ML22230A057

Tran-M771222: Public Meeting Review of Public Comments and Analysis by Staff of Ucs Petition

ML22230A057
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Issue date:	12/22/1977
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Tran-M771222
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E1liRN TO SECRETARIAT RECORD NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:

PUBLIC MEETING REVIEW OF PUBLIC COMMENTS AND ANALYSIS BY STAFF OF UCS PETITION Place - Washington, D. C.

Date - Thursday, 22 December 1977 Pages 1 - 73 Telephone:

(202 ) 347-3700 ACE - FEDERAL REPORTERS, INC.

Official Reporters 444 North Capitol Street Washington, D.C. 20001 NATIONWIDE COVERAGE - DAILY

DISCLAIMER This is an unofficial transcript of a~ting of the United States Nuclear Regulatory Commission held on IJt.l.J 2 2 1977 in the Commission 1 s offices at 1717 H Street, N. W., Washington, D. C. The meeting was open to public attendance and observation. This transcript has not been -reviewed, corrected, or edited, and it may contain inaccuracies.

The transcript is intended solely for general informational purposes.

As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion-in this transcript do not necessarily reflect final determinations or beliefs. No pleading or other paper may be filed with the Commissibn in any proceeding as the result of or addressed to any statement or argument contained herein, except as the Commission may authorize:

1 R5888 UNITED STATES OF AMERICA ER:mp

- sk 2 NUCLEAR REGULATORY COMMISSION 3

4 5

PUBLIC MEETING 6

REVIEW OF.PUBLIC COMMENTS AND ANALYSIS BY 7

STAFF OF UCS PETITION 8

9 10 11 Room 1130 12 1717 H Street, N. W.

Washington, D. C .

13 Thursday, 22 December 1977 14 15 The meeting* was convened at 9:35 a.m., pursuant to 16 notice, Dr. Joseph M. Hendrie, Chairman of the Commission, 17 presiding.

18 BEFORE:

19 JOSEPH M. HENDRIE, Chairman PETER A. BRADFORD, Commissioner VICTOR GILINSKY, Commissioner 20 RICHARP T. KENNEDY, Commissioner 21 Ace

-# 22 23 24 Reporters, Inc.

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CR 5888 HEER 2 pv#l P R O C E E D I N G S 2 CHAIRMAN HENDRIE: If we could come to order, the 3

subject:this morning is a continuation of the Commission's dis-4 cussion on a petition by the Union of Concerned Scientists, 5 dated November 4, on the subject of the safety implications of 6 tests on electrical connectors and electrical cables made by the 7 Sandia Laboratories as part of the NRC safety research program.

8 The purpose of this morning's:*meeting of the Commis-9 sion on this subject is to hear a summary of the full staff 10 report which has now been made, the staff report dated Decem-11 ber 15. This is a report for which the Commission allowed some 12 extensions of time. Originally specified for the report -- the

• 13 14 15 15th was the final due date.

This staff report should cover the full range of the petition matters as contrasted to earlier staff documents that 16 were direct~d*primarily to whatever*emergency aspects there 17 might be in those matters.

18 If the staff is ready, I assum*e, Mr. Case, you are 19 ready?

20 MR. CASE: Dr. Mattson will make the presentation.

21 DR. MATTSON: Mr. Chairman, I would propose that the

- 22 summary I would give would be fairly brief. We've had several 23 opportunities to go over most Of the technical considerations prior to today.

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25 CHAIRMAN HENDRIE: That would be merciful, Mr. Mattso ,

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• - 2 and allow the Commission a fuller opportunity for questions and discussions. That would be helpful, I think.

3 DR. MATTSON: I think what I would like to do is 4 briefly track the general structure of the report that we filed 5 on December 15, giving the results of our overall review of 6 the petition and our conclusions and our recommendations.

7 The central conclusions of that report on safety 8 matters were that, first, there was no immediate safety problem 9 with respect to environmental qualification of electrical equip-10 ment; and second, the actions taken and underway for fire pro-11 tection provide~adequate protection.

12 These central safety aspects raised by the petition

• 13 14 15 are summarily discussed in the introductory chapter 1 of the December 15 report.

