ML20246P501
| ML20246P501 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1749, NUDOCS 8907200228 | |
| Download: ML20246P501 (197) | |
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0 UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS j i
351st ACRS MEETING )
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DAY TWO )
O Pages: 188 through 351 Place: Bethesda, Maryland Date: July 14, 1989 O 1t r/ n1T
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d L .1- PUBLIC NOTICE BY THE
- 2. UNITED' STATES NUCLEAR REGULATORY COMMISSION'S-i 3
ADVISORY COMMITTEE.ON REACTOR SAFEGUARDS- Lj l
4 July 14, 1989' 5
1 1
6 7 The. contents of this stenographic-transcript of" 8' the proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee'on Reactor Safeguards 10 (ACRS), as reported herein, is an uncorrected record of the 11 discussions recorded at the meeting held on the above date.
12 No member of the ACRS staff and no participant at 13- this meeting accepts any responsibility'for errors or
- 14. inaccuracies of statement or data contained in this 15 transcript.
16 17 18 19
, 20 21 22 23 24 25 Heritage Reporting Corporation
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r .s 188 rd,; I j-UNITEDs STATES NUCLEAR REGULATORY COMMISSION l'
ADVISORY. COMMITTEE.ON REACTOR SAFEGUARDS H
, 351stfACRS MEETING )
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DAY TWO- )-
l Friday, July 14, 1989
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Room P-110, Phillips Building.
7920 Norfolk Avenue Bethesca, Maryland The meeting convened, pursuant to notice, at 8:30 a.m.
BEFORE: DR.-FORREST J. REMICK Chairman, ACRS Associate Vice-President for Research Professor of Nuclear Engineering if]s)
. The. Pennsylvania State. University University Park, Pennsylvania-ACRS MEMBERS PRESENT:
DR. WILLIAM KERR
. Professor of Nuclear Engineering Director, office of Energy Research University of Michigan Ann Arbor, Michigan MR. CHARLES J. WYLIE Retired Chief Engineer Electrical Division
' Duke Power Company Charlotte, North Carolina DR. PAUL G. SHEWMON Professor, Metallurgical Engineering Department Ohio State University Columbus, Ohio
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189-ACRS MEMBERS PPESENT (Continued) :
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DR. CHESTER P. SIESS Professor Emeritus of Civil Engineering University of Illinois Urbana, Illinois MR. DAVID A. WARD Research Manager on Special Assignment E.I. du Pont de NemoursS& Company Savannah River Laboratory
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Aiken, South Carolina.
DR. HAROLD W. LEWIS Professor of Physics Department of Physics University of California Santa Barbara, California MR. CARLYLE MICHELSON Retired Principal Nuclear Engineer Tennessee Valley Authority Knoxville, Tennessee, and Retired Director, Office for Analysis and Evaluation of Operational Data U.S. Nuclear Regulatory Commission r
eg Washington, D.C.
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MR. JAMES CARROLL Retired Manager, Nuclear Operations Support Pacific Gas & Electric Company San Francisco, California DR. IVAN CATTON Professor of Engineering Department of Mechanical, Aerospace & Nuclear Engineering School of Engineering and Applied Science University of California Los Angeles, California ACRS DESIGNATED FEDERAL OFFICIAL:
RAYMOND FRALEY
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, NRC STAFF PRESENTERS:
CHRIS GRIMES
~ JIM' WILSON-JIM LYONS PHIL McKEE BOB WARNICK FROM TU ELECTRIC:
- BILL COUNDIL ~(Presenter)
BILL'CAHILL AUSTIN SCOTT.
ROGER WALKER-JIM KELLY JOHN BECK 10 i
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.- 1 .E R Q Q R E p,I N-Q R 2 DR. REMICK: The meeting will now come to order.
3 This is the second day of the 351st meeting of the' 4 ', Advisory Committee on Reactor. Safeguard. During today's 5 meeting the committee will discuss the multiple system e 6 responses program, Comanche Peak Nuclear Station Units 1 and 7 2, human factors, Chernobyl spinoff study, preparation of 8- ACRS reports, and nomination of ACRS members. This latter 9 session will be closed.
10 Although items for consideration on Saturday are 11 listed on this schedule posted on the bulletin board, it is 12 our intent that the meeting will end later today.
13 This meeting is being conducted in accordance with 14 provisions of the Federal Advisory Committee Act and the 15 Government in the Sunshine Act.
- 16. Mr. Raymond Fraley is the Designated Federal 17 Official for the initial portion of the meeting.
18 We have received no written statements or requests 19- to make oral statements from members of the public regarding 20 today's sessions.
21 A transcript of portions of the meeting'is being 22 kept and it is requested that each speaker use one of the 23 microphones, identify himself or herself and speak with 24 su*ficient clarify and volume so that he or she can be 25 readily heard.
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We.will otinue our meeting this morning with a discussion of multiple system responses program. Chet Siess 3 is' subcommittee chairman and a subcommittee meeting was held 4 on Wednesday.
4 5 I turn the meeting over to you, Chet.
6 DR. SIESS: Thank you.
7 This was considered at the meeting of the Generic 8 Issues Subcommittee, I think otherwise knows as the garbage 9 subcommittee.
10 (Laughter) 11 DR. SIESS: That's how we got it on Wednesday.
12 Everybody on the ACRS was there except 13 representatives from Ohio, California and Vienna, two of 14 whom are here this morning. So I guess I will.be-talking
- 15. chiefly to them. But I will also try to summarize what'we 16 learned so that others who were present can add'to that 17 summary or correct it, if I make mistakes.
18 We'found out what the multiple system responses 19 program is. And perhaps mu e important, we found out what 20 it is not.
21 As you will recall, the staff first referred to 22 this program in response to our discussions on the 23 resolution of USIA 17 systems interactions, where we had 24 pointed out that they had limited the scope of that problem 25 perhaps more so than was desirable. And they said well,
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193 1-~ ~we'll take care of these other things. 'We'll set up a new 2- program:to look at these other. things. r
.3 The MSRP, as it has become known --
.4 ' DR . SHEWMON: What was.it previous?
5 DR. SIESS: It wasn't anything.
6 DR. SHEWMON: I just never heard that phrase 7 before.
- 8. DR. SIESS: Well, it is mentioned in the last 9 couple letters as being the answer to our prayers on A-17' .
10 The MSRP is not a continuing program to look at j 11- interactions, as near as I can tell. We have the Staff here
.12- so.they can correct me if necessary.
13 It is essentially a one-shot program to take care-14 of a' number of concerns that have been raised by various 15 people, chiefly.but not exclusively the ACRS, either in its
-1(L letters, in its subcommittee meetings, and comments and 17 . questions by individual members, et cetera. But it is not a 18 continuing program that we could tell. l
.19 I mention that, because in our last. letter on A- l i
-20 17,-the last one or the next to last one, we did say that 21 there should be a continuing effort to look for systems 22 interactions. We did not say there should be a continuing 23 research program.
24 We also said in that letter that the industry 25 should be involved and that people with operating experience Heritage Reporting Corporation
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h '194 1 1: 'should'be consulted to look'for some of these inadvertent,-
2 unsuspected interactions.
'3 TheLMSRP did not do that. What did it do? It-was 4 contracted to Oak Ridge National' Laboratory, which, as you
'5 know, is'a precty. good repository of operating experience.
6 There are a_ lot of-people down there thatlhave looked at 7 operating experience and.they did it on the SCP plants, they 8 always did the operating experience with you, and'there are i
9 people fairly knowledgeable about that.
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10 They went through a number of sources: ACRS -!
11 letters, notes from ACRS subcommittee meetings that they had 12 attended or the staff had attended, transcripts of ACRS j 13 subcommittee meetings, transcripts'I guess of full committee l 14 meetings, LERs and several other things, and identified I O 15 concerns that were expressed relating t'o incompleteness of :
16 certain studies that the staff had made in certain areas.
17 Now, there were three USIs that were involved.
18 One was A-17 systems interactions, which I think was the one 19 that really triggered this; an A-46 seismic qualification l 20 for equipment-in operating nuclear plants; and questions had 21 been raised of a systems interaction nature indicating some 22 incompleteness of the scope; and.in A-47, particularly, ]
23 safety implications of control systems in SWR. Anyway, in 24 nuclear power plants.
25 We've complained that they had truncated the scope Heritage Reporting Corporation O. (202) 628-4888
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(-( ) of it and left a' lot of stuff out, and it again was the kind !
2 of interactions.
3- Now, notice, this program does not refer to 4 interactions. It talks about multiple system responses.
5 And what.they are really looking at is failure of more than 6 one system. A single system they said, no problem. Single 1
7 ' failure handles that. That is not strictly correct, unless 8 it is safety grade systems. They are-single failure. But 9 in non-safety grade or balance of plant, a single failtre is 10 enough to take out certain things. They were looking for 11 that.
12 They looked at those three USIs and all the 13 material comments on them. And then they looked at 14 environmental equipment qualification, seismic qualification
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15- and fire protection, where some of these same types of 16 things had come up, as you well know. And they looked for 17 issues in paper.
18 As far as we can tell, they did not interact with 19 the industry; they did interact with the Staff, of course.
20 And they essentially did the job that is supposed to be done 21 in identifying generic issues within the formal process.
22 They identified the issues, tried to synthesize 23 them or aggregate them or desegregate them depending on wht :
24 it was, tried to collect all the information necessary, 25 describe them so that somebody could understand them, and
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196 1" prioritize them..
2 Now, these.are the steps that.somebody-has to go 3 through to' identify a generic issue. Not that they always 24 do it. But as you know, the first: step is identification;
- 5. the next is-prioritization; the next is resolution; and so
- i. 6 forth..
7 So what Oak Ridge did then was to_look at' a number 8 of things, come up with a number of concerns, try to 9 describe them in sufficient detail that they can be looked
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10 at by the staff in their prioritization program'for generic 11 issues.
12- But they had 31 identified issues. 31 concerns, 13 I'm sorry.
'14 DR. REMICK: 21 concerns.
LO 15 DR. SIESS: 31 concerns.
16 DR. REMICK: Yes. 21 issues.
17 DR. SIESS: And then they combined'these into 21 18 defined safety issues identified for prioritization. And 19 that ends their job.
20- The staff will now take over and 1cok at those 21 issues, using PRA whatever, whatever, to assign priorities 22 on the scale they have for assigning high, medium, low-23 priorities in terms of significance to safety in various 24 ways.
'25 And at that stage, I think this program is Heritage Reporting O (202) 628-4888 Corporation
197 I 1 finished.
2 As I pointed out, it does not satisfy our 3- suggestion that there be an ongoing type thing, although I 4 don't think.we ever said there should be an ongoing formal 5 program. 1tt didn't involve the' industry. It didn't involve 6 people actively concerned with operating plants. I'm sure 7 that some of the Oak Ridge people have operating experience, 6 but certainly not current operating experience.
9 The next step of course is for the staff to put 10 these things through the job of assigning priorities. As 11 usual,.the people that-do that were not at the meeting.
12 That is another group. But they checked up, and with the-13 backlog they have on priorities they thought they could get 14 through these 21 items by a year, which is fairly fast for
- O.l 15 them.
16 I'll repeat it. Of the 21 defined safety issues, 17 ten of them could be considered part of an existing issue.
18 But again, 'chey have to do the prioritization to decide 19 that.
20 Now, the next step for us in terms of this i
21 particular stage is to look at what they come up with on 22 priorities. That is where they will have examined the 23 safety significance, the possible fixes, et cetera.
24 Right now, these are just concerns. They may be 25 real, they may be minor, they may end up being major ones.
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'l MR. MICHELSON: It is probably well to note that 2 several of these came from existing generic and USIs put 3 into this pot and now they are moving back out. It is just 4 a moving on down the line process. These issues are not all 5 new.
6 DR. SIESS: Most of them came out of A-17, 46 and 7 47.
8 MR. MICHELSON: Yes. And they were already in 9 there.
10 DR. SIESS: Yes. Well, we thought they were. And 11 that is really what started it. When we got into 47, we had 12 a lot of items, and some of them got eliminated. And now we 13 tell them to put them back in and look at them. They may 14 get thrown out again, I don't know.
15 But since there is not much to discuss or to 16 criticize or to review in terms of these particular items 17 until they come in with prioritization, that ends that part 18 of our business.
19 We thought that the 31 items they had concerns 20 with were good ones. We are not quite sure that they have 21 captured all of our concerns. And we know of course that 22 they haven't talked to operating people.
23 We were a little bit concerned that there does not 24 seem to be any strong industry interest in this. I don't 25 think we have gotten the attention of industry on systems Heritage Reporting Corporation
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]p 1 interactions. Not at the level,.not as a separate item. I 2! am sure they are concerned and they are interested and they
- 3. wot:ry.about it. And I think some people think that' systems
- 4; interactions is the whole cockeyed thing. And we are not 5: talking simply of systems interactions.
We are talking' 6 about adverse systems interactions.- Most of these are what.
7 you could call subtle, not obvious, systems interactions, 8 and unexpected systems interactions.
9 Now, we know that there are going to continue to 10 be those and we just hope that when they happen they do not 11 get solved on this plant and then.go somewhere else.
12 Now, I think that the subcommittee decided they 13 didn't see.any need to write a letter, because this thing is 14 not at a stage to comment on.
.O 15 If we were to make a comment at this time, I think 16 it would-be on the fact that the scope of this program is 17 rather limited, it is not ongoing, it is certainly not going 18 to solve the overall problem of multiple system responses or 19 ' failures to respond.
20 But we've said that and we've said it, and I think 21 naying it again at this time is not going to change what 22 this group and the staff is do!.na.
23 They are.trying to, I won't say put out brush 24 fires, because these aren't, but they are trying to satisfy 25 us. And they don't, I'm not sure their hearts are in it Heritage Reporting Corporation O- - (202) 628-4888 l
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-3~ And if we want more' industry concern, if wn want-4 another Indian Point systems interaction walkdown type
-5 thing, then'I think we are going to have to go to a 6 different area with the Staff.
7 I think we ought to keep it on the_ front burner, 8' and when these prioritizations como through be sure.that we 9 look at'them in terms of this program so that we know what i
10 they are.
I 11 MR. MICHELSON: You might want to mention the 12_ relationship of'all these issues to the IPEEE program.
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i 13 DR. SIESS: Some of them, I don't know that there '
14 is a relation yet, Carl. Some of them they may be resolved O. 15 by including them in the IPE.
16 MR. MICHELSON: Well, the fact that they may or 17 may not be included I think is.an important consideration, ;
i 18' because if anything is to happen in the near term it would j i
19 have to be I think through that program.
20 DR. SIESS: Yes. The thing is we are dumping q l
21 everything into the IPE. You said IPEEE.
22 MR. MICHELSON: Yes.
23 DR. SIESS: These aren't necessarily.
24 MR. MICHELSON: Many of these though are the, 1
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1 majority are.
2 'DR. SIESS: What is coming out,_not just from 3 that, in the last few days or weeks, the IPE, I think, is 4 going to end up requiring a PRA. But just doing.a PRA does 5 not cover these things,.nor does this one when we talked.
6 about the shutdown outside the control room. And we were 7 talking about the design study where they had done their 8 -fault trees right down to the contact level. I can't 9 -believe many of them are going to do that. And I think w, 10 need to continue to think about how systems interactions.can 11 'be denit with. This is not the end of it, and they are not 12 going.to go away. I don't know whether we are ever going-to 13 solve the problem by singling out systems interactions on a 14 particular. area.
15 DR. SHEWMON: It sounds almost like death and 16 taxes to me. But I don't know.
17 DR. SIESS: Well, there are going to continue to 18 be systems interactions. What I~think is important is that 19 it be understood thet the root cause, that the generic 20 significance of it is underotood and paseed along to other 21 people.
22 I suspect there have been things happen out there 23 that somebody did not recognize as a potential serious 24 interaction and therefore did not call attention of the rest 25 of the people to it. And it is partly a onestion of
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. 1 awareness'of the kind of thing you are looking for and 2 communication with others. I don't think it is ever going l 3 to be handled by regulation.
4 DR. KERR: Chet, I think that is an important 5 point.
1 1 6 I'm not sure if the Staff is still looking for a 7 recipe you can use to make a paper study. You and Carl 8 certainly know that that is not going to work. But I'm not 9 sure that that is clear to the people in the Staff who are 10 responsible for these programs.
11 DR. SIESS: Well, I think we need to talk to the 12 staff more on some of these things, because this particular 13 batch of staff and this particular record is simply to try 14 to take care of concerns that we and some other people have
%) 15 expressed, to get them into the generic issue mill, which is 16 where they can do something with them.
17 They know how to handle generic issues. The Staff 18 knows how to write regulations. The Staff kr e ws how to 19 write rules. The Staff doesn't know how to write policy 20 papers. We know that. There is only certain things the 21 Staff can do. And I'm not sure that they always know their 22 limitation.
23 What can we do? We could get the industry more 24 involved. Maybe they are move involved. I don't know. But 25 again, awareness and communication I don't see.
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203 1 MR. MICHELSON: I have.a little difficulty with 2- :some of tne arguments, Chet. The classical example which
.3 even the committee agreed not to consider was the cases'in 4 A-46 when we were looking at the seismic disturbance of-5 tanks,'and if they fall over we worried about the physical
.6 impact upon safety-related components. But the committee 7 refused to take issue with whether the water in the tank had 8 to be' considered or not.
9 DR. SIESS: I don't know what you mean by the fact 10 that the committee refused to take issue.
11 MR.-MICHELSON: Well, we put it in our letter.
12 DR. SIESS: We shouldn't be putting things like 13 that in a letter. We should be generating those as generic 14 items.
(:) 7.5 MR. MICHELSON: It isn't even generic. Well,.it's 16 . generic, yes. But it certainly is do-able today. You don't 17 need to go through another five years of delay to decide 18 whether you have to account for such things in doing your 19 walkdowns.-
20 DR. SIESS: But if we want to identify that as a 21 generic issue, that is diff'erent than putting two sentences 22 in a letter.
23 MR. MICHELSON: Well, it has been a generic issue.
24 It just didn't end up in A-46, it got put back into the MSRP 25 again.
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() 1 DR. SIESS: But there is a mechanism for 2 identifying specific things as generic issues and seeing if I
3 somebody works them through, prioritizes them, and they I 4 stand up to thr.t test, they will get worked on.
5 But I'm not sure that tossing things into a letter 6 on one subject gets the kind of attention a generic issue 7 would. And I worked up some procedures a few years ago for 8 generating generic issues in the ACRS, which can be a chore 9 if you do everything the Staff says you ought to do.
10 The idea was to do it with the aid of a fellow, 11 and then do researching on it, and writing on it, and we 12 simply present the staff with a generic issue and then it 13 goes into the mill.
14 And if you don't want to do it through the ACRS, 15 you can do it as a private citizen. They will take them 16 from anywhere. Even from a lawyer.
17 But I think if the ACRS has specific concerns at 18 that level, there ought to be a paragraph that says this 19 should be considered a generic issue and let the staff hire 20 Oak Ridge to define ity but not mention it as an example of 21 something, of a class of things.
22 Too many times we mention these individual things 23 as an example of something, which is making it too big, and 24 the Staff don't like things too big. They have got pressure 25 on them to resolve things. And if you give them an issue
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,_- 1 that says the safety of nuclear power plants, that one is a 2 little hard to handle.
3 One thing they did here is they've got abcut six 4 of these items that relate to seismic. It would seem 5 logical to groups those in all seismic interactions. But 6 they have separated them and if they can eliminate some of 7 those by separating them, fine. If they lump them all 8 together, they still keep this large issue. And let's face 9 it, the system we are involved in, the process just can't 10 handle large issues.
11 Look what we did with TMI. Five hundred generic 12 requirements came out of TMI. That was a large issue.
13 I think that we need to think about how we get 14 these things before the staff and before whoever, and right 15 now I don't think it is clear enough for the Commission to 16 say we want to change the generic item, generic issue 17 process. I think we should take advantage of it.
18 MR. CARROLL: You mentioned, Chet, and I think 19 that it is correct, that there is a lack of industry 20 interest in this subject. And I think I can probably guess 21 why.
22 Would this be something we might want to ask Joe 23 Colvin when he comes in next month to comment on?
24 DR. SIESS: I think if you took issue by issue and 25 subject by subject, with the industry, I'm not sure --
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1 'MR. CARROLL: If you just say, solve the systems 2 interaction l problem.
3- ER. SIESS: Is this an IFFO-type thing? INPO is 4- .cperations. .But this is usually hardware.
5 MR. WYLIE: Itfis a programmatic problem within 6 the.particular utility, I think. And I can-speak for the-7- utility I came from, and they don't have a group looking for.
8 systems interaction, this kind of thing. They look at all 9 the events that take place and analyze the plants to see 10 whether or not they'would be vulnerable to those events and 11 this kind of thing and look at the LERs and all tnis.
12 .But a conscientious effort to go out and really 13 look at what if type things, they don't do.
14 DR. SHEWMON: Did all the plaats do a walkdown of
.O 15 the systems interactions?
16 DR ~ SIESS:
. No. As far as I can remember, we 17 ' required or requested it of Indian Point, in connection with 18 what I don't know, it was the key thing or something.
19 Indian Point submitted a plan that involved a 20 multidisciplinary team during the walkdown and I can't 21' ramember what the results were, but we thought that what-22 they did was a good job.
23- Now, we have also recommended in a letter that 24 there should be multidisciplinary teams 9stablished by the 25 utility simply to look at this.
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l' DR. FHEWMON: When are we willing'to quit flogging 2' this tired horse? It seems to me that you've got something-3 where you can't ever prove you have a solution and so it is 4 something you have to keep an awareness of. But it.seems to 5 me if.we cannot figure out a solution and they can't either, 6 except we are sure it's never closed,. maybe we should go 7 look for something where we could do mora fruitfully our 8 flogging.
9 MR. MICHELSON: Well, there are solutions to many of'these questions.
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10 First of all, though, it has to-be 11 identified to the utility that it is a requirement to go and 12 implement such a solution, or first of all go look to see if-
~13' you've got the problem.
14 .DR. SIESS: I don't think then can write O 15 requirements for all these things.
16: MR. MICHELSON: Oh, I'm sure they can't.
17 DR. SIESS: And I still don't think-you can handle 18 systems interactions by regulation much more than we have 19 now. The staff pointed out in the very early days of the 20 standard review plan that the requirements of single failure 21 criteria and the separation criteria take account of a lot
- 2 2 of these things and take care of them.
23 We wrote a letter when we stated that this was an 24 ongoing issue, and it is not a dead horse, because the next 25 accident is going to be some unsuspected type of thing.
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208 1 DR. SHEWMON: I said a tired horse. Not moving
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2 towards the barn at all.
3 DR. SIESS: But I think the key is awareness.
4 MR. WARD: Wait, Chet. You said the next accident 5 is going to be some sort of serious systems interaction. Do 6 you have anything to back that up?
7 DR. SIESS: No. If I knew, it wouldn't happen.
8 MR. WARD: No , I mean in a general sense. Have 9 accidents that we have had, are they attributable to this 10 sort of thing?
11 MR. MICHELSON: I suspect virtually every accident 12 we have had has had some amount of systems interaction in 13 the process of evolution of the accident. It started with jg 14 the systems interaction. It was triggered by an air systems
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15 interaction. That is what triggered the system into the 16 final fact that the safety valve stuck open. That's why I 17 gave the response I did. Every event involves systems 18 interaction.
19 DR. SIESS: Maybe we should quit calling these .
20 things systems interactions and find a better name for it 21 now, multiple system responses doesn't appeal to me. It's 22 not very sexy. But the definition of unexpected adverse 23 interactions, single failures don't bother, but single 24 failures that cause other failures that nobody has thought ;
25 of is part of the problem here, and failure modes and
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1 effects analysis, even when they have done them, usually
(~)T 2 aren't thorough enough. As Carl has pointed out, they look 3 at fire but not at smoke or they look at water but not at 4 heat.
5 It takes imagination. I think it takes more 6 imagination than it does multidisciplinary teams.
7 MR. CARROLL: And it takes a willingness to stick 8 your neck out, if you will, to go look for something that 9 you may not want to find.
10 MR. MICHELSON: Sort of like a witch hunt.
11 MR. CARROLL: I think that is one of the problems 12 you have in getting the industry into it.
13 DR. SIESS: Because once you have found a s 14 potential interaction or postulated a potential interaction, t
15 that still does not mean it is serious,, You then have to 16 evaluate it. If you don't have a PRA you do it on some 17 deterministic basis and if you do have a PRA it may not be 18 detailed enough. And the industry can see a can of worms.
19 I'm not the systems interaction subcommittee. Do 20 we have one?
21 MR. WYLIE: No. We don't even want it.
22 (Laughter) l 23 MR. MICHELSON: That was in a different time 24 regime, of course, Chet. We were not quite as intelligent
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25 or understanding about some of this problem as we are today.
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- f. :1- It'sibeen a long educational process since that Indian Point
[2L ' study.
3- MR. DUUU): We developed this elaborate tool called
- 4 PRA,'which looks for systems interactions of a sort. What SL we are calling systems interactions is the-type of l <
6 interaction that you don't develop from the intended 7 relationships among systems in plants.
8 MR. MICHELSON: Right.
9 MR. WARD: And that is what PRA.--
10 DR. SIESS: Unanticipated.
11 MR. WARD: Unanticipated relationships.
12~ MR. MICHELSON: It deals with the anticipated 13 relationships among systems.
