ML20237C615
| ML20237C615 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1631, NUDOCS 8712220033 | |
| Download: ML20237C615 (156) | |
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NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
GENERIC ITEMS MEETING I
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LOCATION:
PAGES:
Washington, D.C.
1 through 128 DATE:
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December 16, 1987 4...................................................................................
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1 PUBLIC NOTICE BY THE 2
UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4-
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The contents of this stenographic transcript of the 8
proceedings of the United States Nuclear Regulatory y
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Commission's Advisory Committee on Reactor Safeguards (ACRS),
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10 as report'ed herein, is an uncorrected record of the discussions 11 recorded at.the meeting held on the above date.
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12-No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or (f
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' inaccurac'ies of statement or data contained in this transcript.
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
4 In the Matter of:
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SUBCOMMITTEE MEETING ON GENERIC ITEMS
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7 Wednesday, 8
December 16, 1987 g
9 Room 1046
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10 1717 H Street Washington, D.C.
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11 The above-entitled matter came on forhearing, 12 pursuant to notice, at 12:07 p.m.
13 BEFORE:
MR. CHARLES WYLIE Retired Chief Engineer O
14 Electrical Division Duke Power Company 15 Charlotte, North Carolina 16 ACRS MEMBERS PRESENT:
17 MR. CARLYLE MICHELSON 18 Retired Principal Nuclear Engineer Tennessee Valley Authority 19 Knoxville, Tennessee, and Retired Director, Office for Analysis and Evaluation 20 or Operational Data U.S. Nuclear Regulatory Commission 21 Washington, D.C.
22 MR. JESSE EBERSOLE Retired Head Nuclear Engineer 23 Division of Engineering Design Tennesse Valley Authority 24 Knoxville, Tennessee 25 O
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1 ACRS MEMBERS PRESENT (CONTINUED):
2
.DR.
FORREST J.
REMICK Vice-Chairman 3
' Associate Vice-President for Research Professor of Nuclear Engineering 4
The Pennsylvania State. University University Park, Pennsylvania 5
MR. DAVID WARD 6
Research Manager un Special Assignment E.I..du Pont deNemours &-Company 7
Savannah River Laboratory Aiken, South Carolina 8
ACRS COGNIZANT STAFF MEMBER:
Sam Duraiswamy 10 DUKE POWER PRESENTERS:
11 Neal Rutherford 12 Jim Thomas Bob Gill 13 Paul Guill p
Tony Encataba V.
14 Bob Sharp 15 16 17 18 19 20 21 22 23 24 25 0'-
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1 PRO.CEEDINGS 2-MR. WYLIE:
The meeting will.come to order.
This is 3
.a meeting of the1 Advisory Committee on Reactor-Safeguards, 4
Subcommittee on Generic Items.
I am' Charlie Wylie, Acting 5
Subcommittee Chairman.
Dr. Siess, who is Subcommittee 6
Chairman,.was unable to make'the meeting becauseLof snow and 7-sickness.
Other members of the subcommittee'here today are 8
Carlyle Michelson, Jesse Ebersole, and Forrest Remick.
I 9
believe Dave Ward will join us later.
.10 The purpose of the meeting is to discuss with 11 representatives of the Duke Power. Company the steps involved in-12 the. implementation and resolution of generic issues-and or 13 unresolved safety issues and the contribution to plant safety.
14 resulting in implementation of the resolution of' generic issues 15 and USIs'and other related matters,'and to gather information 16-for the use by the ACRS in responding to the Commission on the 17 effectiveness of the NRC Staff's programs that deal with-18 generic-issues.-
19 Mr. Sam Duraiswamy is the ACRS Staff member for this 20 meeting.
The rules for participation in today's meeting have 21 been announced as part of the notice of this meeting previously 22 published in the Federal Register on November 30, 1987.
A 23_
transcript of the meeting is being kept, and will be available i
24 as stated in the. Federal Register Notice.
It is requested that 25 each speaker first identify himself or herself and speak with
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1 sufficient clarity and volume so that he or she can be readily 2
heard.
We have received neither written comments nor requests 3
for time to make oral statements.
4 A suggested agenda was transmitted to Duke, and I 5
believe Mr. Rutherford wanted to make some changes or 6
adjustments to that agenda.
So, I will turn the meeting over 7
to Mr. Rutherford.
Oh, before I do that, are there any 8
comments by members of the subcommittee?
9 Okay.
Go ahead, Mr. Rutherford.
g 10 MR. RUTHERFORD:
Good afternoon, gentlemen.
My name l
11 is Neal Rutherford, and I am the licensing manager of Duke 12 Power.
I would also at this time like to introduce some of the 13 people that I have with me today to address some of the agenda
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14 items, or to address questions as they may come up.
15 We have Jim Thomas, Senior Engineer in our Design i
16 Engineering Electrical Group, and we have the licensing 17 engineer from McGuire, Oconee, and Catawba, Bob Gill from 18 McGuire, Paul Guill for Oconee, and Robert Sharp for Catawba.
19 As Mr. Wylie mentioned, again there was sent 20 out -- we do have a slight reordering of that, if you will.
I 21 First of all, Jim Thomas will be discussing the resolution of 22 USI's equipment qualification and station blackout.
I will be l
23 discussing the status of items on the new plans.
Bob Gill will 24 be talking about the implementation of resolution of certain 25 items.
Now, Bob will be using McGuire as a base, but the Heritage Reporting Corporation (202) 628-4888
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examples we are going to use, I think, are pretty well 3
-2 applicable across the board as far as giving you a feel for our 3
experience.
4 After Bob, I will have some comments on the 5
resolution process, and the contribution to plant safety, and 6
also views on the integrated safety assessment programs and 7
integrated living schedules.
8 But with that, I would like to introduce Mr. Jim 9
Thomas, and he will be addressing the first agenda item.
10 MR. THOMAS:
Thank you, Bill.
I am Jim Thomas with 11 Duke Power Company.
I am currently responsible.for the McGuire 12 and Catawba Engineering and Electrical Divisions.
But I l
13 previously was responsible for qualification over the years at
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14 Duke, and still am involved with it.
I am also involved with 15 the seismic qualification utility group.
16 What I would like to do today is to share with you 17 some thoughts on the process of these issues that I have been 18 dealing with and have at:tually made presentations to here on 19 both subjects -- equipment qualification and seismic 20 qualification.
I haven't had the opportunity to discuss these 21 things from this standpoint, and 1 appreciato this opportunity.
22 One other thing I would like to cover a little bit is station 23 blackout.
And what I don't have with me here, but I do plan to 24 spend a short time on an issue that occurred this year that had 25 all of the potential of becoming a generic issue, similar to O-Heritage Reporting Corporation (202) 628-4888 1
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what happened back in the82 '83 time frame.
In' July of this 2
. year we had a' problem with a switch gear again, which-I think?
3 put our attention on the ways things are to be attacked, maybe 4
to prevent:them from becoming a big generic issue.
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-5 (Slide) 6 The first item is equipment qualification,' USI A-24.
7-I would briefly like to gofover the history, although it's.not 8
too brief because it has a long history.
But what kicked 9
things off,- really, to an issue-type standpoint was the UCS
'10 following a petition in regard to environmental qualification 11 electrical components back ten years ago.
There were a number.
12 of things that took place with regards to responding to that 113 petition, but the first thing that kicked off, I guess, the
'14 issue a far as the utility involvement and with regard to 15 coming up with EQ programs was the June,.1978 circular 16 requesting a review of equipment qualification status.
17 That was soon followed by a bulletin which actually 18 raised the 78-08 to a bulletin status requiring their response.
19 That in itself was then again expanded, expanding both the 20 scope, and putting forth some criteria and guidelines.
We are 21
' talking now of January of 1980 That kind of kicked off a lot 22 of quick-type response efforts on behalf of utilities.
Duke's 23 approach was to set up a task force to review our operating 24 plant; we.had at the time Oconee-, which was one of the things 25 that we had under the scope of 79-01.
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1 But we tried to address equipment qualification on a 1
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. task force-type basis.
There were a number of clarifications 3
.due to misinterpretation.
The whole issue was a lot of 4
uncertainty on behalf of, I think, the industry and the staff 5
of exactly what was being required in reviewing this issue.
6 Everyone understood that we had to demonstrate qualification of 7
equipment, but it was very hazy as to exactly what had to be l
8 done to do that.
9 Of course, the course, the scope of the plants that 10 were in the licensing process also became an issue, and very i.
11 soon after the 79-01B, we had the memorandum and order issuing 12 the DOR guidelines, and NUREG 0588.
This kind of caused a 13 little different type of approach.
The guidelines themselves,
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14 the NUREG, and 79-01B all were trying to get at the same thing, 15 but they were inconsistent in the way they were worded, 16 inconsistent in the approach of how to respond to them, and 17 also they were recovering plants that were in the construction 18 process.
1 19 For that one, Duke tried to do something in regards
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20 to getting it into the normal process rather than a special n
21 task force to handle 79-01B.
I think that was the way it j
22 shculd have been done.
But again, it kind of -- you were
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l 23 changing the way you were doing things in a very short time 24 frame, and reviewing things with a little different criteria.
25 And as some of the responses were being reviewed on 79-01B,
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I there were such things as were coming into question such as 2
auditability and what that meant.
Really the scope of what 3
should be patrolled by, at that time, still hadn't come out, I 4
don't think, with a total definition or a total acceptance of 5
what should be qualified, and I guess the concept of mild 6
environment / harsh environment started to be batted around.
7 Then we started getting some schedule imitations in 8
regard to how soon we would have to respond, and the history 9
continues.
Another follow-up, again kind of causing a little 10 confusion on behalf of the industry, I think, as to what was 11 going on, still a lot of lack of communication.
Again, I will 12 get'to this lack of communication not only on behalf of the 13 industry and the staff pointing at each other, but also the em()
14 industry itself.
15 There was the issuance of SERs and all of this 16 confusion.
The NRC tried to clear some of the things up and 17 conducted some workshops.
Then, in an effort to try to get 18 things totally clear, the Rule 50.49 was issued in '83.
I 19 think it went a long way to try to clear up a lot of the 20 confusion that had been existing for about three years, and try 21 to clean things up.
Still, there was a large interpretation 22 problem with that.
I do think that by this time we had all 23 kind of learned our lesson and started communicating a lot 24 better.
I do think there was a real good interaction between 25 the people involved:
the industry, various different types f^)
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1 of utility groups and the staff, in reviewing Reg. Guide 1.89 1
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and resolving comment.
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I do think that the Reg. Guide did a lot to clear up 4
the confusion that existed on what EQ meant, what was required, 5
what had to be in files, what was auditability, what were the
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6 cases that you would have to take some reasons to the contrary 7
when you didn't have to follow it to the letter.
Then, I 8
guess, the NRC started following up its audit program.
9 The audit programs being called up caused a lot of 10 confusion.
We were getting audited by various national 11 laboratories on behalf of the staff, which were interpreting 12 some of the ruJes and some of the guidelines. The different 13 categories that came out in NUREG 05-88 in different ways, and 14
-in different regions were interpreted in different ways.
So, 15 we kind of went through another confusion phase.
16 We are still resolving it.
I think we have learned 17 our lesson and started communicating a lot better on this 18 issue.
But, as you can see, it continues on through 86.
I 19 think one of the issues that kind of came up with regard to the 20 reviews was the certification process or possible accreditation l
21 programs for test labs.
Industry groups were looking at that 22 and trying to resolve that, I think, in a little more organized 23 manner.
24 Then we have a number of letters, and recently this 25
. year, each one of them attempting to try to further clarify on Heritage Reporting Corporation (202) 628-4888 1
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1 all of these guidelines and regulations and rules, and what it 2
means with regards to enforcing them.
3 So, what I am trying to say here is that we've got a 4
long-term generic issue that rather evolved with a lot of 5
confusion along the way and has taken about ten years to come 6
up with something'that is still being debated on 7
interpretations and how things were handled and what was the 8
in-point and how the results were going to be interpreted.
9 MR. EBERSOLE:
May I ask you a question?
You have a 10 very good overview now on a classical problem.
That is, when 11 NRC issues something, it deliberately puts in ambiguity to 12 avoid being overly specific.
It goes to you fellows, and then 13 you say, "But you weren't clear in what you said.
But if you
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14 say too much, then you are being too picky."
15 So it takes ten years.
Do you think this is 16 reasonable, or should there be more prescriptions or less 17 prescriptions?
What would you do differently?
18 MR. THOMAS:
I think I am going to try to explain 19 that with the next subject.
The prescriptiveness gives you a 20 problem that is one sided.
If you have, I think, incorporation 21 between the industry and the staff, you con come up with some
.22 prescriptiveness that is good.
But I think that is one of the 73 problems.
These early guidelines were pretty prescriptive, 24 really.
But they were subject to a lot of interpretation 25 because they were developed on one side and then presented, and k)
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1 someone went and tried to meet them, but they weren't the part i
2 of developing it.
So they interpreted it different ways.
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I am not trying to blame in any way at all that the
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staff was at fault because of this communication problem.
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certainly share the blame.
6 MR. EDERSOLE:
It may be inevitable.
That is the 7
only way to go.
8 MR. THOMAS:
Well, I would like to point out that the 9
industry itself was not well-coordinated.
There were about 10 four groups.
I had to be involved some way or the other with 11 all four of them through the ten-year period I am talking 12 about.
They were also trying to address equipment 13 qualifications.
14 The first one, IEEE, developed a standard back in '74 15 on equipment qualification, and I think it was probably the 16 leading issue.
We had a standard that had gone through a i
i 17 consensus process and got approved, and supposedly was the 18 industry's method of doing things.
But it was way ahead of 19 what could actually be done, particularly in regard to aging, 20 particularly in regard to not clarifying what a mild 21 environment is, and trying to enforce artificial aging programs 22 in areas where they don't have much meaning.
23 The standard itself still had a lot of problems, or 24 it created a lot of problems.
A lot of the efforts in the 25 final resolution of EQ, I think, was in finding out what that I')
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1 standard really meant, how to interpret it, and where it should 2
be applied and where it shouldn't.
We had a subcommittee on 3
AIF that was trying to interact with the staff, but it was 4
voluntary and without any financial commitment on behalf of the 5
utilities in support of that particular group.
We had a lot of 6
people attending and a lot of people telling war w:r; ries, and 7
coming out with why they were having problems dealing with the 8
staff's positions.
But it was kind of, as I said, more of a 9
voluntary group, and the interaction was not anywhere near what it could have been.
11 We also had at the time an equipment qualification 12 advisory group, which was set up to advise EPRI over research 13 dollars needed to try to resolve this EQ issue.
At that time,
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f 14 there was practically no interaction with the staff.
I am 15 talking about in the late seventies.
It has evolved into 16 something I will get to in a little bit, which due to our 17 experiences now, is getting quite a bit more involved with the 18 staff.
19 We are also, I guess, from an enforcement issue, 20 starting to have problems again regarding the interpretation.
21 We have another group forum which also brought into the concept 22 the legal aspects.
We had a lot of interaction with lawyers on 23 that one.
But at least it did start interacting well with the 24 staff.
Again, we had learned our lesson that you can't try to 25 solve these issues on opposite sides of the table with no O)-
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That group did accomplish, I think, quite a
.2 bit.
'If we had.~ started that way, we wouldn't have had these 3
communication. problems.
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.MR.
EBERSOLE:
Did you get anything out of ANS?-
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-5 remember years ago,.they extended beyond the electrical 6'
apparatuses to all apparatuses.
But I think it was thought to 7
be so stringent that the staff didn't. pick it up.
8 MR. THOMAS:
Yes, I think the.ANS efforts were going-9 towards the design bases, and then-the IEEE work..was 10 inte'rpreting.how you build equipment to prevent consequences of 11 those design bases, or mitigate, and then also extended on the 12 IEEE side, the qualification guidelines.
,13 MR. EBERSOLE:
I still think it ought to be looked 14 at..You know, 279 stuffed the circuitry.
15 MR. THOMAS:
Yes.
' 16 MR. EBERSOLE:
And somebody had to go beyond that.
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'HR. THOMAS:
Yes.
The 279 starts out assuming design 18 bases. 'The design bases were left with the ANS.
19 MR. EBERSOLE:
But it stopped strictly at the 20 electrical apparatus.
Something had to be developed for the 21 rest of it.
22 MR. TilOMAS :
I showed you a ten-year history of the 23 generic issue that I guess had a resolution.
But the 24' implementation is still causing problems, and it still lacks a 25 lot in communication of an understanding.
I think we are Heritage Reporting Corporation (202) 628-4888
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1 getting a lot-be'tter at it.
The Nuclear Utility Group, the 2
last one., had recently -- by "recently" I mean the last couple 3
of years -- arranged a periodic meeting with the members of the 4
NRC staff responsible for equipment qualification.
And they 5
had a kind of a very informal, open discussion on issues, not 6
trying to resolve anything, and not trying to argue about 7
anything, but just to tell each other just what we thought 8
needed attention and what might be weak link, or what might be 9
an issue that is being pushed in an area that does not really 10 contribute to safety.
11 I think that is going a long way in helping some of 12 the plants that have still not seen their actual EQ audit be a 13 little bit more prepared for those audits, and a little more, I
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14 think, appreciative of what the end goal is.
I think we have 15 come a long way, and although the issue itself does have a bad 16 history, in my opinion, it's at a point now that we are making 17 real progress in dealing with it.
18 MR. EBERSOLE:
You say you are making progress, but l
19 you say that there are still some problems.
What is the 20 general nature of those problems?
21 MR. THOMAS:
The issue of documentation for 22 documentation's sake, and clarity, for auditability's sake, 23 versus actual technical capability of the equipment to do its 24 job.
Most audit items have come down to a particular auditor's 25 lack of understanding of what is in the file, needing an
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l-engineer that was responsible for it explaining what happened.
2 I can understand some frustrations, because I guess we at Duke 3
probably had a better way of handling that by having a captive 4
AE when we who designed the plan are now.there to defend it.
5 We'are the ones that came up with all the programs 6
and are at least available to discuss it with the auditors of 7
what we intended to do, and for a utility that had an AE that 8
essentially didn't say "Go!" for five to ten years in the 9
process and didn't have an audit on what he did, and none of 10 the original people could explain it.
It does create a real 11 problem for some auditors to understand some of the files.
12 Still, we are spending a lot of money and a lot of 13 time resolving paper issues and not safety issues.
There have
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14 been a lot of fines on paper issues and not safety issues.
15 Well, let me take that back.
I am not specifically familiar 16 with how many fines there have been, but there have certainly 17 been a lot of them -- open issues, unresolved items, audit-18 follow-ups, and potential enforcement activities having to do 19 more with the paperwork than the safety issues.
20 MR. MICHELSON:
What is the problem with the j
I 21 paperwork?
Simply the fact that there is nothing in the file j
i 22 to document it, or is there some inadequacy in the file?
23 MR. TilOMAS :
All of the above, really.
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24 cases, for example, you go back to a plant that was designed in 25 the late sixties, and the requirement for qualification was a O
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1 design requirement.
The emphasis on documentation of the bases 2
for that design was not anywhere near what it is today.
And 3
you may find, in some cases, that a person relied on the 4
manufacture spec sheet, or a piece of equipment that sees this 5
pseudo-harsh environment -- something like maybe 170 degrees, 6
or something like that, as a result of the steam line break.
7 And the equipment is designed for a normal operation of 200 8
degrees, and it is something that interfacing with the steam 9
line or a hot pipe of some sort -- so the normal operation of 10 the equipment in industry, independent of nuclear, is for 11 something'like 200 degrees.
The Engineering Times decided that 12 that was totally acceptable and didn't require any special 13 tests.
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14 But when you start interpreting " harsh environment" 15 and you classify that 170-degree environment as " harsh," the 16 only result of some kind of postulated accident, then you go 17 back to the-file and you find the spec sheet, and it is 18 challenged by the auditor as not being up to today's 19 standards -- you don't have a test report.
20 That's one problem.
In some cases, you can't find Ir 21 that spec sheet.
That's another problem.
22 MR. EBERSOLE:
Well, maybe it could stand that 23 temperature, but not stand the moisture, or whatever.
24 MR. THOMAS:
A lot of it, back in the early days, was 25 judgement, and to be perfectly honest, most cases that I have O
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1 been familiar with by participating with these industry 2-groups -- the equipment has been. changed not because they 3
thought it wasn't appropriate or couldn't handle the l
4 environment.
It was because the documentation wasn't-there, 5
and it was cheaper to buy _one that had documentation than to 6
requalify.
7
.By and large, most equipment has been replaced.due to 8
lack of paper.
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(Continued on next page.)
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MR. THOMAS:
The industry I think has proven to be l
'2 good, but just not auditable.
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MR.._EBERSOLE:
Well, I am not sure what you mean by t
4 proven to be good, since it has not been necessarily ever 5
exposed to the accident environment.
6 MR. THOMAS:
The ones that we actually tested to try 7
to generate documentation for something that'was not there.
8 MR. EBERSOLE:
When you took a piece of equipment of 9
that vintage, it proved to be okay?
10 MR. THOMAS:
Yes.
I have got numerous examples.
11 MR. EBERSOLE:
When you have the test data, then 12 there is no problem.
13 MR. THOMAS:
True.
(G
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14 MR. EBERSOLE:
The problem lies with the piece of 15 equipment that you have, what you think is okay but do not have 16 a good basis for thinking that it is okay.
17 MR. THOMAS:
We do not have the basis now to audit 18 that thought process.
19 MR. EDERSOLE:
Do you have a basis for requiring a 20 general enclosure characteristic, an apparatus in the general 21 equipment area, do you have a base line for enclosure or 22 environmental protection?
23 MR. THOMAS:
Yes, there are standard industry practices that are adhered to.
Well, I will get into that a little bit later, particularly with regard to SQUG.