The* UCS petition specifically requested six types of 16 action by NRC. These actions dealt with three cases with the 17 Commission's testing program. The first two had to do with a 18 request for accelerated testing, on the one hand, of fire pro-19 tection cables, electrical cables. Another had to do with 20 accelerated testing of the environmental qualification of con-21 nectors.

- 22 The third research-oriented request had to do with 23 independent verification in the laboratory of environmental qualifications of electrical equipment by NRC.

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25 The other*thr~e actions had to do with the

4 pv3 Commission's licensing activities, first to cease the granting 2 of CPs and OLs until general design criteria 3 or 4 and the 3 single-failure.criteria of th~ regulations were satisfied; 4 another havihg to do with the ceisation 0£ construction activi-5 ties involving cables and connectors; and finally, the shutdown 6 of operating reactors until general design criteria 3, 4, and 7 the single-failure criteria were satisfied.

8 Chapter 2 of our December 15 report deals specifi-9 cally with each of these six requested actions.

10 In an attempt to be brief, I will simply say that we:

11 recommend that the Commission deny the petition on all six 12 of those requested actions.

• 13 14 15 The bases for those recommendations of denial are discussed in summary fashion in chapter 2. Then in chapter 3 there is an overall report on our detailed technical basis for 16 those conclusions reached in chapter 2.

17 In addition, chapter 3 contains our analysis of the 18 44 public comments which we received on the petition in respons 19 to the Commission's Federal Register notice.

20 There are several things that I think are worth 21 summarizing here.

- 22 COMMISSIONER KENNEDY: Would it be possible to sum-23 marize briefly, at this meeting, those comments, or are they too diffused?

Ace - Reporters, 24 Inc.

25 DR. MATTSON: Let me try, and if you wish me to go

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further, then we can do that.

COMMISSIONER KENNEDY: I just want a brief summary._

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OR. MATTSON: As I recall, there were 44 comments, of which five supported the petition, that is, suggested that the Commission grant the petition.

6 COMMISSIONER KENEEDY: In whole; in its entirety?

7 DR. MATTSON::: Yes. As a general matter, those five 8 supportive of the petition comments did not contain detailed 9 analysis of the Sandia test information.

10 There were 20-odd -- only four stick in my mind --

11 comments which recommended denial of the petition. Some of 12 those contained no thorough or detailed analysis of the Sandia

• 13 14 15 test results.

Others contained quite thorough engineering and technical analysis of the implications or conclusions to be 16 drawn from the test results.

17 There were another group of comments which offered 18 technical information or technical analys*is or commentary on 19 the-petition without making recommendations with regards to 20 its disposition by the Commission.

21 MR. CASE: Let me go over those numbers again. There

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22 23 24 were 14 recommending that the petition be granted; 24 was right on the mark.

COMMISSIONER KENNEDY: Fourteen recommended that it Ac Reporters, Inc.

25 be granted.

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MR. CASE: Yes.

COMMISSIONER KENNEDY: Thank you.

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DR. MATTSON: If I could summarize some of the prin-cipal areas that we have concentrated on -- in the technical basis in chapter 3, one that is worth bringing up-to-date has 6 to do with the surveys.on electrical connectors, the use and 7 qualifications of those connectors.

8 You will recall we did a preliminary telephone survey 9 in which we identified a number of plants which were using 10 connectors. That was supplemented.by the bulletins 7705, the 11 results of which are in. On page 56 of the report there is a 12 table which is an expanded version of the one which I showed

• 13 14 15 as a slide the last time we met.

In summary, it shows that we have identified 19 plants having safety-related electrical connectors inside a 16 containment which are required to function in the LOCA environ-17 ment. On the basis of preliminary information now supplemented 18 by the formal response to the INE bulleti*n, we have concluded 19 that qualified connectors are in use. We are.continuing our 20 examination of the detailed qualification documentation. We 21 expect that that examination will be completed in January. We

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22 23 24 have examined it to the point where we,~_feel there are; no sur-prises in the information. It is a matter of going through the specific tests, the specific temperatures, pressures, and Ac Reporters, Inc.

25 what have you, to confirm in detail what we have previously

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judged. We don't expect any difficulties in that regard .