14 BGR. WARD: Those that can be anticipated from the 15 desig n .
16 MR. MICHELSON: And that you can.model.
17 DR. SIESS: If you put it in a fault tree, you've 18 . anticipated it. If it is not in the fault tree, you are not 19 going to find it.
- 20. MR. MICHELSON: So it is not any good for the 21 first cut. It is good for the second cut when you finally 22 realize.it might exist. Then.you can start modeling it into 23 your PRA. I think PRA can handle it if you know how to 24 model it well enough.
25 DR. KERR: I had thought that we were going to
'O rie 9e x rerei 9 (202) 628-4888 cereer eie-
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211 ll .have.this seasion to permit those-of us who were not at the- -
.O- /2. subcommittee meeting to listen to'the' staff: presentation.
3 Oh, that's right. The staff is not here. Okay.
4 DR. SIESS:.'What they defined for the MSRF'is the 5 potential potential for multiple simultaneous; failures --
L i
6 'this is one -- multiple-simultaneous failures in non-safety 71 related controls systems to have an adverse impaction safety 8 related' protection. systems.
9 MR. WARD: That one of the concerns. i 10 DR. SIESS: But again, adverse interactions,.and 11 it's'the potential. It may turn out there is no potential.
12 I think'with systems interaction, we may be better off with 13' different. terminology.
14 MR. CARROLL: I.think that scares people. I think-15 it just sounds so broad that nobody can get_their arms 16 around it.
17 DR. SIESS: I think we have come a long way. And 18 I. don't think we are-ever going to get the PRA, computer 19 paper, or walkdown, in Alaska. But in the future they are 20 going to happen. There are going to be precursors that you 21 see. So the key words tc ae are awareness and
- 22. communication. Recognize them when you see them, tell other 23 people abou it, and this sort of proliferates.
24 MR. MICHELSON: Of course then it means an 25 educational process, and how do you get the educational Heritage Reporting Corporation
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2 Some people understand theseithings, some don't.
3 But more.need so.
- 4 DR. SIESS
- I think you are right. I'm.not sure'
~
5 the Staff understands-it. I suspect there are people in the 6 industry that understand it and do it, but I can't say it's 7 true of all of them.
8 So I think it is education. It may be partly 9 education of us to know what other people are doing and 10 thinking.
11 So I suggest on this thing we follow what they.do 12 with these 21 items.-
13 MR. MICHELSON: How will you determine if they are 14 important, Chet?
E :
15 DR. SIESS: Organization of -- -
16 MR. MICHELSON: Yes, but that calls for modeling 17 and so forth, to get some numbers. How are you going to 18 model it?
19 DR. SIESS: That's their job.
20 MR. MICHELSON: It's a plant specific problem.
21 DR. SIESS: Let's assume that they have done it and modeled it and come back and assigned it or dropped it.
23 And at that point we argue with them. How did they get to 24 drop them, et cetera, et cetera.
25 But if it turns out that all 21 are drops, and we O Heritage Reporting Corporation (202) 628-4888
i 213 1 3 i
(} 1 can't beat them on the arguments, we really learned 2 something then.
3 I don't believe it's going to happen. But on 4 these items at this stage on specific items, I think we 5 wait.
6 There are two other things that come out of this.
7 One is we can generate gen 6ric items of our own, do it l
8 outside of standard letters. And the other is that there j 9 should be a continuing effort to see what could be'done or 10 what is being done to maintain awareness, communicating 11 experience. And that should be done through appropriate 12 subcommittee, seminar, or whatever.
13 MR. MICHELSON: Now you are talking about system 14 interaction awareness.
15 DR. SIESS: Maybe we could find a better word.
16 MR. MICHELSON: Whatever the word. It is an 17 educational process, I think. The only resolution of this 18 in the short term has got to be an educational process to 19 the point where people can look at their own plant-specific 20 situations.
21 DR. SIESS: I don't think there is any such thing 22 as an educational process in the short term.
23 MR. MICHELSON: Well, it sure is a lot faster than l
24 talking about five years of generic issue fiddling around,
- 25 Chet, there's just no doubt.
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(}' 1 DR. SIESS: The communication process is long 2 term, don't kid yourself.
3 MR. CARROLL: Is there agreement that this would 4 be a good item to ask, or to talk to Crlvin about,- to tip 5 him off?
6 DR. SIESS: I think so.
7 MR. CARROLL: Joe is going to come in in the 8 August meeting, right? So can somebody convey to him that 9 'we want to --
l 10 DR. SIESS: We'd like to talk systems interaction, 11 and he says what?
12 MR. WYLIE: It's not that. I think what you are 13 talking about is --
14 MR. CARROLL: Communication and information 15 sharing.
16 MR. WYLIE: What the industry can do in this area.
I 17 MR. CARROLL: Right.
l 18 MR. WYLIE: But you know, these things that have 19 been identified are more generic type things that are common 20 in all plants. But a lot of these plants have plant-21 specific situations that only the utility can look at.
22 MR. MICHELSON: And maybe only they know about.
23 MR. WYLIE: And only they know about. And only it 24 would happen in that particular plant. And the utility is 25 the only one that really can analyze those things. And I
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() 1 think that is the message that Colvin ought to hear.
2 DR. SIESS: Well, somebody is going to have to do 3 something to convince the industry and maybe me that this is 4 serious.
5 MR. WYLIE: I know from my own experience, we 6 formed a group back about 15 years ago. We called it the 7 safety analysis group.
8 And that was their marching orders, was to do this 9 type of thing. That group doesn't exist any longer. Bill 10 Razen over at NUMARC, he came out of that group. They 11 dissolved that group and they put these people different 12 places. Johnny Elliott is gone to Oak Ridge and Razen is at 13 NUMARC. They are the stepchild, the unwanted stepchild in 14 the utility.
15 MR. MICHELSON: The organization that I headed in 16 TVA, Nuclear Systems Analysis, was precisely that, and 17 several other responsibilities.
18 And yes, some of the things we found were fixed, 19 some of them weren't fixed. Some of them have never been 20 fixed.
21 And we didn't find them all, either. You'll never 22 find them all. There's always new ones. As you get new 23 insights from new events you have to go back and re-examine 24 your situation with this new knowledge.
25 DR. SHEWMON: The feeling is the IFE will or will
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{} 1 not help in this area?
2 MR. MICHELSON: It will help. It won't fix them 3 all.
4 DR. SHENMON: Nothing will fix them all. When I 5 said death and taxes earlier, I meant it. There's going to 6 be systems interaction as long as there's complex systems.
7 MR. MICHELSON: I've heard the word "all" kicked 8 around so much today already that I want to make sure that I 9 don't, I would never advocate you can find them all. I 10 don't think anybody in their right mind would advocate that.
11 MR. WYLIE: I think the IPE will do one' thing. It 12 will make the utilities get a group of guys together to do 13 the work and they will be in a position to do this kind of 14 thing.
\ l 15 MR. ChAROLL: There is your interdisciplinary 16 group if you are really going to do an IPE right.
17 MR. MICHELSON: That is the most logical place.
18 But that means you have to get some of this going soon j 19 enough to get the educational process into those teams. And 20 that doesn't mean wait for the generic issue five years from 21 now to be resolved, or ten years from now, whenever.
l 22 DR. SIESS: Let me read you two paragraphs from l
23 the letter we wrote in August, 1988, on A-176 24 "Although the proposed resolution of USI-A-17 does 25 not represent a comprehensive and probably not a final
() Heritage Reporting Corporation (202) 628-4888
217 f 1 resolution.of our concerns about systems interaction, we 2 believe that the potential for continuing effort to the 3 MSRP, which is not continuing, is a step in the right 4' direction. In addition, and equally important, systems
~
5 interactions, some of which may be-adverse to safety, will 6_ continue to be revealed by operating experience in existing 7 plants. These should be evaluated by the staff as they 8 occur and the lessons learned incorporated into.the 9 requirements and practices of the agency. In summary, we 10 'believe that the proposed resolution has a real potential to 11 reduce risk. Since the. systems interactions-issue is so 12' . comprehensive, it is unlikely that it will ever be resolved 13 in the sense that all adverse systems interactions will'be 1- 14 found and corrected. We are willing to accept'the proposed O' 15' ' resolution. This acceptance is based on the expectation 16 that the efforts of the MSRP in the search for systems 17 interactions and operating experience will be continuing."
- 18. DR. REMICK: What wise group said that?
19 DR. SIESS: I don't think the MSRP has resolved 20 those concerns and I would leave you with one last thought:
i 21 maybe we could find a better term than systems interaction, 22 and start'over.
23 MR. CARROLL: It is agreed then that somebody is 24 going to tell Colvin what our concerns are?
25 MR. MICHELSON: It would be useful to him if you Eerf'; age O Reporting Corporation (202) 628-4888
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(' 1 had a copy of the draft of the MSRP program at Oak Ridge, 2' but I don't know that we can yet give him a draft of that.
'3 But that would be an educational process for him so he knows 4 what we are talking about.
5 DR. SIESS: Well,'except that the MSRP has just 6 developed 21 generic issues.
7 MR. MICHELSON: Well, it gives him a flavor for 8 what we mean by systems interaction. Because it means many 9 things to many people. He may come and give you a whole 10 hour on the wrong thing.
11 DR. REMICK: So is that it, Mr. Subcommittee 12 Chairman? All right.
13 The next item on the agenda is the Comanche Peak 14 Nuclear Station, Units 1 and 2. J. Carroll is our 15 Subcommittee Chairman, so J., I turn the meeting over to 16 you.
17 MR. CARROLL: ACRS originally reviewed Comanche 18 Peak and wrote a letter on November 12, 1983, stating that 19 Units 2 and 2 could be operated at power levels up to 3475 20 megawatts thermal.
21 It is all in Tab 9 of your book and the letter is 22 included in that tab.
23 Comanche Peak fell on hard timesf shall we say, 24 following that and at the present time the licensee is 25 expecting an operating license in October of this year.
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219 1 We debated at a couple meetings ago as to whether 2 we wanted to re-review the project or write a new letter. I 3 guess the decision was that we wanted to get a briefing by 4 the Staff and the applicant on the present status of the 5 plant.
6 So with that I will turn it over to the Staff, I 7 guess, who is going to begin the presentation.
8 MR. GRIMES: Good morning, gentlemen. My na:.ne is 9 Chris Grimes. I am the Director of the Comanche Peak 10 Project Division. And the Staff has prepared a presentation 11 to brief the committee on the status of the Comanche Peak 12 operating license application.
13 We brought with us today other representatives 14 from the Comanche Peak Project Division who will make the
,O
(_) 15 presentation, including Phil McKee, who is the Deputy 16 Director of the Comanche Peak Project Division; Jim Wilson, 17 who is the Assistant Director for Projects; Jim Lyons, who 18 is the Assistant Director for Technical Programs; and Bob 19 Warnick who is Assistant Director for Inspection Programs.
20 And he had his staff are located at the Comanche Peak site.
21 As Mr. Carroll noted, the ACRS completed its 22 review in November of 1981 at the time when hear;ings had 23 just begun on the Comanche Peak operating license l
24 application.
25 Subsequent to that time, issues were raised in the g Heritage Reporting Corporation g_j (202) 628-4888 1
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220 1 hearings and in the NRC's review and inspection, concerning
(~) '
2 the plant design and construction. The efforts to resolve
. 3 those issues are nearing completion and the Staff felt that 4 it would be appropriate to brief the ACRS on the events that 5 have transpired since its review.
6 We will attempt to describe the activities that 7 have occurred over the last eight years so that the 8 committee can have a clear picture of the plant condition 9 today. That will not be easy in a two-hour meeting.
10 We will broadly describe TU Electric's programs 11 and attempt to answer all of your questions. Please keep in 12 . mind that we could spend the whole meeting on any one for i
13 the topics that we will discuss, but we want you to have an 14 understanding of all of these topics.
tO
(_) 15 We h&ve asked Texas Utilities Electric Company to 16 come today and briefly describe the plant and their current 17 organization. However, the NRC Staff plans on making the 18 bulk of the presentations. TU Electric is prepared to 19 answer any questions that the Staff cannot.
20 At this time I would like to turn over the podium 21 to Mr. Counsil, to introduce Texas Utilities Electric's 22 representatives who have come today, and a description of 23 the plant and their organization.
24 MR. COUNSIL: Good morning. My name is Bill 25 Counsil and I am Vice Chairman of TU Electric. I think I i
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{} l have known many of you for a large number of years and it is 2 a pleasure to be back in front of you again, although with a 3 different company this time.
4 I think those of you who were here in 1981 talked 5 to us about Texas Utilities Electric Company and Texas 6 Utilities Generating Company.
7 About a year and a half ago we changed our company 8 logo for the Electric Company and we are now known aa TU 9 Electric.
10 Representatives of the Generating Division of TU 11 Electric I have with me today, and I would like to point to 12 them and have them just wave their hands at you or whatever:
13 Bill Cahill, who is the Executive Vice President-Nuclear 14 Engineering and Operations for TU Electric; Austin Scott, 15 who is the Vice President of Nuclear Operations; John Beck, 16 Vice President of Nuclear Engineering; Jim Kelly, who is the 17 Plant Manager, and some of you know him from Northeast 18 Utilities; Roger Walker, who is our Manager of Licensing.
19 Now, I note with interest, in your 1981 letter, 20 that we should have more experience. Now, the six 21 individuals, including myself, that we have here with you 22 today have a collective 140 years of nuclear experience, 103 23 of which is commercial experience, 37 Navy. And three of us l
1 24 have held previous SRO licenses.
25 So I think we are coming up on that curve pretty
() Heritage Reporting Corporation (202) 628-4888
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1 fast as far as experience and now we will go into that a
(~}
s-2 little bit more in a few minutes.
3 Obviously, I have thrown up the picture of the 4 plant. If'you all desire at some point, you are invited to j 5 God's country and walk, but I suggest, I suggest very much, 6 don't do it at this point in time, wait until the Fall.
7 It's a little warm now.
8 Background on the plant itself. The owners 9 presently at Comanche Peak are Texas Utilities Electric 10 Company. And truly we have a 100 percent ownership. I 11 listed two others up there: Texas Municipal Power Agency 12 and TEX-LA Electric Cooperative.
13 You may have read we had a suit going and have 14 settled, and we are in the process of settling out and O 15 transferring their ownership shares to TU Electric. So 16 shortly, we will have 100 percent ownership of the plant 17 again.
18 Operator: as I indicated, TU Electric.
19 Location: 2-unit site in Somerville County, the 20 picture I just showed you. That is about 65 miles Southwest 21 of Dallas, Texas, in the Fort Worth Metropolitan Area, truly 22 about 45 miles Soothwest of Fort Worth.
23 Plant design. Westinghouse pressurized water 24 reactor.
25 Architect engineer. The original AE was Gibbs &
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4 223 1~ Hill Engineering Corporation. In 1985, Unit ~ Number 1 was O.. '2 essentially complete and as you are well aware, we were in a 3 .very litigious Atomic Safety and Licensing Board. We had 4 many pieces of work to review and at that time made the 5' decision that it would be better to have the work reviewed 6 by parties that were never associated with the plant in the 7 past.
8 So consequently, we changed to Stone & Webster-
$ Engineering Corporation to conduct the review and I believe 10- NW Grimes' staff will have more to say about that in a 11 moment, about the reviews that we have done on the project.
12 Stone & Webster had the prime piece of'the review.
~
13 We also had EBASCO Services on site as well as IMPELL 14 Corporation. And the main reasons for the three. diverse
( 15 engineering organizations was we needed a great many 16 engineers to facilitate the review in a short period of 17 time.
18 The constructor at the site was and still is Brown 19 & Root.
20 The nuclear steam supply system characteristics, 21 as I indicated, Westinghouse. It's a four-loop, two safety 22 train plant. It is a 12-foot core. I think this 23 organization has seen that before. And it is rated power, i
24 3411 megawatts thermal, similar to Byron, Braidwood, 25 Millstone III, Catawba, a vintage plant. And 1159 megawatts Heritage Reporting Corporation
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224 1 electric.
2 It is a steel containment, reinforced concrete.
3 Current schedule. Our licensing milestones that 4 we have had in the past or in the present.
5 December 1974 construction permit; July of 1988, 6 and more by the Staff on that, we successfully negotiated a 7 settlement with the then current intervenor and had 8 dismissal at the ASLB proceedings; our current schedule says 9 estimated licensing and fuel load in October of this year.
10 During this period of time, in the 1984 and 1985 11 time frame, the ASLB process, we had time to effect a lot of 12 changes and updates of organization as well as plant. We 13 did do that in fact during that period of time and added to 14 the organization.
() 15 I have only brought here on this chart a very 16 small piece of a 1300-person organization at this point in 17 . time.
18 But in that organization, I wanted to point out to 19 you, I have already mentioned, Mr. Cahill, the Executive 20 Vice President. And I have listed the Senior Vice 21 Presidents, Vice Presidents, Plant Managers, Managers of 22 Startups, so forth, down one train; Director of Projects, 23 Construction, and Chief Engineer; and then Nuclear 24 Engineering, Mr. Beck's organization.
25 The little numbers in parentheses on the side are Heritage Reporting Corporation
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(} 1 nuclear experience. And this is only one layer of 2 management at TU Electric and that adds up to over 330 years 3 of experience in nuclear power.
4 And I did very much want to point that out to you.
5 It was one of the things that you had in your 1981 letter, 6 that we did need more experience.
7 And also I vould like to point out too that during 8 this period of time, since 1985, in particular, our 9 operating organization, both the operations personnel, those 10 who are senior licensed, reactor operator licensed and 11 auxiliary operators, as well as our health physics staffs 12 and members of management, have been out to many of the 13 operating plants in the country for long tours of training.
14 Mr. Kelly's operating staff helped Braidwood go 15 through their pre-operational test program and start up that 16 plant.
17 In addition to that, their health physics 18 organizations have been in and worked at many refueling 19 outages at places such as Farley and Virgil Summer.
20 So we have attempted to bring to bear a great deal 21 of operating experience on our plants.
22 We are here today to assist the Staff in any way 23 we can in answering your questions. Should you have 24 questions, please call upon us.
25 And again, it is a pleasure to be here, and I will
() Heritage Reporting Corporation (202) 628-4888
! LLf 226 1 -- turn the? meeting.back over.to Mr. Grimes at this time.
- 2 DR. REMICK: Bill, just a couple'of quick t
3 questions'that come to mind.
4 What is your philosophy on=STA? Are you. going
!5 with the separate STA or one that.is the second SRO? Is 6~ there anything unusual about'your staffing?
7 MR. GRIMES: Mr. Chairman, if I might?
8- DR. REMICK: Yes.
9 MR. GRIMES: Part of the Staff's presentation is .
- 10. to discuss their staffing.
11 DR. REMICK: That is fine. Okay, we can-wait' 12 then.
13 MR. COUNSIL: Are there any other questions on
,14 organization, things of that nature?
() 15 DR. KERR: I trust that all of this NRC Staff D 16 attention that Mr. Grimes indicated, gives you a warm 17 feeling about your operation.
18 MR. COUNSIL: Dr. Kerr, --
19 (Laughter) 20 MR. COUNSIL: What an opportunity.
21 (Laughter) 22 MR. COUNSIL: Yes. I had a very warm feeling 23 about the design and what the operations for this plant will 24 in fact be. It is probably, and in fact I am quite certain l'
12 5 it is, the most heavily scrutinized plant in the history for i
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({ 'll .the United States, both by the Nuclear Regulatory Commission 2' Staff,;by the Intervenor, who is there full. time at our 3' invitation as a result ~ of the. settlement, and by ourselves.
4 DR. REMICK: All right'. Shall we continue with 5 the: Staff, then?
C MR. GRIMES: I would like to introduce Jim 7 Wilson,- Assistant Director for Project s in the Comanche Peak 8 Project Division.
9 And he is going to address the issues that the 10 ACRS identified in their November 17, 2.931 letter to then 11' Chairman Palladino.
12 MR. WILSON: Our committee was concerned with a 13 number of issues. They identified them in their 1981 letter.
14' published in Supplement One.
15 The Staff has published periodic updates to_the 16- status of these items, and SSERs associated with the safety 17 review, and the Advisory Committee has been provided with 18 copies.
19 I will briefly summarize each of these, the 20 current status of each of these issues, at length.
21 The committee was concerned with the use of N-16 22 detectors in the reactor protection system because this was 23 to be the first commercial application of this system.
24 Eight years have gone by and this is still the 25 first commercial application.
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2 system was re-scrutinized by Westinghouse and TU Electric 3 and they concluded that this system is still viable.
4 The system will be calibrated during startup and 5 power ascension and its performance will be closely 6 monitored by the Staff and TU Electric.
7 Tech specs contain operability requirements with 8 actions statements for setpoints, numbers of channels as 9 well as surveillance requirements.y 10 MR. CARROLL: There are no neutron detectors, per 11 se, at that power level?
12 MR. WILSON: There is other instrumentation in the 13 core for operation of the plant, but I think that trips are 14 generated from this particular system.
I) 15 There is an overpower trip and an overtemperature 16 trip associated with these detect'urs.
17 DR. KERR: For startup, you surely must uso 18 neutron detectors.
19 DR. REMICK: Mr. Kelly?
20 MR. KELLY: Jira Kelly, Plant Manager.
21 The 1016 only replaced in the standard 22 Westinghouse instrumentation package the TH RTDs. We have 23 all the standard nuclear detection that the Westinghouse 24 plants would have. It just replaces the TH. It generates a 25 different level for TH signal. That's all it does. So we Heritage Reporting Corporation
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,3 1 do have the source range, intermediate range and power range t'~~)
2 neutron detectors that all other Westinghouse plants, do, L: ~1
! 3 with the appropriate trips.
4 MR. WILSON: Another concern of the ACRS back in 5 1981 was tae lack of con.nercial nuclear power plant 6 experience.
7 As Mr. Counsil indicated, in the past eight years, 8 TU Electric has significantly strengthened their commercial 9 nuclear background at all levels through an extensive and 10 aggressive recruitment and hiring program, 11 Currently, TU Electric has an aggregate of 300-12 plus hours of commercial nuclear experience at the senior 13 management level.
14 This aggregate experience is greater than 400 O
\l 15 years if you count Navy nuclear experience.
16 This is just for senior management. If you go 17 down further into the organization, the number.of years of 18 experience gets very much larger. Also, there will be 19 operators with at least six months of hot ops experience at 20 a commercial PWR assigned to each shift.
21 In addition to hiring experience, qualified 22 people, TU Electric has been enhancing and broadening the 23 experience of their employees through rotational assignments 24 of operators and managers to other power plants already in 25 commercial operation.
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[(}. :1: Another" concern that ACRS expressed was that TU=
2.
'should_ compile a list of. technological matters which may.
3 have to be faced in future operations,~and identify sources 4' ofiskilled personnel and expertise that ought to be 5' available to. address these matters when needed.
6 TU Electric has drawn up a list of contractors and 7 expertise that they. expect to be needed to support 8 operation. This list is maintained and updated by their 9 procurement department.
10 Also, industry groups such as INPO and NUMARC and 11 EPRI have taken a role in assisting licensees'with 12 operational problems.
13 MR. CARROLL: Now, does tais say that they have 14 enough experience on their own operators to obviate the need 15 for --
16 MR. WILSON: :The shift advisor that was 17 contemplated back in the early 1980s, post-TMI, yes. They 18 have the experience on shift. They don't need to have 19 outside expertise on ship to provide hot ops experience.
20 MR. CiARROLL: Okay.
21 MR. WILSON: The ACRS recommended that the various 22 review groups include personnel from outside the operating 23 organization who are experience in the operation and 24 management of large commercial T is and related technology 25 as well as under other indep?ndent advisors with mature Heritage Reporting Corporation (202) 628-4888
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[~) 1 judgment about public safety matters.
U 2 The Station Operations Review Committee is 3 comprised of several members who have significant previous 4 experience at PWRs.
5 The Independent Safety Engineering Group is 6 comprised of degreed engineers and scientists, each with a 7 minimum of three years industry experience.
8 All these members have previous Nuclear Navy 9 experience.
10 MR. CARROLL: How about licenses?
11 MR. WALKER: Pardon me. Roger Walker, Manager of 12 Licensing.
13 The head of ISEG has in my memory about 18-19 14 years of experience. He is ex-Navy. E3 is SRO-certified on (J
15 a boiler, not SRO licensed on a PWR. He has a large degree 16 of construction and operation experience.
17 MR. CARROLL: He is the only cne in ISEG that has 18 held a license?
19 MR. WALKER: I think that's correct. We'd have to 20 double check. We think we have one more that is licensed.
21 MR. CARROLL: Okay.
22 MR. WILSON: The Operations Review Committee has 23 an aggregate of nearly 100 years of operating experience, as 24 well as two very senior independent consultants with an 25 aggregate of more than 65 years of industry experience and Heritage Reporting Corporation
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232 j3 1 there is a representative of the former intervenor group, 2 CASE (Citizens Association for Sound Energy) also on this 3 offaite corporate organization.
4 MR. CARROLL: Is that a result of a resolution 5 with interveners?
6 MR. WILSON: Yes, it is.
7 MR. CARROLL: To have a CASE member on the --
8 MR. WILSON: Yes, it is in the tech specs.
9 MR. CARROLL: Why is it in the tech specs?
10 MR. WILSON: That was part of the agreement, part 11 of the stipulation.
12 MR. CARROLL: Okay.
13 DR. REMICK: Just out of curiosity, what kind of 14 expertise does that CASE representative have?
15 MR. COUNSIL: Why don't I take that one?
16 (Laughter) 17 MR. COUNSIL: Mrs. Ellis, who is the President of 18 CASE, is a high school educated housewife. Don't hold that 19 against her. She has been involved at Comanche Peak for a 20 period of just over ten years. During that ten year period, 1 21 she has developed a working knowledge of many aspects of 22 engineering and construction. She does have technical 23 advice available to her through the CASE organization. And 24 in addition, though, we are going to put her through, as 25 aoon as she is available, a two-week training program on the Heritage Reporting Corporation O (202) 628-4888
H 233 1 -_ operations of a nuclear power pressurized water reactor,.