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r seen all of the s'l'Ipes showing tlio similarities of plants ti.at 2
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essentially good engine'ering puectices have been applied across 5
the board to address such things that have been learned as 6
being problems such as dust, and moisture, and drip shields,
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7 and connections, and things like that that are generally 8
applied.
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MR. WYLIE:
I may be putting words in his mouth, but 10 I think that he is asking you specificql.ly about Duke.
11 MR. EBERSOLE:
Wel,1, yes.
I tin ght that Duke might I
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12 have a base line of minimum enclosure ch'eracteristics, s
13 MR. THOMAS:
The armored cable is a very good example
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14 of a standard practice of taking I think precautions and buying 15 alotofinherentsafetyduetkdesignversusactuallyhaving iQ 16 to for the other characteristler. ' Cable is one.
We do have a
- j 17 standard cabinet that we house all of our eJectronich in that 18 was generically seismically tested, and IM either drip tic),rt, I
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20 A iot of them, we actually tested;6ack in the 1970s
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21 to prove that they were spray tight.
That we took some of our 22 standard cabinets and did some environmental qualification 23 testing of the cabinet by putting components in and verifying that anything due to a sprinkler spray or a steam line break, that the water is not going to get inside the cabinet.
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It'is not hermetical $y senled by any means.
But if 2
you arcs spraying it,jthe way that the louvers are and j
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And
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we do have all of that documented in design criteria that we 5 111ve by. But to be peg;fert4y honest, back in the 1970s, we had 6
to go back und redocument what our criteria had been, so that 7
it was auditable.
8 Now we had a great potential for the exact same thing 9
to occur on A-46, the seismic qualification issue.
Fortunately 10 in the early 1980s, we were already having this bad experience 11 of trying'to get together and understand what we are going to 12 do on EQ beyond the general concept.
Everybody knew that we 13 had to show qualification.
But what that really meant and how
(
14 it was implemented and how it was audited, we had a lesson to 15 be learned and have learned it.
16 And as we were learning it, we tried to see if there 17 was some way that we could prevent that from happening in the 18 seismic arena which was really A-46.
The seismic qualification 19 was all equipment, not just harsh environment.
Potentially, it 20 had a very big scope.
21 All of you are very familiar I think with all of the 22 bases uying to A-46.
But the industry a cided that we might 23 could.,olve this issue by getting together up front, spending, some mons:r up front rather than after the fact, and try to work with the stafi to resolve the issue rather than just react to O
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1 the staff.
2 So this is a very updated slide.
We have forty 3
utilities now.
It started out more in the neighborhood of 4
about a dozen in the early 1980s.
But the seismic 5
qualification utility group was put together to try to 6
determine how would you go about solving this issue, and with 7
the thoughts at the very beginning that the only way that we 8
could resolve it was to establish a relationship with the 9
staff, and to try to together assess the issue, and to try to 10 determine what are the weak links, and what really needs to be 11 done, and what is a practical cost effective approach to do it.
12 And I think that on behalf of the industry including 13 the staff, the vendors, and the utilities that we have done a
)
14 pretty good job on that issue today.
We did get commitment on 15 a very high level from the staff that they would participate 16 with us on this program.
And to date, it certainly followed 17 with that commitment.
All of you know that the SQUG approach 18 has been more or less documented as being the resolution to 19 A-46.
And we are really kind of in the implementation phase.
20 But again showing what a little cooperation can do to 21 solve an issue, we established a goal up front of trying to 22 identify what the problem really was by looking at what happens 23 in real earthquakes rather than what we might postulate, and to try to see if there was something that we could learn from
)
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i 20 l'
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1 those actual earthquakes and what is in those plants to see if 2
we could correlate it any way at all to what we are trying to 3
do in nuclear power, and make sure that what we were looking at 4
was the same scope and the same type of earthquakes.
And again 5
as I said, try to determine what is a significant risk and what 6
is not.
7 That is the way that the SQUG group started out with 8
the sole goal of resolving the generic issue A-46.
As we 9
further developed our program and started collecting this data 10 base, we more or less expanded our goals of what we were trying 11 to do to come up with a realistic assessment of the risk to 12 determine what can happen and know the scope of where you have 13 to really concentrate your manpower and expenditures if you are
()
14 going to truly increase safety.
I mean that was the goal.
15 That if we did anything, let's make sure that we are going to 16 increase safety, not just generate a lot of paperwork.
17 Jumping all of the details of the SQUG program which 18 all of you have been exposed to before, the utility group came 19 to some conclusions that we really did not think that it was 20 anywhere as big an issue as we thought.
And to resolve A-46, 21 we were not going to have explicitly retest the way that we do 22 for new equipment.
23 When we presented that last conclusion to the staff, they could not argue with it very well, but it certainly was l
something that was difficult to deal with.
So again I think
(
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1 that we kind of in a spirit of cooperation and communication 2
reached a compromise of how do you handle such a conclusion.
3 And that was the time that we agreed to form an independent 4
body.
5 MR. EBERSOLE:
You have found that to be the case.
6 And I think that maybe the very basis for it is that you have 7
to ship equipment, you have got to dump it out of trucks,.and 8
you have got to handle it.
And like many other things, you 9
have something that is totally unrelated to its function.
10 How do you handle equipment when they come in, like 11 was said, come into the field and say why do you have to do it i
12 that way when I pack it this way, and you will get that as the l
13 next addition to that same equipment, but now if you breathe on
(])
14 it that it will fall apart?
15 MR. THOMAS:
That is a question that I guess is why 16 we are at the point where we have got to walk a plant down.
17 You cannot answer 100 percent what happened ten to fifteen 18 years ago for this equipment that one manufacturer did not slip 19 in one of those pieces.
So since you cannot answer it 100 20 percent with confidence, the next best thing is to walk through 21 your plant and verify that that did not happen by inspections 22 and comparing it to what we now call caveats and exclusions.
23 MR. EBERSOLE:
Now what you have got are i
characteristics which were not in the specs.
MR. THOMAS:
That is true.
)
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MR. EBERSOLE:.Now how are you going to ensure that
~2 you are going to keep on getting that in the face of continuous 3
" improvements" designed to sell the equipment for more money?
4 MR. THOMAS:
For new equipment, we are pretty much 5
tied to making sure that we tie the spec close enough and 6
inspect it well enough before it is shipped.
7 MR. EBERSOLE:
A case in point might be the solid 8
state equipment.
It used to be that we had pretty good 9
environmental capability.
And you.can put that in another 10 context.
11 MR. THOMAS:
I think that again is a lesson that was 12 learned.
And I think that there were some experiences where l
13 electro-mechanical control equipment had been replaced by solid
)
14 state controls like in the late 1960s and early 1970s.
And the 15 ruggedness of that equipment was not developed.
Recently, I 16 have seen quite a bit of change in that, particularly the 17 manufacturers of equipment that their market is the utility 18 industry, whether it is nuclear or not, and the industrial 19 facilities like refineries and things like that.
20 The solid state equipment is one heck of a lot more 21 rugged when designed for industrial application today than it 22 was ten years ago.
23 MR. MICHELSON:
Not for nuclear plants necessarily, as you well know from your prior experience.
MR. THOMAS:
That is true.
The equipment has had O
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23 2
r~s I
1 some problems with elevated temperatures.
But again the 2
temperatures were something that I think that the manufacturer 3
felt that we would control in regard to the HVAC system for the 4
plant, and we got too close to margins on both sides.
5 MR. MICHELSON:
Well, this is in part what bothers 6
me.
On your seismic qualifications using the A-46 resolution 7
process, you are required to walk down the plant to verify if 8
it could survive the appropriate seismic event.
In the process 9
of doing your walk-down, for instance, you are required to 10 assure yourself that non-qualified structures could not fall on 11 your equipment if anchored inappropriately.
12 But if a non-qualified falls down into this water 13 content, you are not required to trace.the water content into 14 the electrical to make sure that everything is all right.
It 15 is a very narrow resolution, as you are well aware of.
16 Hopefully, the utilities on their own initiative will 17 proceed to check out where the water is going to, because 18 sooner or later they are going to have to answer the question.
19 But'A-46, it says you do not have to worry about water, water 20 contents, and gas contents and so forth.
21
-22 23 Heritage Reporting Corporation (202) 628-4888
24 13
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1 MR. THOMAS:
Again, to resolve an issue, you have to 2
scope it.
How far you scope it will affect the timeliness of 3
implementation and resolution.
I know, beyond the water issue 4
of chasing down stray water as a result of an earthquake, which 5
. was part of the A-46 resolution, we've got another one that 6
again is trying to be resolved and if any work results being 7
required, it certainly should be integrated.
I don't want to 8
walk the plank twice.
9 MR. MICHELSON:
But apparently, the industry _was 10 satisfied just to do what the NRC said that it should do.
11 MR. THOMAS:
There's been a lot of work looking at 12 water, I guess.
Design of plant drains, sumps, a lot of good 13 design in regard --
()
14 MR. MICHELSON:
Your protective system might be a 15 little problem, for instance, in an earthquake.
16 MR. THOMAS:
Protective system?
17 MR. MICHELSON:
If the fire protection comes on.
18 MR. THOMAS:
Again, you have to scope this as to what 19 you think is realistic.
20 MR. MICHELSON:
You can't use past experience, 21 necessarily, because these old plants didn't have all this 22 fancy, exotic fire protection provisions that they had to put 23 in under Appendix R.
If they had, you might have found the 24 experience.
25 Heritage Reporting Corporation (202) 628-4888
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1 MR. THOMAS:
Some of the modern plants that have seen 2
earthquakes do'have some pretty fancy equipment.
If we try to 3
look at what happens and incorporate it into the picture, I 4
think more of an issue than what you're talking about is 5
_probably relays, relay chatter.
And again, it is something 6
that you could postulate "what if," and have a lot of problems 7
proving on a very explicit basis.
But again, the earthquake 8
experience that luss thousands of relays still does not point to 9
-any system malfunctions that of any concern.
10 MR. MICHELSON:
Well, you don't know that too well.
11 I won't debate the point now.
But we talked with the SQUG 1
12 Group many times about just how much did they really know about 13 spurious actuation during those seismic events.
That was very 14 difficult.
That is still, I think, an open issue.
15 MR. THOMAS:
It is-an open issue.
But again, it's 16 the exact same time of auditabilitp in having the paperwork 17 approved, something that is very similar to the engineers 18 designing the equipment back in the 1960s, in the standard 19 environment, and when you go out and retest a lot of things, 20 you found they thought pretty well, but you can't document it.
21 It's my personal opinion from my personal interviews with a lot 22 of people that have gone through earthquakes, that they would 23 be redesigning the plants if the relays had caused them a 24 significant issue.
25 MR. MICHELSON:
Does it bother you a little bit to O
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26 1
read.LARs from other utilities and find that they have had u
2 accidental water-releases, and lo and behold, equipment.that 3
was environmentally-qualified to. withstand water effects was 4
indeed ineffective?
5 Yes, they changed some things, and they forgot'to 6-put a seal here and they forgot to put'something else there.
7 And it's.not just a happenstance. ~ There's a' set of'
.8 LLARs to read if you want to trace both' kinds of events.
And it 9~
Eshakes your confidence a little bit if this equipment that you.
10 really think'is. good, and it turns out that under exposure to 11 these conditions, it turns out it's not effective.
12 MR. THOMAS. There have been some instances even-in 13-
_the Duke system where we have had some random occurrences.
14 MR. MICHELSON:
That's right.
15 MR. THOMAS:
I haven't'seen anything yet that causes 16 me to have a serious concern that we have a common mode 17 problem, at least on the Duke system;.Anyway, we had this 18 third party, which again you've heard testimony from the SSRAP 19 on what we're doing.
We had a lot of support in general for 20 our conclusions on seismic.
Again, narrowing down the issue to-21-make sure you have good anchorage, and these caveats and these 22' conclusions are essentially making sure that you are within the 23 bounds of what you know and what your data base tells you, and 24 if someone hasn't slipped a bad piece of equipment on you, 25 that's flimsy.
That's essentially what all those do.
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1 But'again, this method, what I'm trying to discuss I-
- 2-
'think is more programmatic and more an opinion of how do you 3
resolve something, rather than with technical details.
But we i
L 4
have an example of where some good communication, some 5
cooperation, some listening to both. sides of the story, has-6.
come_out with a way that is a lot better way.to.at least get to 7
- where.we are today than what we did on equipment qualification.-
8:
.Here is'one of'the things that I think that'is the n
9'
' biggest key'to the acceptance of SQUG from the utility's
~10 standpoint'as well as the~NRC is that you've' heard about our 11'-
Generic ImplementationEProgram.
It's a big thick document',
12-where:we're trying to. define up front exactly'what is the 13 scope, exactly how do~you develop this list, for shutdown, and I
14 agree with-the staff how you do that, agree with the_ staff on 15 whether it compares or not,'with our generic equipment list. In 16-detail how do you remove caveats?
How do you determine whether 17-
-this one is a bad one that somebody slipped.in on'you?
How do 18 you use the screening data?
If there are holes, what other 19.
methods could you use to assess is, such as test data, 20' judgment?
Working those out up front, before implementation.
21 Total concurrence that we will agree up front.
If we can 22 narrow the scope, how do you.do that and what are both sides 23
-going to agree on how to do it?
l 24 MR. EBERSOLE:
Let me ask you this.
This morning we l
I 25 heard from Sandia and others.
See this big book here?
It's
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1 supposed to be that in part that matter of developing that 2
list.
Do you all keep together in that?
They are looking for 3
the same list, you know.
They're doing it from the standpoint 4
of looking at the holes in environmental qualification as 5
expressed in the GRE programs.
I'm just asking though, are 6
lots of people doing the same kind of work?
Is the NRC doing 7
one or the other?
l 8
MR. THOMAS:
I guess Mike Bond was here from Sandia.
9 I had the privilege, I guess, to sit on a peer review panel 10
.with Mike on the Maine Yankee Margins Program, and I guess, 11 based on experience, I can say that the approach, and the types 12 of equipment with that were consistent with regard to the SQUG 13 program.
The margins program gets a larger scope.
It's clear j
('T 14 why and it's clear what.
q.)
15 Yes, we are staying closely involved with that effort 16 and they are closely involved with our effort.
17 But anyway, even down to the very end of what's 18 caused a lot of problems with EQ, environmental qualification, 19 what is documented and how do you document the results and what 20 is going to be acceptable from an audit standpoint, if the 21 staff wants to audit?
22 There are some more slides in your handout that are 23 dealing in more detail in the technical resolution of SQUG 24 work.
I think I'm going to jump to the overall what's ahead of 25 us now.
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1 MR. MICHELSON:
Before you jump that far, could you 2
comment just briefly on the, you know, you have done a couple 3
walk-through experiences.
4 MR. THOMAS:
Yes.
5 MR. MICHELSON:
And from those. experiences, what kind 6
of feeling do you have now about how the process is working and 7
so forth?
8 MR. THOMAS:
We've completed Zion, which is the first 9
trial plant.
f 10 MR. MICHELSON:
You didn't do Nine h 2e yet?
11 MR. THOMAS:
It is to be done beginning in January.
l 12 We had some training this month and we've had work going on to 13 identify a list.
Preparation with walkdown hasn't taken place l ()
14 yet.
It starts in January.
So that will be our second 15 feedback.
We do feel that training is very, it's very 16 important that it be successful.
And we are, as part of Nine l
l 17 Mile, we're having a trial training program, for the walkdown 18 people.
So we are very anxious to see the results of our 19 training program and make some improvements there if necessary.
20 MR. MICHELSON:
In the future plants beyond Nine 21 Mile, is there going to be a particular cadre of people that 22 will do one plant after another, or is each plant being set up 23 with a different crew, or how will that work?
[
24 MR. THOMAS:
That flexibility is open for the utility 25 to decide.
The guidance they have to follow is pretty O
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prescriptive. The judgment that can be used is pretty well 2
defined in the training program.
3 MR. EBERSOLE:
Let me ask you about the walkthroughs.
4 Do you agree that walkthroughs are exploratory in character and 5
you are just trying a fortuitous, terminal case.
You ought to 6
be really doing a confirmatory examination, if you've got a 7
product that is intended.
8 MR. THOMAS:
That's true.
9 MR. EBERSOLE:
Is there an effort to make that 1
10 intended product what it ought to be so that your walkthrough 11 is confirmatory rather than exploratory?
Because right now 12 it's exploratory.
I 13 MR. THOMAS:
I can say for Dtke there is.
14 MR. EBERSOLE:
I know.
But we have to deal with the 15 other end of the spectrum.
16 MR. THOMAS:
I'm doing essentially a SQUG walkdown 17 long before I planned to do a SQUG walkdown.
l I
18 MR. EBERSOLE:
Sure.
j 19 MR. THOMAS:
The utilities joining together to Forum 20 40 have been learning a lot.
There is a lot being done by a 21 lot of utilities in regard to what we've learned today, even 22 though they haven't been required to implement it yet.
I can't 23 say that's 100 percent, but I can say that is a significant 24 percent and I can say that the fact that we've been working on 25 this problem and learning things all along, that the success of Heritage Reporting Corporation (202) 628-4888
31
.,.m 1
the walkdowns is going to be a lot more successful than it 2
would have been if such a group didn't exist.
3 MR. MICHELSON:
Now, there must be a common, perhaps 4
there is a common set of things that you notice, you know, 5
things that jump out at you.
The not necessarily unexpected 6
but the surprising at least.
Could you tell us a few things 7
that you've found as a result of this walkdown that certainly.
8 were surprising?
9 MR. THOMAS:
I'll be very explicit.
At Zion they 10 found some safety equipment that wasn't anchored.
11 MR. MICHELSON:
Anchorage seems to be a common 12 denominator problem, doesn't it?
l 13 MR. THOMAS:
Yes.
Anchorage is a common key issue, 14 that you have to be assured of anchorage and if you're assured l
15 of that, you resolve most of the problems.
The interesting 16 part about Zion was that the equipment that wasn't anchored by 17 an after the fact analysis could be shown to be relatively 18 stable and wasn't going to tip over, and that the fix to solve 19 that anchorage problem was to meet what the design drawing 20 said.
They didn't change the anchorage, they just implemented 21 what was issued years ago.
It was more of a QA and 22 construction issue than it was what you might call a seismic 23 issue.
1 24 MR. MICHELSON:
They just hadn't implemented it.
25 MR. THOMAS:
That's true.
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1 HR. MICHELSON:
Hadn't put the bolting in or l
2 whatever.
]
)
3 MR. THOMAS:
That's right.
The bolts were missing.
]
4 And it was an oversight during the construction phase versus 5
something that had to be modified.
By and large, that's what 6
seems to be the comtan thing that we're finding in the SQUG 7
preliminary walkdowns that a lot of people have been going 8
through, that they're learning is, if you come right down to I
9 it, it's more of a QA and construction issue than it is a 10 seismic issue.
11 MR. MICHELSON:
The thing that bothers me a little 12 bit, maybe you want to comment on it, the whole SQUG approach 13 seems to be more structural oriented, I guess, than functional
(}
14 oriented. 'They focus heavily upon the stiffness of cabinets 15 and the bolting of cabinets, and they focused on making sure 16 that things didn't fall over and are thereby interactive with 17 equipment that was needed.
They would have liked, I guess, to 18 have focused on electrical interaction, except they ran into 19 this relay and instrument contact chatter problem 5.hich made it 20 very difficult to cope with.
But I still got the feeling that 21 it was heavily structurally oriented, even the walkdown 22 process.
23 MR. THOMAS:
Well, that was a conscious decision in 12 4 that if the equipment is anchored correctly, we can't find any 25 evidence anywhere that it's going to be damaged.
It is going
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I to remain functional after the strong motion.
It's not going i
2 to be damaged in any way if it's anchored correctly, and also, j
3' as you point out earlier, you don't have a significant 4
interaction problem to where something of a large-size could 5
fall on it or bang it.
The equipment is very rugged in 6
general.
There are exclusions that you can -- as an example, 7
somebody slipped one in that they tried to make it cheaper and 8
packed it in cotton, so to speak. -But those'are by far an 9
exception and a rare case.
I doubt if we find very many of 10 those, in all of the plants that are going to be walked down.
11 The evidence we've seen is that most of it is the standard 12 equipment, but we have found some nonstandard that will have to 13 either be changed or beefed up.
Will have to, I think; in most
(}
14 cases a lot of it already has been.
But the functionality, I 15 think the example earlier, in addition to being shipped and 16 things like that, prior to being installed and expected to 17 operate, you see far more forces in shipping than you do from j
18 inertial loads from seismic.
And also a lot of equipment like 19 motors and pumps and things like that that their own operating 20 forces far exceed anything the inertial forces are going to 21 produce due to an earthquake.
It's the lack of anchorage that 22 can cause it.
23 MR. EBERSOLE:
You're probably quite right.
I've
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24 never had so much concern with the structural part, assuming
)
25 people know how to anchor things properly.
The concern I have
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k!
1 had is the seismic inducement of unwanted actions which leads 2
to difficulty.
3 My first experience with that was the switchings that 4-turned on the fire equipment everywhere.
5 MR. THOMAS:
They should all have been replaced.
6 MR. MICHELSON:
Well, we still find them 7
occasionally, when people jar equipment.
We tell them to hold 8
because there is a mercury switch.
9 MR. THOMAS:
A lot of housekeeping problems.
i 10 Anyway, my point I'm trying to make here is that you 11 can bring some technical points out, and we're still dealing
)
12 with the SQUG.
But they are not anywhere near the technical 13 points we're still trying to resolve on EQ, and trying to reach k.
14 understanding on what it means in regard to is this one 15 qualified.for that environment and is the documentation 16 sufficient, was it totally addressed during the initial 17 qualification test.