MR. SNYDZR: Roger, have you received now all of the documentation you asked for? This table indicates you are 4 waiting ...

5 DR. MATTSON: We have received reports from all 6 operating plants. We have received the formal documentation.of 7 the test.information.where tests were relied upon to demonstrate 8 environmental qualifications.

9 It was my understanding within the last couple of 10 days that they were still awaitirig some formal documentation ..

11 Karl Seyfrit, can you speak to that question? Do we 12 have ali of the documentation in, and it's just a matter of not

• 13 14 15 completing the review yet; is that correct?

MR. SEYFRIT: That's not quite correct. We are still awaiting formal documentation from a couple of facilities that 16 had connectors inside the container.

17 However, I might point out that the facilities in 18 question have:'.reported t.he use of connectors for which we have 19 qualification information from other facilities. I suspect that 20 we will wind up getting the same material at the end.

COMMISSIONER GILINSKY: Can I ask you, Roger, what 21 is the legal status of someone who is operating without quali-22 fications? Suppose it did not exist at all. Would that be 23 covered by a regulation? Is that something covered by an agree-Ac

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ment with any t~chniGal specifications, or is it simply somethin 25

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that is understood to be a commitment through part of the PSAR;*

or what?

MR. CASE: I think it would be required to appendix 4 B to part 50, that they have documentation under the QA criteria 5 to support the qualification of the equipment, so if that were 6 not available, they would not be in compliance with the regula-7 tions.

8 However, given a situation like that, the Commission 9 has a number of actions it might take in light of that situa-10 ti0n, enforcemenE-type actions it could take. The first ques-11 tion is the health and safety problem. Once you get beyond 12 that, then'you are into what sort of sanctions are appropriate

• 13 14 15 in view of th~ fact that the licensee .. does not meet the regula-tions.

DR. $TTSON: Well, you're talking about two regula-16 tions. One is a regulation that it shall be environmentally 17 qualified~ The other is a regulation that you shall have docu-18 mentation to support that.

19 COMMISSION GILINSKY: What is the first?

20 DR. MATTSON: General design criteria 4 would be the 21 one for design environmental qualifications and appendix B to 22 part 50 would be the regulation on the quality assurance docu-23 mentation.

a 24 A c . R_eporters, Inc.

The health and safety matter bears more directly 25 on the first, on the* general design criteria 4,and has been

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the emphasis of our review. We have said, I think, throughout I 2 3

the last couple of months that there were some licensees who were unable, in at least rapid fashion, to produce documentation, 4 and as Karl said, there are still some who have not supplied 5 that documentation yet, although they have said they are rely-6 ing on essentially the same test information as other licensees.

7 Apparently what is involved there is the difficulty 8 on the part of the licensee in obtaining the documentation from 9 the people who performed the test, where they did not have the 10 documentation on site.

11 COMMISSIONER GILINSKY: So, in other words, if you 12 thought it did not *exist at all, you would come to a different

• 13 14 15 conclusion.

D.* C. Cook.

DR. MATTSON:

Yes.

That, in fact, is what happened in 16 COMMISSIONER BRADFORD: I guess I have a little 17 difficulty understanding how one set of licensees would have 18 trouble coming out with data that other .licensees have .already 19 submitted to you.

20 DR. MATTSON: The ones that submitted probably had it at the facility. That is, they had retained it in the 21 record files and were able to just go back and retrieve it and 22

~end it in, where the other had to first search his own files 23 and find it wasn't there, perhaps, and write a letter to the A 24 A c . Reporters, Inc.

people who did the tests. You will often run into multiple 25

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tiers of suppliers, contractors, and subcontractors for a plant that is several years old. You are tracing back through fabrJ-cation reco~ds and testing records, and it could be a rather 4

difficult task.

5 COMMISSIONER BRADFORD: Well, I take it we don't have 6 to conjecture. We know which plants these are, and we must know end#l 7 why they're having trouble providing you the documentation.

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-h MR. SEIFFERT: I think that is true. I would

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4 like to clarify perhaps one comment that Mr. Case made~

And I don't want to take issue with Mr. Case, but I would po.int out that the question of documentation depends to 5 a great extent on the vintage of the plant.