{( i 2- both she and her alternate -- I think many of you know her 3' -designated alternate is Billy Perner Gard'-- as far as the 4 alternate on the ORC.
5 And if-I might, Jim, one other thing. I don't 6: believe_Dr. Kerr's question got answered on the shift 7 technica1' advisor yet. And I believe you are off that 8 subject right now.
9 We do have SRO-licensed engineers as STAS on 10 shift. Or I guess it was-yours, Dr. Remick. 1 11 MR. WILSON: We wi11' amplify on that in a later j i
12 presentation. l 13 MR. COUNSIL: Good.
i 14 MR. WILSON: The ACRS also recommended that TU 15 Electric expand its studies of systems interaction and j
16 probabilistic assessment, so that it would have a better l 1
17 understanding of the Comanche Peak nuclear systems.
i 18 TU Electric has been engaged in the development 19 and implementation of programs.to evaluate the interactions. j 20 with components resulting from high and medium-energy pipe j 21 breaks, flooding, seismically-induced failures of non-22 seismic syrtems, structures and components, internally- ,
23 generated missiles and fires, j 24 These programs and activities were evaluated by 25 the staff in SSER 17.
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. s'* ll' ' DR. SIESS: These evaluations were made of the Q 2 desion,:'or of.the plant as-built?
/
3 MR. WILSON: Yes.
4 DR. SIESS: Did they involve walkdowns?
5- MR. GRIMES: If I might,_ Dr. Siess?
6 DR. SIESS: Yes.
7 MR. GRIMES: It was, of the final desigr.,-there 9- was a reconciliation process that they went through because 9 they were:doing a design validation at the same time that 10 they were. checking the construction.
11 The systems interaction studies were done for the 12 final design and.there was a method built into their process 13 for them t'o look at design changes that resulted as they
-14 went'through-and reconciled the design.that they wanted to
.O 15 get to with the construction that they actually found.
16! DR. SIESS: Okay. Now, I want to go ahead on this 17 and I am going te direct it to the licensee.
18 We had a lot of discussion about systems l 19 interaction in this :ommittee. And some of it occurred an 20 hour ~before you came in.
21 And there are systems interactions you can dig out 22 from the drawings, from the walkdowns,'from the plant, and 23 do something a'nout and there are going to be systems 24 interactions that show up later, as your plant or somebody 25 else's plant is operated and something happens, and there Reporting Corporation O Heritage (202) 628-4888
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a 235 11 was an. unanticipated interaction. I think it is inevitable.
4 2 These things are that complex.
3 To what extent.do your review groups have as part 4 of their assignment to Jook at-things that' happen, to.look 5- .for the unanticipated. interaction, adverse interaction, 6 ' extend that.to see whether there.are any others like it, and 7 to what extent does the. industry disseminate'that kind of 8 information from your plant to another one, or do you expect.
9 to get from other plants to yours?
10
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'12 13 14
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L 236 1 DR. SIESS (Continuing): That is more than one
/ 2 ' question, but I think you know what I am driving at.
3 MR. COUNSIL: Yes, Dr. Siess, I do know what you 4 are driving at, and let me see if I can take a shot at it 5 first. As part of our ongoing reviews when we went back 6 through the plant, I want to do that first, the design 7 validation of the plant, we went back and looked at every 8 issue of safety evaluation report or significant event 9 report from the Instituto of Nuclear Power Operations and we 10 looked at all of the significant operating experience 11 reports from the Institute of Nuclear Power Operations.
12 We have looked at all bulletins, circulars and 13 notices issued by the Nuclear Regulatory Commission and 14 applied those for our two over ones and missile guidance in
() 15 that program at Comanche Peak on the re-review. In addition 16 to that, as those issues come up in industry even today, 17 wherr SSERa come up as an example from the Institute of 18 Nuclear Power Operations, those are in fact reviewed for 19 applicability to our plant on an ongoing basis. And 20 similarly the circulars and notices, and those are all filed 21 at the plant after review and after action by us.
22 That is the charter of the independent safety 23 engineering group, that is part of their charter. It is 24 also beyond that charter though. Every piece of information 25 that comes out of the Nuclear Regulatory Commission or the Heritage Reporting Corporation
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(} 1 Institute of Nuclear Power Operations or from our own-2 organization as an 4ndustry NUMARC,-I also personally 3 review.
4 And as Bill can attest, there have been a great j 5 many things that I have reviewed and sent to him that said 6 hey, take a 1"4 at our plant, I believe that it is 7 applienble.; So we do have a very active program and you are 8 entirely correct that things will come up during operations 9 and have come up in the two over one area already during 10 this period of time.
11 DR. REMICK: If I follow up with a question on 12 that. You say that ISEG has the responsibility for doing 13 that..
14 How do you assure that that gets into training 15 programs if appropriate?
A6 MR. COUNSIL: Jim, do you want to take that or 17 Austin?
18 MR. SCOTT: Austin Scott, vice president of 19 nuclear operations. We have a very aggressive industry 20 experience program keeping very close track of all of the 21 industry experience that we have gathered from INFO or the 22 NRC distribution system. And we have a very meticulous 23 program for outlining the action and keeping track of it 24 through to completion through a group that I have called 25 plant evaluation working directly for me. ,
i l
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^ *238 l.L _. There have been several audits to make sure that' 2- we have~run the corrective action. INPO has'been very 3' consistent'that we follow the action all the way through to 4 conclusion ince 'ing-the training and the procedures'and._so 5 forth. I think that.we have a very aggressive' program for 6- making sure that this is disseminated and kept current.
7 DR. SIESS: I do not know whether'we invented the 8 term systems interaction, but we have certainly popularized 9 it.
10- Is that a term that is used extensively in the 11 industry or consistently or do you have other words'for the 12 kinds of thingsLthat we talk about?
13 MR. COUNSIL: I think that in the short-term-14 jargon in the industry that it is referred to in some
'O_ '
15 quarters as systems-interaction, when one looks at the
-16 physical interactions of flow systems if you will, water, 17 . systems and things of that nature. But I think that most 18 people refer to it more from the seismicity aspect of"two 19 over one, but it is known by both.
20 DR. REMICK; Help me-out on what two over one is.
21 DR. SIESS. Category two non-seismic stuff that' 22 sits on top of seismic stuff. That is just one example.
.23 MR. COUNSIL: That is only one example of it.
24 DR. SIESS: Where the failure of one thing can 25 cause unanticipated and uncalculated failures somewhere else Heritage Reporting Corporation O
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(}- l' to louse things up.
2 MR. COUNSIL: That is correct. One of the ones 3 obviously that we in the industry looked at in great detail 4 at Comanche Peak is high energy line break and missile 5 hazards. Both of t hose can cause damage to seismic category 6 one systems structures or components coming from a 7 non-safety system. And we have a very detailed study in 8 that area.
9 DR. SIESS: Those are the obvious ones.
10 MR. COUNSIL: Yes, sir.
11 DR. SIESS: Of course, as the obvious ones get 12 taken care of, we start looking for the less obvious ones, 13 and some of them are getting quite subtle, fire and smoke 14 spreading, fire extinguishing water ending up two floors 15 down in a cabinet which may not be so obvious. But these 16 are things that you are not operating now but you have 17 operated in a plant.
18 MR. COUNSIL: Those were things, Dr. Siess, that 19 went into this two over one, what we call two or one systems 20 interaction program, both seismicity as well as other 21 things. And in fact we did look at a great many things.
22 But I am quite certain like yourself like fire protection 23 water that it can go in the most unusual places.
24 DR. SIESS: We have just look$d at the results of 25 a program at Oak Ridge called the multiple system responses
() Heritage Reporting Corporation (202) 628-4888
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,_ 1 program which was addressing some of the ACRS concerns on
'--) 2 some of the more subtle system interactions thct were left 3 out of A-17 or A-46. And I would suggest that when that 4 report comes out and it is only a draft now that you might 5 want to have your people look at it. It gives about thirty 6 examples of somewhat more subtle system interactions that 7 are concerns. Whether they are real concerns we do not know 8 yet, but as a type it is a lot clearer than say seismic.
9 You are the first one that we have told that to. We hope to 10 get the word out to others about that program.
11 MR. COUNSIL: It seems like we have been first in li a lot of areas.
13 DR. REMICK: I suggest that the staff proceed.
14 MR. WILSON: As indicated by Mr. Counsil, TU has
) 15 strengthened its capabilities to perform probabilistic risk 16 assessments to investigate and understand systems, their 17 operation, relationship with other systems and effect on the 18 plant. TO Electric has received and is responding to the 19 generic letter 8820 IPE for severe accident vulnerabilities.
20 Guidance for submittal and review of IPEs is expected to be 21 issued in NUREG 1335 in the near future.
22 MR. CARROLL: Have you done a PRA yet or are you 23 waiting until you get guidance?
24 MR. COUNSIL: We have not at this point in time.
25 We are prepared to do the IPE.
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241 1 John, do you want to say a few more words about O 2 it?
3 MR. BECK: John Beck, vice president of nuclear 4 engineering. We are taking an approach in our response to 5 this IPE that started a year and a half ago. We have a 6 group of very highly qualified engineers and scientists in 7 the PRA methodology and technology who have set a program in 8 place to incorporate on an internal basis the development of 9 our response with perhaps only one exception in the area of 10 human factors where we think that we are going to need to go 11 out and get some outside expertise, but to respond entirely 12 on our own with the ultimate philosophical objective of 13 utilizing PRA techniques in our day to day management 14 processes at the power plant.
-(O
_) 15 It is a measured carefully structured strategic 16 plan'and our response to IPE is only part of it. So we are 17 very 4.ntent on taking maximum advantage of these 18 me thodologies.
19 MR. CARROLL: Does this grou include people other
! 20 than PRA practitioners?
21 MR. BECK: Yes. In fact we are using kind of a 22 cross-fertilization approach and drawing on operators very 23 consistently throughout the plant. I work very closely with l
I 24 Austin in that regard. And the approach initially on IPE 25 for example is a matrix task force with the basic scientific l
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/"T 1 people drawn from that group. .But'the rest of them are V
2 coming.from throughout the operating and engineering support 3 organization. It is working very well, I might add.
4 DR. CATTON: Do you have somebody involved who is 1
5 an expert in fire with your PRA?
6 MR. BECK: We have a fire protection engineer at 7 the site who in fact is one of the members of this matrix 8 team approach, yes, our own employee.
9 MR. WILSON: One other concern that the ACRS 10 identified was that the committee believed that 11 instrumentation for the detection of inadequate core cooling 12 should not be installed until it is well establ.ished that l 13 the instruments will provide information of significant 14 value beyond that provided by the instrumentation already 15 installed.
16 TU has installed instrumentation for the detection .
17 of inadequate core cooling utilizing heated junction thermal 18 couples and the reactor vessel head. Although this system 19 is a combustion engineering design that was used in the CE 20 system 80 plants at Palo Verde, heated junction thermal 21 couples are being ucad for the detection of inadequate core 22 cooling at a number of operating PWRs including San Onofre, 23 St. Lucie 2, Byron, Breidwood, Waterford, Catawba, Millstone l
24 3, South Texas 1 and 2, and Beaver Valley. These systems 25 have proved to be accurate and reliable in use.
() Heritage Reporting (202) 628-4888 Corporation
243 The ICC instrumentation at Comanche Peak has been
} I 2 installed and inspected by the NRC site staff. There are 3 provisions in the tech specs, requirements for operability, 4 action statements and surveillance for this system.
5 DR. CATTON: There were some problems with the 6 heated junction thermal couples some years ago in that they 7 would burn out too frequently, that the delay times 8 associated with them were too high relative to the tracking 9 of the level.
10 Were these things cured or just ignored, or do you-11 know?
12 MR. KELLY: Jim Kelly, plant manager. I am not 13 familiar with the problems of heated junction thermal 14 couples. We installed them on Millatone 2 in the late 15 1970s and early 1980s and had no problems during the start-16 up besting. And that was duplicated during our testing 17 here. We did just complete our functional testing in May.
18 We did the tracking of the level both up and down a number 19 of things, and the heated junction thermal couples worked 20 very well. We have not seen those failures.
21 DR. CATTON: I have heard that they have to 22 replace a lot of them each time you go through a refueling 23 cycle, is that true?
24 MR. KELLY: Again my experience does not indicate 25 that.
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, 244 1 MR. GRIMRS: I would like to add, Dr.-Catton, that O;/'\
2 when we talked to the instrumentation and control systems 3 people about what the staff's response to this question 4 should be that they only indicated to us that the experience 5 has been good in terms of reliability. It is conceivable 6 that specific kinds of heated junction thermal couples in 7 specific applications might have particular problems, but 8 they did not identify any to us.
9 DR. CATTON: I just recall from five or six years 10 ago that EPRI was quite concerned about the efficacy of the 11 heated junction thermal couple. I do not know any of the 12 details.
13 DR. KERR: Mr. Wilson, you were referring I think
- 14 to the heated junction thermal couple as an indication of 15 inadequate core cooling?
16 MR. WILSON: Inadequate core cooling, yes.
17 DR. KERR: In an indirect way, I guess that is 18 true, but it is primarily a level indicator, is it not?
19 MR. WILSON: Yes.
20 DR. KERR: I just wanted to make sure that we are 21 talking about the seme thing.
22 DR. CATTON: I guess that they use it to make some 23 sort of predictions about the inadequate core cooling. If 24 you look at the rate that the level moves past the 25 heated junction thermal couples, if it does not respond very
() Heritage Reporting Corporation (202) 628-4888
245 1 qpickly it does not do you much good.
7
\- 2 MR. GRIMES: Dr. Catton, the vessel' level 3 monitoring system that we focused this presentation on was 4 an. area that seemed to be of the greatest debate in 1981 5 ' when the staff's requirements for ICC instrumentation were 6 being criticized by the ACRS. And that is why t;e focused 7 that part of this presentation on it. The whole of the 8 instrumentation for inadequate core cooling is that as is 9 specified in Regulatory Guide 1,97.
10 DR. LEWIG: This is no place to reopen all of the 11 wounds about whether these things have anything to do with 12 water level.
13 DR. CATTON: There were some questions about 14 whether or not they were any good before, and it seems to be
( 15 that there are no answers now. l 16 DR. LEWIS: I can only repeat. This is no time to 17 reopen the wounds.
18 MR. WILSON: Finally, the ACRS at its last meeting 19 was satisfied with the staff's progress in the design review 20 and stated that they believed that the outstanding items, 21 confirmatory items and license conditions, could be 22 satisfactorily resolved by the staff. The numbers on this 23 . slide reflect the status at the time of SSER-21 in April of 24 1989. Currently there are eight outstanding licensing 25 issues, six confirmatory issues, and six potential license Heritage Reporting Corporation
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246 m- -f 1 conditions. . And they are fairly. typical of the issues that -
2 are remaining at this point in lic-en !.ng.
3 MR. GRIMES: It ie &lso important-that we point 4L out that.the number of'pending licensing issues is 5- continuing to change as we conclude our review of.the 6 changes to the final safety analysis report that resulted-7 'from the utility's corrective action program. The purpose 8- of this part of'the presentation was to indicate that we do 9 not see anything unique ~in those issues and that the number 10 is fairly small, so it is unlikely that we.are going to have 11 a large number of licensing issues and a large number of-l 12 confirmatory actions to have to put off beyond fuel load.
13 And that was the message that we wanted to leave with you.
14 DR. EEMICK: If you want to proceed with your 15' ' presentation.
16 MR. GRIMES: Are there any other questions?
17 (No nerponse. )
18 MR. GRIMES: At this point, I had tossed in a 19 break in anticipation, but I would leave it.to you. If you 20 would like us to go on, I can have Mr. Lyons go over the 21' chronology of' events since 1981.
22 DR. REMICK; We arelanxious to get on with it.
23 MR. GRIMES: All right. Nt. Lyons.
24 MR. LYONS: Good morning. I am going to try to 25 provide a brief chronology of the events that have occurred 1
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247 1 since the last ACRS meeting. At that time, the licensing 1
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2 hearings were in progress on the one admitted contention 3 that had to do with the quality assurance and quality 4 control aspects of construction.
S It was during the hearings in 1982 that the staff 6 first became aware of the piping and pipe support concerns 7 which were to become known as the Walsh-Doyle issues. It 8 was these issues that started the chain of events that led 9 to the ultimate implementation of the TU corrective action 10 program.
11 Mark Walsh and Jack Doyle were engineere working 12 in the same pipe support group at Comanche Peak. They had 13 concerns about pipe support design deficiencies that were a 14 result of design changes made in the field by the on site 7
15 field engineering group. These field changes were being 16 installed prior to the final approval of.the original design 17 engineer. Walsh and Doyle felt that the changes being 18 implemented in the field were not correct and that the field 19 engineering interactive design process was being misused.
20 In response to those concerns, the staff formed a 21 special inspection team to review and evaluate the 22 Walsh-Doyle issues during an inspection that occurred from 23 october of 1982 through Februairy of 1983. The special 24 inspection team categorized the Walsh-Doyle issues into 25 nineteen broad areas of concern.
[' Heritage Reporting Corporation (202) 628-4888
l 248 1 Following the hearings in 1983 which included both h 2 the special inspection team findings and issues raised by 3 the NRC's construction appraisal team, the Board issued a '
4 memorandum and order in December of 1983 which found that 5 the applicant had not demonstrated the existence of a system l
l 6 to promptly correct design deficiencies and concluded that 7 the applicant was not in compliance with 10 CFR Appendix B.
l 8 The Board also noted that the hearing record was 9 devoid of a satisfactory explanation for several piping and 10 pipe support concerns raised by the intervenor Case. The 11 Board urged an independent third party review of the 12 technical issues addressed in the hearings.
13 Following the Board's memorandum and order, a 14 number of staff and TU programs identified additional issues
- 15. at Comanche Peak. These included the NRC Cenior review team 16 which was an unannounced inspection team that went to the 17 site to review the plant. The senior review team at that !
18 time concluded that the Texas Utilities' programs were being 19 sufficiently controlled to allow continued construction of 20 the plant. It also formed the basis for putting together 21 the NRC's technical review team, which was a team of 22 approximately fifty NRC specialists, NRC and consultant 23 specialists, which performed ten weeks of inspection at the 24 site. They addressed over 600 allegations and technical 25 issues and their findings are documented in SSER-7 Heritage Reporting Corporation 1 O (202) 628-4888
249
{} 1 through 11.
2 Texas Utilities contracted with Cygna Engineering 3 Services to perform an independent assessment program.
4 Phases 1 and 2 of the Cygna IAP were a limited scope i 5 assessment of a portion of the design control process and 6 its implementation. This was begun during the hearings in 7 1983 at the staff's request.
8 In response to the memorandum and order, Cygna' 9 initiated Phases 3 and 4 of their IAP. Phase 3 was a review 10 of the piping and pipe support designs in selected systems.
11 And Phase 4 was a multi-discipline review of a portion of 12 the main steam and component cooling water systems. All of 13 these programs identified a number of issues that needed to 14 be addressed.
( I 15 TU also formed at that time the Comanche Peak 16 response team to respond to the growing number of issues 17 being raised. Phil McKee will discuss the CPRT and the 18 subsequent TU corrective action program in the next 19 presentation.
20 In August of 1985, the construction permit for 21 Unit 1 expired, and it was not discovered until 22 January of 1986 by the staff. This provided another 23 opportunity for litigation in that Case the intervenor 24 raised issues related to the management practices which they 25 maintained causes the construction delay.
() Heritage Reporting Corporation (202) 628-4888
250 1 Early in 1987, the Commission established the 2 Office of Special Projects which had the licensing and 3 inspection authority for the Comanche Peak and the TVA 4 projects. As part of that organization, this is the 5 Comanche Peak project division as it stands today. Since 6 the inception of the Office of Special Projects, we have 7 been reincorporated into the Office of Nuclear Reactor 8 Regulation, and now we are the Associate Directorship for 9 Special Projects.
, s 10 Our original staffing level was 24, and the 11 Comanche Peak project division has subsequently been reduced 12 to 20 on the project as it becomes more like a normal plant 13 review and the staff's reviewn are being completed. The la Comanche Peak project division staff and its consultants 15 have reviewed the Texas Utilities' corrective action program 16 since its inception as Phil McKee will describe later.
17 In addition to the people shown here, we have 18 contractors that we use in our technical reviews and we have 19 six contractors at the site that we use almost full time in 20 our inspections.
21 Following the completion of the design validation 22 portion of the corrective action program, Texas Utilities 23 and the intervenor Case reached a settlement agreement which 24 provided an innovative way for Case to monitor the 25 implementation of the corrective action program and also Heritage Reporting Corporation s_ (202) 628-4088
,y 1 provided a way for them to resolve their technical issues L]
2 g without resorting to litigation.
3 A joint' stipulation between TU, Case and the NRC L
4 was signed in July 1988 which called for the submittal of a 5 motion for dismissal of hearings. There is nothing in the L 6' joint stipulation that takes the NRC out of its normal
'i 7 regulatory mode.
8 In mid-July the ASLB discussed the hearings.
9 Since the dismissal of the hearings in 1988, the staff has 10 continued to monitor the implementation of the corrective 11 actior. program including the review and has resumed normal 12- plant inspection and licensing activities including the 13 review of design changes resulting from the corrective 14 action program which are being incorporated into the FSAR.
15 In 1984 the SALP process had been suspended for 16 Comanche Peak. It was reinitiated in 1987, and a SALP 17 report was issued in October of 1988. And it covered the 18 time period from September of 1987 through August of 1988.
19 In that SALP report, the staff rated Texas Utilities as a 20 category two in all areas except for the functional area of 21 security where we see a category one rating.
22 The SALP report indicated that the overall 23 performance of Texas Utilities has improved markedly from 24 their past performance. Currently the staff is focusing on 25 determining the operational readiness of the Comanche Peak
(^ Heritage Reporting Corporation T (202) 628-4888
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2 Are there.any-questions?
s;. , , 3' DR. KERR: ' In terms of.the problem 1 that were
[' '
4 perceived and investigated, could you estimate what fraction 5 of those involved record keeping and what fraction involved
'6 serious deficiencies in design construction or whatever?
7 MR. LYONS: I think that'I'have to defer to the ji 8 licensee utility.
b 9 DR. KERR: Surely NRC must have mome idea of what
.10 this is since you were responsible for identifying the 11 deficiencies.
12 MR. GRIMES: The licensee over the last three 13 years:has submitted over 200 construction deficiency reports 14 that have identified actual physical problems in the plant.
- i. .
s -
15 Out of a total number of issues that is roughly in the
~16 20,000 to 30,000 range, you can play with the statistics in 17 any way you like.
18 DR. SIESS: That is 200 over 20,000 is your 19 answer?
20 MR. GRIMES: Yes, sir.
21 MR. CARROLL: What is the 20,000?
22 MR. GRIMES: The total number of individual counts 23 on issues that we have tried to track down.
24 MR. MCKEE: I would 11ke to add, and I will cover 25 in the next presentation at least the process, but as far as
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{
1 Lthe' corrective action programs and the CPRT efforts, there 2 .was an extensive review and independent evaluation, a-3 self-assessment,; of a wide range of construction issues. and 4 design issues.
L 5 For example in the construction area, I think of
- 6. the issues, and you can add after I. complete, the issues 7 reviewed, not the issues but the issues reviewed, it was 8 almost 98 percent of the items reviewed were indicated as no
.9 problems. And of the remaining two percent as a result of 10 the evaluations, just a small fraction of those were 11- identified of any significance. And those were deaI; with 12 as findings and recommendations and fell'into the utild'y's 13 corrective action programs for correction.
14 MR. GRIMES: And I would like to add to that
.O 15 explanation a caution. There is a considerable amount of 16 confusion about what constitutes a real or unreal problem.
17 We can count things in a variety of different ways. But
.18 ultimately the safe operation of the plant is dependent on a 19 clear match between the design and the construction of the 20 facility. And there were a lot of instances where those 21 things did not match. So with all of that information, I L2 will leave it to each of you to decide how significant the 23 problems were.
24 DR. KERR: What I was trying to get from you is 25 some estimate on your part of what fraction of the
() Heritage Reporting Corporation (202) 628-4888
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() 1 originally identified deficiencies were the result of 2 inadequate record keeping and what fraction were actually 3 things that would have contributed to additional risk. I 4 recognize that this involves a certain amount of judgment.
5 I was just trying to learn something.
6 MR. GRIMES: As a simple answer to that, I will !
7 point to a conclusion that the technical review team came to 8 early on in their findings on the 600 allegations. They l 9 essentially found that about 20 percent of them were 10 substantiated, and the other 80 percent were essentially 11 record keeping problems. There is a point of reference that 12 you can use.
13 DR. KERR: Thank you.
14
(-
V DR. CATTON: I notice that the agreement mentions 15 only one intervening group. I think initially there were 16 several.