At least the issues, we think, are on the 18 table, and we're working with them and nobody is in the dark, 19 and nobody is very nervous that something is going to come up 20 that isn't expected on either side.
We know things we've got 21 to deal with and we've tried to establish, as you can see, at 22 this. phase of the game we have a very programmatic control over 23 the SQUG program of what we're trying to do and by when and 24 what are the issues.
You're seeing issues.
You're seeing how 25 do we make sure the guidelines are addressed, what is it we're Heritage Reporting Corporation (202) 628-4888 i
35 O
1 going to do about this functionality of relays, what are we 2
doing about kind of an expanded scope cable tray and what are 3-we going to do about actual implementation.
It's all being 4
done before implementation is attempted.
Implementation of-EQ 5
started from Day One.
6 MR. EBERSOLE:
This cable tray issue isn't really 7
significant, is it?
In the long run, you can probably hold 8
cables up with rope, can't you?
9 MR. THOMAS:
My opinion is it's a non-issue.
10 MR. EBERSOLE:
So if you were to do something and say 11 well, sure, the roots of the trey broke but I'm still holding 12 it up with whatever I hold it up with.
13 MR. MICHELSON:
You don't want the tray to fall down.
O)
(-
14 MR. EEERSOLE:
There's no linearity problem or 15' anything like that.
16 MR. THOMAS:
You can essentially, in most cases, pull 17 most of the anchorage out of the cable, I mean'the tray, and 18 the cable will hold the tray up.
I think one of the best i
19 examples, from my actual experience, was a slide -- I don't 20 know whether you've seen it or not -- but in the Mexico 21 earthquake, out on the court, where the real raotion was taking 22 place, not Mexico City, but the example of the cable tray that 23 was actually buckling from overload, and after the earthquake, 24 it was sti.ll buckled.
But there was no falling.
I 25 MR. EDERSOLE.
I look on it like seeing the power i
([)
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pole broken off in a storm but they're still held up with 2
cables.
3 MR. THOMAS:
Yes.
That's true.
4 MR. WYLIE:
In the seismic margin, there are plants 5
that went under the seismic margin.
6 MR. THOMAS:
We have two seismic margin plants so i
7 far.
Maine Yankee and Catawba.
8 MR. WYLIE:
Maine Yankee.
Yes.
It was Maine Yankee.
9 As I recall, they analyzed the cable tray system which 10 basically was an industrial grade cable tray system, was held 11 up by rods.
And they found it passed the seismic margin 12 analysis.
13 MR. THOMAS:
Yes. The margins even above the design 14 basis.
15 One of the things, as an electrical engineer being 16 educated to seismic events and what happens in seeing some of 17 the real things and again talking with analysts, is that you 18 are much better off letting the equipment be able to dissipate 19 some energy by swinging a little bit, make sure you got enough 20 room where it doesn't bang something that's going to damage.
21 But trying to tie it down where it can't move is, in hindsight, 22 not the best way to do it.
But we have certainly tied a Jot of 23 things down, again, by solving issues before we understood
)
24 them.
We've solved a lot of issues without communicating and I
)
25 think cable tray hangers, pipe hangers, snubbers, all fall into i
f-Heritage Reporting Corporation (202) 628-4888
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. q/
N-1 where we implemented something before we understood it.
And 2
we're trying to avoid that with SQUG.
And I know it has 3
frustrated a lot of people that we're so long in implementing, 4
but if we implement, I think what we've done is at least get 5
some safety benefit out of it, rather than go in the wrong 6
direction.
i 7
Finalizing SQUG just quickly, I hope SQUG goes beyond 8
A-46. There's a lot of thinge we're talking about.
Maybe we 9
can simplify things in the future, j
i 10 I don't want to get into the detail I did with those 11 two, because this one I haven't been as closely involved, but I j
i 12 just want to give an example of another issue that I think 13 there's been an effort to try to communicate between the
()
14 industry and an effort to try to understand the issue before 15 you implement the resolution.
There's been a lot of industry 16 groups, a lot of it has been coordinated, there's been 17 substantial interaction.
There's other issues again that are 18 beyond the actual scope that might well be implemented 19 together, but I think there is an indication that on major 20 issues that we are getting resolutions accomplished in a better 21 way than we did in the past.
Very briefly, this is the issue I 22 said I would like to quickly cover, is a way to prevent a j
23 generic issue.
We had one back in the 82-83 time frame and a 24 generic letter resulting, 83-28, on undervoltage trip devices 25 on reactor trip switch
,i
\\l Heritage Reporting Corporation (202) 628-4888
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(])
1 gear.
July of this year we had a failure to trip of a breaker 2.
that's widely used in the industry, and immediately realizing 3
the importance of that, the NRC sent a special assessment team 4
to the site immediately to meet with the Duke staff. We worked 5
very closely trying to determine what happened to that breaker.
6 The information notice, again, I think, did not try to 7
implement any resolution without understanding the problem. I 8
think that is a complement of the way things seem to be, that 9
didn't seem to be five, ten years ago.
We agreed to an 10
-approach of how we were going to investigate, the vendor 11 investigations, also an independent investigation by Franklin 12 with parts supplied by Duke to the staff for that 13 investigation, and agreed that we would follow both from all 14 sides.
Everyone would be invited to all meetings and have an
(}
15 opportunity to contribute.
It took six months to come to a 16 final resolution.
For those of you, again, this is a 17 presentation. I've talked technically with you before. But we 18 had a pole shaft with a weld to break, and what happened was, 19 it's not shown on this shaft, but there is another lever 20 mechanism very similar to this one that connects to this shaft, 21 having to do with the anti-bounce mechanism.
What happened, 22 this well, due to poor quality from original manufacturers, l
23 after about 2,500 cycles, broke loose and all the loads on this 24 closed cam was transferred by the anti-bounce lever.
That, in 25 itself, wouldn't cause anything to happen. At worst, it would
()
Heritage Reporting Corporation (202) 628-4888
39 h
1 cause a breaker not to close.
However, with this particular 2
breaker, the cam laminations, this has two side plates on the 3
side and it rolls on a roller, right here. The combination of a 4
broken well, combination of this out of tolerance, combination 5
of the cam being out of tolerance, combination of the way the 6
laminations were made, that one in about 200 times with a 7
broken well this roller could jam on the side plate and you 8
wouldn't know they wouldn't be able to trip.
But that was a 9
very in-depth investigation.
And the point I'm trying to make, 1
10 not technical, but again, I think a compliment on both sides, 11 the industry and the NRC, of holding off on implementation --
l 12 (Continued, next page) 13 lll 14 15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
40 m
1 MR. THOMAS:
-- until we finally came up with a 2
conclusion that all aspects of concern was developed and put 3-together within the bulletin which just came out about two 4
weeks ago.
I think the only thing that should be followed up 5
by the staff is another notice that maybe prioritizes some of 6
the inspections required by this bulletin, such as look at your 7
switch gear first.
8.
But it's an excellent example, at least I-think, on 9
behalf of the Duke project managers on the staff and the 10 support and that a lot of people have learned a lot of lessons 11 that it's better to understand a problem before you try to 12 implement the resolution.
And I think we went a long way on a I
13 specific example to do that.
14 Those are the examples that I had planned to cover.
15 And I think maybe Neal is going to take on from here and 16 discuss how we think about the overall process.
17 MR. RUTHERFORD:
What I would like to do first is 18 just briefly go over the status of a number of issues on the 19' Duke plants and then we will get into a discussion on 20 implementation.
21 First of all I would like to cover the status on 22 unresolved esfety issues.
And these are the only issues 23 outstanding on the Duke plants where there has been a 24 resolution to a USI.
25 First of all, for A-3 and A-5 on steam generator tube O
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)
1 integrity, McGuire and Catawba are complete as far as the i
2 actions required by the generic letter.
Oconee, the only issue 3
that we really have outstanding there is a clarification to our 4
leakage limits for tube leaks in the text specs.
5 A-9, on ATWS, on Oconee we are awaiting the staff 6
approval of the generic design concept for BMW plants in order 7
to be able to implement that on Oconee.
8 For McGuire and Catawba the generic.and plant-9 specific designs have been approved and we expect 10 implementation by 1989.
11 For A-46, of course Jim has really just covered that.
12-On Oconee we will be adopting the SQUG program in response to 13 the generic letter.
()
14 Next category of issues that I wanted to talk about -
15 16 MR. EBERSOLE:
Let me ask you a little bit about the 17 ATWS.
I believe you all favor Westinghouse reactors?
I'm 18 talking about Duke in particular.
And the thing that bothers 19 me is the fact that in the perception of the public at large if 20 you do have an ATWS zone and they're not willing to keep out of 21 it there is going to be a lot of excitement.
{
22 23 24 25 l
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L Heritage Reporting Corporation (202) 628-4888 i
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42 k'
1 And I don't'think that consequence has been factored 2
into the overall consideration of the need for diversity to get 3
away from just those two breakers and provide some sort of a 4
smaller but effective backup to a diverse system, i
5 Have you all considered that?
You know, Westinghouse 6
says, gee, we've got lots of relief with that.
Just wait till 7
we have an accident.
8 MR. RUTHERFORD:
No, I don't think we've considered l
9 it from that angle.
Certainly we are always concerned about 10 public perceptions, but we do have to design the plants as to 11 what we expect to occur realistically.
12 MR. EBERSOLE:
Look at the TMI 2.
Look at the impact 13 of it.
()
14 MR. RUTHERFORD:
I'm sure that there are a lot of 15 things that you could go spend money on if we were just 16 concerned about public perception.
And there has to be some 17 balancing there, obviously.
10 MR. EBERSOLE:
Oh, sure.
All you've got to do is 19 look at what happened at TMI 2.
It's up at the billions now, 20 but nobody got hurt.
21 MR. RUTHERFORD:
That's true.
l 22 MR. THOMAS:
From the design standpoint we did look 23 at methods of converting.
I think we've discussed those with 24 you.
And there are trades.
It isn't something that we 1
25 Heritage Reporting Corporation (202) 628-4888
43
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1 ignored.
It is something we looked at.
2 And from the standpoint that you were addressing, 3
from that viewpoint that certainly is a strong point of going q
4 towards something like that.
5 There are some negativo aspects with regards to 6
maintenance and complexity and design.
7 MR. EBERSOLE:
You're talking about incremental 8
trips?
9 MR. THOMAS:
I'm talking about we've complicated the 10 system to where we couldn't possibly have inadvertent trips.
11 We'd be adding the systems that again in themselves were found 12 defective.
13 MR. EBERSOLE:
Well, couldn't that be done just by
(
14 moderating the voltage regulator on each site?
15 MR. THOMAS:
It could be done in a lot of ways and it 16 could be implemented I think in a lot of ways.
And if you did 17 them from the practical standpoint versus needing all of the 18 regulations with regard to on-line testing, if you could get 19 around a lot of those you could do a lot of things.
But we're 20 forced to live with a lot of things in the design that are not 21 practical.
22 MR. EBERSOLE:
One of the fears is you would be 23 forced into a 1-A configuration instead of just a standard 24 piece of equipment, which really wouldn't be necessary.
25 MR. THOMAS:
There are benefits that you could do
(
Heritage Reporting Corporation (202) 628-4888
1 44
. (3 1
things and get a lot of --
2 MR. EBERSOLE:
Well, would you guess that the staff 3
would push you into a 1-A configuration?
Why would you?
How 4
could the staff when the only direction of function would be in 5
the right direction?
6 MR. THOMAS:
We would have to address six remedial 7
actions.
We would have to address isolation and safety.
8 MR. RUTHERFORD:
Well, let me digress a little bit 9
and jump ahead.
Might as well cover this item right now.
10 On ATWS, this would.be one of the issues that we 11 would classify probably as limited benefit as far as the 12 benefit of actual resolution.
We see more benefit probably in 13' the generic letter that came after Salem in improving the 14 reliability of the reactor trip switch gear'than we do on the 15 overall ATWS resolution.
j 16 MR. EDERSOLE:
I think there have been a couple or 17 three occasions since Salem that indicates the focus on the two 18 breakers comes to a point of diminishing returns.
And you're 19 saying I must go to another field and build my circuits j
20 somewhere else.
I don't know whether we've reached that yet or 21 not.
We've just fixed one, you know.
I don't know, I think 22 there have been six others.
23 In any limited area there are a number of l
24 compromises.
I think you start pumping a dry hole in 25 attempting to perfect them.
At some point it's a practical O
Heritage Reporting Corporation (202) 628-4888
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3 MR. RUTHERFORD:
Well, obviously, you've goc to look l
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at'the overall reliability of your system, whether you perceive i x )~,
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that's sufficient.
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6 Okay, moving on to the TMI items, let's briefly go 7
through the status on those items that we still have '
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8 outstanding on dny of the plants.
4 9
First of all, on the control room design reviyr, all i
10 of the reviews of course have been done.
On Oconee we t
11 presently have 63 percent of the modifications on Unit 1 12 completed that were identified during the review; 45 percent 13 complete on Unit 2 and 60 percent complete on Unit 3.
And our
( >D
(
14 current schedule calls for implementation to be complete by 15
,1990 on Oconee.
.t 16 McGuire we are just about complete.
Unit 1, 98 17 percent and Unit 2, 92 percent.
18 Catawba, Unit 1 is complete and Unit 2 will be 19 completed in the first refueling outage, which is scheduled to 20 start this month.
21 DR. REMICK:
Could you explain why you have taken so
)
l 22 long to implement those changes as a result of the design
)
23 review?
24 MR. RUTHERFORD:
They compete with everything else 25 that we are doing.
That is basically the reason.
We have i
l l
p' Heritage Reporting Corporation
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(202) 628-4888 j
i
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1 prioritized the modifications and attempted to do those first
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2
.that had the'most benefit.
But particularly in the electrical i
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3 area -- and maybe Jim can elaborate -- we are very stretched 4
for resources in that we have got a lot of modification work on u
l 5
all our plants that are focusing on that one area.
So that's 6
the main reason.
7 MR. THOMAS:
I would like to make another point, 8
particularly with regard to that.
When you are trying to.
9 modify something on a control room you create a very serious 10 problem during the modification process.
You've got one unit 11 operating and you're trying to niodify the control room of the 12 other one, you're moving wires, you're drilling, it's very 13' difficult to get the systems aligned in a way to where you can
()
14 safely implement some of these mods.
15 It takes a lot of time and a lot of innovation 16
. precisely.from an operating standpoint because you still have 17 to do the operating, to get things to where we feel that we are 18 safe in making the mods.
19 We recently had a re-review of some of the wire 20 changes that we originally planned to do and we came up with a 21 decision that the risk that we would be taking far outweighed 22 any improvement that we would be coming up with to effect the 23 changes.
24 And it's just that we don't want to get too many 25 things going at one time to where you get out of hand and.you g~
Heritage Reporting Corporation (202) 628-4888 o
47
.i 1
can't assess what you need to do.
]
2 And so Oconee in particular I think the new control l
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3 room has had to take its time in implementation.
4 DR. REMICK:
Could you just kind of briefly summarize 5
the types of changes that have been necessary as a result of 6
this review?
Are they mostly human factors, engineering type 7
things, location of something or other, or do you have to 8
relocate something?
9 MR. RUTHERFORD:
Some of the things, of course, are 10 easy to do -- labelling, gauge adjustment -- some of those 11 types of. things.
12 DR. REMICK:
I assume those are done.
13 MR. RUTHERFORD:
Those are generally done on the
)
14 front end unless they need to.be coordinated with a later 15 modification.
16 DR. REMICK:
How about if you have to add any cords 17 or anything like that or color coding controls?
18 MR. GILL:
Well, I think one big one we've done in I
19 the enunciators above t,he control boards, relocating some of 20 those.
It's one mod, HUB, but it's, you know, 500 or 800 wires 21 to change.
It's significant.
Hook a new one, test it out, and 22 keep going.
l 23 In fact, we decided on the wire to do Unit 2 in the
.24 spring and Unit 1 in the fall so that there is very little time 25 when the two control sides are different from each other, for 1
l l
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48 es()
1 the operators' c'nvenience, as opposed to splitting them up.
2 DR. REMICK:
In your modifications of the enunciators 3
did you add any expert systems for prioritizing the modes or 4
anything like that or is it just straightforward moving of 5
enunciators?
6 MR. THOMAS:
Most of those we've moved.
It has been 7
some 60 days.
8 MR. GILL:
Titles.
Didn't we change the titles on 9
some of them to be more, you know --
10 MR. THOMAS:
Some of them, yes.
More specific.
11 MR. GILL:
Flip it around from being lit when.it's 12 operating versus lit when it's inoperable.
That type of logic.
13 Some of them were color-changed, too, weren't they?
(}
14 MR. THOMAS:
Some of the modifications that we've 15 made in themselves took care of being effective like simply 16 putting in the displays where they're.more user friendly and 17 things like that.
18 MR. EDERSOLE:
When you do these things do you go 19 back and bring the drawings up to date?
I once heard an 20 engineer make an observation it would take $1,000 to change a 21 red light to a green light.
Most of that was in the drawing 22 changes.
23 MR. THOMAS:
Drawings and simulators.
24 MR. EBERSOLE:
Yes.
It's a major job.
The physical 25 change is nothing but the records must be kept up.
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l' MR. RUTHERFORD:
You've got those elements with any 2
modification procedures, drawings, training, above and beyond 3
the actual modifications themselves, for every modification.
4 DR. REMICK:
How about FSAR updates?
On some of 5
these things do you have to do that, too?
6 MR. GILL:
There is one modification up on'McGuire 7
where we were actually changing out a control system.
The HED 8
was changed to be in effect a part of the control room.
- Well, 9
they were having problems with the control system in 10 monitoring.
So we're changing out that control system.
And 11 that will also clear up the HEDs.
It's a separate mod but we 12 tied it together; we wanted to do it once and not have to go 13 back and redo it.
(~')
14 So that also builds in a delay.
When you decide on
(./
15 the solution for that then you have to design that through 16 equipment to make that modification.
A fixture had to be 17 modified and then the circuitry feeding back to the control 18 room.
19 DR. REMICK:
Was Catawba operating when the 20 requirement for the control room design review came out?
21 MR. RUTHERFORD:
No.
No.
l 22 DR. REMICK:
Why wasn't that done before you 23 operated?
Just time?
24 MR. RUTHERFORD:
Well, a lot of those were done prior 25 to operation.
We just had a portion of the HEDs that were
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1 implemented or to Ima. implemented after operation began on l'
2 Catawba.
l' 3
-The next item --
4 MR. WARD:
Let me ask a couple questions.
l 5
In view of what you said about the difficulty when 6
you shared the control room, do you think sharing facilities, 7
control rooms or other facilities is the best design now?
Or 8
have you changed your mind about that approach?
.9 MR. RUTHERFORD:
There are a number of advantages in 10 having operating crews that can help each other out at certain 11 times, the relief requirements, et cetera.
