
20 MR. MCKENNA:
That's correct.
21 CHAIRMAN KERR:
Do you expect they will follow your 22 recommendations?
23-MR. PERKINS:
That's up to the governor.
It's his 24 decision.
Understand that if we think that the licensee and 25 the state are in the right ball park, we're going to say we LO Heritage Reporting Corporation (202) 628-4888
167
[vb 1
concur.
Real numbers bottled aren't going to lead to the same 2
numbers -- that is we're not going to all wind up with the same 3
number.
If, however, we thought that there was some important 4
consideration that was not being taken into account, we would 5
make an independent recommendation to the governor, and then 6
it's up to him to decide whether to implement our 7
recommendation or not.
There's a lot of politics involved 8
there.
9 CHAIRMAN KERR:
Well, it's also a matter of judgment.
10 MR. PERKINS:
Judgment, as well as wanting another 11 set of hands on the bag.
12 CHAIRMAN KERR:
It's possible, even for people in the 13 NRC, to panic, and a governor has to take that into account as j
(~J l
(-
14 a possibility.
l 1
15 MR. PERKINS:
There's also the possibility that a 16 governor knows something about the local conditions that might 17 make our recommendation inappropriate, and we sure hope he will 18 exercise his single decision-maker responsibility there.
Could 19 be a football game going on about to --
20 CilAIRMAN KERR:
That's both ways.
He may decide to 21 evacuate before you tell him.
22 MR. PERKINS:
Yes, sir.
23 DR. MOELLER:
Were the Canadians involved in the Zion 24 exercise?
25 MR. PERKINS:
They monitored it.
They observed it, O
Heritage Reporting Corporation (202) 628-4888 i
I 168-().
1 and"I think they received phone calls.
I s. t h a t ' c o r r e c t ',.
=2 Bernie?
ItEwas more of a communications -
11 for; thbm' lthey 3
weren't'actually technically involved.
-4 DR.' MOELLER '
Do.you plan,(sometime.in the future, to.
5 have-a field exercise at one of.'the plants where the canadians-6-
would be. fully involved?
7-MR. PERKINS:
There's no specific-plan'for;that'yet,-
l 8
Dr. Moeller,'but we have.been having discussions about 9
' coordinating and exchanging information, and respective roles i
10 if either of us has an accident ~within our boundaries."
I'
'll.
DR. MOELLER:
One last one.
Do you have any; plans in and exercises.to involve the National Guard?' I say that 12 13 because at Chernobyl, apparently, or not apparently, but the 14 military played a role in,.you know, many roles in clean up_and 15 response..
16
-MR.
PERKINS:
I'm going to.ask my folks to refresh 17 me, but I believe there are several state plans that in fact 18 rely upon the national guard to help implement them,'is,that 19 correct?
20 BERNIE:
I believe in the FFE they stipulate the 21-calling out of the National Guard.
22 CHAIRMAN KERR:
Thank you.
Thank.you very much.
23 MR. PERKINS:
Thank you.
24 (Whereupon, at 3:32 p.m.,
the meeting was recessed.)
,25 O
Heritage Reporting Corporation (202) 628-4888
169 1
CERTIFICATE O
2 3
This is to certify that the attached proceedings before the 4
United States Nuclear Regulatory Commission in the matter of:
S Name:
Advisory Committee on Reactor Safeguards 6'
330th General Meeting 7
Docket Number:
8 Place:
Washington, D.C.
9 Date:
October 8, 1987 10 were held as herein appears, and that this is the original 11.
transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction
({}
14 of the court reporting company, and that the transcript is a 15 true and accurate record o the foregoin proceedings.
16
/s//
a sj, h D
\\-si
(
Kathy Boyd)and Donna Cook 17 (Signature typed):
18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 O
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-REJECTED UCS POSITION THAT ECONOMIC COSTS'MAY NEVER BE A FACTOR IN SAFETY DECISIONS UNDER THE ATOMIC ENERGY ACT..
.1.
VACATED THE RULE AND. MANUAL CHAPTER BECAUSE THEY DID NOT SPEAK UNAMBIGU0USLY IN TERMS THAT CONSTRAINED THE COMMISSION FROM CONSIDERING ECONOMIC COSTS IN ESTABLISHING STANDARDS TO ENSURE ADEQUATE ~ PROTECTION OF
- THE PUBLIC HEALTH A_ND SAFETY.
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ONCE AN ADEQUATE LEVEL 0F SAFETY PROTECTION IS ACHIEVED, THE C0fEISSION IS AUTHORIZED BY THE ATOMIC ENERGY ACT TO CONSIDER AND TAKE. ECONOMIC COSTS INTO ACCOUNT IN ORDERING FURTHER SAFETY IMPROVEMENTS.
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-THE COMMISSION SHALL REQUIRE A SYSTEMATIC AND DOCUMENTED ANALYSIS FOR BACKFITS-g I
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I COMMISSION SHALL REQUIRE THE BACKFITTING OF A FACILITY-ONLY WHEN IT. DETERMINES-d
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BACKFIT ANALYSIS.IS NOT REQUIRED IF:
pV 1.
THE MODIFICATION IS NECESSARY TO BRING A FACILITY INTO COMPLIANCE 2..
ACTION IS'NECESSARY TO ENSURE THAT THE FACILITY PROVIDES ADEQUATE PROTECTION ~TO THE HEALTH AND SAFETY OF THE-PUBLIC
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ACTION INVOLVES DEFINING OR REDEFINING WHAT LEVEL OF PROTECTION TO THE l
PUBLIC HEALTH SHOULD BE REGARDED AS ADEQUATE
'THE COMMISSION SHALL ALWAYS REQUIRE THE BACKFITTING OF A FACILITY IF IT DETERMINES THAT SUCH ACTION IS NECESSARY TO ENSURE'THAT THE FACILITY PROVIDES
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