17 Did they drop out along the way?
18 MR. LYONS: They dropped out earlier in the 19 process.
20 DR. CATTON: So Case was the only remaining 21 intervenor?
22 MR. LYONS: Case was the only remaining 23 intervenor.
24 MR. GRIMES: One of the interveners that dropped 25 out has come back and is not suing for intervention in the
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,3 l' Fifth Circuit.
\
') 2 DR. CATTON: As a result of the settlement?
3 MR. GRIMES: Yes.
4 DR. REMICK: Are there any other questions?
5 (No response.)
6 DR. REMICK: If not, please proceed.
7 MR. GRIMES: Mr. McKee will now describe the 8 activities associated ~with the Comanche Peak response team 9 and the corrective action program.
10 11 12 13 14
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256 (f 1 MR. GRIMES (Continuing) : While he is getting 2 ready, I would point out the review and inspection 3 activities that resulted in the Staff's Supplemental Safety 4 Evaluation 20 that was the Staff's conclusions relative to 5 the CPRT's activities and their findings.
6 MR. McEEE: I will be using the slides here in 7 just a second. But let me say good morning. I think it is 8 still morning.
9 I am going to cover two programs. We have 10 mentioned them earlier in the discussion.
11 And these two programs were the primary to the 12 investigation and evaluation and resolution of the issues 13 that were raised in the time frame that Jim presented from gg 14 about 1982 to 1984, when a number of issues were coming up.
Q) 15 In my presentation, I hope to convey a sense of 16 the breadth and the scope of the evaluations that were done 17 by TU Electric, and also as was mentioned earlier, the 18 extensive NRC oversight of those activities.
19 Before I begin, I want to just kind of mention and 20 alert you that I think at least from my experience that this 21 project is a champion of acronym and abbreviation. So I 22 will try to keep those to a minimum in my presentation. But 23 one I will rely on a lot is CPRT, Comanche Peak Response 24 Team.
25 DR. SIESS: It's not even in the big leagues.
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1 MR. McKEE: TU Electric established th'e Comanche 2 ' Peak Response Team in October of 1984. They established it 3 to provide an independent third party organization that was 4 comprised of consultants and contractors who were not 5 originally associated with the design and construction of 6 Comanche Peak.
7 The organization, which, over the four years that 8 the CPRT was in existence, varied in numbers, but was not a 9 small organization, was up to 300 people or thereabouts at 10 various time, and was divided into discipline groups.
11 The activities of the CPRT were directed and 12 monitored by the Senior Review Team which was comprised of 13 senior, third party consultants, with the exception of the 14 Chairman of the Senior Review Team who was TU Electric's 15 Executive Vice President for Nuclear Engineering, Mr. John 16 Beck, who is with the TU Electric group here today.
17 The Senior Review Team was charged with 18 formulating the policy and directing CPRT activities.
19 The Chairman of the Senior Review Team, Mr. Beck, 20 served as the primary contact between TU Electric management 21 and the CPRT organization.
22 The CPRT was charged with responding to and 23 resolving the numerous issues raised by the NRC Technical 24 Review Team, the ASLB, NRC inspections, and many of the 25 other inspections, issues that were raised by the
() IIeritage Reporting Corporation (202) 628-4888
258 j 1 Intervenor, and other sources.
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2 These issues that were raised during the 1982 to 3 1984 time frame were called or term conveniently external 4 source issues, i
5 To accomplish their goal, the CPRT committed 6 itself to three primary objectives. One was to investigate 7 each of the external source issues, determine the nature of 8 any safety-significant deficiencies, and identify the 9 necessary corrective actions to be taken.
10 The second objective was to determine root causes, 11 adverse trends and generic implications of any safety-12 significant deficiencies.
13 Finally, in recognizing that the external source 14 issues were not inclusive and did not bound all the isst.gs, O 15 the CPRT committed as a third objective to conduct self-16 initiated evaluations of construction and design activities.
17 To accomplish these objectives, the CPRT, through 18 direction of the Senior Review Team, developed an extensive 19 program plan. This program plan contained two major 20 elements. The first addressed the quality of construction, 21 including construction quality assurance and testing 22 programs; the second addressed the adequacy of plant design.
23 DR. KERR: What does one mean by " quality of 24 construction"? That is, how do you judge the quality of 25 construction? l r~ Heritage Reporting Corporation (202) 628-4888 l
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() 1 MR. McKEE: The quality of construction refers to 2 really the hardware aspects. The construction activities.
3 The actual erection.
4 DR. KERR: How do you decide whether it is good 5 quality, medium, poor or what?
6 MR. GRIMES: Mr. Kerr, there had to be a 7 distinction made in this program between construction in and 8 of itself and the design, where they might not match.
9 So there was a review done to determine whether or j 10 not the construction, even though it did not match the 11 design, whether it was still suitable for use, in much the 12 same way that a deficiency report is evaluated by a plant to 13 determine when they find a problem whether or not they 14 should use it as is or fix it.
15 And so the assessment on the quality of 16 construction was to determine essentially shall we use it as 17 it is and modify the design or is it something that needs to 18 be fixed?
19 DR. KERR: I guess I didn't make my question 20 clear.
21 How did you decide whether the construction was 22 adequate or not, or acceptable, or whatever the correct term 23 is?
24 MR. BECK: If I may, Dr. Kerr, John Beck, Vice 25 President-Nuclear Engineering. As was mentioned earli'3r, I
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,3 1 was Chairman of the SRT.
U 2 Quality of construction was really an all-3 inclusive term that we used to not only focus our attention 4 on specific issues that had come up from one source or 5 another but more importantly to the SRT, to encompass the 6 entirety of the power plant and to evaluate the adequacy of 7 construction, the adequacy of the end product. And the way 8 we did that was through a very rigid, scientifically-derived 9 sample of the entirety of the Comanche Peak plant, and went 10 out and reinspected the facility in some 30 different 11 subdivisions if you will that were predicated on 12 construction practices so that we could hava a strong 13 measure of confidence that once this sample reinspection was 14 completed, and it consisted of over 650,000 individual 15 decision points, how did that end product, the end 16 construction piece, compare with that which was dictated by 17 the design at the time it was done?
18 DR. KERR: I think you may be crediting me with a 19 lot more knowledge and information than 1 have.
20 What I am trying to find out maybe is do you look 21 to see if the things are exactly as designed, and if they 22 are then that is high quality; or do you see if it is 23 painted gray when the plans call for it to be painted green?
24 MR. BECK: The first step was to match the design 25 requirement with the end product.
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1 1 DR. KERR: Okay. I
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2 MR. BECK: And then to evaluate that finding. And 3 in 98 percent of the cases, the match was proper. What was 4 there was what was specified.
5 DR. KERR: Yes.
6 MR. BECK: And that was the 2 percent that was 7 mentioned a bit earlier. Less than 1/2 percent of that 8 remaining area where there was not a good match had any 9 safety significance at all.
10 DR. KERR: Okay. Now, was there ever a care in 11 which you found that what was there was exactly what was 12 designed but that the design was lousy or is that another 13 part of the process?
g- 14 MR. BECK: That was the second part and thct is l
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15 the design adequacy program.
16 DR. KERR: Okay.
17 MR. BECK: And I think --
18 MR. McKEE: I believe I will be covering that 19 later on.
20 DR. KERR: Okay.
21 MR. McKEE: Because I will talk to both design and 22 construction.
23 DR. KERR: Okay.
24 MR. McKEE: I think what I was just going to say 25 wa already covered. But I will repeat it, nevertheless.
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2 program.
3 And with respect to that aspect'of the program, 4 there were 46 issue-specific' action plans developed to
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5 encompass and address all the external-source issues that d 6 were' brought up that applied to the construction activi',ies.;
7 In addition, there was a self-initiated aspect of 8 the quality of construction program which consisted of i
9 hardware inspections, which I think gets to the heart of- 1 10 your question, and also documentation reviews.
11 And.these' represented a sample of safety-related 12 construction work activities.
13 This was accomplished through categorizing the 14 safety-related hardware, identifying appropriate 15 construction attributes to be inspected for each of the 16 categories and implementing an inspection plan for those 17 attributes.
18 For the design adequacy piece of the program, the 19 discipline-specific action plans were developed, which
- 20 covered the four design disciplines. These disciplines'were 1
21 civil structural, piping add pipe supports, mechanical-22 systems and components, and electrical and I&C.
23 Each of the four plans included an approach to 24 address the external source issues associated with that 25 design discipline, and a comprehensive, self-initiated
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{)- l' . sample base. evaluation of the architect-engineer safety-2 -related design.
3- Because of the large number of-external source.
4 issues for two areas, piping and pipe supports,Jand.those 5 'were generated as a result of the lost oil issues, and the 6 cable tray conduit supports,.a program for complete 7 reverification of design in these. areas was established.
8 TU Electric review of the results during the 9 preliminary stages of the design adequacy program revealed 10 to them that the findings identified were very broad in 11 scope and included most disciplines.
12 The number and significance of these preliminary-13 findings prompted TU Electric to initiate a comprehensive I 14 corrective action program which essentially included a 0, 15 complete design validation of the. safety-related components 16 systems.
17 And I am going to talk about the corrective action 18 program in a little more detail in an upcoming slide.
19 This commitment by TU Electric to do a complete 20 validation of the design obviated the necessity to continue 21 the design adequacy program as it was originally planned.
22 Getting into the Staff program evaluation, the 23 Staff followed closely the development of the CPRT program 24 and there were a number of meetings and comments and 25 questions and answers related to the early stages of the l
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/~T 1 program, and found the plan acceptable subject to continuing V
2 reviews by the Staff of the program during implementation.
L 3 The results of the Staff reviews were documented 4 in SSER 13. And essentially the Staff found that the 5 approach that was identified by this CPRT in resolution of l 6 the issues was an acceptable approach.
7 Also, a special inspection group consisting of 8 four inspectors and four to six contractors was formed in 9 July 1985 and was assigned full time to the site, to inspect 10 implementation of the program.
11 Just to give you a little idea of that program, 12 from July 1985 through July 1988, where a lot of the CPRT 13 activities occurred, there was over 61 inspection reports 14 issued in this aren and it represented about 50,000 15 inspection hours.
16 And Bob will discuss a little bit of the 17 continuing and some of the other inspection activities in 18 little bit.
19 The Staff also evaluated revisions to the CPRT 20 program plan, and these are principally those that adjusted 21 and reidentified the design adequacy program aspects and 22 approved those revisions in an evaluation issued in January, 23 1988.
24 That staff revision also approved TU Electric's 25 corrective action program.
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-('] 1 In_ December 1987, the CPRT issued their collective 2 evaluation report that presented a summary of the individual 3 construction related findings, an evaluation of the findings 4 when looked at collectively and an overall conclusion on the 5 quality of construction.
6 In February, 1988, the CPRT issued their 7 collective significance report that provided integrated 8 perspective of the results of the CPRT investigative and 9 overview activities, including their assessment of design 10 and CPRT overview activities.
11 And the next slide gives a summary of the CPRT 12 conclusions as a result of their effort. And in essence, 13 the CPRT considered that the construction and design 14 problems resulting from the historical program. weaknesses 15 have been identified; second, corrective actions to address 16 these issues have been taken, are defined, and pending 17 proper implementation of the corrective action program there 18 is reasonable assurance that the structure systems and 19 components will be capable of performing their intended 20 safety functions.
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! 21 And these recommendations as the charter stated 22 were provided to TU Electric management.
23 DR. REMICK: What was the date of thoss 24 conclusions?
25 MR. McKEE: The date of those two was December of
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o 266-1 1987 - it was'before the collective evaluation. report - .
2 and February 1988 when the collective significance report 3 was issued.
.4 The results of the Staff review of the CPRT's i 5 implementation,of the program plan, the Staff's evaluation 1
l' 6 and CPRT's collective evaluation, and the Staff's review of 7 CPRT's' conclusions that I just went over, were contained in 8 SSER 20.
9- In SSER 20 the staff concluded that-the program 10 was adequately implemented and the CPRT investigations were 11 thorough and complete, and the recommendations for 12 corrective actions were sufficient to resolve' identified 13 deficiencies.
14 The next slide I will put up briefly. I don't O. 15 want to linger on this slide because it is rather busy and 16 it contains a lot of information. But points I want to make 17 about that, the first, the top half of the slide represents 18 the CPIEC effort, the investigation and the. evaluation 19 effort. And the main point of that slide, if you leak at 20 the box in the dotted line, !s the next area that I am going 21 to talk about, the corrective action program and essentially 22 the CPRT efforts and findings that they had fed into TU 23 Electric's extensive corrective action program which is the 24 final resolution of the issue.
25 DR. KERR: What .nould I conclude from that slide?
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{) 2 1 That'you have a beautiful computer program for drawing boxes?
3 MR. McKEE: I don't know if that wa part of a 4 program. I think.Chris is our expert in that area.
5 MR. GRIMES: What you should conclude from the 6 complexity of that slide is that there was a considerable 7 amount of activity and that there was.at least a short delay 8 while-we tried to learn what everything was that was going 9 on and who was responsible for it.
10 Another important point from this is that while 11 there were a considerable number of independent consultants 12 and review groups that identified issues and problems and 13 concerne and recommendations, it was Texas Utilities that' 14 took responsibility for developing a means to control,
.O 15 track, evaluate and implement whatever corrective actions -(
i 16 were necessary in order to resolve those issues.
17 DR. KERR: Thank you.
18 MR. McKEE: The next slide talks about the 19 ' corrective action program. !
20 TU Electric initiated'the corrective action-21 program to one, accomplish a comprehensive design and 22 hardware validation of the safety-related and selected non-23 safety-related portions of the Comanche Peak plant; and two, 24 provide a planned, integrated resolution of identified 25 problems rather than resolving each issue individually. In
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f 1 other words, it provided a' coordinated' plan.
2 The program was broken down into 11 work scopes or 3 disciplines, which-are' listed there.
4 TU Electric as was mentioned earlier contracted' 5 Stone & Webster Engineering Corporation, EBASCO and IMPELL-6 to conduct the program, and each was. assigned a work scope 7 as indicated on the diagram.
8 I will get to it later. But the last column talks 9 about the.SSERs where that CAP program and the processes of
'10 that CAP program were addressed and assessed and written up 11 in those SSERs.
12 DR. KERR: As a matter of curiosity, what is the 13 significance of the fact that trains A ano B are justfthere 14 and train C is included for conduit, I presume it is, bigger O 15 than two inches in train C. Was train C the only train 16 that had conduit less than two inches?
17 MR. McKEE: I'll make a try at that question and 18 then I may punt. But essentially there was a different 19 seismic design criteria that applied to train C. Train C is 20 the non-safety-related train. However, it is included in 21 the A and B, greater than 2 inches, because of the supports 22 and the seismic considerations for the supports are needed 23 for the larger piping.
I 24 For the smaller piping, the seismic considerations 25 are generally considered less, and that is why the two are
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t'Y 1 broken off.
Q.]
2 DR. KERR: Now, wait a minute. That is conduit.
3 When you say piping --
4 MR. McKEE: I meant the conduit supports for the ,
l 5 piping.
6 DR. KERR: Okay.
7 MR. McKEE: I mean the conduit size for the 8 supports. !
9 DR. KERR: Okay.
10 MR. CARROLL: I'm confused. I thought I heard 11 that this was a two-train plant.
12 MR. McKEE: It is A and B are the safety trains 13 and C is a non-safety train.
14 However, the supports for the C train are, because 15 of the seismic considerations and their impact on other 16 equipment during a seismic event, have special seismic 17 considerations.
l 18 DR. REMICK: So it is really a three-train plant, 19 two of which are safety grade.
20 Is that what we're saying?
21 MR. McKEE: Well, that's getting off. We're 22 talking in the electrical and the conduit. And I think I 23 may have confused it when I was talking about piping.
l 24 MR. GRIMES: Now, it is a two-train system. A l 25 and B are the two safety trains. Non-safety is separated l
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f 1l from. s a fety r 2 '. MR. CARROLL: What for example'is'in Train C7
-3 What kind of' equipment?
~4 MR. GRIMES: Lighting.
5' .MR. CARROLL: Lighting?
- 6. MR. GRIMES: Lighting.
7 MR . - ~ CARROLL: . Why;isn't it' called lighting,;then?
8 . MR . GRIMES: That's one' thing that could be,1but 9- you asked.for an example.
10 MR. CARROLL: Oh.
11 IGR. GRIMES: It'could.also be:the power for the 12- = cooler on'the -- for drinking water. It is non-safety.
13 electrical power that you separate from the safety.
14 . electrical power. However, all of the conduit;in the plant O 15- has a design basis. The design basis for theLnon-safety 16 -conduit supports is different from the design basis for the 17 safety conduit suppo;.s. And that is why it was: split into 18' these two different kinds:of work scopes.
19 MR. CARROLL: Okay.
20 MR. McKEE: You are correct in pointing out that 21- that does stick out on the chart, I think. That question 22 has been asked before.
23 My final slide in the area that I am going to 24 cover is the corrective action program.
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2 reports identify and describe the resolution of issues, 3 describe in detail the correction action approach for that 4 design sdiscipline and provide the results of issue 5 resolution at the time of the report, when that report was 6 issued.
7 The methodology, although the methodology for each 8 of the 11 workscopes varied somewhat, each contained the !
9 processes for design validation, hardware validation, design 10 hardware reconciliation.
11 As part of the design validation, the responsible 12 contractor conducted a detailed review of the design data, <
13 such as calculations, drawings, specifications, licensing 14 commitments, FSAR commitments, and applicable regulatory 15 guides and other documents. '
16 From this review, the design-related licensing 17 commitments were captured and documented in a series of ;
18 design basis documents which were developed to clearly 19 identify the basis for the design validation.
l 20 Design documentation along with identified design 21 issues were then reviewed to the design basis to ensure that 22 the design satisfied the licensing commitments.
23 The validation process also included 24 identification of installation attributes which when 25 verified would assure conformance of the design to the I
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2 That leads into the hardware validation. Once the 3 design basis had been established,.and the critical design 4 attributes are identified, hardware validation was 5 accomplished to provide for complete validation of the final 6 acceptance inspection attributes.
7 Validation of each of the attributes was 8 accomplished by physical validation or engineering 9 evaluation.
10 For those attributes requiring physical 11 verification, field verifications methods were prepared 12 which contained the acceptance criteria which was traceable 13 to the validated design documents.
14 DR. KERR: What fraction of the plant was subject
() 15 to this sort of detail?
16 MR. McKEE: The hardware validation.
17 DR. KERR: This whole project status methodology 18 you described could have been applied to the 10 percent or .
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19 100 percent.
20 MR. McKEE: The whole design process, the design 21 validation process, applied to all the safety-related, with 22 some exceptions. They did not cover the NSSS supplier and 23 some other vendors where there was no question during the 24 issues, where there was no issues brought up as to the 25 question of that design aspect.
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, 1 DR. KERR: So you only looked at that part of the 2 plan about which someone had raised issues?
3 MR. McKEE: They looked at the whole design with 4 tha exception of I believe Westinghouse design matters and a 5 few other vendors. But essentially it was a complete, 6 comprehensive --
7 DR. KERR: In effect it was a redesign, is that 8 correct?
9 MR. McKEE: That is correct. Or a complete design 10 validation.
11 That is one point I was trying to get across in 12 the breadth and the extent of the program, that it really 13 essentially was a redesign of a substantial portion of the 14 plant, or a validation of a substantial portion.
() 15 DR. KERR: And you found a lot of mistakes that 16 had been made, or did you just discover that the design was 17 pretty good?
I' 18 MR. McKEE: I think as they looked through the Ii 19 construction, the construction aspect in the CPRT, I think 20 in the construction there were relatively few issues or 21 problems in that area.
22 I think the issues were in some of the design 23 areas, and some of the original design, as far as the 24 documents mat .ning construction. And that really generated 25 --
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Wait a minute. . I'm.sorry.
l' DR. KERR: I thought'
- 2. you said the. mistakes were in the design and'then you said 1
3' 'something about the construction matching the design. There 'l
.I 4 is.a difference, I think.
5 Were a lot of mistakes found in-the' design itself?
6 'MR. GRIMES: I will attempt to --LI may get in- ]
I 7 . trouble again, but I will try. !
8 "A lot" is relative term. As ILpointed out j 9 before, over the last, I think it is'three years, we have 10 .had 200 construction deficiency reports.
11 Sometimes the deficiencies that have been 12 identified are design deficiencies. It is.very difficult 13 for us to articulate what constitutes a lot in the problems i
14 that have been identified in the design.
15 When we talk a little bit later about what we 4
16 recently found with regard to some check valve failures,
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i 17 depending on who you talk to or what you think we found, it j 18 is either a design problem or it is a construction program 19 or it is a matching of the two. !
20 And so we kind of hesitate to try and characterize 21 shat we found over the last two years. l
- DR. EERR
- I asked, Mr. Grimes, because I would 23 guess that we would both agree that a lot of resources were 23 expended in the process. And I was just curious as to 25 whether -- I mean, you probably had to expend the resources l
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2 having expended them, I wondered what the cost: benefit 3 ration was. And it is just sort of a matter of curiosity.
4 I would think you would be asking yourselves the same sorts 5 of questions.
6 MR. GRIMES: On the record aspect, there is a 7 certainly, on the utility's work and on the NRC part, if you 8 add up, it has been a tremendous cost.
9 DR. KERR: Yes.
10 MR. GRINES: And I don't know how to measure that 11 against the benefit.
12 DR. KERR: Well, and again I realize "a lot" is 13 not very quantitative, if you found a lot of deficiencies in 14 the design, then the effort was worthwhile. 'If you did not, 15 then you probably had to do it because you weren't sure but 16 given that experience, one wonders what one might do the 17 next time.
18 MR. GRIMES: Well, this has been a wonderful 19 experience for us. We have had a lot of fun.
20 I do want to point out, we have a bit of a bias, 21 because we feel like we have made a substantial contribution 22 in the work that we have done over the last two years to try 23 and see to the resolution of all of the issues that have 24 been raised on Comanche Peak.
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.() 1 what the benefit of that effort f was. I think that we did 2 find a lot in that respect. But I am still having some 3 trouble determining whether or not that lot was enough to 4 justify my existenee.
5 6
7 8
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277 rx 1 DR. SIESS: The only possible way of measuring the tg 2 benefits from the point of view of the NRC or the ACRS.
3 Suppose you made a PRA, did a PRA of the plant as found and 4 another PRA of the plant after you got through with it.
5 Now, wouldn't that measure the benefits? That is the way 6 the staff svaluates generic issues and other things.
7 MR. GRIMES: That is somewhat abstract for this 8 case, though, because --
9 DR. SIESS: Why?
10 MR. GRIMES: -- a lot of the corrective action --
11 well, the front end of a PRA is first writing down what your 12 plant is.
13 DR. SIESS: Yes, but I would say take it as found.
14 That would have been about what, six years ago?
15 MR. GRIMES: Eighty-four.
16 DR. SIESS: And then take it today. And how many 17 of the changes that are made in the plant would even come 18 into the PRA? I don't know, but you would have to -- that 19 is a way to do it.
20 MR. GRIMES: Yes.
21 DR. SIESS: And it probably, you Know, wouldn't 22 cost as much as you have already spent by a hell of a large 23 amount. Why couldn't you do that? .
24 MR. GRIMES: The reason that I don't think that 25 that is a valid test is because about half or more of the Heritage Reporting Corporation O (202) 628-4888 l
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4 2 what is the plant; what --
3 DR. SIESS: That is all right.
4 MR. GRIMES: One of the benefits of a PRA is the 5 ability to understand what he has got in his plant.
6 DR. SIESS: Yes. But if you spent money just to 7 find out what you have got there, that meant that the plant 8 wasn't really made any safer by doing it, necessarily, but 9 that the potential for operating it safer was greater? I am 10 trying to -- I am not quantifying now. I am just trying to 11 get a qualitative description of what we are talking about.
12 MR. GRINES: I understand.
13 DR. KERR: Mr. Grimes, I didn't mean to be 14 critical of what you had done. I don't know what the O 15 alternative would be. I mean, you had these allegations and 16 you had to do something to try to substantiate that either 17 the plant was okay or it wasn't. I was just curious about 18 having done it, whether you really found a lot of things 19 that changed and then made the plant safer, or whether you 20 had to expend a lot of effort, and as I say, I don't see how 21 you could avoid doing it, but whether in having done it, 22 have a great many changes resulted which made the plant a 23 lot safer? And I realize that I am asking a question, the 24 answer to which may be impossible. I don't know.
25 DR. SIESS: Or any safer because there are an 1
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l 279 q 1 1 awful lot of plants out there, t'or example, having trouble LJ 2 with check valves. Some of them have been operating 15 3 years.
4 MR. GRIMES: Well, I know that if - you know, I 5 will point out that over half of the pipe supports in the 6 plant were changed and that if I told you what they had done 7 to their pipe supports, I know that Dr. Siess would say the 8 plant isn't any safer because you made it more rigid and it 9 is probably going to really get damaged now. We have been 10 through that debate before.
11 DR. SIESS: Even leaving that out, the change may 12 have simply made thor,e pipe supports withstand three times 13 the SSE instead of two and a half which would provide an 14 imperceptible difference in the safety of the plant.