There are a number 12 of human factors type advantages as well as finding some I
13 possible disadvantages. 14 MR. EBERSOLE: This kind of sharing has the 15 connotation of being a. nasty thing to do. I would like to 16 differentiate it from helping. I believe you have provisional 17 aides at other units to help a unit in trouble. The NRC has 18 always taken sharing in a negative context and rarely give you 19 credit for the contributing side of helping. How do you feel 20 about that when you're not sharing just to economize but just 21 to increase flexibility and add resources to one unit? We 22 might get rid of using the word sharing" f or that process. 23 MR. RUTHERFORD: Well, I think where you've got 24 appropriate safeguards it's very beneficial. 25 MR. EBERSOLE: Oh, sure. () Heritage Reporting Corporation (202) 628-4888 l 1
l 51 ,a() 1 MR. RUTHERFORD: Now, you don't want to have the 2 potential for, for instance, automatic or inadvertent 3 operations getting you into trouble on a shared situation, but 4 you would like to be able to share power supplies with limited 5 operator actions, that's all. 6 MR. EBERSOLE: Right now it's all poured into that 7 one nasty word. 8 MR. WARD: Another question. Neal, a few minutes ago 9 you said that you have a list of things that you prioritized 10 into things by the greatest benefit first. How do you define 11 that? How do you define benefit? How do you prioritize that? 12 Are you going to talk about that later? 13 MR. RUTHERFORD: Well, as far as control room design ?.(n) 14 review HEDs, those were evaluated as far as their worth, what 15 contribution did they have to the overall plant safety. 16 MR. WARD: In what terms? In judgmental terms? 17 MR. RUTHERFORD: I'm not familiar with the actual 18 process that was used. It was a team approach to looking at 19 the operator convenience, the liability issues, et cetera, that 20 were used to come up with a point system to assign so many 21 points to each modification. And we used that not only to 22 throw out some things that didn't come up high enough on the 23 point system, but also to prioritize some of the things that 24 should be done first. 25 Now, obviously, some of the easier things we would go 's Heritage Reporting Corporation (202) 628-4888
1 ) 52 7,- L 1 ahead and do irregardless of the priority system, a percent of 2 the more complex ones-we would prioritize. ) 3 MR. WARD: Was it a benefit to cost prioritization? 4 MR. RUTHERFORD: It has been about four years since I 1 5 have seen that and I can't remember the elements of it. i 6 Jim, do you have any memory on that? 7 MR. THOMAS: Cost was factored in but it was one of 8 the lesser weights. But it was a point. Safety, obviously, is 9 the highest one. 10 MR. EBERSOLE: You're suggesting if you have a 11 threshold back at some point you will do a good thing r.o that 12 you can control something. What is something? The :.nC doesn't 13 have any thresholds. H( k 14 MR. RUTHERFORD: Well, it's cost versus benefit, 15 obviously. 16 MR. EBERSOLE: 'I know. But you suggested that you 17 said the easy things -- 18 MR. RUTHERFORD: No, I said the easy things we would 19 go ahead and do first irregardless of where they fell in the 20 priority scheme. 21 MR. EBERSOLE: Yes. What is easy in a cost context? 22 MR. RUTHERFORD: Labelling. 23 MR. EBERSOLE: I'm thinking about dollars. 24 MR. RUTHERFORD: Labelling is cheap. 25 MR. EBERSOLE: Yes, sure. I understand. But up the O' Heritage Reporting Corporation (202) 628-4888
53 (_) 1 line someplace it gets not easy. I don't know where that is 2 compared to a dollar context. I 3 DR. REMICK: You are not saying that you would not 4 carry out the correct HED because of cost; is that correct? 5 MR. RUTHERFORD: No, I'm not saying that. I'm saying 6 that we came up with a number of things during our control room 7 design review. And some of those were screened out as not j 8 cost-effective to do. 9 Well, cost and benefit. The balance there. 10 MR. EBERSOLE: You know there is something called 11 good practice. There's not a dollar value to it. And I'm 12 trying to find out where that is in a dollar context. And I'll-13 never find it, I'm sure. (]) 14 MR. RUTHERFORD: Well, there's lots of factors when 15 you have to consider backfitting an existing control room, 16 whether you go and do something that changes an item that an 17 operator has been used to for ten years or so. Those types of 18 factors have to be included, too. 19 MR. THOMAS: You know, from a human factor standpoint 20 you can show that you're much better off with an automobile and 21 a steering wheel. I've been driving a pickup truck for ten 22 years and I still try to stomp the thing in a new car. And a 23 lot of times you're not sure you're getting a benefit if the 24 operator has been trained with something with poor human 25 factors to start with, well, he knows it and that's what he /7 (_) Horitage Reporting Corporation ] (202) 628-4888 J l 1
I 1 54 (V \\. 1 _ reacts.to. And some of those things come into the picture too. 2 Is it a benefit? 3 It's obvious 1y better engineered but is it a real 4 benefit. To make a change would create more confusion. 5 MR. GILL: I think from.a programmatic aspect, and 6 this came out in 1982-83 in a generic letter and Supplemental 7 107-37 order, we put together a report of the control design 8 review team, put together a report of the results of that team, 9 worked with the staff in identifying what HEDs were identified, 10 which ones were selected not to be installed, which ones were 11 to be installed. We reviewed that with the staff, got an SER, 12 And in early '85 we agreed upon an implementation schedule. 13 But programmatically working with the staff to come () 14 up with that we basically set a commitment of 25 to 30 percent 15 of the HEDs would be installed on each McGuire unit. And 16 that's where we are now that we worked with the staff from late 17 '82 -- I can't recall the year we made that submittal, but it 18 was late '83 or '84 when the results were put in. 19 And we had a dialogue with the staff and we reached 20 agreement on what to put in. And we took at least 150 per unit i 21 going in. And we tried to keep the units close to each other l 22 so you don't have one, you know, so far away different than the 23 other because the operators do shift from unit to unit on the 24 thing. 25 And the same thing happened on Catawba and on Oconee (') ) 's/ Heritage Reporting Corporation (202) 628-4888
55 ./'N. kl' 1 -- the same type of programmatic process to get the agreement as 2 to what we needed; and if staff had questions -- if we can use ) 1 3-the questions, we'll try answer them; resolve the differences. I 4-We will negotiate; we can do it on this commitment. 5 We'll tell you which ones we'll do. We've met that. And now, 6 here, by the end of '88, we'll have all done with an exception 7 of one. L 8 And we worked very well in getting it resolved in a 9 reasonable time period. Here we are talking seven years -- 10 eight years after TMI -- relatively short period of time after l 11 the generic order came out. 12 So all these things were discussed in that process 13 that we're going over now. () 14 MR. WARD: I still would like to try to understand a 15 little better. I guess -- this internal design we used - 'your 16 commitment was apparently to face all the HED to do something L 17 about it. 18 MR.. RUTHERFORD: No, first of all we decided to use 19 20 i 21 22 23 24 25 Heritage' Reporting Corporation (202) 628-4888
56 l% kl 1 that scheme or a waiting scheme to decide what we were going to 2 do. We might have had 500 HEDs identified during the 3 . designing. 4 Okay. Now we went in and we evaluated those and 5 weighted those. And we threw out -- I can't remember the exact 6 number, but we came up with, say, 125 or 150 per unit. 7 But we threw out a good many that didn't make the 8 threshold as being worthwhile to do. 9 MR., WARD: Okay. And that's what I'm trying to 10 figure out -- how you're reaching that schedule; how did you 11 define the threshold? 12 We have a PRA for Tony. I don't know if he has some 13 wires or not. Was that used in the process, or is it just 14 experts getting together and thinking about it? 15 MR. RUTHERFORD: 'It was a team approach of operators 16 and designers that evaluated each one of those, and they had a 17 scoring system. 18 And like I say, I can't remember the exact weights 19 and categories they used to score each one of these, but it was 20 a very systematic approach with each one of those people 21 waiting on the individual HED to see whether it passed the 22 23 24 25 O k' Heritage Reporting Corporation (202) 628-4888
I 57 ) 1-threshold. 2 And then, after we had identified those to be 3 implemented, we used a priority method to schedule the j 4 modification zones. 5 MR. WARD: Thank you. 6 MR. RUTHERFORD: Okay. The next item on the list is 7 Item 1.b-2. Ar.d basically, all tnree plants are essentially the l 8 same. 9 The system is installed and operational; the staff 10 has conducted a review; and there have been items identified on 11 each plant where we have some outstanding questions to resolve 12 between us and the staff. 13 MR. REMICK: You indicated they're installed and () 14 operational. Are they being used? 15 MR. RUTHERFORD: They are a part -- 16 MR. REMICK: Operational could be, being capable of 17 being used. Are they actually being used by your operators? 18 MR. RUTHERFORD: Yes. 19 MR. MICHELSON: What is your intention concerning the 20 use of the SPBS in a normal or accident situation? 21 MR. RUTHERFORD: It is one more monitoring tool. 22 MR. MICHELSON: Would your operators use the control 23 board instrumentation or would they go to SPDS to see how .24 things are going? 25 l ) Heritage Reporting Corporation (202) 628-4888
1 l 58 ) 'l MR. RUTHERFORD: -There are some -- 2 MR. MICHELSON: And again, how are your procedures,- i 3 your emergency procedures, written? Do they go over its SPDS' i 4 or.do they only reference control board instruments? 5 MR. RUTHERFORD: He would rely, primarily, on the 6 control board instrumentation. But there are backed up 7 displays associated with SPBS. I don't know whether you're 8 familiar with our -- 9 MR. MICHELSON: Well, is he trained to use the 10 control board then or is he trained to use SPBS, and then if he 11 had a question with SPBS to go and read the instruments in the 12 13 MR. RUTHERFORD: He's trained to use both. () 14 MR. MICHELSON: And are there procedures integrating 15 both, or do you know? 16 MR. RUTHERFORD: Yes. 17 MR. MICHELSON: The reason for asking is that we 18 heard from a different side yesterday. And we were a little 19 surprised to find that they do not use SPDS, even though they - 20 - as near as I can tell, they do not have emergncy situations 21 with SPDS. 22 And I was a little bit surprised because the thought 23 was for SPBS to bring together, into focus, the principal l 24 parameters of watch and so forth when things are happening 25 rapidly and you can't run up and down the bench board checking r (_)/ Heritage Reporting Corporation (202) 628-4888 A _ _ _. _ _ _ _. - - _ ~ - - _ - _..
t 59 1 .this number and_that number. 2 But we were surprised that they don't use SPDS, and I 3 was just wondering what your general intention was, f -. p 5 l 6 8 7 l 8 9 10 2 - 11 12 l 13 14 l 15 i 16 17 18 19 20 21 - 22 23 24 l 25 l 4 !!eritage Reporting Corporation (202) 628-4888
I 60 1 ,/- k-1 MR. RUTHERFORD: Our particular SPDS nesign, as far 2 'as just defining what SPDS is, involves lights. 3 MR. MICHELSON: You have a CRT readout. 4 MR. RUTHERFORD: That correspond to critical safety 5 functions. 6 MR. MICHELSON: I thought you had a CRT display and 7 could hook up the various flow charts. 8-MR. EDERSOLE: Right. And the backup displays are 9 there available to use by the operator, also '10 MR. MICHET. SON: But I was just trying to find out, I 11 just wondered whether it is integrated with the SPDS. 12 MR. GILL: I think we have the STA use the SPDS a 13 bit. () 14 MR. EBERSOLE: Well, their STA used it too,.but the 15 operators didn't. 16 MR. GILL: To check what procedures to follow up on 17 restoration guidelines that Westinghouse should put together, l 18 as to what type of position he's going in and to provide 19 overall guidance to management. ] j 20 An overall view where things go while the operator is 1 21 focusing on valve manipulations, pump manipulations. j l 22 MR. EBERSOLE: Using qualification information, with j 23 300 verifications. 24 MR. GILL: Right. I think we had two sets of l 25 l f~'t k/ Heritage Reporting Corporation (202) 628-4888 i i
61 ()' 1 monitors in the control room, one by the STA and one by the 2 operator. 3 MR. MICHELSON: The SPDA or the SPDS came about 4 before the STA. 5 The SPDS was delayed somewhat. 6-MR. GILL: Initial operators or SROs, they were some 7 senior type of thing. That was almost immediate. I'll get 8 into the SPDS, and we'll go where we are. 9 MR. MICHELSON: I was just very puzzled as to why we 10 .even, after a while, when I listened to one case, where they 11 apparently weren't paying that much attention to emergency 12 action. And I wondered what it was there for, except for an 13 .STA to sit and look at because they wouldn't want to do (~T 14 anything else, y 15 If the control room environment gets that bad, you're 16 out of luck. 17. MR. RUTHERFORD: The next item is II.B.1 on RCS 18 vents. And the only outstanding item there is agreeing on 19 final tech specs on attainment. The vents are installed and 20 operational. 21 Item II.D.1. Basically the three plants are at the 22 same place. The testing was completed a number of years ago, 23 reports submitted. Those have been reviewed by the staff and 24 we have gone through rounds of questions on those reports. We 25 do have outstanding questions on Oconee and Catawba at this l 1 -[ ) Heritage Reporting Corporation (202) 628-4888 l lu
1 l l 62 1 point in time also. 2 The next item is II.F.1, Accident Monitoring. l 3 McGuire and Catawba are complete. And here again, the only 4 thing outstanding on Oconee is agreejng on the final tech specs 1 5 for those monitoring aspects. ) l 6 Item II.F.2, Instrumentation for Detection of I i 7 . Inadequate Coil Cooling McGuire and Catawba are complete. 8 MR. MICHELSON: Can I interrupt just a minute. On 9-Oconee instrumentation for coil cooling, did you install a 10 vessel water level indication on Oconee or did you install a 11 hot link level indication? k 12 MR. RUTHERFORD: Both. 13-MR. MICHELSON: Both. They're the only one I guess O 5/ 14 that has vessel on the B&Ws, is that right? 1
- 15 MR. RUTHERFORD:
Is that right, Paul? 16 MR. MICHELSON: See the B&W -- I thought in the J 17 resolution that would just be hot linked, but yours is true l l 18 vessel level indications. i ) 19 MR. GILL: I believe everyone has a vessel level l 20 indication. 21 MR. MICHELSON: Not on B&W. 22 MR. GILL: Arkansas has a different design, but it's 23 still a vessel level. i 24 MR. MICHELSON: But it's truly vessel level? 1 25 MR. EBERSOLE: South Texas went to the CD, for their ) i 1 s. Heritage Reporting Corporation l (202) 628-4888 l
1 j 1 1 63 1 /~T j \\l 1 Westinghouse plant. 2 They're pretty. careful. I've had to figure out why-3 they do that because it's very controversial. 4 They recently had this half price operation -- what-5 do you want to do about that half price operation? Are you 6 aware of what I'm talking about? 7 MR. RUTIIERFORD: That's the issue of the recent 8 generic letter? 9 MR. EBERSOLE: At the time, I was shocked because 10 they disconnected most of the instrumentation they had, but 11 then I could see part of the reason why they had to do that. 12 MR. RUTilERFORD: When you take off the head, you have 13 to take off the instrument. 14 MR. EBERSOLE: On the other hand, you don't need that 15 connection any more, and the bottom might work by itself. 16 MR. RUTHERFORD: Well, and tco, you need a finer 17 instrument. 18 MR. EBERSOLE: That's pretty final. 19 MR. RUTHERFORD: We have leveled instruments. 20 MR. GILL: We had sone low pressure transmitters. 21 MR. RUTHERFORD: You have to valve in some level 22 instruments for that purpose. He at one time, I think, used 23 tag-on tubing, but I think we're away from that on all our 24 plans now. l 25 MR. EBERSOLE: I guess the thing is you set up safety Heritage Reporting Corporation (202) 628-4888
64 A 1 grades. .1 2 MR. RUTHERFORD: It is not safety grade level. It is 3 reliable instrumentation. 4 MR. EBERSOLEt It is hard piped in, though. j l 5 MR. RUTHERFORD: Yes. 6 MR. GILL: But it's only used for low temperature, 7 low pressure. 8 MR. MICHELSON: But we knew exactly how to do it at j 9 that time and recognized that something had to be done while we 10 worked on something better. You're saying the something better 11 never got worked on. Is that what you're saying? 12 MR. WARD: It's a pretty fundamentally important 13 parameter. I guess I was surprised to think there might be a () 14 better approach. 15 MR. RUTHERFORD: Well, this is another item where we. 16 disagree with the importance of the instrumentation, and you'll 17 see on a later slide, I've got this one in the category of at 18 least our perception anyway, and this has been backed up by 19 some PRA type work that we've done also. Had we been left to 20 our own devices, we would not have installed the instrument. 21 MR. MICHELSON: What would you have done? 22 MR. RUTHERFORD: The training of'the operators, the 23 use of sub-cooling core exit kernel couples we felt was 24 sufficient. 25 MR. EBERSOLE: Core exit tells you you're already in Heritage Reporting Corporation (202) 628-4888
l 65 i k)s 1-trouble. 2 MR. RUTHERFORD: And sub-cooling does also, of 3 course, much earlier. And if the operator would have taken all 4 .possible actions by that point in time, then he's not going to 5 be taking actions off of a vessel level. 6 MR. MICHELSON: The problem always was misleading to 7 the operator by other indications which seemed to indicate 8 everything is all right, so that cuts off the safety 9 injunction, whatever, and then you talk about training 10 operators. But we can't train operators for what we haven't l 11 foreseen yet. That's when the vessel level indication may very 12 well save the day, in the events you haven't even foreseen yet 13 that you might even get into. You can't train an operator for (O _/ 14 those. He has instruments to go by, and help him along, give .15 him the basic instrument. 16 MR. RUTHERFORD: We can debate that issue ad 17-infinitum. 18 Okay. Next issue. II.K.3.5 the Auto Trip of Reactor 19 Coolant Pumps. That issue is complete on McGuire and Catawba. 20 On Oconee the generic analysis has been approved and the plant 21 specific information has been submitted to the staff for 22 review. 23 II.K.3.31, McGuire and Catawba are complete. Oconee, 24 the small brake loca analysis has been submitted to the staff '5 for review. 2 r~%J Heritage Reporting Corporation (202) 628-4888
l l l I 66 n 1 1 III.A 1.2, McGuire and Catawba are complete. Oconee i 1 2 we have an interim EOF in use at this point in time. Late in i 3 1988 we will have our permanent facility in operation. 4 III.D.3.4, Control Room Habitability. We have few 5 modifications remaining to be done on that system. Also the 6 staff review is still outstanding on this issue on Oconee. 7 MR. EBERSOLE: In this morning's discussion we were-l 8 talking about various stages of degradation of the plant. We 9 looked at the equipment qualification problems of PRAs, and one 10 of them was 1:~.at core containment test failed but the core and 11 the vessel are okay. That included the spectrum of events 12 after our loca -- you know, effective operations. 13. I wondered if there was a very large source current, (~(j) 14 because the containment had failed. But you still had enough 15 of a core. 16 You are not currently required to look at that source 17 current. That's a very large source current. You know, the i 18 whole concept was to have a large core damage and seal it all 19 up in containment. 20 MR. RUTHERFORD: Right. It depends on what that ) 1 21 source term is. .22 MR. EBERSOLE: You're supposed to calculate that. 4 23 That ought to be available. You know, it's the consequential l l 24 level of damage. 25 MR. RUTHERFORD: Yes, in the design basis but as far k-Heritage Reporting Corporation (202) 628-4888 1 1
67 1 as containment failure associated with that -- in terms of 2 keeping the frontal area pressurized, that aspect of it, yes. 3 MR. EBERSOLE: I don't think it's your design basis. 4 But it's come as a sort of a gratuitous designing? 5 MR. RUTHERFORD: I think for McGuire and Catawba that 6 is probably true. For Oconee, we hava a very old system and 7 we've had to do some things to that system to ensure 8 pressurization. 9 MR. EBERSOLE: Room filters. 10 MR. RUTHERFORD: And that type of thing. Not through 11 filtration, but through keeping the area pressurized. 12 MR. REMICK: As a general observation, Oconee seems 13 far less complete than others. Is there a reason? Is it () 14 because it's an old operating plant? 15 MR. RUTHERFORD: All of the above. Being an older 16 plant, a B&W plant, having a larger backlog of modifications on l 17 that plant. All.those things contributed to Oconee being 18 slightly behind. But I think if you look at a lot of these 19 issue it's not hardware related, we're down to, alas, to the 20 administrative-type issues versus really impacting the design 21 or operation or procedures of the plant. In that respect, 22 Oconee, McGuire and Catawba are very similar, I think. 23 MS. POSTIS: To give you the staff's point of view, 24 if I may -- what you see here is the answer to your question is 25 yes. What you have for McGuire and Catawba is the benefit of O IIeritage Reporting Corporation (202) 628-4888 L
i 68 j - ([ ) I their coming into a license that is a motivation to resolve the 2 issues. With Oconee being older and if you do have'to backfit, 3 solutions are not as easy. The staff tries to talk and has a 4 lot of meetings to resolve the issue in a manner that is 5 agreeable to both, when you do have discussions. B&W was the 6 last to receive a safety evaluation. 7~ MR. REMICK: Was that because of the staff inability 8 to come to a resolution themselves on what was satisfactory? 9 MS. POSTIS: On small brake loca? We were working 10 with the owners groups. It was a matter of scheduling 11 resources, interacting with owners groups, and questions and 12-answers to our questions and interactions like that. 13 MR. RUTHERFORD: We also had the test -- you're (} 14 familiar with the Miss. facility, Otis facility, that B&W 15 plants did not have perhaps quite the data that Westinghouse or 16 other plants had. l 17 MR. REMICK: Were any delayed because of staff having 18 difficulty coming to something acceptable in their own minds, 19 and B&W plants paid particular attention to that and therefore l 20 the staff needs to be more careful. 21 MS. POSTIS: In some cases where an older plant like 22 Oconee, you can't check it off and you do have to use your 23 judgment, then it does come into a factor that you have to 24 25 ( j-Heritage Reporting Corporation (202) 628-4888
69 kJ-1 review it individually, the plant itself, you can't just 2 enclose it in a vacuum. 3 What you do see in that respect though is something 4 like a second area where you have technical specifications that 5 are required, and the staff-has issued guidance like standard 6 technical specifications for the attorneys to follow and 7 McGuire and Catawba have adopted those for getting a license, 8 but some like Oconee that has custom-made tech specs, the i 9 standard is here, Oconee proposes this, we want'this somewhere, 10 and we come to the middle. And that's the big area where we see 11 to try and come up with the standard technical specification 12 for Oconee that everyone agrees on. So in that case, the staff 13 tries to recognize that we need this, but at the same time, 't3 's_/ 14 being consistent, and that's what we're facing there in the 15 second aren. 16 The third area I think is simply modifications that 17 need to be physically impleranted in the plant, and it is never 18 prioritized. But I.think if you want to pinpoint it to one 19 area it's either by being an old p; ant, in some cases, and a 20 B&W plant. 21 MR. WARD: That's an interesting point. But it 22 sounds like at least one of the reasons, and a big one, was 23 that the staff just had 6 bigger club. 24 Let me ask the people from Duke. Do you think that 25 the resolutions that are being reached for Oconee are better Heritage Reporting Corporation (202) 628-4888