6 In some cases, if you go back far enough, you 7 will find that there was no specific requirement for the 8 documentation being available or held for a specific time, 9 and some of that is very difficult to come by.

10 Dresden 1 is a good case in point where, as they 11 begin to look for their documentation, initially, they 12 did not even remember who had performed the tests, but

• 13 14 15 they were able .to trace this back through their chain and discover who had performed the test and, again, were able eventually to get the documentation~

16 Some of the facilities, as Dr. Mattson has 17 pOinted out, had the tests performed by other laboratories.

18 They did not retain the details of the tests in their 19 files but merely certifications that the tests had been 20 performed. And now they must go back to the laboratory

. 21 who had performed the tests and get the details of the 22 test results.

And that is the reason for some of the d~lay.

23 24 COMM! SSIONER BRADFORD: Which plants are those?

25 MR. SEIFFERT: I don*'t have those details with

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.h 588 * *2 me today. I could look them up and ge.t them for you, 12

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4 but I do not remember specifically which plants we have the. information from and which we don-~t at this point.

COMMISSIONER BRADFORD: How does Dresden l get 5 into the picture at all? They are not on this table.

6 MR. SEIFFERT: I know, but they were one of the 7 plants initially, where we had some question about their 8 documentation of some penetration tests.

9 DR~ MATTSON: You recall we did two surveys:

to one on penetration and one on connectors.

11 MR. SEIFFERT: And it was that same process that 12 they had to go through to obtain the qualification from

• 13 14 15 the penetration tests.

DR. MATTSON: Another point I would like to make under the environmental qualification area is that the 16 December.. 15th staff report contained the summary of the 17 state of knowledge., if you will, of the staff concerning the 18 environmental qualification of other electrical equipment.

19 There is an Appendix B to the staff report which goes to 20 some length to describe that state of knowledge.

. 21 If I can summarize it~ the principal feature of 22 the staff actions ongoing pertaining to the environmental 23 qualification of other electrical equipment is the decision

- 24 25 to make environmental qualifications of electrical equipment the first subject for consideration under the systematic

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7 I3 evaluation program. The 11 licensees in that program, 2 or currently in that program, have_. been told through their 3 owners group that this Would be the first item, the letter 4 to the licensees telling them of the information we need 5 and the scope of inquiry we intend to make is about to 6 go out, I guess over the Christmas holidays sometime.

7 Basically, we are shooting for a three-month goal with 8 two questions in mind: first, the status of environmental 9 qualification of electrical equipment on those I I plants; 10 and then, given some general picture there, we will make 11 a judgment on a second quest ion, that is, the need to look 12 further at this time at the environmental qualifications of

• 13 14 I5 the other operating plants. That is, equipment other than the penetrations and connector_s, which we just recently 1o ok ed at.

16 Our judgment at this ti me is that it is not 17 necessary to initiate a full-blown detailed study of these 18 other operating plants and other electrical equipment. We 19 have explained the basis for that in some detail, drawing 20 from the evolutionary history of environmental qualification 21 standards and their use in the licensing process.

22 But the systematic evaluation program gi.ves us an 23 opportunity to confer in that judgment. We will be doing 24 that within the next 90 days. And the Judgment is that if 25 we need to do more in the operating plants, we will do it.

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14 I would like to leave the environmental 2 qualification area in this summary -- overview, at least---

3 and speak of fire protection quite briefly.

4 As we said the last time we were up here, the 5 Sandia tests, to our way of thinking, are confirmatory 6 to our previous position on the required protection for 7 exposure fires; that is, separation ard retardancy 8 criteria are not sufficient in themselves to protect against 9 the propagation of exposure fires and other measures such 10 as detections, suppression, administrative measures, and 11 so forth, are necessary.

12 The fire protection program we've described at

• 13 14 15 some length in our December 15th report *. Its overall adequacy is continuing to be supported by the report. Our work is-continuing on standards, as we refine the standards 16 on the basis of public comments and their use in the 17 licensing pro~ess.

18 Our review of operating plants is c01tinuing.

19 We have given you a current picture of the status of that 20 review. Our work in the licensing of new OLs and CPs we

. 21 reported on in the report and our research program has been 22 summarized.