15 MR. GRIMES: It might make other things --
16 DR. SIESS: Well, no. We are agreed on that. We 17 have been through that from Big Rock.
18 DR. REMICK: I think the licensee wants to make a 19 comment on this. No?
20 MR. COUNSIL: Yes, I feel obligated to make some 21 comment for various reasons. Let's take the pipe supports.
22 All right? I would like to give you just one as an example, 23 and there is a reason for it. U-bolts, u-bolt supports. It 24 is a round piece of steel, goes around onta a base, and they 25 can be cinched or non-cinched. They are in plants Heritage Reporting Corporation (202) 628-4888
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2 As a matter of fact, at Harold Denton's i 3 suggestion in 1985 I made a tour of plants in Japan, and 4 they are almost used exclusively in Japan, as u-bolts or 5 cinch u-bolts. ife took them all out, and the reason we took 6 them all out of our plant is they basically can't'be 7 analyzed as a stable support, and not only did we.take them-8 out because of that, but if you cinch a u-bolt, you have got 9 a circle on a big circle. Right? You have got one point of 10 contact on the circle.
11 If you look at strain and the equations for 12 strain, the force on that point is infinite so therefore you 13 are in a non-analyzable condition and they ask,'"Well, what 14 are you going to do about it?" Whereas you know and I know 15 it is a point contact. It isn't an infinite force, and it 16 isn't going to do a e\mned thing to that pipe, but we could 17 not analyte it and explain it to a judge so we took them all 18 out.
19 Dh. SIESS: And probably nobody would accept the 20 test.
21 MR. COUNSIL: Also true. Also true, so they were, 22 in fact, taken out, and there were other changes made like 23 that because there is no way in our present situation in 24 this country we can go before an administrative law judge 25 and explain to him what it really means and have it O Heritage Reporting Corporation (202) 628-4888
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h() l' 2 DR. SIESS: I-have got to interrupt. You have got 3 a sympathetic audience for some of these things.
4- MR. COUNSIL: I hope so.
5 DR. SIESS: Back in '75 I remember 1when I first 6 became in-olved in,this-business we ran through exactly the 7 same issue having to.do with the hold-down bolts on the 8 reactor head because somebody proved that the contact 9 between the thread on the bolt and the thread on the nut was 10 a point ' contact and therefore exceeded the strength of the.
11 material. Therefore, they were not reliable, and it just 12 carried on through the scenario. And you are right; it is 13 impossible to make those points.
14 DR. REMICK: From the licensee's viewpoint.were 15' there things found that you would say had safety 16 significance?
17 MR. COUNSIL: Well, we reported, Dr. Remick, 18 approximately 200 part 50, paragraph 55 (e) reports, using a 19 very conservative scenario.
20 Now, albeit it most of those fell in the seismic l
l 21 area; all right? And if one assumes that in Texas that you 22 have an operating basis earthquake, I suppose there was the 23 potential for limited failures in some of those instances, 24 but largely, you know, there hasn't been, that I am aware 25 of, an earthquake anywhere in that region for some time.
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1 But even with that some of the items that we were i
\~ 2 into, even as far as seismicity, fell into the range of very 3 difficult or almost impossible to analyze.
4- A lot of that, though, what we did, even though we 5 reported them as 50-55 (e) s, we went through a significant 6 test program to prove they were okay because there was no 7 method of analyzing it so we actual 2 7 went out and tested it 8 on shake tables.
9 DR. REMICK: I think perhaps we had best proceed.
10 We are running out of time.
11 MR. COUNSIL: I don't have much more.
12 MR. CARROLL: Let me just shift the emphasis here.
13 One of the products of all of this was good documentation of 14 the design basis.
()
' 15 MR. WARNICK: That is correct.
16 MR. CARROLL: How, has that been thoroughly and 17 completely reflected in operating procedures and maintenance 18 procedures? Has somebody made a conscientious effort to 19 make sure that what some designer had in the back of his 20 head is --
21 MR. WARNICK: That the programs are designed to 22 accomplish just that, and I think they are far along in 23 those programs, and Bob may talk about some of that, but 24 yes. There has been a concerted effort to do just what you 25 just said.
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- 1 MR. COUNSIL: In fact, we went out of our way to 2 make it easier for the operator and the engineer. Since we 3 were doing these reviews, we took what you are probably very 4 familiar with, specifications and design things from the 5 nuclear steam supplier and the architect engineer and all 6 the places these things come from as well as the specs from 7 the vendors that are building the components and so forth 8 and brought them into the plant.
9 We incorporated all of those into design basis 10 documents so there is one place you go. You don't have to 11 hunt for 18 different documents and maybe a thousand 12 drawings to find what you are looking for, to make sure you 13 maintain the configuration of the plant over its whole life, 14 so we do have design basis documents. We are living to 15 them. The operationa personnel have incorporated those 16 limits into their operating procedures, too.
17 MR. GRIMES: Mr. Carroll, I would also like to 18 point out that I am informed that our inspection activities 19 which are upcoming for the emergency operating procedures 20 and for the operations and maintenance procedures do spot 21 checks against design calculations in order to make sure 22 that the procedures are up to date.
23 MR. CARROLL: I know all that, but I also know, am 24 very familiar with, have found a few examples of where 25 there were communication problems between good design basis Heritage Reporting Corporation O (202) 628-4888 L____-__
284 1 documents'and people ~ writing operating procedures.
([
2 DR. REMICK: Please proceed.
3 MR. WARNICK: Okay. 1[ think I am down to design.
4 hardware reconciliation, and the final reconciliation 5 process uses the results of the hardware validation to 6 determine whether the validated design and the installed 7 hardware are consistent and includes provisions to insure 8 that the fir.al, validated design is complete and consistent.
- 9. The design valitation i packages represented the as-10 built, verified design and are then finalized and the 11 documentation is vaulted. .
12 DR. KERR: I am sitting here drawing a picture-of 13 'somebody vaulting over design records, but --
14 MR. WARNICK: A large vault, I am sure. The staff 15 and review activities, again in this-area, have been quite 16 extensive for each of the 11 scopes of work the staff 17 evaluated, each of the processes of the corrective action 18 program. These safety evaluations, as was shown earlier on 19 the slide, were documented in SSERs 14 through'19.
20 Also, the staff has conducted two and plans to 21 . conduct a third team inspection of the design validation 22 process. The first inspection covered an aspect of design 23 validation. The second team inspection covered the hardware 24 validation aspect, and the final inspection will be covering 25 the last aspect, the design hardware reconciliation.
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285 1 In addition to that, we still have an ongoing, t]
' 2 large site presence that is following the final stages of 3 the corrective action program and that implementation which 4 Bob is going to talk about so I just leave with a note, I 5 think as the discussion progressed, you did get the 6 impression that there was pretty vast and large programs to 7 deal with these issues, and there was fairly elaborate and 8 extensive NRC oversight of those programs.
9 Thank you.
10 DR. REMICK: Will the staff please continue?
11 MR. GRIMES: All right. Mr. Robert Warnick wall 12 now describe the inspection activities and the current plant 13 status.
14 I see a fair number of view graphs yet. We are
() 15 going to have to speed up our process a little bit to the 16 best of our ability.
17 MR. WARNICK: All right.
18 MR. GRIMES: Bob, did you get that comment?
19 MR. WARNICK: Yes. We will do the best we can.
20 My name is Bob Warnick. I am the assistant director for 21 inspection programs in the Comanche Peak Project Division.
22 I work full time at the site. I have eight NRC inspectors 23 that wort for me, and six consultant inspectors, and we have 24 been on the site essentially for the last two years full 25 time.
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- 1 Five of those eight NRC inspectors are reviewin'g 2 and inspecting the construction, corrective action program '
3 modifications. Three of the eight NRC inspectors'are 4 reviewing the pre-operational testing program in the 5 operations areas.
6 In addition, Region Four conducts inspections in.
7 the security, radiation protection, emergency planning, 8 environmental monitoring, confirmatory _ measurements, and 9 operator licensing areas and other special areas s2ch as the 10 integrated leak rate test.
11 MR. CARROLL: What are the areas of specialty of 12 your six consultants?
13 MR. WARNICK: We have mechanical,' electrical, 14 civil structural, quality assurance, so in general we can
. 15 cover all of the normal construction things.
.16 MR. CARROLL: The six consultants are dedicated'to 17 the construction activities?
l 18 MR. WARNICK: Yes. They sometimes assist us with L 19 the operations, but it is primarily the construction side.
20 The NRC site inspectors also have about those same kinds of 21 qualifications. They span the whole range.
22 DR. SIESS: These inspectors are actually 23 physically inspecting construction installation work?-
24 MR. WARNICK: Yes, sir.
25 DR. SIESS: I assume that the applicant also has Heritage Reporting Corporation O (202) 628-4888
287 1 inspectors inspecting that work?
-}
2 MR. WARNICK: Yes, they have 600-and some odd 3 _ quality control inspectors, and we have our 14 that do an 4 overview.
5 DR. SIESS: You do a sampling process?
6 EMR. WARNICK: Yes, sir. Last year we put in some 7 19,000 direct inspection hours in the plant.
8 I was going to touch on each of these topics that 9 are listed on the slide. The Corrective Action Program, or 10 CAT, is scheduled by the utility company for. completion by 11 October 2. Our findings to date confirm thet the utility 12 has done a very good job of implementing the Corrective 13 Action Program.
,,, 14 The pre-operational testing program was originally 15 completed in 1984.. Because of the elapsed time the many 16 changes made to the systems, and because Comanche Peak had 17 been identified by the NRC as a problem plant, I asked the 18 utility company to either repeat the pre-operational tests 19 or to provide the justification explaining why it was not 20 necessary to repeat those tests.
21 The applicant intends to repeat approximately 90 22 percent of the pre-operational testing program.
23 I have a couple of examples of tests that they are 24 not going to repeat if you would like to -- or I can go on.
25 DR KERR: In justifying the request for repeating O, Heritage Reporting Corporation (202) 628-4888
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,- 1 -- I say in justifying your request for asking them to 2 repeat the tests, you mentioned the fact that one of the 3 reasons was because the NRC had declared this a problem 4 plant. Why is that a justification?
5 MR. WARNICK: It really isn't. It is the 6 political atmosphere that it puts it in where people have to 7 -
you have to be able to sell what you are trying to sell, 8 that this plant is ready to license, and so we wanted to 9 make sure that they did a good job in their reviews of what 10 they had to retest and what they didn't have to retest.
11 MR. GRIMES: Mr. Kerr, as I heard Senator Simpson 12- say last month when I attended a subcommittee meeting that 13 Senator Breaux held, sometimes you find yourself in a much 14 brighter, harsher light, and you have to prove yourself to a 15 greater extent. I think that was the message Bob was trying 16 to get across.
17 MR. WARNICK: The applicant's staffing 18 requirements for one unit operation and for both units 19 operating are shown on the bottom part of the slide. The 20 current staffing of each of six shifts is also shown.
21 As you can see, the applicant has more than the 22 number required for operating one unit, and they have more 23 than enough people to meet their technical specification 24 minimum requirements for operating either one or two unit 25 plants.
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- l' I might point out that the tech specs require two 2 ' auxiliary operators to operate one urit. The utility is 3 committed to five auxiliary operators to operate one unit 4 and ten to operate two units. They currently have eight 5 . auxiliary operators on shift.
6 DR. REMICK: Is this a common control room?
7 MR..WARNICK: Yes.
8 DR..REMICK: Is there any administrative support 9 or shift supervisor and so forth'provided?.
10 MR. WARNICK: Yes. There is a shift clerk 11 assigned to each shift. In addition --
12 MR. CARROLL: How many of the shift supervisors 13- and unit supervisors are degreed people?
14 MR. WARNICK: Jim?
15 MR. KELLY: Jim Kelly, plant manager. Of the 16 shift supervisors-and unit shift supervisors, only one 17 presently that has -- I am sorry, we just promoted another 18 one. There is.two that have degrees. The majority of the 19 shift supervisors and unit supervisors are the traditional 20 Navy nuke or ex-fossil plant operator, significant 21 experience in operating a power plant. We are in the 22 process of integrating more completely the shift technical 23 advisors into the shift management. All of the shift 24 ' technical advisors are degreed, senior licensed individuals.
25 One individual I mentioned was just promoted was one of 1 Heritage Reporting Corporation (202) 628-4888
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,e 1 those shift technical advisors who was recently promoted to i
2 be unit supervisor.
3 We hope to in the near future integrate the STA 4 position into a unit supervisor position so that we will 5 have one shift supervisor and three unit supervisors for 6 each of the shifts, and eventually make that a dual path for 7 future individuals, but as of right now we have two shift 8 supervisors and unit supervisors who have degrees. i l
9 MR. WARNICK: The operations people have been on 10 shift since late 1980, and all the equipment in unit one and 11 unit two has been operated by operations since August of 12 1987. They have attempted to use operations procedures to 13 the fullest extent during the pre-operational testing 14 program.
s 15 In general, the NRC believes operations management 16 is very strong and the operators in general have been doing 17 a good job. However, there is still need for improvement, 18 and I will discuss that more in detail on my last slide.
19 DR. REMICK: A question for the licensee. I 20 assume, then, that your philosophy is that the STA should be 21 integrated in the shift operation. Obviously he is 22 licensed, and --
23 MR. BECK: Yes, sir. The shift technical advisor 24 at Comanche Peak has been integrated much more into the 25 shift than I have seen before. They do train with the Heritage Reporting Corporation O (202) 628-4888
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291 1 shifts. In fact,-when~we split the shifts up'for the 2 training, the shift technical advisor and one of the. unit-3 supervisors will train.the two reactor operators while the
.4 shift supervisor and the unit supervisor will train.the 5- other'two operators to increase that team. spirit.
6: In addition, we do emergency planning exercises so 7 it just seems.that they are much more involved. They will 8 become a integral part of the shift. They are, more 9 importantly in my mind, accepted by the shift. The shift 10 supervisors and the unit supervisors depend upon' STAS for 11- additional expertise on shift.
12 DR. REMICK: Thank you.
13 MR. WARNICK: Because of the utility's poor past 14 rate on the operator licensing examinations administered by-15 the'NRC and because of concerns expressed by the NRC, the 16 utility conducted an in depth self-evaluation of-their 17 training program and they embarked on a program to~ improve 18 it.
19 We had a management meeting in August of 1988 to 20 discuss the NRC concerns and the utility's program. Some of 2~ the changes that they discussed and have implemented: an 22 experienced consultant was brought in while a new training 23 manager was sought out and hired, and the new training 24 manager has been on site since earlier this year.
25 Changes were made to secure more management Heritage Reporting Corporation O (202) 628-4888
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- 1- < involvement, particularly in monitoring and evaluating the 2 ' training classes. They increases the operator simulator 3 training time. They strengthened the auxiliary operator ~and 4 reactor operator training programs, including on-the-job.
5 training to give the operators a stronger base of knowledge 6 and to increase their understanding and expertise, and they 7 have committed to a better or tougher screening process'for 8 evaluating candidates' readiness to take a licensing 9 examination.
10 A week ago Region Four was on site to administer 11 the requalification examination of 12' licensed operators.
12 All 12 successfully passed. In addition, Region Four found 13 the applicant's requalification program to be satisfactory, 14 and I might add Region Four told me that out of four of
'15- these examinations they have given, requal, examinations 16 using the new testing procedures, this was the first utility 17 where all of the candidates had successfully passed the 18 examination.
19 DR. REMICK: A question for the licensee. How 20 frequently does a plant manager or some of the VPs observe 21 operators on the simulator?
22 MR. BECK: I go down at least once a month.
23 During periods of time Mr. Warnick discussed, I was down 24 there at least once a week. I not only observe the 25 simulator but I do sit in on several of the classroom Heritage Reporting Corporation (202) 628-4888
3 293 activities. The operations manager for a good portion of
( 1-2 this time during the program to improve the training 3 syllabus was down there and spent, I will bet, 50 percent of
- 4. his time down there'so we have had management involvement.
5 Mr. Scott also has been involved. He can speak for himself, 6 but he was down there during those periods of time.
7 DR. REMICK: How about Mr. Counsil or Mr. Cahill; 8 do you ever go down and observe people on the simulator, any 9 of the crews?
10 MR. CAHILL: I have been down there once.
11 MR. COUNSIL: I have, but not as often as I 12 'should. I,-although I do like to watch operators on 13 simulators and so forth, as they will talk about in a 14 ' moment, I hope, I prefer going into the maintenance training 15 facility and seeing what is going-on there.
16 DR. REMICK: You do have an on-site simulator?
17 MR. COUNSIL: Yes, sir.
18 DR. KERR: The man who is trying to record this is 19 having difficulty picking up the conversation. Okay, please 20 proceed.
- 21. MR. WARNICK: The utility has been very proactive 22 in the area of maintenance training. They have a 39,000 23 square foot maintenance training building that contains 24 classrooms, laboratories, mock-ups and actual duplicates of 25 some piping, valves, pumps, motors, crane, switch gear,
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- )~ 1 control room panel, and instrumentation. .They have a room t,
2 set up to simulate a contaminated plant room, complete with 3- .a pump, a valve, a sample station, .and piping. Maintenance 4 men receive ALARA training in work on radioactive 5 equipment, spills, keeping procedures and paper work clean, 6 bagging out tools, and crossing step-off pads.
7 They also have a full. size mock-up-of the unit 8 one, number four, steam generator platform and the bottom of-9' the steam generator, complete with columns, railings, 10 everything exactly the way it is in the plant. They are
-11 able to give a maintenance man practical, hands on 12 experienco.
13 The NRC commissioner and NRC manatJement that have 14 seen this facility have been very' favorably impressed with 15 it, and I have two back-up slides that -- this first one is 16 one of the instrument laboratories with some of the 17 equipment you can see.
18- The second one.:Us the ALARA mock-up room. You can 19 see the windows where outside people can look in to see how 20 they are doing and monitor them.
21 The plant has successfully completed its HOP 22 functional test and integrated leak rate test. The leak 23 rate was about one-third of the allowable leak rate. They 24 plan to start the integrated test sequence Monday. This
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295 1 injection system tests, e.nd the utility ereects it to take
. O- 2 about 12 days.
3 The utility continues to indicate they will be 4 ready to load fuel on October 2, 1989. Most indications 5 point to them being ready by then. However, there are meny.
6 systems remaining to be tvrned over and accepted by 7 Operations. The last fig trer; I have showed Operations has-8 accepted 28 out of 92 systems, leaving 64 remaining to be:
9 accepted.
10 Approximately half or the pre-op tests: remain to 11 be completed. Approximately three-fourths of the test 12 results remain to be approved by the Joint Test Group, and 13 some 173 operations and maintenance procedures remain to be 14 written.
( 15 The site staff is over 9,000 people, including r 16 approximately 500 dedicated to unit two, and there-are 17 approximately 3,000 people working inside the protected 18 area. They are doing limited work on unit two. They are 19 doing work that is required of unit two to support. unit one 20 operations, and they are doing some work on unit two 21 equipment that is located in unit one areas to minimize the 22 amount of traffic unit two construction forces would create 23 in unit one areas while unit one was operating.
24 There is considerable work remaining for both the 25 utility and the NRC. We have several team inspections i
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2 broader:NRC review of these critical. areas.
3 MR. CARROLL: I get the feeling from what-you have 4 'said -- I am thinking that we are talking about two and a
- 5. half months from now -- an awful lot to.be done. That seems 6 like an optimistic schedule.
7 :MR. WARNICK: Yes, sir.
8 MR. CARROLL: Are there any emergency planning 9 issues? Are'we happy between the utility and the NRC and 10 theflocals?
11 MR. WARNICK: Yes, and no. They had a practice, 12 drill earlier this month, and the Hood County. judge.did not 13 'come out too well on that drill, and FEMA said that if they 14 would have been grading that drill, they would have flunked
-O- 15 him, and so the utility is working with him to bring him up.
16 There is going to be a graded exercise later this month.
17 There is going to be an EOP emergency team inspection.
18 MR. CARROLL: What does the Hood C7unty' judge have 19 .to do with the emergency plan?
20 MR. WARNICK: It is the county part, the locals..
21 MR. KELLY: The timing of this. exercise is bad for 22 Hood Counby. It is right in the middle of their budget 23 period. The Hood County judge is spending too much time on 24- his county budget and not enough time on our emergency plan, 25 but we are working on that, and we will have that corrective Heritage Reporting Corporation O- (202) 628-4888 i
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.O 2 :25th of this month. ,
-3 MR. WARNICK: On April.23 during the hot 4 functional. test a valve in the e.uxiliary feedwater system
.5 .was' opened out of'the specified sequence. When-the check 6 valves failed to seat, a back leakage, path was created which 7 allowed high temperature water from the steam generators.to 8 flow to the condensate storage tank.
9 Texas-Utilities later determined that at least ten 10- of its feedwater check valves were stuck open. These valves i 11- .had been disassembled in 1983. Tack' welds on the internals 12 were replaced with a full fillet weld, and these changes had. l 13 been recommended by the vendor following weld failure and i 14 disengagement of the parts. When the valves were ;
fk 15 reassembled, the maintenance man followed the procedures-16 specified in the vendor supplied manual. However, the
- 17. procedure was incorrect.
18 The procedure called for tb - threaded retaining j 19 ring to be screwed in until it bottomed out. Now, I will i
20 put a view of the va'ving on the slide in a minute. I 21 This resulted in the disk or flapper being.too low 22 in the valve body, and allowed the flapper to hang up under i 23 the lip of the seat. 1 i
24 MR. GRIMES: I was supposed to jump in a little 25 earlier and indicate that this is -- a recent experience at l Heritage Reporting Corporation
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290- 1 Comanche Peak, we had been informed that theACRS was-2 interested in these particular check valve-failures,'and so' 3- we put -- this last piece of the presentation was to tell 4 you about the particular failure, and it has got both some 5 operational lessons to it and also some generic aspects to 6 it, and in view of the time we are prepared to talk about 7 any and all of that experience to the extent ~that you would' 8 like to, and Bob is putting the cutaway on there. I will 9 bring up -- this is actually one of the valve flapper 10 arrangements, and this will answer your questions. We will 11 just show you this thing. 12 DR. REMICK: We appreciate your alerting it to us. 13 I think'we will be limited in the amount of time we can 14 spend on that particular thing today, but it is something 15 the subcommittee might want to pick up. I don't know if you 16 are aware of that or not. 17 MR. CARROLL: That is why we had asked to hear 18 about it, but we can delay it now and pick it up someday. 19 MR. GRIMES: This is ten out of how many potential 20 valves that -- 21 MR. WARNICK: They have 160. 22 MR. GRIMES: I mean in this system. 23 MR. WARNICK: It covers more than one system. Let 24 me give you -- 25 MR. MICHELSON: How many within the one system
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. .. 1 does'it cover? For instance,'how many.within the auxiliary
- 2 feedwater does'it cover? Every one of them?
3 MR. WARNICK: I don't know the exact number, but I' 4 do know there was 160 Borg Warner ch'eck valves in the plant, 5 the two units; 114 of them were a different design than this 6 'one, and were not subject to this mechanism of failure. 7 It turns out that they -- I believe there was 22 8 check valves of this size in the plant, and I believe that 9 all 22 -- I could be wrong, but I think all 22 are in the. 10 auxiliaryf feedwater system where it is subject to this 11 failure mechanism. 12 The six-inch and eight-inch check valves-which are 13 built this same way, the vendor manual specified correctly
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14 that you bottom it out and then you back it off some () 15 specified distance to get the correct elevation of-your 16 bonnet so that the disk sits against the seat, and so I 17 think it is 22 valves, and they found by radiographs and 18 testing that there was 10 of these, and I think they had 19' repaired -- had identified one earlier and had repaired it 20 and thought it was an isolated case, and so that made a 21 total of 11. 22 MR. MICHELSON: Why did it take so long to see 23 this problem? Since this happened back in '83, I think you 24 said? 25 MR. WARNICK: Yes. Heritage Reporting Corporation .
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7 300 1 MR. MICHELSON: Why did it take so long? 2 MR. WARNICK: Because the post-maintenance -- 3 there was no post-maintenance testing conducted after the 4 valves were worked on in 1983, and the utility failed to 5 recognize the problem in precursor events. 6 MR. GRIMES: Mr. Chairman, do you want to go into 7 the rest of the discussion'about the lessons from this, or 8 would you like us to conclude at this point? 9 DR. REMICK: On the valves? 10 MR. GRIMES: Yes. 11 DR. REMICK: I would suggest we not. We are 12 already over time, and we have another group of staff 13 scheduled to come in right after lunch so I would suggest 14 that the subcommittee-e, if it has questions, pursue this I
' \ 15 independently.
16 MR. GRIMES: We are prepared to show the hardware 17 and the cutaways to any interested ACRS members after this 18 meeting, then, and I will go on with my concluding remarks, 19 and then we will wrap it up. 20 MR. CARROLL: Just one quick question. Is an 21 information notice in preparation on this? 22 MR. WARNICK: Yes, we have prepared an information 23 notice. It has been sent in to Headquarters. It is under 24 review by the Generic Communications Branch. 25 MR. GRIMES: Thank you, Bob. Mr. Chairman, I
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,-(6 1 would like at this point to make closing remarks on behalf
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2 of the staff, and I am not sure that part of a question that 3 you raised earlier was satisfactorily answered, and I would 4 like to add my own view. 5 When I first started working on this project in 6 March of 1987, I first met Juanita Ellis, and with respect 7 to her qualifications to contribute to the off-site review 8 committee, I would like to add my own personal view that I 9 have been very' impressed with Ms. Ellis and her public 10 perspective and what it provides. 11 DR. REMICK: I happen to know her, too. I was on l 12 the original licensing board for Comanche Peak. I did not 13 know she was a representative on the committee. 14 MR. GRIMES: She is Case's representative on the 15 committee, and Billy Guard is her designated alternate, and 16 we have grown very close to both of them over the last two 17 years. 18 We have covered a substantial amount of material 19 today in a very short period, and I hope you have found this 20 information more enlightening than confusing. 21 More importantly, I hope that we have been able to 22 demonstrate to the committee that subject to the final 23 completion of the construction rework activities and pre-24 operational tests that Comanche Peak can be operated without j l 25 undue risk to the public health and safety. I i gm Beritage Reporting Corporation (,) (202} 628-4888 1 i I
302-1 In view of the unique circumstances of this case.