1 P 70 e ,{s) 1 ' quality, or merely optimized from some sort of cost beneficial '2 standpoint,.than those that you.did under the PLUS? Have'you ~ 1 3 had more time to negotiate what might be received as.more 4 sensible notions? 5 MR. RUTHERFORD: For the most part,.I'm comfortable 6 -with what we did on all three plants. I think where we had 7 differences of opinion -- let me give you an example. Back up 8-to accident. monitoring, and the tech specs on accident 9 ' monitoring. We disagree with the standard tech specs,.if you 10 will,. action;to shut down a plant, if you have some of this . 11 instrumentation, and if it is secondary type instrumentation, ' 12 it should not requires a plant shutdown. 13 On McGuire and Catawba, like you say, the f3 14. circumstances at that point in time didn't give us the x.). . 15 flexibility of negotiation at that' point. But those are - 16 relatively minor things in the overall context. Other than 17 some issues like that, I'think we did things pretty constantly 18 'across the board'as-far as'all those plants are concerned. - 19 When you get into the big areas like design review or Reg. .20' Guide 1.97,.those kinds of issues that impacted the plants as 21 far as modifications, emergency procedure development, that 22 type of thing was done essentially the same way across the 23 board. . 24' MR. WARD: Well, again, the case of Oconee, was there 25 'more opportunity or did you do more integration of responses? L .q. Ij Heritage Reporting Corporation (202) 628-4888 ~ l*
4 y 71 1. Was it possible to do one engineering project to provide a 2 resolution of several issues? 3 MR. RUTHERFORD: Well, I think the biggest thing 4 we're done as far as integration on our plants here again was 5 done across the board as far as the standby shutdown facilities 6 where we provided an integrated approach to resolving several 7 past and hopefully issues on all the plants. But I can't point 8 to any one thing. Certainly on a plant under construction like 9 the Catawba, and we've already talked about that, on 10 implementing modification of Reg. Guide 1.97 or program HEDs, 11 it's a lot easier just to go into the control room and do it 12 all at once while you're not operating, versus on an operating 13 unit where you've got to stretch things out. There have been (_) 14 those kinds of differences. But I don't know that as far as 15 taking the integrated approach or anything like that that we've 16 done anything differently on Oconoe than any other stations. 17 Okay. The last item is Reg. Guide 1.97. We are at 18 essentially the same point on all three stations. There are 19 some differences as far as implementation schedules, but staff 20 has reviewed our responses. There are some outstanding items on 21 each plant to resolve. This involves issue as to whether 22 certain instrumentation ought to be environmentally qualified, 23. etc., those kinds of issues. 24 The next slide I have is really just a small list of 25 typical other issues that we have open on each of the plants l ~/ 'T \\> Heritage Reporting Corporation (202) 628-4888 L- - ---- o
-i 72 () 1 and this list is by no means complete but it does hit soue of 2 the bigger item at least in terms of generic letters and 3 bulletins. 4 I'm not going to go through that in detail, but you 5 can see 83-28 and 87-06 and 87-12 as far as generic letters. l l 6 Bulletins, the MOV torque switch settings is a big ticket item 7 for each of the plants. We are addressing an item that meets 8 not only the scope of the bulletin but we're looking at all 9 safety-related valves at all the plants. So that is going to 10 take us a bit of time to work through that large number of 11 valves. You can see some of the other bulletins there. 12 Then we have of course a laundry list of plant 13 specific items. We have a number of tech spec changes O 14 " tete"ai"9 " eeca t the ete"te, teca erec che"9e rea"e te-15 ISI and IST programs on relief requests, exemption requests for 16 Appendix R and then a number of commitments that you might find 17 in licensee event reports or responses to violations where we 18 committed certain actions or modifications, procedure changes, 19 etc. 20 MR. EBERSOLE: Let me ask you a question. Appendix 21 R, in South Texas we have an interesting problem. The old GDC 22 19 required that you operate the plant from a point outside the 23 control room. Willy-nilly, the industry ran out and put the 24 extension cords in the terminal boards in the control rooms, 25 ran out in all sorts of places and put switches. And then thus () Heritage Reporting Corporation (202) 628-4888
73 l \\.. 1 extended the fireball locus from where it was to all these L 2 extended places. In short, they made the fireball worse-3 because they've now extended the boundary of the locus. When 4 they finally did come in and put in the Appendix R requirements l 5 to fix it, from an isolated shutoff, they didn't disconnect all l 6 that other traffic, so there it stands as a sort of example of 7 ineptitude and something that ought to be taken out. 8 What would you all do? 9 MR. RUTHERFORD: Well, we still have the shutdown 10 panel outside the control room, but our standby shutdown 11 facilities are isolated, totally isolated from the plant, and .12 independent in and of themselves. So we make sure that we do 13 provide that isolation. ( 14 MR. EBERSOLE: Well, let me get back to my -- do you 15 still have the extension cords? 16 MR. RUTHERFORD: Yes. 17 MR. EBERSOLE: Don't you regard them as an 18 instrumental hazard? Because you can go out and mess them up i 19 with any kind of industrial accident and literally extend the 20 vulnerability of the control room to distant places. 21 MR. RUTHERFORD: Well, you've still got the backup, 22 the standby shutdown facilities, and the shutdown outside the 23 control room would still be useful for certain scenarios, and 1 24 would be preferred, rather than going to the standby shutdown 25 facility in our particular case. O Heritage Reporting Corporation (202) 628-4888 i
f L: I 74 () 1 For Oconce, of course, it handles a number of issues 2 for us, as far as a backup for Appendix R purposes, for 3 security purposes, for station blackout purposes. 4 MR. EBERSOLE: Does it extend security vulnerability? 5 MR. RUTHERFORD: No, it reduces it. 6 MR. EBERSOLE: How does it do that? 7 MR. RUTHERFORD: You don't have to have as many vital 8 areas. 9 MR. EBERSOLE: I thought the interpretation was it 10 extended the circuits off to distant places from the control -11 room. That's about the greatest level of damage you could 12 invoke. 13 [} 14 15 16 1 17 18 19 i 20 21 22 23 i 24 l 25 ) () Heritage Reporting Corporation (202) 628-4888 l l
1 1 1 75 j r" 1 MR. EBERSOLE: I think as though they probably'are 2 negative. 3 MR. RUTHERFORD: We would certainly disagree with 4 you. 5 MR. EBERSOLE: You would like to have that there for 6 what purpose? 7 MR. RUTHERFORD: For OCONEE, of course, it handles a 8 number of issues for us as far as the backup for Appendix R 9 purposes, for security purposes, for station blackout 10 purposes -- l 11 MR. EBERSOLE: Does that extensive curtain overhold l 12 it? 13 MR. RUTHERFORD: No, it reduces it. O) ( 14 MR. EBERSOLE: Does it? How does it do that? 15 MR. RUTHERFORD: You don't have to have as many vital 16 areas. 17 MR. EBERSOLE: Well, I thought the interpretation of 18 B-19 wasn't to extend the circuits -- so if the skunks walked 19 through it you didn't have to smell it. That's about the l 20 greatest level of damage you can invoke. You did have single 1 21 channels there. 22 P,ut in so doing you extended the damage lovel. 23 MR. MICHELSON. It really didn't do the system's 24 interaction -- 25 MR. EDERSOLE: No. It was just a blind adherence -- O Heritage Reporting Corporation (202) 628-4888
l 76 ] 'l MR. RUTHERFORD: Well, if the function is what was 2 assumed -- 3 MR. EBERSOLE: It was just a blind adhertnce to the 4 AC19s. 5 MR. RUTHERFORD: Well now when you said you felt 6 stand-by shut down facilities were a detriment -- 7 MR. EBERSOLE: No, no. That's what you call the old 8 original. 9 MR. RUTHERFORD: Oh, okay. I misunderstood. 10 MR. EBERSOLE: No,, no. 'll MR. RUTHERFORD: I was thinking of our stand-by shut 12 down facility -- independent -- 13 MR. REMICK: Oh, that includes -- () 14 MR. RUTHERFORD: -- stand-by shut down. 15 MR. EBERSOLE: -- the one you had to put in to cope 16 with the fires. 17 MR. RUTHERFORD: Right, and other things. 18 MR. EBERSOLE: And the ones you had preceding that 19 were just kind of a sleazy interpretation of GDC19. I think 20 those are the ones I'm talking about -- 21 MR. RUTHERFORD: Okay. 22 MR. EBERSOLE: -- that ought to be stripped out. You 23 follow me? 24 MR. RUTHERFORD: Yes. Oh, yes, I understand what 25 you're saying. And here again, I think they're still useful ,.] Heritage Reporting Corporation (202) 628-4888
77 1 though for certain things. 2 MR. EBERSOLE: Well, is their use value capable of 3 contradicting their expenses -- 4 MR. RUTHERFORD: I can't really -- 5 MR. EBERSOLE: I'm almost sure what you'll find out. 6 MR. RUTHERFORD: -- give a response to that. Jim -- 7 Jim's perspective for you here. We've been discussing the shut 8 down outside the control room, the panels that wt have and 9 whether those offer some vulnerabilities in addition to the 10 benefits that they might have. 11 You may want to elaborate. 12 MR. EBERSOLE: They lost their primary purpose. You 13 have to really address the fire issue. ) 14 MR. THOMAS: I guess I'm not totally agreeing with 15 the -- 16 MR. EBERSOLE: Well, now I don't have to have some 17-damage just out in the control room; I could have it out where 18 we put these switches, you know, cause that would tell it. 19 You break critical control functions distributed in 20 any kind of a random way out in the plant, to cope with the 21 fact you -- as you just mentioned -- you couldn't stand the 22 smell in the control room but there was no damage in there. 23 MR. THOMAS: Of course one design concept is to make 24 them operative. You've got to transfer them from the control 25 room. i Heritage Reporting Corporation (202) 628-4888
78 ] ()l 1 MR. EBERSOLE: Yes, there were reasons,.though, that 2 we originally thought they were going to handle them like that. 3 So in putting in an extension cord you accomplished what you 4 couldn't have done by putting on masks. As a matter of fact,. 5 you made it worse. 6 MR. THOMAS: It is inoperable, the transference. 7 MR. EBERSOLE: Wait a minute. .It was in a loop, a 8 physical loop. 9 MR. MICHELSON: That'is why you could not use it. 10 MR. WARD: That is the old system. 11 MR. RUTilERFORD: Well, they left-it in and it 12 increases the vulnerability. 13 MR. EBERSOLE: Yes. () 14 MR. RUTHERFORD: For the safe shut-down facility, you 15 have that kind of transfer. 16 MR. EBERSOLE: You do now, but you did not before. 17 MR. RUTHERFORD: But for the other old facilities, 18 there is really not any transfer in there. 19 MR. EBERSOLE: I think that you will find that it is 20 just sort of the residual pieces. 21 MR. WARD: Those are left in, because there are 22 certain scenarios that you can think of that would be useful, 23 is that the idea? 24 MR. RUTHERFORD: Right. And you have the ability to 25 control' normal plant equipment from the panel, versus in our () Heritage Reporting Corporation (202) 628-4888 l
79 .(- 1 case as compared to the standby shut-down facility, you are 2 putting light water in the generators and that kind of thing 3 -that you would like to avoid. 4 MR. EBERSOLE: I think that you ought to atrike a S balance. 6 MR. MICHELSON: Generally, they were better 7 instruments and so forth that prevented shut-down. The prior 8 shut-down panel allows a lot of running around. 9 MR. WARD: Yes. i 10 MR. THOMAS: The only point that I was trying to make 11 is that I think that there has to be a plant by plant 12 evaluation as to whether it really degraded safety. And since 13 it has to be considered in the Appendix R review, then it may 'O (_/ 14 make the Appendix R review more difficult, and you end up with 15 more things to resolve, and you may still end up with more 16 safety benefit than detriment. And I think'that I was probably 17 leaning that way. I would have to agree with you that there 18 could be some hang-over that might suggest getting rid of it. 19 MR. RUTHERFORD: Are there any other questions on 20 that subject? 21 (No response.) 22 MR. WYLIE: Proceed. 23 MR. RUTHERFORD: I would like to bring up Bob Gill, 24 and Bob will talk about some of our experiences in implementing 25 issues. O' Heritage Reporting Corporation (202) 628-4888 s
( I 80 () 1 MR. GILL: I have been with McGuire licensing for 2 approximately three of our years, I have lost track. And 3 before that, I was in licensing. So I have been through a 4 number of issues and attempts to resolve them. And I thinh 5 that the number one bullet here and I think that it has been 6 communicated earlier today is that communication is the key. 7 Looking back for the past few weeks in trying to put 8 this presentation together, we saw successes that were 9 indicative of communication within the industry, before the 10 industry and the staff, and even within the staff. And we saw 11 in the poor implementation history that there was a lack of 12 communication, establishing requirements and then attempting to 13 implement something, and then coming back later and adjusting O 14 it etter it "ee e1reeer dee" 1"ete11ea-15 This has led to two basic processes that the staff 16 has used, and I have got several examples attached that I will 17 go through. I would like to cover the post-implementation 18 review type process, and some of the problems that I have seen 19 and we have seen at McGuire in particular associated with this. 20 The three broad categories include changes in the NRC 21 interpretation of what the original requirement was. This is 22 where we thought that we had reasonable acceptance, and then 23 actually put the item in and then found out that we did not. 24 In many cases, changes were different with NRC 25 reviewers. That includes a LLR reviewer versus a regional A(,) Heritage Reporting Corporation (202) 628-4888
i 81 () 1 inspector-who comes in and says I am not quite sure that I like 2 what you are doing. 3 MR. MICHELSON: 'Is the situation getting better or l 4 worse? i 5 MR. GILL: I think that it is getting better. l 6 MR. MICHELSON: If.it is getting better, why do you 7 think that it is better? You know, I might speculate that it 8 is getting better, because the NRC is not paying as much 9 attention anymore. That would be one reason, and you would 10 have less problem with them. 11 MR. GILL: Well, as I go through the examples, you 12 will see recent history where we worked on that. 13 MR. RUTHERFORD: I think that one of the biggest l( ) 14 reasons is the number of issues on the table now is more 15 manageable than it was three, four, five years ago. And I will 16 talk a little bit more about that later We are in a situation 17 where we are trying to handle these issues, and that gets to be 18 very difficult for us and the staff. 19 MR. MICHELSON: Well, you pointed out about NRC 20 reviewers and also resident inspectors. There is quite a 21 difference now in resident inspections. 22 Is that helping the situation, or are the resident 23 inspectors just adding confusion to the issue? 24 MR. RUTHERFORD: Well, I think that resident 25 inspectors are a plus as far as knowing the thing, knowing the () Heritage Reporting Corporation (202) 628-4888
l 82 llh 1 problems, and being able to communicate with other parts of the 2 NRC. I think that they are a plus. 3 MR. MICHELSON: The NRC reviewers, you say that there 4 are changes in the reviewers. I thought that there were also 5 changes for the better. 6 Is it getting better? 7 MR. RUTHERFORD: Well, when Bob said changes in the 8 reviewers, we had an issue like on the emergency decision where 9 we changed reviewers four or five times. Not that one was any 10 better or worse than the other. It was just that he had to 11 come up and see, and he had a whole other agenda and questions. l l 12 MR. MICHELSON: So by the time that he arrived, he 13 left again. ll) 14 MR. RUTHERFORD: Right. 15 MR. GILL: The staff reorganized, and we had an 16 exchange fellow from Finland. And he came in for a year, and 17 took over doing the job. You know, a number of things like 18 that causes a delay. Reorganizations and shifting of 19 assignments and priorities cause delays. It is usually more 20 effective if we can work together to resolve it in a reasonable 21 period, say a year or two., 22 MR. MICHELSON: In spite of this, it is still getting 23 better? 24 MR. GILL: I think so. And I will show you some 25 examples of how I think it has. llh Heritage Reporting Corporation (202) 628-4888
4 l 83 - ("> -). 1 MR. WARD: But it sounds like it is getting better ~ 2 just because the job is smaller. 3 MR. GILL: Things are getting behind us. 4 MR. WARD: Not because there has been any systematic-5 improvement in the process. 6 MR. MICHELSON: Well, there is that possibility. 7 MR. WARD: Well, that is what he is saying. 8 MR. MICHELSCN: That is what he is saying. But I 9 think that in and of itself is certainly good. 10 MR. WARD: Well, if there are not any issues of 11 communication, it would not matter at all. 12 MR. MICHELSON: No matter how good your organization-13 is, you can always handle certain issues at any point in time. ()- 14 I.think that is the biggest problem that we have. 15 MR. WARD: Bob, you started saying communications is 16 the key. You do not have to go back. But you threw out a 17 number of words, something about coramunications in the industry 18 and so forth. 19 MR. GILL: Right. 20 MR. WARD: Are you going to be talking about that? 21 You seem to be zeroing in really on the internal NRC 22 communications. 23 MR. GILL: No. I think that is one element of it. 24 Let me show you some examples of where we have had successes. 25 And as Jim pointed out earlier, SQUG, that is an industry b \\- Heritage Reporting Corporation (202) 628-4888
84 () 1 effort where there was communication within the industry to 2 come up and work with the staff on a generic solution. 3 I have seen it vith the B&W owners group working with 4. the staff on an owners group level. I have got a couple of 5 examples here on Westinghouse specifically. The Westinghouse 6 owners group has come up and communicated a solution to the 7 ATWS-AMSAC issue. I do not know if we want to go into that or 8 not, but communicated a solution to that issue. And that 9 helped facilitate getting implementation through as opposed to 10 thirty-some utilities with Westinghouse designs coming in 11 individually trying to do the same thing. That type of 12 communication within the industry coming up with generic 13 solutions to generic problems helps. f') 14 MR. MICHELSON: Well, if that is the thing that v 15 helps, then I am a little surprised that you do not have an 1 16 owners group with as many problems. 17 MR. GILL: We do. 18 MR. MICHELSON: You have got an owners group now? 19 MR. GILL: Well, that is one of our committees in the 20 B&W owners group. 21 MR. MICHELSON: Oh, yes. B&W is the not the only 22 kind of plant that has got those problems. There is nothing 23 unique there. 24 MR. GILL: There was a NUMARC coordinated effort. 25 MR. MICHELSON: It has been piecemeal in many () Heritage Reporting Corporation (202) 628-4888 l
85 ' (~. 1 respects. 2 MR. GILL: There is an industry group that addresses 3 check valves. 4 MR. MICHELSON: And it is in bits and pieces, and it ~ 5 is still is not a major effort. And it would seem to me that 6 the industry would have gathered together by now and have an l 7 owners group. Nothing seems to have, and it is a major 8 problem. You spent, I am sure, a great deal of money. And yet f j 9 I do not see you working with the NRC to get some of questions 10 resolved and so forth. That is just a side comment, because I 11 am a believer in owners group too. And I am surprised that one 12 has not appeared, and I am just to see~if I can solicit'any '13 response positively or negatively. In other words,-why is it ) 14 not a good idea or why is it a good idea. Just go back home 15 and push it among your colleagues. 16 MR. RUTHERFORD: In the future, NUMARC is going to be 17 able to provide a little bit more leadership. 18 MR. MICHELSON: Yes, NUMARC is one place. It is 19 something in your own best interests. 20 MR. RUTHERFORD: NUMARC is a vehicle to pull together 21 some of these things. 22 MR. MICHELSON: Thank you. l 23 MR. G1LL: On the next slide, I just want to give i 24 this example of a situation with the electrical system vents 25 that were installed with wire, and how a change over the years I .O Ileritage Reporting Corporation j (202) 628-4888 j
86 (' 1 caused us to have to iterate. 2 Originally, the design was described in the. licensing 3 process and actually reviewed and approved prior to licensing. 4 It was contained in the SER. 5 And subsequent to that, the generic letter on the 6 model tech specs came out with a surveillance requirement to 7 verify flow. Well, that had not been part of the original 8 design criteria 2(b)(1). One would think that you would want 9 to do that anyway. But it certainly was not built into the 10 design for flow verification of sorts. 11 The staff was open to suggestions as to how one would 12 so that recognizing that these are about one inch lines. They 13 are not real large flow lines. It is a steam-air-water mixture () 14 going there as you vent off the system. And you certainly 15 cannot do it under design basis conditions. You do it 16 typically during start-up as you are fueling and venting the 17 system. 18 In addition, the technical reviewer when we went in 19 with those tech specs had questions on the piping design and i 20 the flow losses, and wanted to go back and reengineer the j 21 system for us. 22 Fortunately, we were able over time to work out the 23 details using a temperature probe type monitoring system to 24 monitor the hot fluid as it goes through to verify that the 25 piping was not clogged. The valves themselves are cycled I Heritage Reporting Corporation (202) 628-4888 t ._ __________ a
87 p[ (, 1-periodically, so we know we have the system there. 2 This is a case where the original requirement came 3 out that there was not any provision for the periodic 4 verification that the system was. going to work, and that did 5 not come to pass until the generic letter came out. And'had we 6 known that earlier, we might have been able to do a better 7 design process and cover all of that in there. 8 Fortunately, we just closed that issue out here in 9 October, and that is some seven years after the original 10 requirement. That is an example where the requirement really 11 evolved with time. And fortunately, there was not much of a 12 hardware change to fix on that. 13 This is a case where the sampling system, which you r' (_)s 14 may be familiar with, at the Duke plants and some of the 15 generic design. We designed the system to provide the ability 16 to obtain direct control in the event of a core accident. And 17 it was not intended to do so under normal plant operating 18 conditions. 19 We have the original design described in the 20 licensing process. And at McGuire, they determined that it was 21 acceptable. And in April of 1981, prior to the first unit 22 reaching full power. And then we had a post-implementation 23 inspection in April of 1984. And the regional inspector, not 24 the resident, but a regional inspector came by, and said I do 25 not think that your system is operable, because you have not Heritage Reporting Corporation (202) 628-4888
88 T-/ 1 demonstrated it by taking periodic samples of testing the error 2 analysis for the various things that you had to monitor, and 3 how accurate they were. 4 And the simple problem is that'under degrading core 5 conditions that you have quite a bit of activity, when you have 6 to dilute it. We originally diluted one part to a thousand to 7 cut down. But when you have normal operating conditions, you 8 do not have that much activity, or hydrogen, or anything else 9 in there. So when you dilute it that much, you cannot see it 10 and you cannot get good results. 11 We ended up changing the dilution factor to be able 12 to accommodate the acceptance criteria contained in the 13 original design. The negative on that is that it adds a little I) 14 bit of dose to the operator, the HP, the technician taking the 15 sample. 16 Again this was not part of the original design. It 17 was something that we had to go back and do in order to prove 18 that the design would work under normal conditions or under 19 accident conditions by taking samples and monitoring under 20 normal conditions. 21 MR. REMICK: What was the basis for that regional 22 inspector requiring that? 23 MR. GILL: Well, the numbers are in, the plus or 24 .minus five percent, and 50 ppbs, and things like that are in 25 the criteria. The problem is that when you take a normal lleritage Reporting Corporation (202) 628-4888
i 89 (~ 1 sample and you dilute it that you get all kinds of errors 2 scattered. Because you do not have much activity in there, and 3 you do not have much hydrogen. And when you dilute it, it just 4 falls apart. 5 So he was saying that you were not meeting the 6 requirements, that all you had to work with was normal plant 7 system cooling. And obviously, we are going to'make an 8 accident to do that. So we had to compromise on that. 9 We thought that we had a good design that had 10 reasonable confidence. We had some test conditions set up by 11 that to do that. But we just did not have the monthly or the 12 periodic test data to show that. 13 So that was a problem again with a change or (). 14 reviewers or a change in criteria, and things like that. It 15 might have been thought about had we not gone'so fast in 16 putting that system in. 17 The last item that I would mention is back-fit 18 considerations. And we have had a long history with the safety 19 parameters system at the Duke stations. I will not go through 20 all of these. But suffice it to say that we put the system in 21 prior to operation on McGuire and Catawba. And inspectors came 22 in afterwards and said that it did not meet the original design 23 criteria. 24-And we have gone around with the staff on that. We 25 had an outside audit here at Catawba in 1985. And then they Heritage Reporting Corporation (202) 628-4888
[ 90 () 1 came back this summer on-McGuire. We have a number of open 2 issues, and it has been mentioned earlier on that thing. But 3: again it is the interpretation of what the original 4 requirements were, what the use of it is, who is supposed to 5 use it, how does it interface with other plant systems, and a 1 6 number of things like that where we felt that we had met the 7 criteria and the best interests of the operators in interfacing 8 with the emergency response guidelines that were developed. 9 And the staff was coming in after the fact saying, 10 well, you should add a few more lights, and charts, and things 1. like that to meet fully the requirements. And we said what, 12 yea are coming in now after the fact, after we have had the 13 license approved, and we lost our appeals. 14 Let me'see, Robert, you had the phone call last week, [} 15 right, trying to resolve this? 16 MR. SHARP: Yes. 17 MR. GILL: Is it resolved? 18 MR. SHARP: I think that we have pretty good 19 agreement with the staff at this point. They are waiting for 20 the formal submittal to give them all of the details. 21 MR. GILL: Okay. Again it is a place where we have 22 tried to communicate after the fact of here is what we have, 23 here is why we feel this way, and it sure would have been nice 24 if we had had all of this settled beforehand. Although we do 1 25 have it in place, and it has been operational for some time. () Heritage Reporting Corporation (202) 628-4888 i .______-__a
l' l 91
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MR. EBERSOLE: Are you pushing for prescriptivity? l 2 MR. SHARP: Well, that was part of the problem with l-3 this issue. If you look at the early guidance on this, some of 4 the first documents on that slide, it was simply a concept. 5 That we should not have a safety parameter system, and it was 6 left up to the utility to come up with the design. And some of 7 the later documents that came out did have slightly more i 8 -guidance, but every time the guidance became,much more 9 prescriptive. 10 But what was happening is that we had to implement 11 this on a schedule that we had to set out design and go about 12 installing in on a schedule. Meanwhile, the staff is working 13' on their idea. The details are becoming more and more i 14 prescriptive in later regulatory documents, such that at the I 15 time that we have it implemented that the staff does not 16 consider that our system meet their criteria at that point. So 17 we just diverged in our point of view. 18 MR. GILL: Many times they will go to a number of 19 plants and see what that utility has implemented, and start 20 comparing notes and picking up a hybrid of everything that they 21 liko that is good, and then that becomes the new standard by 22 which you have to bench mark. 23 MR. EBERSOLE: That seems that that ought to be a 24 case for the industry to get its head together and address the 25 standard interpretation. l Heritage Reporting Corporation (202) 628-4888 l l
92 O k/ 1 MR. GILL: The first time right up front, 2 MR. EBERSOLE: Right. 3 MR. GILL: Unfortunately, we could not do that in the 4 = licensing process. Because you had license conditions or items 5 that you had to get in in order to get your licensing. That is 6 what we would call the pre-implementation review type process. 7 MR. RUTHERFORD: Let me address that issue a little 8 bit, Bob. 9 MR. GILL: Okay. 10 MR. RUTHERFORD: I was going to later anyway. But as-11 far as being prescriptive or not, I guess that people say 12 different things at different times. I am not in favor of 13 prescriptive regulations, but I am in favor of the industry and () 14 the staff working together as best they can to define things, 15 whether that comes out of the regulatory guide or some other 16 vehicle. I do not have any problem with that, as long as we 17 have dialogue to arrive at some understanding. 18 MR. THOMAS: The conflict is that the guidance is 19 relative and it is to be non-prescriptive. The review in the 20 final granting of a safety evaluation also should be 21 non-prescriptive. What happens is that they get prescriptive, 22 and the purpose of the guide to start with is totally lost. 23 MR. RUTHERFORD: There you get into individual 24 reviewers and what they think is necessary. 25 MR. MICHELSON: It is also the problem of individual Heritage Reporting Corporation (202) 628-4888
93 1 utilities, no two of which necessarily see the same problem the 2 same way. Now the staff has to sit down with fifty different 3 . licensees and try to figure out what to do. And-they kind of 4 give up and they write a prescriptive one. It has much better 5 lately. 6 At least the utilities are trying to get into owners 7 groups which I think the utilities will back. In'other words, 8 what the owners groups work out, the utilities agree to do 9 individuals. But in the past, they just did not exist, and 10 then the staff had to deal with fifty individual ideas. 11 (Continued on next page.) 12 13 4 14 15 16 17 18 19 20 21 22 1 23 l 24 25 11eritage Reporting Corporation (202) 628-4888
1 94 -1 MR. MICHELSON: That's the way to go. 2 MR. GILL: The next major bullet I have is a review 3 process.where it follows along the line we have been talking 4 about in an attempt to establish some type of acceptable 5 solution. And sometimes Duke works and tries to get all three 1 6 stations to do the same thing. It reduces the staff resource 7 review requirements. I am back up to the first slide that I 8 had when I came up here. 9 In many cases, this will minimize any backfit 10 concerns lur having the solution identified. We go into the 11 implementation of the item. And in many respects, it is going 12 to be a more timely solution across the board in that you don t 13 have to go back and reinvent the wheel. ) 14 I have got several examples that go into that to show 15 how that type of effort has worked in recent years. This from 16 McGuire and Catawba and it was'a similar effort on the B&W 17 plants regarding solving this problem generically. And in the 18-Westinghouse Owners' review case, there was an initial effort -19 performed. And this was even prior to the 1983 time period. 20 At that time, the staff issued a generic letter with several 21 parts providing some criteria for the resolution of the pump 22 trip. Duke provided a response. The Westinghouse owners' 23 group provided certain generic responses becauce we laid 24 heavily on that. The staff approved all that and then came 25 back with Generic Letter 8512 talking about the plant's l IIeritage Reporting Corporation i (202) 628-4888
95 1 specific implement. Duke has re ponded to that. And, in fact, ) 2 we resolved this issue in McGuire and Catawba simultaneously by 3 working together with a single steff reviewer. It did take 4 some time because of other priorities, but all the while we 5 already had this pump trip criteria implemented in the' plan, 6 probably back in the -- November '84 for McGuire and I'm not 7 sure when it was on Catawba in the prior initial licensing 8 there. 9 What we were doing here is really a review of 10 something we already had, but we had a lot of generic work that 11 had been done already where the staff agreed in Weston.
- And, 12 really, it was just a matter of discussing what we had, the 13 instrumentation we had, the capabilities we have and we've been
() 14 able to resolve this issue. 15 MR. EBERSOLE: The pumps and all the circuitry 16 associated with it is non-1E. It is not environmental 17-qualified. You don't have any right to expect that the pump 18 will survive. 19 Yet, the postulation is you are going to try to run 20 it. You don't run it without risk because you may have a 21 short. Lots of circuits. It's a monster. I'm not at all sure 22 that it is smart to try to run that pump. 23 MR. GILL: Well, there were some discussions with the l 24 reviewers regarding that. Because if you don't trip initially, j 25 do you keep the pump running. That type of thing: scenarios. O Heritage Reporting Corporation (202) 628-4888
- ),
96 f A 1 If.it trips off at the worst possible time, is that bad? You 2 know, the preferential type situation. 3 MR. EBERSOLE: I am talking about tripping as a 4 circuit pump. 5 MR. GILL: Well, that's tripping at anytime and we 6 would pick the worst possible time. l 7 MR. EBERSOLE: I am really talking about the 8 challenge to the circuits. Fire, whatever. 9 So, you didn't have any guarantee to say that the 10 trip would really work in the context of reliability. 11 MR. GILL: The scenario has been looked at as if they 12 trip off at the worst possible time, is that a problem? And 13 regardless of what causes it. () 14 MR. EBERSOLE: Sometimes, the original penetration 15 will prove wrong. They make a big hole. And that is not good. 16 MR. WYLIE: Isn't it true that you have got some 17 being closed, reactor cooler, pump motor water cooled? 18 MR. GILL: We put some type of water collection 19 system around there. I know that. If the guidance says he has 20 to trip it within 10 minutes and he doesn't what should he do? l 21 And what happens if they failed for any reason? Not just 22 water. It could be seal failure, loss of cooling. It could be 23 any reason. Is that a 24 25 O Heritage Reporting Corporation (202) 628-4888 l lI
p l 97 1 problem? What is the likelihood of that? The system doesn't 2-care why the pump trips, what's the core uncovered 3 characteristics or anything else. And that has been looked at. 4 MR. EBERSOLE: So, you have to live at the bottom 5 line with the fact that it's tripped whether you want it or 6 not. 7 MR. GILL: Right. The next item that seemed to work 8 fairly well is REG Guide 197. Neal has given you the exact 9 status of where we are. I want to tell you exactly how we got 10 there. You recall back in 1982 Generic Letter 8233 provided a 11 number of issues for HUREG 0736, control and design reviews, 12 REG Guide 197, SPDS, totalled all together, do put together 13 responses for all three stations' simultaneously on that. We () 14 covered all those issues and an initial response was made in 15 March of '84. 16 Catawba was still being licensed, so, they were on a 17 little bit faster track than McGuire. McGuire, both of the 1 18 units had licenses at the time. But you can see the delay time 19 there from the t.ime of the submittal until the time the TR was 20 issued was a couple of years. That was the initial review by 21 the staff. Once we resolved the open issues with the staff in 22 March of '83, we had already committed, interna))y, to be 23 putting these modifications in this coming year, 1988. 24 There is one item we have to do in 1989 and that is the steam 25 generator wide range level instrument which we Heritage Reporting Corporation (202) 628-4888 J ) i
98 ) 1 disagreed with the staff on, but by communicating this summer 2 and having meetings and showing where our design was a little i 3 bit different than all the other Westinghouse designs, we have J 4 made a compromise solution and agreed to put that in the 1989. 5 But we sort of worked in parallel here by licensing the 6 solutions to the problems in addition to doing the design work. 7 And we are allowed to put those in during the outages coming 8 up. It is again a place where you work with the staff. You get 9 agreement on things. We might have had problems. We had 10 something we decided to do being unacceptable to the staff. 11 There are two open items that the staff has. One has 12 to do with level and pressure. And the other is sump 13 temperature. We thought we didn't need to have those qualified. () 14 The staff, REG Guide 197 said we did. The staff has agreed to 15 go back and look at that and I presume they still are with 16 those two items. But other than that, we have been able to 17 resolve this one in a relatively short period of time, 18 approximately five or six years from the original generic 19 letter. 20 The last one without going into the total history of 21 that was when AMSAC was picking up where the rule was issued. 22-When that became issued, the clock started rolling on getting 23 the hardware fix in. We did have to wait for a generic letter 24 on quality assurance, but even preceding that, the Westinghouse 25 Owners Group put together a W cap to Heritage Reporting Corporation (202) 628-4888 l
l 99 I ( 1 discucs the various designs that they felt would be acceptable 2 to meet the basic rule, 3 That was submitted in July of '85. In fact, there are 4 three different design concepts that were licensed by that W f 5 cap. The staff issued an SER. The SER had a number of plans, 6 specific items had to be-reviewed. .7 Shortly after the SER was issued, Duke began working 8 on its own plant-specific submittal. We made that submittal-in 9 January of '87. About six months later, we requested an early 10 review date so we would have design approval prior to starting 11 the design process. We asked for review and approval by May. 12 We didn't get it, but we started on a risk anyway 13 with design to do the design review and continued working with ih 14 the staff through the summer. With the second deadline date of 15 November, which is when the design has to be released to the 16 first station for implementation process. l 17 We did in fact get the SER by the staff in November. 18 It covered all four units, McGuire, Catawba and the 19 implementation schedule is McGuire by the end of '89 and 20 Catawba in '89, which will meet the regulation. 21 Again, it's where we worked together up front. It is 22 a relatively expeditious process when you look at it overall, 23 starting in '84 with the rule to have it implemented within 5 l 24 years:by having owner's group approval of documents up front 25 with the staff allowed to get three basic designs. And as long Heritage Reporting Corporation (202) 628-4888
100 () 1 as you match up to one of those three, you should have a 2 relatively easy process to go through to get it implemented by 3 the staff. You don't have to review the 50 or so different 4 design processes. It makes it easier for the staff and easier 5 for licensing engineers and designers and all that. 6 The last major item I wanted to talk about are the 7 modification process and how extensive it is. I think in the 8 early days, early part of 1980s when the TMI action plan was 9 coming out, there was a lack of understanding of both parties 10 of how extensive the design process is to implement any kind of 11 modification. 12 And remember, we had the due dates of January 1st, 13 1980 and 1981, three arbitrary dates. Slowly, that's evolved (J 14 to refueling outages, one or two refueling outages away. And 15 there is good reason for it. The design process, itself, is 16 rather extensive, a lot of reviews and procurement. Once the 17 design is finalized, it has to be scheduled by the operating 18 side of our house, the stations, integrate a scheduling. You 19 have to identify resource requirements, the people that install 20 the devices, procure equipment. If this has to be ordered, 21 there is some lead time receiving qualified equipment. 22 The outage planning, itself, you know, you don't take 23 out Train A and Train B of the same system simultaneously. You 24 need to have one train operable. A lot of scheduling to make 25 sure the outage fuels efficiently. And, last but not least, is () Heritage Re. porting Corporation (202) 628-4888
101 1 the proposed implementation testing. Once this thing gets 2 installed, you have got to make sure it works right. And that 3 always comes into play and sometimes you find you had bugs 4 either in the design or the installation process that you don't 5 find until you actually do some testing. 6 when we communicate this total process to the staff 7 reviewers, they have a full understanding of what it is. It is O not just putting a design together and shipping it out. This 9 is very instrumental in our control and design review process, 10 where rather than having an arbitrary deadline of everything 11 being done by the end of the year or the second year, we really 12 communicate this total design process to the staff, we worked 13 out a process where we had 25 to 30 percent commitment of HEDs () 14 completed per outage and we would work with the region on 15 telling them which ones we would have done before the outage. 16 They could come in during the outage or after the outage to see 17 if we were making a commitment. And we were able at McGuire to 18 meet the type of numbers that we have right now. 98 percent 19 done in approximately four years. Three to four years. It was 20 1985 when we started doing this. 21 So, when the staff has an understanding of what is 22 involved to install something, I think they are more likely to 23 allow you to go to the next outage and they understand the 24 process rather than just saying it has got to be in by the end 25 of the year, January 1st, or some other arbitrary date. Heritage Reporting Corporation (202) 628-4888
102 () 1 And key with all this is dealing with the project l 2 manager. That is our focal point in working with the staff l 3 technical reviewers. We have to have good communications. L 4 They have to have good communications within the staff as to 5 what the priorities are, what the questions are. And we are 6 able to work together on that and get the solutions achieved in 7 a more reasonable time period and not have the long drawn out l 8 schedules, the, "Well, I'll implement something." And come 9 back two or three years later and find out that-it really 10 wasn't acceptable to the staff or the region or something like l 11 that. Or you come up with a new Tech Spec requirement that you 12 .didn't know about ahead of time. You are communicating up 13 front what the requirements are, what is acceptable using the () 14 total body of knowledge and not just isolated sets of it. 15 So, interacting with the project manager is very key 16 in this whole process. You need to have their support and their 17 understanding. Site visits help. Meeting the people. Don't do 18 it unilateral, but have a collective type agreement. 19 Questions? 20 MR. WARD: You are the project manager? 21 MS. PASTIS: Yes. 22 MR. WARD: How long have you been there? 23 MS. PASTIS: It is coming up to four years. 24 Site visits do help. We had two controversial 25 () Heritage Reporting Corporation (202) 628 4888
L 1 \\ l 1 1 103 () 1 complex issues. They were long and drawn out. We just took 2 the staff down there. One was size and qualifications. And 3 the other one was control compatibility. And very difficult j 4 issues. We went down there and we solved both of them. 5 MR. GILL: I have seen a lot more of project managers 6 site visits in the past two or three years than in previous 7 years. Too many times it was by telecopy or sending letters or 8 a licensee coming up to Bethesda to have meetings and show 9 drawings. 10 Jim mentioned the breaker business at McGuire this 11 year. We had a site inspection team come down there and we had 12 technical reviewers. We had the project manager come down. A 13 dedicated team effort for at least one week. And I think they. { () 14 came back. And then everyone went to Franklin in Philadelphia 15 to look at the breaker there. 16 On the SPDS, we have had site visits. So, its best 17 to have a face-to-face communication and at the site as opposed 18 to the Bethesda area. Getting the right people down and the 19 right reviewers to understand the particular nuances of the 20 plant design, why you can't or can do something to meet the 21 literal requirement that may have existed out there. 22 It just gets back to communications. I think we have 23 good communications now. We need to work on it. We may not 24 have had as good communications 10 years ago. Certainly, since t 25 l l Heritage Reporting Corporation (202) 628-4888
1 I i 104 1 .TMI. 2 MR. TURNER: The key to success is good interaction 3 with the. project managers. And you are saying that exists 4 today. 5 MR. GILL: I think so. When it works, it works real 6 well. And we see when.it doesn't work where the breakdown is. 7 I mean if you try to tie in some reviewer out there, if he is 8 trying to do a review on something, he needs to see the plant 9 'and not do it from afar. It is very hard to communicate. 10 Engineers have a hard time communicating in general. When they 11 write something, it really doesn't mean what they thought it 12 did. And we see that all the time with differences of 13 interpretation of the written word. And we need to all work on -O 14 taet. 15 MR. TURNER: I think the McGuire project manager took 16 a lot of heat in holding off a bulletin until we had an 17 appropriate time to solve it ourselves. And I think that there 18 was a lot of cooperation there by at least the staff supporting 19-us of really having an effort of trying to get this thing 20 resolved and coming out with a technical bulletin that is ) 21 meaningful and that is implementable versus trying to respond { 22 to the time pressures to get something out quick that you end 23 up having to go back and re-do. And I think we had to re-do a 24 25 ( Heritage Reporting Corporation (202) 628-4888 9 ..----__--__._._---__J
i 105 i 1 lot of stuff after the fact. 2 MR. WYLIE: Suppose we take a break. 3 (Whereupon, a brief recess was taken.-) 4-5 6 7 8-9- 10 11 12 13 O 14 15 -16 17-18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
106 ( )' 1 MR. WYLIE: Let's get started. Here we go. ) 2 MR. RUTHERFORD: I'd like to offer a little bit of a 3 summary; I think we covered most of these items already. Just 4 a few comments on the resolution process itself. 5 As we were talking earlier, things had improved, I 6 think. And one of the big reason is that we don't have the 7 number of issues on the table that we've had in the past -- if 8 you go back to the post-TMI period, we had a lot of issues; 9 they weren't very well followed at times. 10 They were somewhat the wish-list approach in the 11 post-TMI era. And it was a very inefficient way to handle a 12 number of issues. 13 Perhaps it was the only way at times. I don't know. (]) 14 I'll leave that to others to speculate. But hopefully, we will 15 not have to get into that mode of operational features. 16 We will have a list of issues that both sides can 17 manage appropriately; by that I mean the NRC and the industry. 18 Secondly, and we talked about this a good deal too, 19 maintaining good communications between the NRC and the 20 industry to, one, properly define the issue, and two, then to 21-develop document. I think is a very key point. 22 We'll talk today about industry efforts that I think 23 have gone well, and some examples of things where we've i 24 suffered in the past. 25 () Heritage Reporting Corporation (202) 628-4888
107 ,~ \\ 1 But I think we've seen like in issues such as station 2 black-out, where the industry does act as one, where we give 3 the staff sufficient information to make their judgments, and 4 then we work together to define the best solutions. That's the 5 best way to resolve issues, where we all buy into a solution, 6 and then the implementation is a lot smoother. 7 I'm a little bit concerned here that in the last few 8 months, for one reason or another, we've seen a little bit of a 9 chill on the communication between NRC and the industry. 10 I would hope, though, that this wouldn't stand 11 between us in the future in resolving some of these issues. We 12 do need to communicate. There is a proper way to do that where 13 the staff preserves their duties, as far as being the () 14 regulator, but at the same time, takes time to learn the issue 15 and to discuss the best solution. 1 16 Next, where appropriate in resolving issues, I think 17 it's also best to look at best estimate methods to define 18 problems and solutions, versus some of the very conservative 19 licensing approaches that were used for issues in the past. 20 I'm not saying that all issues can be treated that 21 way, but certainly issues such as we've discussed here today. 22 Scrub work, for instance, where we went out and used actual 23 real experience to define a problem, and define a solution. '24 I think that, if at all possible, is the way to treat 25 issues. Next, we've had a number of issues that, on the high Heritage Reporting Corporation (202) 628-4888