. (]) _
2 it is not clear to the staff what-action or continued i l 3 activity.the ACRS needs to do with respect to Comanche Peak, 4 but'I want'to assure you that the staff is prepared to
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[ 5 support the committee in whatever action you feel is 6 appropriate.
- 7. That concludes our presentation.
8 DR. REMICK:. Okay. I thank the staff very much. 9 Does the licensee want to add any final comments? 10 'MR. COUNSIL: If I may, just in respect to one 11 commentLyou'just made to Mr. Warnick about"the very
- 12. ambitious schedule, you are right, and we are supporting 13 what we think is a very ambitious schedule, but please don't 14 lose sight of the fact that we have now conducted three-O- 15 -functionals and one complete pre-operational test program, 16 and we are. redoing essentially those tests over again, and 17 when we say we are rewriting or writing 173 maintenance 18 procedures, it is a review and rewrite of procedures already 19 in existence, so it is ambitious. Don't get me wrong, and I 20 don't to denigrate Mr. Warnick's comments. However, it is a 21 doable program.
22 MR. MICHELSON: I don't want to belabor the check 23 valve question, but from the utility's perspective, why did 24 this problem not be picked up sometime during pre-op testing 25 and so forth? Why did it take them until recently to find () Heritage Reporting Corporation (202) 628-4888
303 1 out? 2 MR. CAHILL: It didn't show up in the earlier pre-3 op tests. The work that was done, as I understand, in 1983, 4 was a modification to those. valves. .It was done during 5 construction, and there wasn't a significant, if any, 6 incident of hang-up of those check valves at that time. 7 Now, we experienced this incident during our hot 8 functional test. We mado some operating mistakes in valve 9, ' lineup which allowed these check valves to be challenged 10 against back flow. 11 MR. MICHELSON: They aren't challenged during pre-12 op testing?
'13 NR. CAHILL: Normally, that loop would have been 14 isolated and --
) -15 MR. MICHELSON: I thought somehow most of the 16 active components of a system are - you design your pre-op 17 test to make sure that all your active components are
-18 functional.
19 MR. CAHILL: In this particular test where the . 20 incident occurred, the valves, gate valves, would have 1 21 isolated the check valves. There was an operating mistake. 22 The operating mistakes with respect to valve lineup have 23 been very carefully reviewed and indicate that we need to 24 establish a better discipline in operator adherence to that 25 kind of procedure. Heritage Reporting Corporation () (202) 628-4888 n < - .. _ . - - . - - - . . . - , - -
7 304 1 MR. MICHELSON: Did you go back to look at your
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2 pre-operational' tests to determine whether or not perhaps 3- they need to be looked at to make sure you are testing all 4 of-your active components? That is the purpose of pre-op 5 testing is -- 6 - MR. KELLY: We would have picked it up in 7 surveillance testing although not.necessarily in pre-t 8 operational testing. We had not'gotten to that point in the 9 plant yet where.we would be doing periodic surveillance.
- 10. MR. CARROLL: On a feedwater system, but is.this 11 same thing a problem in other systems where you rely on 12 check valves?
13 MR. CAHILL: Well, this particular design of check 14 valve, if it is not assembled right, lends itself to this 15 ' difficulty. 16 I would like to point out that this particular 17 problem, although there are a lot of problems with check 18 valves, is not widely understood in the industry, and there-19 were two other incidents of it, one at McGuire, one at St. 20 Lucy, which were not -- we got after we found this and 21 checked around, but it wasn't widely known in the industry. 22 When this happened to us, one of the things that 23 made it take so long to identify what the problem was is 24 that we very carefully checked it out. We x-rayed those 25 valves rather than taking them apart, which would have not l l Heritage Reporting Corporation O (202) 628-4888 u-__-____-________
305 1 identified the problem. f( ) 2 We saw the problem, probably for the first time in
, 3 the industry, by taking those x-rays. The incident has a i
4 lot of. good lessons for us, and a lot of lessons for the
,5 rest of the industry.
6 DR. REMICK: Does the staff want to make a comment 7 on that? l 8 MR. GRIMES: I would just like to add that with 9 respect to Mr. Michelson's questions, there are valid 10 questions. There are a lot of concerns that.we have, both 11 with regard to the implications for the operating staff 12 procedures and process. The pre-op test did not require 13 that these valves be tested. They weren't part of that
- 14 program. We would have expected to find them during hot 15 functionals, but we found a lot more than just this 16 particular problem, and we intend to continue to pursue that 17 until it is satisfactorily resolved, and we want it resolved 18 before licensing.
19 DR. REMICK: Are there any other questions? Bill? 20 DR. KERR: How long a period of less than, say, 25 21 percent power operation will staff require in the course of 22 start-up of this plant? 23 MR. GRIMES: Staff has not developed a position in 24 that regard. We will be meeting with the utility on Monday 25 to discuss their proposal for a start-up test program, and O rit e- verti-9 cera t tie-(202) 628-4888
1' i 306 _s 1 we will come to a judgment after we have heard what they
'\_] 2 would like to do..
3 DR. REMICh: Mr. Subcommittee Chairman, I assume l 4 than you don't propose a letter or anything else? 5 MR. CARROLL: No, I don't. 6 DR. REMICK: We thatk the staff very much, and 7 also the licensee for coming in and briefing us on the l 8 status. We greatly appreciate it. 9 With that we will break for lunch, and I suggest 10 we return at 1:30. 11 (Whereupon, at 12:30 p.m. the hearing was 12 recessed, to reconvene at 1:30 p.m. the same day.) 13 14 15 16 17 18 19 20 21 22 23 24 25 i Heritage Reporting Corporation O (202) 628-4888 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . 3
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-I 2 DR.!REMICK: Good afternoon, ladies and gentlemen.
V 3 To continue with our agenda, the next item is a Chernobyl 4 follow-up status update. The staff was asked to come in and-5 brief us on an initiative that was a spin-off'of the 6 Chernobyl implications study on trying to determine the 7 seriousness of procedural violations. The staff has asked 6 to:come in and tell us what they are doing and planning on 9 doing so this is a briefing in which they are soliciting any 10 comments that we might have. 11 There has not been a' subcommittee meetirg on this 12- so all of us are hearing it for the first time. 13 With that fairly brief introduction, I understand 14 that George Sege is going to lead for the staff. Is that () 15 right, George? 16 MR. SEGE: That is correct, Mr. Chairman. 17 DR. KERR: Mr. Chairman, before we get into that, 18 a point of logistics. What comes right after this? I am 19 trying to set up a meeting with Denny Ross and Jill Murphy 20 later in the afternoon, and if you could give me sonie idea 21 of when we are likely to be finished? 22 DR. REMICK: Our report preparation is scheduled 23 afterwards, but we will certainly not need the two hours 24 that are scheduled so I would expect that about -- I am just 25 guessing now -- 3:00 o' clock we will take up the last agenda , Heritage Reporting Corporation () (202) 628-4888 I _m___________ _ _ _ _ - _ _ . _ _ _ _ _ . _ _ _ _ _ _ - _ - - _ _ --
v. t 308 1 item which is the nomination of ACRS members.
'2 DR. KERR: So if I set a meeting at 3:30 or 3:45 3 we'would probably be finished?
4 DRi REMICK: That.3s my current guess ur.less other
.5 members have' issues that they want to bring up.
'6 'DR. KERR: Thank you.
7 DR. REMICK: Okay. All right, George. 8 MR. SEGE: Mr. Chairman, for the record my nuue is 9 George Sege, O ffice of Nuclear Regulatory Research. lt want 10 to spend just a few moments to bring the committee up to 11 date on the status of the Chernobyl follow-up research 12 activities as a'whole. 13 As I think all or most of you know, the Chernobyl 14 Implications Report, NUREG 1251, was approved by-the v 15 Commission and issued in final form in April of this year. 16 It had been previously reviewed by the ACRS. Public lL7 comments had been received on a draft and resolved, and the
- 18. comments in the resolution are documented in a separately 19 bound appendix volume to NUREG 1251.
20 The Chernobyl follow-up research effort consists 21 'of 23 tasks carrying out the studies recommended in NUREG 22 1251. Three of the tasks are new, are initiated as a 23 result of Chernobyl implicat. ions. That includes the 24 reactivity transience study at Brookhaven about which there 25 was a subcommittee and then a brief committee review last Heritage Reporting Corporation O (202) 628-4888
309-1 August and September; the procedure violations studi acout {} 2 .w hich you were here today; and a study of risks at low power-3 and shutdown. 4 'The rest of tus' tasks are limited adjustments to 5 studies of non-Chernobyl origin. The work is now well 6 along. Task closeout summary reports are being written now 1 7 and should be completed in the next few months, and we 8 expect to issue an overall closeout report on the program 9 early next fiscal year. There will, clearly, be further 10- work on some of the topics in the program, but they will be 11 pursued in the normal course of agency research and 12 regulatory development work, and the Chernobyl collector 13- label will not be continued beyond that time. 14 The ACRJ last reviewed the Chernobyl program last O 15 September. There was a general review of plans at the time. 16 There was a progress review of the reactivity transience 17 study by Brookhaven, and that followed, as I mentioned, a 18 more detailed review by the subcommittee on philosophy, 19 technology, and criteria. 20 The committee review today is about the procedure 21 violations study which will be introduced in a moment by 22 Jerry Wachtel. This is a progress review for the 23 committee's information, and we are soliciting discussion 24 and comment and advice in the course of this review. A 25 lettar is not required on this, but of course ve are pleased Heritage Reporting Corporation
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1310' 7( 1 .to have the. committee's comments and advice in whatever form 2 the committee deems appropriate under the circumstances. . 3 Unless the committee wishes to ask any general 4i questions about the program, I would like to turn the' mike 5 'over to Jerry Wachtel at this point. 6 DR. REMICK: Hearing none, I suggest you proceed. 7 Thank you, George, for that concise background. My 8 understanding is that the view graphs are contained in tab . j 9 ten so there is not a separate handout. Is it tab nine; 10' ' excuse me? I have tab ten. Tab ten; yes. ! 11 . HR. WACHTEL: My name is Jerry Wachtel. I am the. l 12 program manager for the procedure violations effort. I.am 13 with the Human Factors Branch of the Office of Research.- 14 The actual presentation will be made by Dr. I O 15 Valerie Barnes of Battelle's Human Affairs Research Center 16 with assistance from Dr. John Olson of the same I 1 17 organization. 18 '
. don't want to steal their time or their thunder 1 19 since we have a lot to cover in a relatively short time. I-20 just wanted to make some few administrative points.
21 First, as you have just heard, there is a package 22 of slides in your briefing books. They are marked " Draft." 23 They are essentially the same material that Dr. Barnes will 24 be talking from this afternoon, but please be aware that the 25 order of some of the slides within the package may have Heritage Reporting Corporation [) (202) 628-4888 _ _ _ - . - _ - - _ _ - _ . . _ _ - _ _ _ _ . - _ _ _ _ _ . _ _ _ . - _ . _ . _ _ _ _ _ _ _ . _ _ _ . . _ _ _ _ _ . _ _ . _ _ _ . . . _ _ _ . _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ . . _ _ _ . _ . _ _ _ _ _ _ - _ . _ - . _ _ _ _ _ _ _ _ _ _ _ _____.________.____]
l 311 f^' 1 changed somewhat. )
- (- J 2 One other point I wanted to make is that in order I
3 to contain this research effort within the available time 1 4 and budget, ins asked the contractor to limit their 5 investigation to events and incidents which occurred between 6 1984 and July of 1988. 7 We have continued to follow incidents involving 8 procedure related errors and procedure violations that have 9 occurred since July of 1988, including the most recent 10 incident which occurred during start-up testing at the 11 Seabrook plant which may be a classic case of what you will 12 soon hear is considered to be a Level A violation. We can 13 talk about that some more in discussion. 14 And with that let me turn the floor over to Dr. 15 Barnes. 16 DR. REMICK: Dr. Barnes? 17 DR. KERR: Excuse me. What did you ask Battelle 18 to do? 19 MR. WACHTEL: She will address that. 20 DR. KERR: All right. I 21 DR. BARNES: The issue of procedure violations is 22 obviouriy of interest because, in addition to the design 23 flaws of the RBMK reactor, procedure violations by the plant 24 engineering and operations staff were among the root causes , 25 of che Chernobyl event. (')
\d Heritage Reporting Corporation (202) 628-4888
M 312 i 1 The violations that we saw at Chernobyl were
~2- primarily,of'two types. They included violations of'the 3 ' organization's administrative review procedures as well as 4 violations of'the plant standard operating procedures.
5 .Now, the administrative review procedures 6 violations basically consisted of the plant 1 engineer who was 7 only an electrical rather than a nuclear' engineer preparing. 8 the safety analysis of the test in a rote-manner. He may 9 not even have been qualified to have performed the safety 10 analysis at all, and the violations of the standard-11 operating procedures included such actions as'taking the 12 reactor to low power performed in an unstable manner and 13 disabling the ECCS. 14 In addition to which, as I know you all know, the () 15 operators violated some of the steps in the test program 16 itself, and because of the major role that these failures to 17 follow procedures played in the Chernobyl accident, this 18 study was initiated to assess the extent of procedure 19 violations in the U.S. nuclear power industry and their 20 potential safety significance. 21 We were given three objectives. 22 DR. LEWIS: I just want t', interject for one 23 second. I am really not all that clear. Do the Soviets 24 have the same collection of procedure books around that our 25 plant operators do? That is, I understand trying to study Heritage Reporting Corporation (202) 620-4888 ((}
1 1 313 9 1. our procedure violations because of the Chernobyl accident, 2 but is there an implication that the Soviets also violated
-1' 3 an enormous collection of written procedures in'the same way 4 that'we are studying these?'
L. 5 DR. BARNES: That is what I have read on the basis
- 6. 'of the .eport. That is my understanding on the basis-of the 7 reports 8 DR. LEWIS: Is that true, Bill?
9 DR. KERR: I don't know. They had some 10 procedures, and the implication in the presentation was that 11 certainly that they violated them, but whether they were 12 formal written procedures is not clear to me. Other people 13 must have looked at this in more detail. George? George, 14 you are supposed to use the microphone. 15 MR. SEGE: George Sege. The Soviets don't have
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16 the sort of detailed procedures that we have. They do have 17 procedures, but they are less detailed. It is our 18 understanding that the procedure that they do have were 19 clearly violated, and there have been some convictions as a 20 result of that. 21 DR. LEWIS: That they violated common sense was 22 clear, but -- 23 MR. SEGE: They violated common sense, and they 24 violated the plccadures. 25 DR. LEWIS: No, the thing I am groping for is that () Heritage Reporting Corporation (202) 628-4888
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.that,"then, led'us-to look at the violation of=our-detailed, 1;
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;2 written procedures'as a reasonable-subject for'preventingLa 3 Chernobyl type. accident-in this crhntry.
):.{ 4 DR. BARNES: And our administrative review %) @ ~5 procedures. H 6 DR. LEWIS: Pardon" i-
, 7- DR. BARNES: And our administrative' review 8- procedures.
9 DR. LEWIS: - Yes,: I am just noticing where ,there -is 10 'a.little bit of' fuzziness in the logic. That is all. 11 DR. SIESS: Your analogy is more. general than 12 detailed. 13 DR. LEWIS: Okay, fine. 14 MR. CARROLL: I guess I am not clear on what an 0 15 administrative-review procedure is. 16 DR. BARNES: 'It would be a -- it is the plant 17 policies and procedures that guide the development used in 18 administrative control of the procedure documents in the 19 . plant. A procedure for procedures. 20' MR. CARROLL: We don't call them administrative 21' review procedures in, at least, my vocabulary. 22 MR. WARD: What do they call them in your narrow 23 perspective? 24 (Laughter.. ) 25 DR. BARNES: Okay, the objectives of this study l O Heritage Reporting (202) 628-4888 Corporation l
315 J 1 were.to distinguish procedus violations from procedure 2 related~ errors because the actions that the NRC might 3 considerLin response to violationa versus errors would 4 likely' differ; secondly, to determine the causes, nature, 5 _ extent, and consequences of procedure violations in power 6 plants to the extent that we could; and third, to recommend 7 methods for minimizing the problems that were identified. 8 Now,.when we went into this study we expected'en 9- the basis of prior work that we were familiar with to-find-10 . that there is, in fact -- there are not surprisingly likely 11 to be procedure violations in nuclear power plants. 12 In 1985 NPO conducted a study, a root cause 13 analysis, of 387 events of 180 significant event reports 14 that had occurred in '85, and identified that out'of 387 O 15 root causes, 16 percent of those causes of the significant 16' events were a failure to follow procedure. 17 AEOD conducted a study in the.'87 timeframe where
.18 they looked at significant events following procedures and 19 found that failure to follow procedures occurred in about 20 two percent of the LERs that they looked at. They looked at 21 101 LERs.
22 DR. REMICKt Excuse me. A question: are those 23 intentional failures to follow, or intentional or 24 inadvertent? 25 DR. BARNES: It is unclear from the descriptions ( Heritage Reporting Corporation (202) 628-4888 . - _ _ - - _ _ _ _ _ _ _ . . . _ m . _ _ _ . _ _ . _ _m __.._______--_.-.-_s__-_-___-___m_--_____-
316 L 1 that were in the studies what the distinctions were in these 7s r
\ 2 studies.
3 In the two NUREGs contractor reports that are 4 described up here, a study of maintenance procedures that 5 HARK and P&L conducted for the NRC ar.d a study of operating l L 6 procedures, one of the issues that we looked at was the 7 issue of procedural compliance; what are the administrative 8 policies; what are the practices with regard to procedure 9 compliance for both maintenance and operating procedures. 10 We visited 18 sites in the course of those tsro 11 studies, and we also have been interested in this issue in 12 the course of the work that we have done for the NRC, 13 auditing the effectiveness of the earlier version of the 14 emergency operating procedure program, and some of the () 15 findings from those studies also seemed relevant to this 16 issue. 17 One of those findings is that few licensees that 18 we are aware of require verbatim compliance; that is, step 19 by step compliance with the procedures as written, and in 20 fact often the decision of how to use a procedure is left up 21 to the individual workers, and the kinds of reports that we 22 heard from the people that we interviewed -- operations, 23 maintenance personnel, and so on, were that they would 1 24 review a procedure sometimes before they would perform the 25 task, and then not have it available while they performed Heritage Reporting Corporation () (202) 628-4888 j
l ' 'e 317-( 1 the task, r 2 Some of them would follow it in a step-by-step a 3 manner, or some of them would perform the task, then pull )1 4 out the procedure afterwards and go over it to see if they
$" had left anything out.
6 So the. approaches that we saw out in the field y i 7' varied pretty significantly, and one of the major findings 8 of those earlier studies was that the quality of the 9 procedures in terms of their usability, often in terms of 10 their technical accuracy, was so poor that verbatim 11 compliance was not a good way to go. The users of the 12 procedures would not have been able to accomplish their 13 tasks in an error free manner if they had followed the 14 procedures as written. 15 DR. REMICK: That is very interesting. I 16 certainly would have said that myself ten years ago. I am 17 out of date. It is interesting that that is still the case. 18 It is unfortunate, though, but -- 19 DR. BARNES: Yes. The failure to. follow 20- procedures can involve several types of behaviors, ranging 21 from intentional departures from procedural guidance to 22 simple slips in tie execution of some action that is 23 required by a procedure. 24 Consequently, one of our first tasks in this 25 project was to develop a taxonomy of the behaviors that Heritage Reporting Corporation (202) 628-4888
318
,. 1 could be characterized as failures to follow procedures, and
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2 so to develop operational definitions of those behaviors in 3 each of the classes, and based on our literature review we 4 initially came up with three categoriss of behavior 5 associated with failing to follow procedures that could be 6 distinguished by worker intent. 7 The first category that has been identified in the 8 literature has to do with sabotage with the intent to do 9 harm, which is clearly outside the scope of what we are 10 interested in here. 11 The other one had more to do -- had not to do with l'2 an intent to do harm, but in fact was an operator or a 13 maintainer intending to achieve the goal of a particular 14 procedure, knowing that the procedure existed but choosing 0) (, 15 to take some action that was not included in the procedure l 16 or choosing not to use the procedure, and then we had a 17 category, basically, of procedure related errors. 18 And so based on what we found in the literature, 19 we identified a Level A violation in these terms. A worker 20 performs actions that deviate from the procedure's intent, 21 and the worker is aware of his or her actions, and the 22 worker is aware that his or her actions deviate from the 23 procedure. 24 This sentence means that their actions were not 25 accidental. And in the course of reviewing incidents -- Ileritage Reporting Corporation () (202) 628-4888
319 1 MR. WARD: So Level A would include -- well, could 2 include sabotage, conceivably, but also the second class of 3 -event you talked about? l 4 DR.~BARNES: Right,. yes.
-5 DR. KERR: It is an intentional violation?
6 DR. BARNES: Yes, and some of the examples that we 7 ran into in'the' course of reviewing incidents -- one of 8 .these was similar -- well, almost similar to the Seabrook 9 event that Jerry Wachtel referenced earlier -- in that a 10 plant engineer, although it occurred earlier in the chain of 11 events in the start-up, a plant engineer approved a change 12 to a test procedure that had not been reviewed or approved 13 by the NRC. He knew that that review and approvt.1 by the
- 14. NRC was required, and he also knew that it hadn't been done 15 when he approved the chain.
16 A second example of a Level A violation occurred-17 in October of ' 86 where plant operating staff . incorrectly 18 concluded that the auxiliary feedwater flow shouldn't be 19 interrupted since it was providing core cooling in the 20 course of the event that they were involved in, and 21 essentially in this case they decided that the procedu're 22 step simply didn't apply to what it was they were doing, 23 which is of some significance since this was -- they were in 24 an emergency procedure. 25 MR. CARROLL: " Violation" has a very negative Heritage Reporting Corporation O (202) 628-4888
- _ _ _ _ _ _ _ - _ _ - - _ l
I 320-i
%r' 1 _ connotation.. The example that you'just gave, it was ;
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2 probably -- it sounds.as though it was the right thing to 3' do. 4 DR. BARNES: No, it wasn't, in; fact. In the'last 5 example, that was the Rancho Seco overcooling event. l l 6 MR. MICHELSON: I agree with that -- we'need'a 7 better word than " violation" because I agree that-8 " violation"--- 9 DR. SliLC: " Deviation." 10 DR. BARNES: That also has the enforcement 11 connotation. 12 DR. SIESS: Not necessarily. Lots of my friends 13 are deviants. 14 (Laughter.) 0 15 DR. wtRNES: Discrepancy, deviation -- we have 16 gone over ano over what are we going to call these things, 17 and this is what we have come up with so far, but if you l 18 have better ideas we would be really happy to hear them. 19 Now, this is one of those places in which we get 20 out of order. I want to talk about the Level C violations 21 or procedure related errors. These are violations os 22 departures from procedures in which the worker performs 23 actions that deviate from the procedure's intent, and the 24 worker is either unaware that the actions were incorrect or 25 unaware of his or her actions, or unaware that the actions Heritage Reporting Corporation O (202) 628-4888
321 11- deviated from the procedure. An action slip, from: 2 everybody's experience, might be driving to one location
'3- when you get:in your car as opposed to the one'you' really 4' intended to go to because you were thinking about something.
5 else. Maybe that never happens to you.
'6 DR. SIESS: But when you use the word " mistake,"
7 you are' assuming that the failure to conform to the
'8. procedure is wrong because within the definition, certainly, 9 of Level A there could be included intentional deviations 10 for good and adequate reasons because the procedure was 11 incorrectly written, and yet to call that a mistake would be 12 wrong, would be incorrect, so --
13 DR. BARNES: Right. The difference here is the 14 lack of intent, lack of intent to violate a procedure. 15 DR. SIESS: It may still have been right. 16 DR. REMICK: How about the definition failure to 17 follow procedures? Then you can call them Level A, B, and.C 18 failures? 19 MR. CARROLL: The point is, for example, in your 20 Level A definition, all of those conditions could be met, 21 and it could be exactly the right thing to do. 22 DR. BARNES: Right. 23 MR. CARROLL: As opposed to a situation where it 24 is exactly the wrong thing to do. l 25 DR. BARNES: That is right. () Heritage Reporting Corporation (202) 628-4888
322 1 DR. SIESS: And somehow I guess I am concerned [
^-)' 2 that it isn't in the interests of safety to lump exactly the 3 wrong thing to do with exactly the right thing to do under 4 the same category. That isn't helpful.