108 A (~). 1 level, everybody agrees that it's a good thing to do. 2. But we get down into the implementation and we get 3 into a lot of plant-specific issues, a lot of details, 4 technical review or perspectives coming into play, and we end 5 up doing a lot of things that probably are not very useful, or 6 don't contribute much to resolution of the issues. 7 And that kind of gets back to the point I was making 8 about good communication. If we can communicate up-front and 9 define the solutions in enough detail, then we can avoid some 10 of those things. And we talked about descriptive type 11 requirements. Those aren't all bad, where we do work together 12 and come to a legitimate understanding. 13 Lastly, we want to insure timely staff review in i () 14 accordance with those defined solutions. We've seen cases in 15 the past where reviews have taken years. You have developing 16 acceptance criteria, changes in viewpoints of reviewers, 17 changes in reviewers themselves, and this does create problems 18 in trying to resolve issues. 19 Here, again, with a more limited number of 20 outstanding issues on the table, hopefully we can all do a 21 better job, and do a more timely job in taking care of some of 22 these issues. 23 MR. WYLIE: Heal, do you think in the future, because 24 of the reorganization of NUMARC and others, that there'll 25 Heritage Reporting Corporation (202) 628-4888
i 109 j /~% i kJ 1 be more of an effort to solve these issues generically at the 2 industry level, as in the past? 3 MR. RUTHERFORD: Oh, yes. I think we will definitely 4 be solving problems more on a generic basis. 5 And as you're more aware that through NUMARK, we do 6 get a buy-in by the industry to that solution, versus trying to 7 deal with utilities one on one. 8 MR. EBERSOLE: I'd like to ask you, as a progressive 9 utility, I've heard a variety of approaches now that the 10 utilities deal with as a matter of the containment atmospheric 11 radiation level control. 12 Some utilities say, gee, just to keep good seals on 13 your equipment you'll have a problem. And the others have to () 14 blow a gale through the plant to clean it up every so often if 15 not continuously. 16 I believe you had a history of these problems about 17 the containment isolation valves being open to atmosphere, the 18 suction and discharge, and the difficulty in closing them in 19 the face of a hypothetical loca. 20 How did you ever really come to grips with the whole 21 problem, and either insure your containments were closed, or 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
110 /- m k-) 1 else you could close them? 2 MR. RUTHERFORD: We don't use the vats. 3-MR. EBERSOLE: You keep them closed? 4 MR. RUTHERFORD: Keep.them-closed. 5 MR. EBERSOLE: Is that suggesting that you have to go 6 around and dress up the seal so they don't. leak so bad? 7 MR~. RUTHERFORD: Now which seals are you referring n 8 to? 9 MR. EBERSOLE: In the primary coolant. Why was it 10 dirty in the first place or why did you have to keep 11 ventilation going? 12 MR. RUTHERFORD: Well, in most any containment, 13 you're going to have at least some leakage to atmosphere. () 14 MR. EBERSOLE: Yes. Early on, a lot of utilities had 15 a veritable gale blowing through the containment. But they 16 couldn't close the valves. 17 And I think that was pretty much universal. 18 What's the current process? ~ 19 MR. RUTHERFORD: We purge our containment now. We 20 have some mini-purges at Catawba and McGuire. But in the case 21 of Oconee, the big purge valves aren't used at hot conditions. 22 MR. EBERSOLE: You close them. 23 24 25 \\ Heritage Reporting Corporation (202) 628-4888 ______________w
l 111 (f 1 MR. RUTHERFORD: Right. 1 2 MR. EBERSOLE: Did you have to do any work on the l 3 seal systems? 4 MR. RUTHERFORD: No, it impacts critical path time, 5 as far as when you come down in order to purge the containment 6 and gain the entry. It impacts that to some degree. 7 But we're always, of course, working on valve 8 leakage, and that type of thing, to keep it as tight as 9 possible, irregardless of the ability to purge or not. 10 MR. EBERSOLE: Well, is it a fair statement to say 11 that you don't really need much of a purge in containments if 12 you keep your valves and seals all in good order? 13 MR. RUTHERFORD: It does hurt us some, here again. 14 If you're coming down for an outage -- not being able to purge ( } 15 and gain entry on the schedule that you'd like to, that does 16 cost you some time. 17 And we haven't been successful, I don't think, in 18 keeping things so tight that we can get around that problem. 19 MR. EBERSOLE: So you have some purging at all times 20 -- to dilute it, right? No? Just on occasions? 21 MR. RUTHERFORD: Here again, on McGuire and Catawba, 22 we have some limited capabilities there. Oconee, we don't. 23 MR. EBERSOLE: Okay. 24 MR. RUTHERFORD: Next, I would like to talk just a 25 little bit about our prospective on the contribution to plant ( Heritage Reporting Corporation (202) 628-4888
112 m 1~) 1 safety, the resolution of generic issues thereto. 2 Clearly, there are a number of issues that have 3 increased plant safety. And I think you would probably find 4 unanimous agreement throughout the industry that these types of 5 issues have been a benefit. 6 In our particular case, Appendix R, where we had the 7 stand-by shut down facility was definitely a plant safety 8 improvement. 9 And I would qualify that by saying that that doesn't-10 apply to all Appendix R requirements that came out; there were 11 a number of problems with a resolution of that issue. 12 But certainly that phase of it was a contributor. 13 The issue on high-low pressure systems interface -- the Event B () 14 scenario -- is another one. Another one we've already 15 mentioned today, the improvements and reliability of reactor 16 trip switch gear. 17 And then the next three issues are, I guess where I 18 feel that we've -- outside of a couple of hardware issues -- 19 done things that contribute most to plant safety, and that's l 20 improving our procedures, improving our training; setting up i 21 good programs to look at operating experience. 22 All these issues relate to running the plant well; 23 maintaining the plant well -- that aspect of it, which I think 24 there is really no hardware substitute as far as plant safety 25 is concerned. (" k-Heritage Reporting Corporation (202) 628-4888
l 113 1 rs 1 k) 1 MR. EBERSOLE: Do you think that high-low pressure f 2 systems interface solution is what you would have picked had 3 you been free to pick what you wanted? 4 MR. RUTHERFORD: Just as far as the testing of the 5 valves? 6 MR. EBERSOLE: Well, I recall I think it's the l 7 French. They told me that they built in an inoperability 8 factor so that those valves simply can't open at all if they 9 have excess differential beyond the capacity of the low l 10 pressure system. They' simply can't work. 11 And we depend on interlocks, remember? And I've l 12 often wondered if the interlocks have a degree of independence l 13 to guarantee that you won't open when you have successive () 14 pressure on the primary high pressure side. I 15 MR. RUTHERFORD: I guess the portion of that that I 16 was referring to was the testing of check valves' back leakage. 17 MR. EBERSOLE: Oh, no. I'm talking about he MOV's 18 opening inadvertently, and subjecting the low pressure system l 19 to a high pressure. 20 MR. RUTHERFORD: I-was referring more to the check 21 valves. 22 MR. EBERSOLE: The leakage business. What about the 23 other matter, where you open the valves prematurely and subject 24 the system to high pressure? 25 MR. RUTHERFORD: Well, there's I guess a trade-off k Heritage Reporting Corporation (202) 628-4888 1 1
114-1- there. 2i MR. EBERSOLE: .You use interlocks. 3 . MR '. RUTHERFORD: You've got appropriate interlocks to, 4 prevent you'from doing that. 5 MR. EBERSOLE: Are those interlocks trulyfsingle-6 -failure. proof? -7 MR. RUTHERFORD: .You've got two valves. 8 MR. EBERSOLE: Yes, do they both see excess' pressure !9 interlock independently? .10 MR. RUTHERFORD: I'm not sure of the answer to that. 11 MR. EBERSOLE: Okay. 12 MR. RUTHERFORD: The next part of this slide -- .13 there's certainly some issues. We: feel have provided h(]). jl4f unquestionable improvements in terms.of plant safety; and I've 15 just listed a few there. 16 ATWS reactor vessel water level, which we already 17 discussed; REG.. GUIDE 1.97, portions of that. I'm not talking 18 about the entire issue by any means. 19. Likewise, equipment qualifications. Portions of what. 20 we'did'to resolve that issue. I think did not contribute much 21 to plant safety. 22 And this gets back to my comments about the overall 23 process of resolving the issues.. In the post-TMI era, we have 24 .a lot of things, like I said, previously, that on a high level, i 25 people agreed they were good things to do. ~() Heritage Reporting Corporation (202) 628-4888 = _ _ - _ _
115 1 But when it got down into the details we did a number 2 of things that probably did not contribute very much to the 3 overall resolution of the issues. 4 And that gets back to the communications aspect of 5 trying to resolve these issues. We truly do need to hone in on 6 things that are useful and beneficial to the plants, and get 7 away from everybody's wish list approach to resolving safety 8 issues. 1 9 Do you have any questions on this? 10-(Pause) 11 I might add, this Committee is never guilty of that. 12 (Laughter) 13 Oh, changing subjects just a little bit -- () 14 MR. WYLIE: Well, let me ask a question. Were any 15 items, issues that have been implemented that you feel were 16 detrimental to plant safety? 17 MR. RUTHERFORD: Well, one item. I didn't really 18 cover on the previous slide. The bottom item there -- the way 19 we did business in the post-TMI era had the potential as far as 20 an adverse impact on safety. 21 I think in retrospect, we got through that, 22 hopefully, okay. But there's no doubt that we took a lot of 23 resources away from looking at the operation and maintenance of 24 the plant, and put them on other things -- modifications, et 25 cetera. /7) \\> Heritage Reporting Corporation (202) 628-4888 1 !l-
) 116 ([ 1 And so we are just now recovering in some areas in 2 the plant, as far as paying attention to preventative 3 . maintenance issues -- those types of things that the post-TMI' 4 era interfered with as far as us put' ting appropriate resources 5 in that area as soon as we would like to. E 6 MR. EBERSOLE: On those first two up there -- on ATWS' 7 and Vessel Level, what would you have done had you been 8 emperor? 9 MR. RUTHERFORD: Well, on ATWS, like we've discussed-10 before, I think.the efforts to improve reactor trip reliability 11 in most cases would probably be sufficient, versus implementing 12 any of the additional. hardware changes that we're going through 13 right'now. !/3 14 MR. EBERSOLE: And how would you have done that -- 'V 15 check for liability? 16 MR. RUTHERFORD: What we've done, as far as the 17 responses to the generic letter, I think those were appropriate 18 things to do as far as reactor trip switch gear. 19 Vessel water level -- again, we discussed'that. And 20 I feel that the instrumentation we have added and the claiming 21 we had done is sufficient in that area, irregardless of adding 22 . reactor vessel water level. But that's water over the dam, so 23 to speak. -24 But to turn to your question, Charlie. I can't point 25 to anything where we really think we have had an adverse effect .( )' Heritage Reporting Corporation (202) 628-4888
l 1 i 117 k-l' on safety because we implemented something. '2 If we had felt very strongly about it at the time we 3 would have fought it at the time, on that basis. But I don't 4 think we ever addressed an issue on that level. 5 MR. THOMAS: In hindsight, I think from a seismic 6 standpoint, I think the pipehanger, and some are snubber issues - i 7 havo tied things down more than they should be to perform the .8 best during and following an earthquake. 9 MR. RUTHERFORD: Well, if you want to get into more 1 10 global issues, certainly, I guess two of my pet peeves are 11 pipehangers in general, and security. l 12 I was just thinking about the post-TMI types of 13 things we did. Those two items I think in some cases have been () 14 a detriment. I'm certainly agreeing with what Jim is saying. 15 Some of the things we've done in the security area, 16 likewise, I think are not commensurate with the threat to 17 interfere with operations at the station. 18 MR. EBERSOLE: Yes, certainly security provisions 19 have had to be short-cut in some emergencies in order to save a 20 plant. And Davis-Besse had a good example of one of them. i 21 MR. GILL: We had one in accounting, too, when they 22 lost a computer. I 23 MR. EBERSOLE: What was in place at your B&W plant 24 that was not in place at TMI-2, that would have argued you 25 would never have had that accident? Heritage Reporting Corporation (202) 628-4888 i l l ________w
118 ,(> 1 MR. RUTHERFORD: Well, we had had the currents before 2 as far as a PORV failing to open. 3 MR. EBERSOLE: No, I 'm talking about the l 4 misinterpretation of the vessel level as a result of looking at S the pressurizer level. 6 MR. RUTHERFORD: I don't know that we had any more 7 instrumentation at the time. 8 We subsequently added sub-cooling. 4 9 MR. EBERSOLE: Did your operator know what super-heat 10 was? l 11 MR. RUTHERFORD: I think they knew when water boils. 12 MR. EBERSOLE: So you think that would have caught l 13 them? I /'s (_) 14 MR. RUTHERFORD: The only thing I can say is that we 15 did have a similar type of event. Our operators identified it 16 very quickly and took care of it. 17 MR. EBERSOLE: Did they know there was a void in the 18 vessel? 19 MR. RUTHERFORD: We did not create a void at that -- 20 MR. EBERSOLE: -- In that case? 21 MR. RUTHERFORD: -- at that point in time. No, we 22 caught it sufficiently soon to avoid. That type of situation. 23 The only thing, like I say, I can say that we've got good i 24 confidence in our operating crew, and hopefully they would have 25 done the right thing in those circumstances. \\ Heritage Reporting Corporation (202) 628-4888 i
119 (~s (4.) 'l But we've added additional training and 2 instrumentation above and beyond reactor vessel water level 4 3 since that time to help that out. 4 MR. EBERSOLE: Well, what was your first convulsive 5 reaction to TMI2 in aspect of what your operators would have 6 done? I guess you had one didn't you? 7 MR. RUTHERFORD: Well, I made a presentation not too 8 long'after TMI and I made a similar comment about water 9 boiling, and the temperature it takes to do that that I felt 10 our folks would have been aware of that. 11 MR. THOMAS: I think one thing, too, that I'd like to 12 add is, if all of the systems performed as the vendors said 13 they were going to when they proposed a resolution to some TMI () 14' concerns, I would be a lot less concerned of the results. 15 We were, in many cases, promised a product that had 16 not been sufficiently develop. And installed it, and found out 17 after the fact that it is either something that doesn't add as 18 much as you thought it would because you can't make it perform 19 correctly under all conditions. l 20 I think an example -- it's not one that bothers me 21 too much from a safety concerns but bothers me that I spent so 22 much money and time to do it, and got something that won't work 23 very well, is high-range containment monitors -- radiation 24 monitors -- because of the extremely low currents that they 25 work on; and the resulting inaccuracies you're going to get /*) \\s-Heritage Reporting Corporation (202) 628-4888
l 120 1 due to the generic characteristics of cable and penetrations of 2 exhibiting some leakage that there's nothing in the industry 3 that can meet those accuracy requirements that we had to commit 4 to in 197. 5 And the vendor, at this date, we've got the system 6 and he can't solve it. And the same thing is -- the Rivler 7 [ph) system is a calibration and maintenance nightmare -- not 8 to mention the installation nightmare. 9 And the point is that implementation of a system that 10 was designed under pressure and a very tight schedule is far 11 less from something that we would like to have that is an 12 extremely high-cost item in modifying the system now at this 13 point.in stage. It would be a very high cost' item. 14 MR. EBERSOLE: Since you mentioned small currents and 'o you have a policy of permitting permeable 15
- voltages, d
16 equipment, such as TVA dust, and allowing moisture intrusion 17 into apparatus and accepting the leakage current that goes with 18 it as a depressant to keep the pulse signal on critical control 19 functions. 20 Do you follow me? 21 MR. TIIOMAS : Yes, our design, in general, is to seal. 22 MR. EBERSOLE: That's what I thought. See, I just l 23 got a report from Chattanooga that this is the universal way of j 24 doing things, which I don't believe -- of letting leakage 25 current prevail. O lieritage Reporting Corporation (202) 628-4888 i
121 l' And, you know, permitting permeability. After all 2 the trouble you've gone through to make penetrations 100 3 impervious; and then to open up the circuits to moisture 4 intrusion seems to me to be asinine. 5 MR. THOMAS: There are some cases where I think you 6 don't have much choice. But in general, we try to prevent 7 that. 8 MR. EBERSOLE: Well, where is it you. don't have a 9 choice? 10 MR. THOMAS: Some of the designs of the equipment was 11 tested and qualified. 12 MR. EBERSOLE: Well, that was due to a fault in the 13 procurement specs. () 14 MR. THOMAS: Well, maybe something like -- some of 15 the motor-operated valves, but it doesn't seem to be a 16 qualification problem. 17 MR. EBERSOLE: See, they have invalidated that by 18 making permeable terminal boxes. And they suffer this I 19 condensation intrusion and the result of partial short.[ph) 20 And they lose some fraction of their signal j 21 amplitude; and you know, it's a compromised design. 22 MR. THOMAS: Yes. 23 MR. GILL: Some of the leakage that you're going to 24 see in instrumentation is not due to moisture but due to cable 25 characteristic as temperature increases. Heritage Reporting Corporation (202) 628-4888
122 es k,I 1 MR. EBERSOLE: Sure. 2 MR. GILL: And those probably cause us the most 3 problem of these instruments like high-range containment 4 monitors that -- there's not a whole heck of a lot you can do 5 about it unless you go back and spec a specific cable for a 6 specific devise, and a specific penetration, and redo the 7 entire system. 8 (Continued on next page.) 9 10 11 12 13 I )' -[ 4 15 16 17 18 19 20 21 22 23 24 25 kl 11eritage Reporting Corporation (202) 628-4888 l l'L-_____ __
123 i y N. (,, 1-MR. RUTHERFORD: The next item I have to cover were 2 some comments on the assessment program, the schedule. As far 1 3 as our staff is concerned, in the context of OCONEE we already { 4 have conducted a PRA, of course, and implemented a number'of 5 modifications as a result of that PRA. We had gone through the 6 TMI and other generic issue resolutions that we have talked 7 about today. We have added a shut down facility. We are doing 8 a number of things in house, including self-initiated systems 9 audits similar to the SSFI that the NRC is doing. 10 So, I guess the bottom line is that we don't consider 11 that ISAP as it is presently defined would be beneficial.
- Now, 12 we are having discussions with ONRR about whether there are 13 certain elements of this process that might be beneficial.
And n is_) 14 so we are in the process of looking at that. 15 MR. EBERSOLE: But you said you had already done a 16 PRA. 17 MR. RUTHERFORD: Right. 18 MR. EDERSOLE: If you hadn't done that, what would 19 you say? 20 MR. RUTHERFORD: My answer might be a little 21 different. 22 MR. EBERSOLE: Do you think the program really ought 23 to be an extrapolation of the SSAR in quantitative terms to be 24 kept for the record? 25 MR. RUTHERFORD: I'm sorry. I don't follow you. Heritage Reporting Corporation (202) 628-4888 _________________________________--_A
124 rx (_) 1 MR. EBERSOLE: I say do you think that the 2 integrated safety assessment, which is a PRA, ought to be 3 regarded as a numerical version of the FSAR. It expresses a 4 plant's state at a point in time and you would keep it up to 5 date with this living schedule concept. 6 MR. RUTifERFORD: Well, we are keeping our PRA up to L 7 date. 8 MR. EDERSOLE: In essence, it sounds to me like you 9 have in the safety assessment program. 10 MR. RUTHERFORD: Well, the ISAP also includes an 11 evaluation by the staff against certain portions of the 12 standard review plan or whatever. And I guess that is the 13 portion that I was refe ~ing to that at this point in time we () 14 don't see that it would be too beneficial. The other things we 15 have already done for the most part or just about are there. 16 Like I mentioned, we are having some discussions to see if 17 there was any variation or parts of that overall program that 18 might be appropriate. And that gets down to the point about 19 living schedules. Back when the generic letter was put out, we 20 responded that we were going to do some internal integrated 21 schedules. But our intention at that point in time was not to 22 enter into any formal agreement with the staff. 23 In conjunction with looking at the ISAP program, we 24 are also looking at integrated living schedules to see if we 25 change our mind or if there is anything beneficial there at l i O Heritage Reporting Corporation (202) 628-4888
125 1 this point in time. 2 MR. REMICK: How about Catawba? You speak of Oconee 3 here on the integrated safety assessments program. McGuire and 4 Catawba, how about those plants? 5 MR. RUTHEEFORD: Well, ISAP, as I understand it 6 really is geared towards the older plants. McGuire and Catawba 7 have already been reviewed against current standard review 0 plans. They do also have PRAs that have been done on those 9 plants. 10 MR. REMICK: But looking ahead to the future, 11 assuming that there will be some kind of future bar:kfits and so 12 forth, is it an advantage to have an integrated schedule, a 13 living schedule that you can negotiate those things from an () 14 integrated standpoint rather than handling it case by case? 15 MR. RUTHERFORD: Well, that's what we are looking at 16 at this point in time. I think that depends to some degree on 17 the level of issues that you think are going to be coming up in 18 the future. Right now, it appears that the level is 19 decreasing. If that continues, then maybe that does not require 20 the integrated concept. Even so, there may be some things 21 associated with the integrated living schedules methods to 22 evaluate issues on a plant specific basis, et cetera, that 23 might be beneficial. 24 MR. REMICK: Well, one of my understandings of some 25 of the potential advantages of the integrated approach is that Heritage Reporting Corporation (202) 628-4888
126 ) 1 if you do it on a case-by-case basis, you might have certain 2 requirements that you must do this, you must do that. If you 3 look at it on an integrated standpoint with a PRA, you find. 4 out, well, maybe two of those things don't make any sense. If I 5 you do this one, it basically satisfies the intent of all 6 three. And you can negotiate that type of thing. And I l 7 thought this was one of the advantages you would do, 8 especially, if you had a PRA. 9 MR. RUTHERFORD: It's an integrated approach that 10 solves a lot of past and open future issues. And certainly, 11 when we looked at resolution of issues, we do have an eye on l >12 the future and what is coming out there and whether that is I 13 going to impact?what we are.doing at the time. '( ) 14 MR. EDERSOLih. 1s you standby shutdown facility -- 15 most of the standby shutdown f acilities involve mostly just h 16 arranging control fdnctions at a protected place and didn't Ji 17 have tchdo with a lot of primary power circuits. Did'your A T 1stampnyshutdownfacilityinvolvethsuseofpowercircuits? 18 19 4450,'4160 or whatever? t MR. RUTHERFORD: Yes. We had to add a high pressure 20 ( 21 service water pump. ?s 22 N MR. EBERSOLE: So, you had to add hardware beyond { o i i C
- 2 3' contro.1 circuits.
r t h3 24 MR. RUTnUcohot 'AbouU 60 or 70 million dollars. i. EBERSOLE: See, thes, original concept was that it m., l%. '2$ MR. n L i v" N Heritage Reporting Corporation i "( (202) 620-4088 k w A ( i,. '( LA__________._.