5 MR. WARD: What, do you want to include slips in 6 that? 7 DR. SIESS: I don't know. I -- 0 DR. BARNES: It is an important issue. Let's talk 9 about it in the question and answer period because it is an 10 important issue. 11 DR. SIESS: Okay. 12 DR. BARNES: Okay, some examples that we ran into 13 of the Level C violations or the errors, were a case in 14 which the operators had a high bearing temperature alarm on () 15 a motor drive feedwater pump, and they began to reduce power 16 of it to prevent equipment damage, and in the reducing of 17 the power they were making a mistake because the procedure 18 simply said to stop the pump, and it didn't provide any 19 additional information at all about the context in which 20 they could either downpower or would have to just trip it, 21 and the procedure also didn't provide them with the 22 information that if they were going to take one of them out 23 that they needed to start a thi.-d, and so the operators got 24 themselves into trouble but it was primarily -- not because 25 they intended to violate the procedure but because the l Heritage Reporting Corporation I () (202) 628-4888 I l - - _ _ _ _ _ _ _ l
1 323-1 procedure was_ inadequate. 2- Then in~a second example they.made some changes to 3' :their controls on the control ~ panel, and the technicians who 4 were involved in the change knew that you had to hold the 5 valve switch that had been installed closed for at least 15 6 seconds because there was a delay between closing it on the 7 control panel and what happened out'in the plant, to insure. 8 that it was completely closed, and some of the operators who 9 had been involved in the change also knew about it,.but'none 10 of that was ever integrated into the procedure and so there 11- was a procedural inadequacy that led to an error that ended 12 up leading to a tech spec violation. 13 But in the course of working.on these two 14 . definitions and trying to use these in. reading the incident
-O 15- reports'that we gathered in the course of the study, it 16 became clear that there was a whole'other category of. events 17 that we weren't catching and weren't categorizing correctly.
l 18 in the course of coding the information that we gathered, 19 and one of the reasons that we came to the conclusion that 1 20 we clearly needed a third category was that so much of the
~21 information that we were reading lacked adequate amounts of 22 detail with regard to the human behavior involved to be able 23 to come to any conclusion about whether or not there was 24 intent to violate the procedure or just what the causes of 25 the actual behavior or violation were.
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, : 1 And so we ended up with.a Level B violation or 2 Level B failure to follow procedures which we have defined 3 as a worker performing actions that deviate from the 4 procedure's intent,.and it is not possible.on the basis of 5 the informationLwe had to state that the worker was aware of 6 his or her actions, and it was our belief that a worker with 7 minimum qualifications experience exercising a minimal 8 degree of care would not have performed the action.
9 And some of the examples that we ran into that 10 fell into this category'-- 11 DR. SIESS: Excuse me. Maybe I missed.it, but why 12 is it that you always refer to the procedure's intent rather 13 than the procedure? Is there some significance to that? 14 MR. SHEWMAN: A very large one. 15 DR. BARNES; Yes. 16 DR. SIESL: I know there is a very large one, but 17 why is it brought in here? If-it is a written procedure and 18 .the procedure is wrong, and he does it, is that complying 19 with the procedure or with the procedure's intent, or what? 20 DR. BARNES: Presumably, the procedure's intent is 21 to accomplish a specific task. 22 DR. SIESS: And the procedure is right? 23 DR. BARNES: Well, and the procedure may be right. 1 24 The procedure may be wrong. The procedure may be lacking in 25 detail. f- Heritage Reporting Corporation (202) 628-4888 l l
-325 1 HDR . SIESS: But then how do you know from your.
f( }} 2 review of.these things -- do you have the information-on 2L both the, intent of a procedure and.the text of a procedure 4 .that you can compare? 5 DR. BARNES: We don't have the text of the 6 procedure available. .Sometimes we can make a distinction,
- 7. and sometimes we can't.
8 DR. SIESS: So if you don't have the text -- 9 DR. BARNES:- -- of the procedure. 10 DR. SIESS: Some of these errors could be that the 11 procedure was wrong? 12 DR. BARNES: Right. 13 DR. SIESS: Which is another level of error 14 somewhere further up the line? 15 DR. BARNES: Right. 16 DR. SIESS: And we don't know that? 17 .DR. BARNES: Right, and one of the -- 18 DR. SIESS: Without seeing the procedure, you 19 think you know the intent? 20 DR. BARNES: All of this is secondhand 21 information. I mean, it is even a more difficult problem to 22 determine some human being's intent. Presumably, three 23 people could read the same procedure, read the scope and the l 24 ' purpose section of it, and come to a similar conclusion 25 about what the intent of the procedure was. () Heritage Reporting Corporation (202) 628-4888
E. 326. 1 On the other. hand,'three people could see the same
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2 event occur and come to three separate and equally 3- justifiable conclusions about what the intent of the person-4 was. 5 All of this, because of the quality and' lack of 6 detail of the information and because it is a difficult-7 problem to address, is best judgment. It is a best judgment 8 kind of activity. 9- So one of these Level B violations that we ran 10 into'was the case of a health physics technician leaving a 11 .very high radiation area and forgetting to lock the door,.or 13 how he described it. He described it as forgetting to lock 13 the door and forgetting that he had to post warning lights.
. 14 Another example we ran into was a case in which a 15 turbine operator closed valves that he thought were 16 misaligned and consequently he inadvertently isolated the-17 nitrogen supply to the AFW automatic flow control valves for 18 a 20-hour period. He did it without a procedure. He just 19 took independent thought and action and closed the val res, 20 with the consequence that they lost their boration 21 capability.
- 2:2 Now, the levels that we have come up with are 23 similar to terms that are used within other parts of the 24 agency, particularly in the Office of Enforcement. In our 25 case the Level A violations are similar -- our Level A
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. " 1-327 1 violations are similar.to what the Office of Enforcement ,f 2 will call'in their enforcement letters willful violations..
3 Our Level B violations are similar to'what they 4 callfcareless disregard, careless disregard for the 5 procedure; and then our Level C would be just a procedure ~ > 6 related error. 7 DR. REMICK: Let me give you another example.- If. 8 we look at the Davis Besse case where, let us say, an 9 operator is following pr. ' tes but 'in doing it he has to
.10 push a= button.- He inadvertently pushes the wrong button.
11 Now, would you count that as a violation of procedure, or is 12 that just operator error and outside your study? 13 DR. BARNES: That would be an action slip. 14 DR. REMICK: A slip; a slip. les, okay. () 15 MR. CARROLL: Not an error? 16 DR. BARNES: We are not talking about errors. We 17 are talking about Level C violations. 18 MR. CARROLL: But using your definitions, I mean, 19 okay, he did deviate from the procedure's intent, but not
- 20. through any cognitive process. He just pushed the wrong 21 button.
22 DR. BARNES: Fight. 23 MR. WARDt That is what Level C is, isn't it? 24 MR. CARROLL: But error is not in the vocabulary? n 25 DR. REMICK: A slip is pretty close. Heritage Reporting Corporation () (202) 628-4888
328 [') v 1 DR. BARNES: Yes. Okay, as was pointed cut 2 earlier, our search for incidents was limited to significant 3 events as defined by the NRC that occurred during the years 4 of~1983 to July of 1988 inclusive, and so we began trying to 5 identify significant events with the expectations that the 6 LERs would be the major source of our data for the study, 7 and that was our experience. Some of them are, and many of 8 them that we read were just not focused on the human 9 behavior or the description didn't focus on the human 10 behavior. 11 We started out in looking at Licensee Events 12 Reports by focusing on events that resulted in a SCRAM only, 13 and we sampled 100 out of those; began by hoping that we 14 could read the abstracts; found that the abstracts didn't i 15 provide us with sufficient information, and so then went and 16 pulled up the actual LERs and read and coded those; found 17 very little, as I said, human performance information and 18 very few incidents that could be coded or could be used for 19 this study at all. 20 So we broadened our search criteria and ended up 21 sampling an additional 500 LERs that were coded as involving 22 human errors, task description inadequacies, procedures, and 23 so on, a sample of those, and so over all we looked at a 24 total of 600 LERs in the course of this study. 25 A much more fruitful avenue of endeavor was (') Heritage Reporting (202) 628-4888 Corporation
329 () 1 looking at inspection reports. In particular wt read all 2 the volumes of NUREG 0940 which is the NUREG regarding 3 enforcement actions, significant actions resolved, and these 4 were very useful because the reports included the NRC's 5 inspection team's perspective on what had happened, and 6 oftentimes they also included the licensee's response to the 7 enforcement action which, in the course of describing their 8 correcti?* actions, it was possible to sometimes identify 9 how they had categorized the event; whether they believed 10 thht, in fact, there was intentirsnal non-compliance or if it 11 was simply an error or a procedural inadequacy or whatever. 12 We were able to get at the causes of the violation 13 itself much more than we were in the LERs because the LERs fs 14 were focused on the equipment event rather than on the k-) 15 causes of the human performance in the situation. 16 But we also looked at other types of inspection 17 reports that were follow-ups to some of the LERs. We would 18 look at the LERs that would look promising, and we would try 19 to follow it up by looking for an inspection report related 20 to the LER. 21 We also looked at one office of Investigation 22 report. We reviewed al: of the augmented inspection team 23 reports. We were able to access, and we also read through 24 all of NUREG 0090 which is the report to Congress on 25 abnormal occurrences. () Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _______-_______a
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330-1 DR. REMICK:- Out of-curiosity, why didn't the
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2 staff ask them to lock at IMPO SCRa? 3 MR. MINNERS: I don't have an answer to-that. We 4 already had that data; right? IMPO report, this is on:a-5 previous slide -- 6 DR. BARNES: But it is.a. summary report'. .It was
- 7. part of our literature review. It summarizes their analysis-8 of the root causes of the events that they looked at.. It 9 doesn't provide detailed information about who did what.in a 10' particular. event.
11- MR. WACHTEL: I am not sure the IMPO reports are 12 available to us, the detailed -- 13- DR. REMICK: I expected that would be your answer, 14 but I wasn't sure. I didn't know. 15 MR. WACHTEL: Yes, the summary report was,.but the 16 ' detailed reports, I think,'were not made available to us.. 17 DR. BARNES: And Jerry, you guys attempted to get' 18 access to HPES data for the purposes of this study and were 19 unsuccessful. 20 MR. WACHTEL: Right. I 21 MR. CARROLL: Can you tell me why? 22 DR. BARNES: I don't know why. I wasn't involved ' i 23 in it. ) 24 MR. WACHTEL: Yes, they just -- IMPO has not 25 chosen to make that available to us. There have been a lot Heritage Reporting Corporation () (202) 628-4888 1
331 1 of discussions with them between NRR management and IMPO ( }) 2 personnel, and we have never reached a successful agreement. 3 MR. CARROLL: What are the problems preventing an 4 agreement? 5 MR. WACHTEL: I don't know the answer to that. I 6 don't know if anyone behind me does. 7 MR. CARROLL: I can understand IMPO not wanting 8 just to send you a copy of every HPS report that a utility 9 sends them, but for some special purpose study like this I 10 would almost think IMPO would be willing to at least give 11 you expurgated versions of the reports. 12 MR. WACHTEL: All of the discussions that have 13 been held, and they have been held at a level much higher 14 than myself, have been fruitless in trying to get any of 15 that data. 16 MR. CARROLL: Maybe we ought to put that on our 17 list for the next meeting. 18 DR. BARNES: Okay. For each of the incident 19 reports that we were able to access, we developed a coding 20 form that required the coders to record the following 21 information. We identified the plant, the region, mode 22 power level, reactor type, the severity of the violation 23 where possible, and that was primarily out of the 24 enforec:aent actions where they were categorized as a Level 25 3, 4, and so on. () Heritage Reporting Corporation (202) 628-4888
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[} 1 2 We also tried'to look for the cause of the violation if any of that information was in the report, the 3' kind of activity and the procedure that were involved in the-4 ' event, the. people that were involved, and the consequences 5 of the violation, if it was possible to identify those. 6 To do the coding we had human factors specialists 7 with knowledge of nuclear power plant procedures read 8 through them first, and then we had their coding, are in the 9 cours a of having .their coding QA'd by license , examiners at 10 P&L who are much more familiar with the equipment and 11 systems and operations maintenance activities than we are. 12 And here is what'we have identified so far. Maybe-13 first I should point out that the reason that these totals 14 don't agree with the totals you saw in the earlier slide is O 15 that there were whatever the difference is number of 16 incidents that we called out that didn't have anything to do 17 with a pre?edural or human error at all, that were, in fact, l 18 just equipment failures that somehow had gotten into the 19 LERs as a human performance issue or were just part of the 20 sample that we got. 21 DR. REMICK: A question. Is there any chance that 22 those for an LER might be the same as some of those for 23 NUREG 0090, or did you screen out any duplicates? 24 DR. BARNES: We screened out duplicates. 25 DR. REMICK: Okay. l j () Heritage Reporting Corporation (202) 628-4888 l l f.. u-_-___-___ !
O t 333
'l DR.-BARNES: So as you can see so far,.the Level A' 2 and Level B violations are a fairly small percentage.of the 3 total: number of incidents that we coded, and it may be more 4 interesting to note that Level C violations accounted for 5 the majority of the events that we looked at.
6 MR. CARROLL: What is the fourth category? l l 7' -DR. BARNES:- Non procedure related errors where 8 there.was human error involved in it, but it wasn't. human 9 error that was associated with the procedure in any way, 10 shape, or form. 11 MR. CARROLL: Well, our earlier example, it seems 12 to me,.of the guy, you know, knowing what he should do but 13 pushing the wrong button ~would be.in that category, wouldn't 14 it? O. 15 DR. BARNES: Well, only if there was no procedure 16 to guide him;.if there was no written document that he 17 violated. 18 DR. KERR: How can there be anything that an 19 operator does that isn't covered by a procedure? And 20 particularly, can there be 28 percent of what operators do 21 that are not covered by procedures? That is astounding. 22 MR. CARROLL: It is to me, too. 23 DR. CATTON: That is 28 percent of where they did 24 the wrong thing. 25 MR. CARROLL: Well, the other thing that I guess Heritage Reporting Corporation O (202) 628-4888
334 4 { .1 gives~me~ problems with this is,JI don't-know what the six 2 percent means under Level A because I could have a good
'3 Level A violation or a bad Level'A violation.
4 DR. BARNES: Yes.
- [5' MR. WARD
- Also, you could have good Level C l , .
L 6 slips and bad -- I mean, you could have somebody that-7 accidentally did the right thing. I think we are kind of l 8 over-emphasizing the importance of that. I mean, did you -- 9 DR. BARNES: The focus, I think -- I mean I know 10 of what we studied on was the behavior, and didn't focus on 11 . the consequences of the behavior, and didn't make the value 1 12 judgment about the behavior. We are concerned with did they 13 violate the procedure. 14 MR. WACHTEL: Keep in mind that the numbers here 15 refer not only to operators, most of whom have their 16 activities governed by procedures, but other personnel in 17 the plant, maintenance technicians, INC techs, who may or , 18 may not be operating under strict procedures. Those show up 1' 19 in these data as well. 20 MR. WARD: I think what Jay is looking for is some 21- non-events that were caused by Level A. 22 DR. BARNES: That were prevented? 23 MR. MARD: Yes. You don't have data on those. 24 MR. CARROLL: I mean, I want bperators to 25 consciously and willfully violate a procedure if the Heritage Reporting Corporation (202) 628-4888
335 -(J 1 procedure, you know, didn't anticipate the situation they 12 are-in.-
'3 DR. REMICK: Under what conditions? I assume 4 under emergency -- routinely, would you want'them.to.do 5 that,-or would you want them to stop there.and get the 6 procedure corrected by somebody.
7 MR. CARROLL: Sometimes you are in'a realLtime
.8 situation.
9 DR. REMICK: Okay, that is right. Well, but there' 10 are different situations. You certainly woulu.pt encourage 11 an operator to violate under any condition; right? 12 MR. CARROLL: No. 13 DR. REMICK: Okay. 14 MR. CARROLL: But if, you know, the procedure says O 15' this. He has been trained on it, and all of a' sudden a 16 situation occurs that the procedure really doesn't cover, 17 you know, he gets an "Atta boy" if he figures out how to 18 violate the procedure -- 19 MR. WARD: That is what those guys were trying to 20 do at Chernobyl. That is exactly what they were trying to 21 do. 22 DR. KERL: Jay, this is interesting because I have 23 asked recently at least two licensee managements what they 24 would want an operatar to do if they thought -- if they were 25 convinced the procedure was wrong, and the answer in both Heritage Reporting Corporation ( }. (202) 628-1888 i
b; 336 1: cases was " Follow the procedure." 2 DR. SIESS: This is concerned with following the L 3 intent of the procedure. The procedure could be wrong, but 4 they might still follow the intent. 5 MR. WARD: Or the procedure may lead them-the 6 wrong way. 7 DR. SIESS: What is bothering me more than that is 8 the-differentiation in Levels A, B, and C. Why is it 9 different if an operator willfully reaches up~and pushes the 10 SCRAM button versus the guy that inadvertently leaned up 11 against something and SCRAM' d the reactor? 12 MR. WARD: Just in simplest terms Level C might 13 mean you ought to make the buttons look different so they 14 won't tend to make that mistake. Level.B might'be that he O 15 needs some training. Level A might be that he needs some H16 education. 17 DR. SIESS: But none of. this is related to 18 procedures. This is all related to operators. 19 MR. WARD: No. It tells you what, if you are 20 getting a certain class -- what they.are trying to do is 21 sort out the classes of violations or wrongful actions and 22 procedures so that you know what to do about them. 23 DR. SIESS: But in order to do that you really 24 have to get into the level she mentioned of some of these 25 are RO; some of them are SO; some of them are maintenance Heritage Reporting Corporation O (202) 628-4888
337 () 1 2 technicians; some of them are physics people. MR. WARD: Well, they only had $150,000. 3 DR. BARNES: And only a year. 4 DR. SIESS: Somehow you have got to cross 5 reference that to severity. 6 MR. WARD: And we spent a billion dollars on -- 7 DR. SIESS: We spent a billion dollars on a lot of 8 things. 9 DR. BARNES: Okay. Then wa also have looked at 10 the personnel involved in Level A and Level B incidents. As 11 you can see, the largest group of incidents involved 12 operations personnel which probably shouldn't lead us to the 13 conclusion that operations personnel are prone to violate es 14 procedures. It may simply be a function of what he pointed 15 out earlier, that they have a lot more procedures. They are 16 under a lot more scrutiny. They are a lot more visible 17 because they are in fish tank. 18 Maintenance activities, again, I might not want to 19 jump to the conclusiot. that maintenance technicians follow 20 rrocedures very closely because earlier work has indicated I 21 that often there are not procedures in exi.stence for 22 maintenance activities. The use philosophies in the 23 maintenance crafts are often different than for operations 24 personnel. 25 MR. MICHELSO'J: I am puzzled again. Your () Heritage Reporting (202) 628-4888 Corporation l l
338 e 1- predominant source must have been the LERs. You.had other 2 sources, but that was dominating it. 3- DR. BARNES: No. In fact, it wasn't. If you look 4 back on that' earlier sheet, you will notice how very few of 5 either Level A or Level B incidents we got out of the LERs, 6 and in fact the NUREG 0940 enforcement actions, inspection 7 reports in the second column, are what dominated it since 1 8 that is what they are intended to describe'is violations. 9 And'the other aspect of this-that was a surprise 10 to me, I guess, simply because I haven't studied these
=11 procedures in the past was the number of health physics 12 violations that were identified. The other group is 13 primarily security violations, securi&v personnel.
14 The type of procedure or activity that was 15 involved -- 16 MR. MICHELSON: Now, what do you -- I am sure you 17 recognize that whatever data base you are using is only a 18 partial set of everything going on. 19 DR. BARNES: Oh, yes. 20 MR. MICHELSON: In the case of the LERs they are 21 only triggered by rather significant events, and you would 22 expect those to be coming mostly from operators and reactor 23 operators as opposed to the fe31ow doing the maintenance 24 work which triggers fewer -- see, if he makes a single 25 miscake and there is a single failure, that isn't reported E Heritage Reporting Corporation (202) 628-4888
ta
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f 339 {} 'l under LER. It has to be an event of' sufficient impact to 2 meet the criteria of LER reporting so.I expect those-to be- - 3 fewer reports simply because most of what he screws up 4 through this process isn't reported by that means, at least. 5 Now, are your other meens -- are you assured by 6' your other means that you are picking up these single 7 situations that aren't reporte( under.LERs? 8 DR. BARNES: No. 9 MR. MICHELSON: In some proportion? 10 DR. BARNES: .I am sure we are not. I am sure we 11 are not. 12 MR. MICHELSON: It is hard, then, to judge from 13 looking -- I certainly would expect that senior operators 14 and reactor operators would be high on the list because they 15 ' trigger the kind of events that get LERs issued very often. 16 DR. SIESS: They do more' things than anybody else. 17 MR. MICHELSON: Yes. In terms of triggering 18 events that cause LERs, but the maintenance men do a lot of 19 things in terms of triggering single failures, you know; the 20 valve.that doesn't work right and so forth, and those I 21 reported, 22 DR. BARNES: Or setting up a situation for 23 aomething that happens to the operr. tor. 24 DR. KERR: You recognize that she is only talking 25 about A and Bs, not Cs, in these charts? () Beritage Reporting (202) 628-4888 Corporation
340
<- 1 MR. MICHELSON: I didn't quite recognize - yes,
(_)g 2 this particular chart is just for the -- 3 DR. KERR: The one just before that, also. 4 DR. BARNES: It is Level A and Level B. 5 DR. SIESS: The Cs, forget about. The Cs are 6 mistakes. Right? t 7 DR. BARNES: Procedural -- we haven't analyzed, we 8 haven't finished analyzing the Cs yet so I don't have those. 9 I don't have anything to report with regard to those yet. 10 The type of procedure activity that was involved, more than 11 one document or activity might be coded here so, for 12 example, you could have, especially in the enforcement 13 action reports, they are often written in the format where 14 they will say, okay, "This particular action violated your i
\ 15 tech spec, violated your administrative procedure, and 16 violated this step of your operating precedure," and all 17 three of those documents would then be coded on our form as 18 having been violated.
19 DR. SIESS: The guy did the wrong thing, knew he l 20 did it, knew he was doing it wrong. 21 DR. BARNES: Knew he did it; meant to do it. 22 DR. SIESS: And B is -- l 23 MR. WACHTEL: B is we don't know. We don't have 24 enough data to tell us whether it was willful or not.
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25 DR. SIESS: I continue to be surprised that they pg Heritage Reporting Corporation (/ (202) 628-4888
341 1 'run so close to each other, that -- fl 2 DR. BARNES: That they are so consistent? Well, 3 the Level B violations were oftentimes cases where, in our 4 perception, how we informally describe it to ourselves, 5 where he ought to have known. You know, if he didn't know 6 at that point in time that what he was doing was a 7 violation, he sure ought to have known,'and it was our gut 8 feeling or something that he probably did and it just didn't 9 get represented that way in the information that we had. 10 D:t. SIESS: Maybe they gave him the benefit of the 11 doubt. 12- DR. BARNES: Yes, in the information that came out 13 in the report so from that standpoint -- 14 DR. SIESS: The Bs ".re more likely to be As than 15 Cs. 16 DR. BARNES: That would be my feeling about them. 17 You bet. If we had more detailed information, I would 18 expect that they would become A rather than C, although it 19 has gone both ways once we have been able to gather 20 additional information. 21 MR. MICHELSON: Is there some reason why the 22 deviation from prescribed order only occurred at Level A? 23 You didn't see any Level Bs, or just not a big enough sample 24 or what? 25 DR. BARNES: As you can see -- I don't know, but Heritage Reporting Corporation (202) 628-4888
i x 342 1- as you can see,'there weren't very many of either of those, 2 and I' don't think it is because there, in fact, aren't a lot 3 of.those out in the world. I think that those are just 4 difficult to observe and once again it is the level of-5- detail issue and the information that we were able to get. 6 MR. MICHELSON: Well, but there is no bar shown 7 which infers that it is extremely small or zero. 8 DR. SIESS: But the difference between five 9 percent and zero is -- here you have got a difference 10 between 30 and 40. 11 MR. MICHELSON: Well, she shows bars down to one 12 percent without any difficulty. That is why I am trying to 13 get an answer. -Apparently, they were well below one. Well, 14 she shows ones down there at the bottom on the incorrect 15 procedure. 16 DR. BARNES: Use of incorrect procedure for a 17 level -- at Level A. 18 DR. SIESS: What is your total As.and Bs? Can I 19 find that somewhere? 20 DR. BARNES: One hundred forty-focr. 21 DR. SIESS: Onu hundred forty-two?
- 22. DR. BARNES: One hundred forty-two.
23 MR. CARROLL: Out of 1136. I 24 DR. BARNES: What I found to be interesting about 25 the omission of steps as well as the failure to use the Heritage Reporting Corporation (202) 628-4888
. _ _ . _ _ ._ __.____.__..____._m
343 l' procedure results was that those findings were similar to 2 some other studies that have be-an done. Rasmussen in 1980-3 looked at human errors in maintenance, 200 reports of those, 4 and found that.34 percent of the reports described omissions 5 of actions that he described as functionally. isolated acts, 6 and 17 percent included other omissions. That IMPO '83 7 study found that 64.5 percent of the tunnan errors in those . 8 events in maintenance were acts of omission;.76 percent of 9 the human errors in operations were acts of omission; and 10 then a study of developing y'ogrammatic performance 11 indicators that John was involved in that was published in 12 ' 86 found that 66.1 percent of the procedure related LERs 13 that they looked at from 1986 involved the omission of steps 14 or the omission'of entire tasks that were required by. 15- administrative procedures so what we are finding is fairly 16 consistent with things that have gone before. 17 Then we have got the consequences of the Level A 18 and Level B violations, and as you can see, we haven't had a 19 Chernobyl in the United States, and that the major 20 consequence of most of the incidents that we looked at was 21' that they exceeded tech specs. 22 We have had SCRAMS, safety function actuations, 23 and one of the issues of concern is that we have had quite a 24 bit of personnel exposure associated with non-compliance l l 25 with procedures. Heritage Reporting Corporation O (202) 628-4888 E _ _ _ _ _
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,( { 1- DR .' SIESS: In your judgment how much difference-2' does it'take on those graphs to be significant?