1 127 L em. l _) I was a control room vulnerability problem. But then it extended s 2 to. include any points of focused vulnerability to fire. And 3 then you picked up these other things. So, I can see why it 4 shows up up there. You added a lot of equipment. 1 5 MR. RUTHERFORD: Right. Now, the requirements at 6 Catawba and McGuire were not as extensive as far as hardware 7 additions. 8 MR. EBERSOLE: What did you find? Common cable 9 tunnels or something like that? 10 MR. RUTHERFORD: Just the difficulty in separating 11 fire areas. Oconec turned out to be, in essence, one big fire 12 area. Those kind of issues. Cable separation, of course, at 13 McGuire and Catawba was a real problem. That was the most cost /~ t 14 effective and the best way to handle the issue, as we saw it. s. 15 And like I say, it does capture some of these other issues: 16 station blackout, et cetera. 17 MR. EBERSOLE: Your earlier statement, you didn't 18 think that Oconee needed to do this because it was built before 19 the standard review plan was invoked. It suggests that maybe 20 the standard review plan has got something in it, some things 21 in it that Oconee doesn't have. 2.' MR. RUTHERFORD: That wasn't my point. Part of the 23 ISAP does, as I understand, take portions of the standard 24 review plan and compare your plan against that. My point was 25 that Oconee has already done a number of other things, has a (,h) Heritage Reporting Corporation r (202) 628-4888
128 1 number of other programs that I tnink has identified any 2 vulnerabilities at the' plant that we might have. And that to 3 go through that portion of an ISAP, we don't coe any benefit at 4 this point. 5 MR. EBERSOLE: So, you have sidestepped some of the 6 standard review plan requirements by adaptinq, using other 7 ways. 8 MR. RUTIIEDFORD: Not in a design fashion. We haven't 9 gone to the standard review plan and say, "We're okay here, 10 there and there." But just the overall programo we've gone 11 through as far as conducting PRAs and identifying those types 12 of vulnerabilities and the other programs that we have gone 13 through. We feel like we have in essence'done that. ()- 14 MR. WYLIE: Any other questions? 15 (No response.) 16 Well, I would like to thank Mr. Rutherford and the 17 other two representatives for a very constructive and factual 18 meeting. If there are no other questions, I will call the 19 meeting adjourned. 20 (Whereupon, at 4:03 p.m., the meeting was adjourned.) 21 22 23 i 24 25 ) lleritage Reporting Corporation (202) 628-4888 J
3 4' e PRESENTATION SCHEDULE - l ACRS SUBCOMMITTEE MEETING ON GENERIC ITEMS l DECEMBER 16, 1987 i ROOM 1046, 1717 H STREET, N.W. l WASHINGTON, D.C. l ACRS CONTACT: SAM DURAISWAMY 202-634-3267 NOTE: ' Presentation time should not exceed 50% of the total time 3 allocated for a specific item. The remaining 50% of the time is reserved for Subcormittec questions and answers by the Staff.
- Number of copies of the presentation mate-ials to be submitted to the Subcommittee:
25 copies ) TOTAL PRESENTATION ITEM PRESENTER TIME ACTUAL TIME 15 mins. 12:00N - 12:15p 1. _ Executive Session g 2. Presentation by the Duke Power Company 2.1 Steps Involved in DUKE POWER 180 mins. 12:15p - 3:15p Implementation Process /IFAP a. By means of specific exanples, selected as described below, illustrate and discuss the nature and duration of the several steps involved in implementing the resolution of Generic Issues and/or USIs. To the extent possible, select examples involving: (1)long vs. short times for implementation, (2) difficult vs. easy to implement, and (3) hardware fixes vs. procedural changes. The number of exemples should be selected to fit within the time allotted for presentation.
- b.
- What is the current status of implementation of generic and plant-specific issues, or other NRC requirements, at the Duke plants.
- Discuss the factors that have contributed to delays in implementing the resolution of issues.
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PRESENTATION SCHEDULE NOVEMBER 6, 1987 1 ,U GENERIC ITEMS - DECMEBER 16, 1987 l TOTAL PRESENTATION ITEM PRESENTER TIME ACTUAL TIME 2.1(cont'd) W
- c. What is Duke Power Company's position on In-tegrated Safety Assessment Program (ISAP) and Integrated Living Schedule 15 mins.
3:15p - 3:30p
BREAK 2.2 Interaction with DUKE POWER 45 mins.
3:30p - 4:15p NRC/ Effectiveness of the Process
- a. How effective is your interaction with the NRC project managers in establishing schedules for implementation, c()
reviewing licensee proposals, etc.?
- b. Do you think that the overall process, (identification, prioritization, resolution, imposition, implementation, and verification) of dealing with generic issues and USIs is effective? If not, what could be done to improve it?
2.3 Contribution to DUKE POWER 30 mins. 4:15p - 4:45p Plant Safety Do you have any evidence (based on quantitative risk assessments) or opinions (based on judgment) relating to the increase in safety that can be attributed to the implementation of the fixes, resulting from the resolution of Generic Issues and USIs? 30 mins. 4':45p - 5:15p 3. Subcommittee Remarks 5:15p ADJOURN ..sL) b_.
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- lOL DUKE POWER COMPANY PRESENTATION-
' TO -ACRS SUBCOMMITTEE ON GENERIC ITEMS DECEMBER 16, 1987 l --(0 h l l LO-
3' Q DUKE PARTICIPANTS NEAL RUTHERFORD SYSTEM ENGINEER, LICENSING JIM THOMAS . SENIOR ENGINEER, DESIGN ENGINEERING, ELECTRICAL ROBERT GILL MCGUIRE LICENSING ENGINEER PAUL GUILL OCONEE LICENSING ENGINEER ROBERT SHARPE CATAWBA LICENSING ENGINEER LO O
I !O AGENDA q 0 DISCUSSION OF SELECTED USI'S JIM THOMAS - EQUIPMENT QUALIFICATION .l ' SEISMIC QUALIFICATION STATION BLACK 0UT 'O STATUS OF. ITEMS ON DUKE PLANTS NEAL RUTHERFORD O IMPLEMENTATION OF RESOLUTION OF ISSUES B0B GILL 0 ' COMMENTS ON RESOLUTION PROCESS NEAL RUTHERFORD .O AND CONTRIBUTION TO PLANT SAFETY 0 VIEWS ON INTEGRATED SAFETY NEAL RUTHERFORD ASSESSMENT PROGRAM AND INTEGRATED LIVING' SCHEDULE 9 O
GBERIC ISSIES/USIs - O o ENVIROWENTAL QUALIFICATION (USI A-24) Il 0; ' SEISMIC QUALIFICATION (USI A-46) o STATION BLACKDUT (USI A-44) LOL 8 i O. 1
HISTORY OF EQUIfNENT QUALIFICATION ISSUE o U o TO 9 BER 4, 1977 UCS FILES A PETITION FOR EERGENCY AND REMEDIAL RELIEF CONCERNING FIRE PROTECTION AND BNIR0fMNTAL QUALIFICATION OF ELECTRICAL COMPONENTS i l o APRIL 13, 1978 NRC DENIES UCS REDUESTS, BUT ORDERS j STAFF TO TAKE CERTAIN ACTIONS 0 JUNE 2, 1978 IE CIRCULAR 78-08 ISSUED REDUESTING'A REVIEW 0F EQUIPMENT QUALIFICATION STATUS - NO RESPONSE REDUIRED l 0 FEBRUARY 8,1979 IE BULLETIN 79-01 ISSUED WHICH RAISED IEC 78-08 TO BULLETIN STARIS EUS REQUIRING A RESPONSE ~ o JANUARY 13,1980 IE BULLETIN 79-01B ISSUED WHICH EXPANDED ('~') THE SCOPE OF IEB 79-01 AND SET FORE THE NRC'S REVIEW CRITERIA (DOR GUIDELINES AND 4 tLIREG 0588) i o FEBRUARY 29, 1980 NRC ISSUES SUPPLEENTS TO SEP W 1BER 30, 1980 IEB 79-01B FOR CLARIFICATION OCTOBER 24,1980 o MAY 23, 1980 NRC ISSUES MEf0RANDlN AND ORDER ESTAB-LISHItG D0R GUIDELINES AND NUREG 0588 AS REQUIREMENTS FOR MEETING GDC-4 o AUGUST 29, 1980 ALL OPERATItE LICENSES MDDIFIED REQUIRING IEB 79-01B COW LETE RESPONSES BY 11/01/80 oO
1 HISTORY OF EQUIPMENT QUALIFICATION ISSUE (CONTINUED) nU o 0CTOBER 24, 1980-ALL OPERATING LICENSES MODIFIED REQUIRING:
- 1) ALL SAFETY-RELATED EQUIPK NT TO BE QUALIFIED TO D0R GUIDELINES OR NUREG 0588 BY 06/30/82, AND
- 2) ESTABLIS}f0ff 0F A CENTRAL QUALIFICATION RECORDS FILE BY DEEMBER 1,1980 o
JUNE,1981 NRC COWLETES ISSUANCE OF SER'S o JULY 7-10, 1981 NRC CONDUCTS INDUSTRY WORKSHOP o FEBRUARY 22, 1983 SECTION 50.49 0F 10TR PART 50 RULE FOR ENVIR0ffENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT IWORTANT TO SAFETY o JUNE,1984 REG. GUIDE 1.89 DESCRIBES QUALIFICATION Q ETHODOLOGY ACCEPTABLE TO THE NRC STAFF FOR INDUSTRY COWLIANCE WITH 10CFR 50.49 o OCTOBER 15,1984 PILOT AUDIT PROGRAM INITIATED o MAY 22, 1985 IE I WORMATION NOTICE 85-40 DEFICIENCIES IN EQ TESTING AND CERTIFICATION PROCESS o SEPTEMBER 22, 1986 GENERIC LETTER 86 ADDITIONAL GUIDELINES ON LICENSEE ACTIONS AND NRC POLICY WITH REGARD TO EWORCEKNT OF 10CFR 50.49 o FEBRUAitt6,1987 SECY-87-32 EXAWLES OF HOW POLICY APPLIED TO EQ DEFICIENCIES o APRIL 10, 1987 J.M. TAYLOR MEMDRANDlM TO REGIONAL A MINISTRATORS - FURTHER GUIDANCE ON 'O APPLICATION OF EWDRCEENT POLICY
g. g. INDUSTRY EQ GROUPS D o IEEE NEC SC2 ? o AIF SUBCO MITTEE ON EQ-1 o EPRI EQ AWISORY GROUP O-o NUCLEAR UTILITY GROUP ON EQ i O I
USNRC UNRESOLVED SAFETY ISSUE (USI) A-46. O ADDRESSES SEISMIC QUALIFICATION OF OPERATING NUCLEAR PLANT EQUIPNNT o SAFE SHUTDOWN lijST BE ASSURED FOLLOWING A DESIGN BASIS EARTHQUAKE. o SAFE SHlffDOWN (HOT OR COLD) tilST BE MAINTAIED FOR A DETERMINED LENGTH OF TIME (PLANT SPECIFIC). o IT IS ASSlFED THAT TE EARTHQUAKE DTS NOT CAUSE A LOCA. O o IT IS ASSifED THAT A LOSS OF 0FF-SITE POWER OCCURS. o USI A-46 APPLIES TO PLANTS WITH CP APPLICATIONS DOCKETED BEFORE OCTOBER,1972. IT APPLIES TO 72 UNITS. o USI A-46 ADDRESSES SPECIFICALLY ONLY ACTIVE ~ ECHANICAL AND ELECTRICAL EQUIFMENT (NOT PIPING, CABLE TRAYS, HEAT EXCHANGERS). O
THE SEISMIC QUALIFICATION UTILITIES GROUP (SOUG) DEVELOPED A PRACTICAL AND COST EFFECTIVE 1 5GHDD TO RESOLVE USI A-46 AND PIONEERED A ] NEW LICENSING CONCEPT o SQUG INCLUDES ABOUT 40 UTILITIES 4 o lHE NRC HAS BEEN A MAJOR CONTRIBUTOR / PARTICIPANT IN SQUG ACTIVITIES SINCE SQUG'S INCEPTION (JANUARY 1982) o SQUG COIPLETED A " PILOT PROGRAM" TO EVALUATE THE O SEISMIC PERFORMANCE OF EIGHT CLASSES OF EQUIPENT (SEPTEMBER 1982) o THIS PROGRAM WAS REVIEWED BY THE NRC, ITS CONSULTANTS AND AN APPOINTED INDEPENDENT PAEL OF EARTHQUAKE EXPERTS o TE NRC OFFIE OF NJCLEAR REACTOR REGULATION ENDORSED .THE USE OF EXPERIENCE DATA (SEPTENER 1983) o CRGR EVIEWED THE USI A-46 RESOLUTION PACKAGE BY THE C NRC AND APPROVED IT (JULY 1985) ______________A
g t THE G0AL OF THE SQUG PROGRAM HAS BEEN T0 '3' I V MAE THE BEST POSSIBLE USE OF ACTUAL EARTHQUAE EXPERIENCE DATA TO RESOLVE USI A-46 l o DEVELOP A HISTORICAL DATA BASE ON THE PERFORMANCE OF EQUIPENT IN CONVENTIONAL POWER AND INDUSTRIAL FACILITIES DURING AND AFTER STRONG EARTHQUAES. o SHOW THAT THE EQUIPENT IN THOSE PLANTS IS THE SAE AS EQUIPENT FOUND IN NUCLEAR POWER PLANTS, i O o SHOW THAT THE DATA BASE EQUIPMENT WAS SUIUECTED TO STRONGER GROUND MOTION THAN SSEs FOR PLANTS OUTSIDE CALIFORNIA, o DETERMINE WHAT EDVIPMENT OR EQUIPMENT FEATURES PRESENT SIGNIFICANT RISKS IN AN EARTHOUAE. .O i
I l lliE' FUNCTIONS OF THE SEISMIC EXPERIENCE DATA BASE ARE: O l l o TO PRWIDE A REALISTIC ASSESSENT OF TliE EARTHQUAKE RISK TO F0WER FACILITIES L l 1 o TO DETERMINE WHAT TYPES OF SEISMIC DAMAGE TYPICALLY OCCUR IN POWER FACILITIES i o TO DETERMINE TENDENCIES FOR SEISMIC DAMAGE TO VARIOUS TYPES OF FACILITIES AND THEIR STRUCTURES, SYSTEMS, EQUIPENT, AND " "3 .O o TO DETERMINE WHAT IS TYPICALLY NOT DAMAGED i i ~ t l 1 O 1 I l
SQUG CONCLUSIONS LO. o SEISMIC RESISTANCE OF STANDARD-POWER PLANT EQUIPMNT, WHEN PROPERLY ANCHORED, WAS VERIFIED DURING THE PILOT PROGRAM. o EXPLICIT, SEISMIC QUALIFICATION OF THIS EQUIPMENT IS NOT JUSTIFIED. i o SEISMIC QUALIFICATION IS NOT A SIGNIFICANT SAFETY .Q CONCERN, THEREFORE, FURTHER ACTION IS NOT REQUIRED. i l i { l l O l
FORMATION OF TliE SENIOR SEISMIC REVIEW O: AND ADVISORY PAEL (SSRAP) 1 ) o PURPOSE OF SSRAP REVIEW: i o PROVIDE AN INDEPENDENT ASSESSMENT BY EXPERIENCED SEISMIC EXPERTS OF SQJG RESULTS AND CONCLUSIONS, o PROVIDE APPROPRIATE REC 0WENDATIONS FOR USE OF TE SQUG RESULTS O o WNERS OF SSRAP ERE AGREED UPON AND CHOSG BY SQUG AND NRC 4 o i i o
1 AN EXTENSIVE REVIEW BY AN INDEPENDENT PAEL, O. EESSRAP,SUPPORTEDTHEFINDINGSOFSQUGFOR THE FIRST EIGHT CLASSES OF EQUIPMENT 1 o EQUIPENT INSTALLED IN NUCLEAR POWER PLANTS IS GENERALLY SIMILAR AND AT LEAST AS RUGGED AS THAT INSTALLED IN l CONVENTIONAL POWER PLANTS, i o THIS EQUIPENT, WHEN PROPERLY ANCHORED AND WITH SCE RESERVATIONS, HAS AN INHERENT SEISMIC RUGGEDESS AND l HAS A DEMONSTRATED CAPABILITY TO WITHSTAND SUBSTANTIAL I SEISMIC MOTION WITHOUT STRUCTURAL DAMAGE. 1 b o FUNCTIONALITY AFTER THE STRONG SHAKING HAS ENDED HAS BEEN DEMONSTRATED; ltE ABSENCE OF RELAY CHATTER DURING STRONG n V SHAKING HAS NOT BEEN DENNSTRATED. o WITH SEVERAL Iff0RTANT CAVEATS AND EXCLUSIONS, IT IS THE L SSRAP JUDGENT THAT BELOW CERTAIN SEISMIC MOTION BOUNDS IT l IS UffECESSARY TO PERFORM EXPLICIT SEISMU SJALIFICATION OF EXISTING EQUIPENT. o THE EXISTING DATA BASE REASONABLY DEtt)NSTRATES THE SEISMIC RUGGEDESS OF BIS EQUIFNENT UP TO THESE SEISMIC MOTION BOUNDS.
REFERENCE:
SENIOR SEISMIC REVIEW AND ADVISORY PANEL (SSRAP), "USE OF PAST EARTHQUAKE EXPERIENCE DATA To SHow SEISMIC RUGGEDNESS OF CERTAIN CLASSES OF EQUIPMENT IN NUCLE /R POWER PLANTS" (FEBRUARY,19814). O 1 4
A GENERIC IELEENTATION PLAN IS b-BEING DEVELOPED TO RESOLVE A-46 ON A PLANT SECIFIC BASIS IT INCLUDES: \\ l o DEVELOP LIST OF EQUIPENT REQUIRED FOR SAFE SHUTDOWN. o' C0EARE WITH SQUG GEERIC EQUIPMENT LIST. ] i o REVIEW EQUIPE NT DETAIL: o EQUIPENT LOCATION o PHYSICAL DATA j o ANCHORAGE DETAIL o IDENTIFY EQUIPEKf WHICH CAN BE SCREENED USING EXPERIENE DATA. o IDENTIFY EQUIPENT WHICH CAN BE SCREENED USING OTER EANS. n o TEST DATA V o ENGINEERING JUDGE NT o EXCLUSIONARY RESTRICTIONS WHICH j CAN E CTERCOE o REDUCE PLANT EQUIPENT LIST T0: ) o EQUIPENT THAT IS POTENTIALLY VULERABLE ) o EQUIPENT THAT FALLS OUTSIDE THE LIMITS OF THE SQUG DATA BASE o EQUIPENT WITH FUNCTIONALITY IN QUESTION o DEERMINE PROCEDUES FOR QUALIFYING EQUIPMENT THAT CANNOT i BE SCREEED o 'ARALYSIS o SHAKE TABLE TESTING o REPLACEENT o STRUCRJRAL MODIFICATION o DOCLENT THE RESULTS \\ l h__,_____.-____
i SOUG PROGRAM OUTLIE O o SCREEN ESSENTIAL EQUIFTENT LIST o COVERED IN SQUG PROGRAM o 0 B ER DATA AVAILABLE (EXPERIENCE, TEST) o ENGINEERING JUDGENT o DOCLEKT SEISMIC RUGGEDESS OF EQUIPENT o ASSIGN RUGGEDNESS LEVELS WHICH CAN BE JUSTIFIED ( o IDENTIFY EXCEPTIONS / VULNERABILITIES FOR EACH EQUIPENT CLASS o DEFINE DATA NEEDS, IF ANY o COW LETE/ REVIEW EPRI PROGRAMS, DEVELOP ANCHORAGE INSECTION GUIDELIES o ANCHORAGE o TEST DATA ASSIMILATION t o DEVELOP SIWLIFIED APPROACH FOR DETERMINING Q REQUIRED SEISMIC RUGGEDNESS IN NJCLEAR PLANTS o ELEVATIONS LESS THAN O FEET o HIGER ELEVATIONS o ATTEW T TO LIMIT SCOPE OF RELAY FUNCTIONALITY REQUIREE NTS ON GENERIC BASIS o DEVELOP PLANT WALK-THROUGH GUIDELIES AND TEAM i o PERFORM " TEST" WALK-THROUGH o D5VELOP PLANS FOR SQUG f9BER IWLEENTATION f o SEMINARS o GENERIC SQUG TEAM APPROACH o SSRAP/NRC AUDIT O
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1 CERTIFICATE 2 g-3 This is to certify that the attached proceedings before the \\,g '/ 4 United States Nuclear Regulatory Commission in the matter of: 5 Names GENERIC ITEMS 6 MEETING 7 Docket Number: 8 Places Washington, D.C. 9 Date: December 16, 1987 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear I 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 of the foregoing proceedings. /S/ Y +2 16 ,,d u 17 (Signature typed): Irwin Coffenberry 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 O .. 1}}