3 DR. BARNES: I don't know. l 4- DR. REMICK: What do.you mean by-difference? 5 DR. SIESS: Well, difference in percentage;.what
'6 is statistically significant?
- 7. DR. BARNES: To say whether this is significantly.
~
8 different.from that? I would want a lot more. 9 MR. WACHTEL: Let me remind you this.is an interim 10 progress' report. This is not a final report of the study. 11 There are still several months to go so there is more data 12' yet to be analyzed.
.13 DR. BARNES: Our prelim..aary conclusions baced on 14 what we have so far, you have heard already, basically, that .-f. '
15 very few of the violations or failures or non-compliances 16 ' led directly to SCRAMS or safety system actuations; that the 17 number of Level A and Level B violations that we have 18 identified so far is likely to be an underestimation for the 19 reasons we have discussed today; the biases in reporting, 20 the fact that our sample is not complete, and the fact that 21 the level of detail didn't allow for an accurate judgment 22 for many of the incidents. 23 The large number of Level C violations suggests 24 that there are some inadequacies in the procedures 25' themselves, and as we have discussed earlier, more detailed Heritage Reporting Corporation (202) 628-4888
345 l description of the human performance aspects of these in the (} 2 LERs and in the inspection reports would help. 3 DR. KERR: What number of Level Cs would have led 4 you to believe that the procedures were okay? 5 DR. BARNES: I think that if I found similar 6 numbers across all three categories. 7 DR. KERR: Why would that be the same because it 8 seems to me people are more likely to make inadvertent 9 mistakes than willful mistakes? 10 DR. BARNES: I don't know. 11 DR. KERR: I don't doubt that there are procedural 12 inadequacies, but I wouldn't know whether the number you 13 have seen is a large number in terms of what one .*hould .f 14 anticipate in a normal situation, and I thought perhaps you 15 had developed some numbers that led you to believe that this 16 is much more than one should havr. expected to see. 17 DR. BARNES: No. It is just based on the prior 18 studies that we have done, and looking at them out in the 19 field led us to put that interpretation on the number, and 20 also the descriptions of the incidents themselves led us to 21 the conclusion that it was primarily -- that the kinds of 22 errors and actions we are seeing are primarily due to 23 inadequacies in how the procedures were -- 24 DR. KERR: Okay, that I can und'srstand, but unless 25 you have something to compare it with, 't isn't clear to me () Heritage Reporting Corporation (202) 628-4888
346 1 that this is necessarily an abnormally large number or --'so ( 2 it wasn't the large number that you depended on so much as 3 that you read and saw something of the procedure, and it was 4 hard to understand or poorly written or something? 5 MR. CARROLL: Do you have any insights into why 6 people, quote, " willfully violate" procedures? 7 DR. BARNES: Yes, based on interviews that we have j 8 done and work that we have done out in the field, when they 9 are technically inaccurate; when they are hard to use; when 10 they get in the way of getting the job done or the 11 perttption is that they are in the way of getting the job 12 done; when there is an organizational climate that says, you 13 know, the best way is to try to get around these rs 14 requirements rather than to fulfill the requirements, you 15 know, the organizational culture; all the way up to the fact 16 that the NRC doesn't have a procedure use policy. 17 DR. SIESS: But, Jay, according to these figures 18 that she has so far, willful violations occur at about a 19 rate of one each five years at a plant, the reactor year 20 figure. Now, I almost find that hard to believe. 21 MR. CARROLL: I guess I do, too. 22 DR. REMICK: Based on this data, this data base. 23 DR. SIESS: How much worse could it be? If a data 24 set is off by a factor of 100, then, you know, we ought to 25 just forget about it. It is just twice as many out there as Heritage Reporting Corporation [) (202) 628-4888
I i 347- l l 1 this.
'DR. BARNES: 'The other issue, though, ist that this
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2
- j. , 13 ' data set is oriented toward significant events, and~as we 4 . were discussing earlier with-single failures or with, you i 5 know -- there-must be thousands per year.
6 DR. SIESS: It is still well below the 7 significance of Chernobyl. 8- DR. BARNES: These are.
'9 IHl. SIESS: By a few orders 'of magnitude.
10 DR. REMICK: If the staff is looking for any kind 11 of comments on-the status of the study at this= time, I -- 12' DR. SIESS: You haven't gotten any so far. 13 DR. REMICK: What I would suggest is, you try to g- - 14 get away,from violations. You might consider that failure 15 to follow procedures -- and call these failures if you want 16 to get away from the word violation. 17 MR. CARROLL: Have you seen anything up to now 18 that you consider startling? 19 DR. BARNES: No. 20 MR. CARROLL: I guess -- I' don't know what you do 21 about it, but I guess one comment I would have, given the 22 reliance you are putting on inspection reports, is that in 23 my experience from the other side of the fence, inspection 24 reports tend to be written very negatively, and oftentimes 25 an inspector tends to leave out some things or hasn't done a l () Heritage Reporting Corporation (202) 628-4888
348 (} 1 2 very good job of finding out what really happened. He leaps to conclusions very often, and part of it is, he puts this 3 down on paper and it is up to the. utility.to come back and 4 say, " Hey, you got the wrong story here," but that never 5 appears in the inspection report. 6 So I guess I would just say you should exercise 7 . some caution in believing inspection reports. 8' DR. BARNES: Yes, yes I definitely -- even if we 9 were to go out, which we hope to be able to do at some point 10 and sit down and talk to all the people that are involved in 11 a particular incident -- 12 MR. CARROLL: You will hear the other side of the 13 story. 14 DR. BARNES: Yes, but even if we.were to do that, r 15 we would be very likely to get ten different stories if we 16 talked to ten different people, and how do you decide what 17 is truth in those cases as well. So there is one kind of 18 bias you might see in the LERs and another kind of bias in 19 the inspection reports and -- 20 DR. SIESS: What you are suggesting, maybe, 21 clnting at, is that some selected case histories might be 22 more revealing as to what should be done or could be done 23 than is a purely statistical study. 24 DR. BARNES: I think that more detailed case
- 25 studies would provide us with greater insight.
1 [) Heritage Reporting (202) 628-4888 Corporation
.._________m____.___.___ _ _ _ _ _ _
V 349 [
~1 DR. SIESS: I presume there are two objectives a
2 here; one, to find out if we have got a problem; and the 3 other is, if'we have a problem, what do we do about it. 4 DR. BARNES: What can we do about it. 5 MR. MACHTEL: That is right. We had hoped to get 6 into -- l l 7 DR. SIESS: We know little enough about how to l 8 teach people'now without knowing what we are trying to teach 9 them. 10 MR. WACHTEL: We had hoped in this' study to get 4 11 into some case history evaluations to look beyond the 12 statistics, and we simply did not have the time or the money. 13 within the project. We are considering doing that as a 14 follov-on if this merits further investigation. O 15 DR. REMICK: Jerry, what is planned for the 16 current study between now and the completion of the report? 17 What activities still need to be done? 18 MR. WACHTEL: Well, essentially there is a lot 19 more data that has not yet been refined that would be 20 incorporated into these charts that you have seen so far, 21 and they would be updated appropriately, and that is really 22 it. 23 Then there will be a report to indicate what we 24 have found and whether or not we think we need to look 25 further bnyond the statistics. () Heritage Reporting Corporation (202) 628-4888
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350 l()- 1 'DR. BARNES: We are also going to pick several of 2 the incidents that are of Level A, that fell into the Level 3' A category, .and attempt to think those through in a "what 4 if" manner, to try to do a little bit more assessment of the 5 safety significance of this' stuff. 6 .DR. REMICK: Any final questions for the 7 committee? 8 MR. WACHTEL: Do you want to see it before they 9 publish it? 10 DR. REMICK: Before they publish it? No, I 11 definitely would be' interested when you publish it. l 12 MR. WACHTEL: You would like that after the 13 . publication of this final report, or prior? 14 MR. WARD: Well, somebody has got to make some ' 15 sort of policy decisions on what research to do further or I 16 what else to do in response to this. I would like for the 17 committee to be in on that and give its comments on that. 18 DR. REMICK: Yes, that will be in your report, and 19 we can review the report. It is what, two months away? 20 MR. WACHTEL: Yes. 21 DR. REMICK: Two montha away. 22 MR. WACHTEL: Would you trefer to see that for the 23- full committee, or one or more of the subcommittees? 24 DR. REMICK: Well, we will determine that when we 25 see the report. Okay? l l () Heritage Reporting Corporation (202) 628-4888
l s 351 l [J 1 MR. WACHTEL: Fine. l 2 DR. REMICK: All right, I wish to thank the staff 3 and the contractor personnel for briefing us. It was < 4 interesting. Thank you. 5 (Whereupon, at 2:45 p.m., the hearing was 6' concluded.) 7 8 9 10 11 12 13 14 v 15 16 17 LB 19 20 21 22 23 24 25
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/-)
(_/- 1 CERTIFICATE 2 , 3 This is to certify that the attached proceedings before the 2 4 United States Nuclear Regulatory Commission in the matter 5 of: 6 , Name: 351st ACRS ,
?
P Docket Number: 9 Place: Bethesda, Maryland 10 Date: July 14, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear
~ "
13 Regulatory Commission taken stenographically-by me and, 14 thereafter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and, curate record of the foregoing 17 proceedings. (,< 18 /s 1 L C0o- : B: 19 (Signature typed) : 20 official Reporter 21 Heritaga Reporting Corporation 22 23 24 25 O rie e i'-earei=9 carear ** - (202) 628-4888
- s
( - c AGENDA ADVISORY. COMMITTEE ON REACTOR SAFEGUARDS i- COMANCHE PEAK STEAM ELECTRIC STATION 1 OPENING REMARKS C. GRIMES PLANT ~ & UTILITY DESCRIPTION TU ELECTRIC 1 ISSUES IN ACRS LETTER J. WILSON OF NOVEMBER .17 , 1981 BREAK
SUMMARY
OF EVENTS J. LYONS SINCE ACRS REVIEW COMANCHE. PEAK RESPONSE TEAM P. McKEE
& CORRECTIVE ACTION PROGRAM INSPECTION ACTIVITIES R. WARNICK
& PLANT STATUS CLOSTNG REMARKS C. GRIMES ADJOURN CONTACT: C. GRIMES, X233OO 1
l
}
c CONCERNS IN ACRS NOVEMBER 17, 1981' LETTER
- USE OF N-16 DETECTORS IN RPS
- LACK OF COMMERCIAL NUCLEAR EXPERIENCE
*- REVIEW GROUPS SHOULD INCLUDE INDEPENDENT, EXPERIENCED PERSONNEL
- TU ELECTRIC SHOULD EXPAND STUDIES ON SYSTEMS INTERACTION AND PRA
- INADEQUATE CORE COOLING INSTRUMENTATION
- LICENSING ISSUES STATUS
\
J i t ; _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _J
r\
%)
USE OF N-16 DETECTORS I N "'RPS ACRS CONCERN FIRST COMMERCIAL APPLICATION OF N-16 GAMMA RADIATION DETECTOR TO GENERATE REACTOR PHOTECTION SIGNAL STATUS
- STILL FIRST APPLICATION
- N-16 DETECTOR USED FOR:
OVERTEMPERATURE OVERPOWER COOLANT FLOW (TTFM)
- CALIBRATION DURING STARTUP
& POWER ASCENSION TESTING l
- TECH SPEC REQUIREMENTS FOR OPERABILITY & SURVEILLANCE i I
() 3
9 LACK OF COMMERCIAL NUCLEAR EXPERIENCE ACRS CONCERN TU ELECTRIC LACKS HANDS-ON EXPERIENCE WITH COMMERCIAL NUCLEAR POWER PLANTS TU ELECTRIC SHOULD ESTABLISH A LIST OF TECHNOLOGICAL MATTERS AND SKILLED PERSONNEL AND EXPERTISE AVAILABLE STATUS
- AUGMENTED MANAGEMENT TEAM COMMERCIAL EXPERIENCE > 300 YR TOTAL EXPERIENCE > 400 YR
- SUBSTANTIAL STAFF ENHANCEMENTS
- ROTATIONAL ASSIGNMENTS FOR OPERATORS &
MANAGERS AT OPERATING PLANTS
- TU ELECTRIC COMPILED AND MAINTAINS ISSUE LIST AND RESOURCES
- INPO ASSIST VISITS
() REVIEW GROUPS ACRS CONCERN THE REVIEW GROUPS (SORC, ISEG & ORC) SHOULD INCLUDE EXPERIENCED PERSONNEL OUTSIDE THE OPERATIONS ORGANIZATION l STATUS SORC (MINIMUM S MEMBERS) STATION OPERATIONS REVIEW COMMITTEE
- AT LEAST 3 MEMBERS WITH COMBINED EXPERIENCE > 22 YEARS AT PWRs ISEG (MINIMUM 5 FULL-TIME ENGINEERS)
INDEPENDENT SAFETY ENGINEERING GROUP
- ALL HAVE NUCLEAR NAVY EXPERIENCE ORC ( M I N I M u i' 6 MEMBERS)
OPERATIONS REVIEW COMMITTEE
- CONBINED EXPERIENCE > 92 YEARS
- TWO INDEPENDENT CONSULTANTS
- CASE MEMBER A
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SYSTEMS INTERACTION & PRA ACRS CONCERN TU ELECTRIC SHOULD EXPAND STUDIES ON SYSTEMS INTERACTION AND PROBABILISTIC ASSESSMENT, SO IT WILL HAVE A BETTER UNDERSTANDING OF COMANCHE PEAK STATUS INTERACTION STUDIES WHICH HAVE EVOLVED FROM THE CORRECTIVE ACTION PROGRAM: PIPE BREAK EFFECTS FLOODING SEISMIC /NONSEISMIC INTERACTIONS INTERNAL MISSILES FIRES ) y PROBABILISTIC ASSESSMENTS
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STRENGTHENING CAPABILIT'IES STUDYING 7PE APPRCACHES l ) .. O 1 _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ . _ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ .3
bO. INADEGUATE CORE CQQLING ACRS CONCERN THIS EQUIPMENT SHOULD NOT BE INSTALLED UNTIL IT IS WELL ESTABLISHED THAT THE INSTRUMENTS WILL- PROVIDE RELIABLE INFORMATION OF SIGNIFICANT VALUE BEYOND THAT PROVIDED BY THE INSTRUMENTS STATUS GUIDELINES ESTABLISHED IN: 4 NUREG 0737, ITEM II.F.2 REG -GUIDE 1.97, REU. 2 VESSEL LEVEL MONITORING SYSTEM CE SYSTEM BO DESIGN (PALO VERDE) HEATED JUNCTION THERMOCOUPLE MOUNTED IN VESSEL HEAD DESIGN ACCEPTED IN SSER 21 SYSTEM INSTALLED L7MITING CONDITIONS FOR 'OsERATION j l INCLUDED IN TECH SPECR I J
E. O
' STATUS' OF OTHER' LICENSING 'I SSUES -
10 OUTSTANDING LICENSING ISSUES 1 9 CONFIRMATORY ISSUES 9 POTENTIAL LICENSE CONDITIONS
- CHANGES RESULTING FROM ONGOING STAFF. REVIEWS OF THE FSAR O
*' ISSUES FAIRLY TYPICAL NOTE = S T A 7 U Gi AS O F~ Ei S E R 21 !
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l r O CHRONOLOGY OF EVENTS 1982 QA/QC & "WALSH-DOYtE" ISSUES SPECIAL INSPECTION TEAM l 1983 CONSTRUCTION APPRAISAL TEAM HOT FUNCTIONAL TESTING ASLB ORDER ON DESIGN QA 1984 CYGNA PROGRAM TECHNICAL REVIEW TEAM CPRT FORMED H&I - WELDING HEARINGS 1985 HEARINGS SUSPENDED BEGIN DESIGN REVIEW UNIT 1 CP EXPIRES l 1986 SSER 13 ON CPRT PLAN O
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" \,J CHRONOLOGY CONTINUED 1
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.1987 OFFICE OF SPECIAL PROJECTS 1
! TU CORRECTIVE ACTION PROGRAM !s CPRT FINDINGS & REPORTS 1988 OSP PROGRAM EVALUATION CPRT COLLECTIVE SIGNIFICANCE SSERs 14 - 20 TU - CASE - NRC AGREEMENT O HEARINGS DISMISSED SALP REPORT 87-40/31 1989' SSER 21 - LICENSING STATUS TECHNICAL SPECIFICATIONS d OPERATIONAL READINESS O
l'3 Q -- COMANCHE PEAK PROJECT DIVISION Christopher I. Grimes, Director Phillip F. McKee, Deputy Director l Cordell C. Williams, Technical Assistant i. Assistant Director Assistant Director for Projects for Technical Programs James H. Wilson James E. Lyons Carol Morris Catherine Berney Melinda Malloy Frank Ashe Mel Fields Donald P. Norkin Assistant Director for Inspection Programs Robrirt F. Warnick Wanda Warren Nancy Hodges i Herbert M. Livermore Joel S. Wiebe H. 're hannon . f-+11111ps , SRI Stephen P. Burris, SRI C111 ton J. Hole Steven D. Bitter, RI Michael F. Fiuny an Robert M. Latta O
s e O a COMANCHE' PEAK RESPONSE TEAM CPRT CHARTER & ORGANIZATION CPRT PROGRAM PLAN QUALITY OF CONSTRUCTION PROGRAM
- 46 ISSUE-SPECIFIC ACTION PLANS
- SELF-INITIATED EUALUATION DESIGN ADEQUACY PROGRAM.
- 4 DISCIPLINE-SPECIFIC ACTION PLANS
- SUBSUMED BY CAP O
STAFF PROGRAM- EUALUATION IMPLEMENTATION INSPECTION ACTIVITIES CPRT COLLECTIVE EUALUATION-i O 1 1
4 h V CPRT CONCLUSIONS
- CURRENT PROGRAMS FOR DESIGN, CONSTRUCTION, TESTING, AND ASSURANCE OF GUALITY ARE ADEQUATE
- PROBLEMS ARISING FROM WEAKNESSES IN HISTORICAL PROGRAMS HAVE BEEN IDENTIFIED AND APPROPRIATE CORRECTIVE ACTIONS DEFINED
- THE CORRECTIVE ACTION PROGRAM PROVIDES AN ADEQUATE MEANS OF UALIDATING THE DESIGN AND HARDWARE
- THE CORRECTIVE ACTIONS ENCOMPASSED BY THE CORRECTIVE ACTION PROGRAM GIVE REASONABLE ASSURANCE THAT STRUCTURES, SYSTEMS AND COMPONENTS WILL BE CAPABLE OF PERFORMING THEIR INTENDED SAFETY FUNCTION O
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l CORRECTIVE ACTION PROGRAM SCOPE WORK SCOPE CONTRACTOR SSER MECHANICAL SYSTEMS SWEC 17 CIVIL-STRUCTURAL SWEC 17 ELECTRICAL SYSTEMS SWEC 17 INSTRUMENTATION & CONTROL SWEC 17 LARGE-BORE PIPING SWEC 14 SMALL-BORE PIPING SWEC 14 HUAC EBASCO 18 CONDUIT SUPPORTS EBASCO 16 TRAINS A & B TRAIN C > 2" CONDUIT SUPPORTS IMPELL 16 TRAIN C < 2" EQUIPMENT QUALIFICATION IMPELL 19 CABLE TRAY HANGERS EBASCO 15
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, .C O R R E C T'I V E ACTION PROGRAM MAJOR FEATUREG
- PROJECT STATUS REPORTS
- METHODOLOGY DESIGN VALIDATION DESIGN BASIS DOCUMENTS HARDWARE VALIDATION FIELD VERIFICATION METHODS DESIGNeHARDWARE RECONCILIATION FINAL DESIGN RECORDS VAULTED
- STAFF- REVIEW & INSPECTIONS O
h----______.- _ _ - _ - _ _ - _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ - _ . - _ - -- - -_.__.-.a-_ _ - - _ - _ .
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INSPECTION ACTIVITIES
-PLANT STATUS
- CAP IMPLEMENTATION
'* PREOPERATIONAL TESTING
- STAFFING
- OPERATOR LICENSING & TRAINING O'
- MAJOR PLANT MILESTONES
- AUXILIARY FEEDWATER B A C VE L O W EVENT AIT FINDINGS l
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PREDPERATIONAL TESTING
- ORIGINALLY COMPLETED IN 1984
- PROGRAM EVALUATION STAFF POSITION REPEAT ALL PREOP TESTS EXCEPTIONS MAY BE JUSTIFIED ON A' CASE-BY-CASE BASIS
- TESTING STATUU AS OF JULY 8, 1989 100 TESTS TOTAL 83 PROCEDURES APPROVED BY JTG 47 TESTS COMPLETED 28 TEST RESULTS APPROVED BY JTG JTG = JOINT TEST GROUP l
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COMANCHE PEAK STAFFING 6 SHIFT CYCLE 3 WORKING SHIFTS 1 TRAINING SHIFT-1 RELIEF SHIFTL 1 SHIFT OFF PRESENT STAFF COMPLEMENT SHIFT STAFF-l SRO 25 11 RO 22 O O SHIFT CREW 1/2 UNIT CURRENT R E:Q
- D STAFF SHIFT SUPERVISOR SRO 1/1 1 UNIT SUPERVISOR SRO 1/2 2 SHIFT TECH ADUISOR SRO 1/1 1 REACTOR OPERATOR RO 2/4 4 AUXILIARY OPERATOR S/10 S l
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OPERATOR TRAINING i
- AUGUST 1988 MEETING ON EXAM FAILURES
- TU ELECTRIC COMMITTED TO TRAINING PROGRAM IMPROVEMENTS
- INPO PROGRAM REVIEWS ACCREDITATION UNDERWAY
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- REQUALIFICATION EXAMS IN JULY 1989 RESULTS ENCOURAGING
- MAINTENANCE TRAINING FACILITY O
y MAJOR FACILITY MILESTONES BEGIN PLANT HEATUP 4/3/89- C
'BEGIN ILRT 7/1'/89 C BEGIN INTEGRATED 7/17/89 TEST SEQUENCE !
.I READY TO LOAD FUEL 10/2/89
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. lj NRC TEAM' INSPECTIONS' CURRECTIVE ACTION PROGRAM FEB 89 APR 89 JUL 89 AUGMENTED INSPECTION TEAM MAY 89 O & M -PROCEDURES JUL 89 EMERGENCY PLANNING DRILL JUL 89 O
EMERGENCY PROCEDURES AUG 89 EQUIPMENT QUALIFICATION AUG 89 AUG OPERATIONAL READINESS 89 to SEP 89 O
L3J AUXILIARY FEEDWATER BACKFLOW EVENT AUGMENTED INSPECTION TEAM
- TEN 3" & 4" BORG-WARNER CHECK VALUES STUCK OPEN DURING HOT FUNCTIONAL TESTING
- VENDOR MANUAL INCORRECT IMPROPER ASSEMBLY BONNET BOTTOMED OUT DISK TOO L .7 W O
- OPERATIONAL LESSONS
- GENERIC LESSONS INFORMATION NOTICE BEING PREPARED l ()
1 1 l . L_ .
O I ACRS BRIEFING ON COWDE PEAK LNIT 1 JtLY 14, 1989 O 1 O l
i.] i OUTLINE i l o VISUAL OF CPSES - VISUAL 1 i o BACKGROWO - VISUAL 2 o PLANT DESIGN - VISUAL 3 o LICENSING MILESTDES - VISUAL 4 o ORGANIZATIONAL CHART - VISUAL 5 ,O l i i O
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- TEXAS UTILITIES ELECTRIC CGPANY (TU ELECTRIC)
TEXAS IGICIPAL POER AGENCY (TWA) TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC. (TEX-LA) o OPERATOR i O -. Tu ELECTRIC o LOCATION
- 2 LMIT SITE IN SOERVELL COLNTY, TEXAS
- 65 MILES SOUTMEST OF TE DALLAS - RRT M)RTH ETHOPOLITAN AREA O
VISUAL 2
l 1 O V l i l 4 PUNT DESIGN I o GDERAL i
- nESTDEHOUSE PWt
- ARCHITECT ENGDEER GtIGINAL - GDES & Hni, E. ;
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O BR M & ROOT, E . o NSSS CHARACTERISTICS i
- FutR-lfl0P, ino TRAIN SYSTEM
- inELVE FOOT CGE
- RATED PGER - 3411 M,1159 K o CORADMNT Di4RACTERISTICS
- STEEL-LDED, REDRECED CONCRETE l i
VISUAL 3
O TU ELE 1GC-1 LEEN5DE NII.ESIGES CD6TRUCTEN PEIDET ISSLED DECEMIER 1974 ASLB PIWCEEDDES DISMISSAL JILY 1988 ESTDETED ISSLE ID( PGER LEENSE OCRBER 1989 SOEILED REL L0llD OCHEER 1989 O 1 l l O VISUAL 4
I President I.<O) TU Electric
%> Generating Division I l Executive Vice President, Nuclear Eng &
Operations (3,3 l Senior Vice President g,33 I Vice President, Vice President, Nuclear Nuclear Operations (2a) Engineering (2s) Plant - Director of _ Manger, e Manager Projects Licensina (23) (1s) T2s
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Director of
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Startup Construction r Engineering (t r) (2s) gg 1 I - Plant Evaluation Managey1,} Chief Engineer g,,, Director, QuaW Mswag,, Manager of
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