23 I might indicate that the program at Sandia is 24 continuing~ Its first phase can be roughly characterized I I

25 as the separation tests, the sub,ject of the petition. The I I

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15 second topic now being studied at Sandia c01cems the 2 fire retardancy capability of coatings for electrical 3 cables. The next set of tests will have to do with 4 ~uppression systems, fire extinguishing systems. Then 5 there will be some tests beginning in February or so on 6 our barriers, the effectiveness of barriers on stopping 7 the propagation of fire.

8 The continuing tests are providing us useful 9 information on coatings. We have yet to receive written 10 reports from Sandia laboratory. Sane preliminary information 11 is that they have tested for coatings. Some do well, some 12 donJt do so well.

13 We will be examining that kind of information 14 expeditiously as it is received. We continue to believe 15 the Sandia program is useful and supportive of our 16 standards development and criteria-setting activities 17 for use in the licensing process.

18 The final section of the December 15th report 19 had to do with the question of conformance with the 20 regulations, which is one of the principal thrusts of the 21 Un ion of Concerned Scientists' pe.t it ion.

22 I could briefly summarize that by saying that 23 we believe that the general design criteria 3 and 4 are 24 being met in the licensing process and are being met for 25 operating reactors. The single-failure criterion, as it

16 appears in many of the general design criteria, we 2 believe has been misconstrued by the Union of Concerned 3 Scientists. The single-failure criteria is not a design 4 basis in and of itself; it is, rather, a way of assuring 5 the .liability of the systems which have other design 6 bases. For example, the prevention of fire.

7 We have gone into some detail to try to sort 8 that out in Chapter 4 in the report. We can say simply 9 that the single-failure criteria are being met. We have JO tried to elucidate that subject by providing with the 11 staff report a copy of a staff report on single-failure 12 criteria, which we delivered to the Commission some months

• 13 14 15 ago and we have appended it here, attempting to show how the single-failure criteria has tended to be used and, in fact, is used in the licensing process. Not just in 16 fire protection and electrical equipment, but across the 17 spectrum of safety systems.

18 That completes an overview of the report*, Mr.

19 Chairman. I would be glad to answer your questions.

20 COMMISSIONER BRADFORD: I guess I have a fairly 21 broad range of questions. I don't know how you want to do 22 this. Sec ti on-by-sect ion?

23 CHAIRMAN HENDRIE: Not particularly. Why don't 24 you go ahead.

25 COMMISSIONER BRADFORD: Well, let me just start

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17 with something that picks up on what you're talking about 2 at the end, Roger.

3 On page 22 of the report, down toward the 4 ,,bottom of the page, could you just explain a little bit 5 more -- well, the specific language that puzzles me is 6 where you say, "for fire protection it may not be necessary 7 for the system to be designed with the seismic category 8 criteria or meet single-failure criteria because it 9 serves only as a system of last resort if other systems IO ha ve fa i le d. 11 11 Now on its face, you say a system of last 12 resort is one you wanted to be especially care_ful about *

• 13 14 15 DR. MATTSON: It may be you're reading the sentence a little too broadly. The sentence is talking about the dedicated system which is described in the 16 preceding sentences.

17 Let me try to talk about what the dedicated 18 system is, and then I think it would be easier to answer 19 your questions.

20 What is being said here is that, although

. 21 current regulatory guides and branch technical .positions 22 implementing general design criteria 3 on fire protection 23 require a measure of separation and barriers or other 24 fire protection measures which may exceed what exists 25 at operating plants, that that does not necessarily mean

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• 8 I that not:. __ operating plants have insufficient fire 18 I

2 protecticn. In fact, where the review of an operating I

3 plant has shown that it is physicially not possible to 4 separate these systems, there are alternative ways of 5 providing fire protection.

6 One would be to provide an additional sys.tern; 7 that is, to add hardware to an operating plant or to 8 qualify existing previously nonsafety grade-type equipment 9 to another service which would provide a dedicated system 10 which, in itself, would be the system which would function 11 given a fire that wiped out otlierwis~ redundant trains. That 12 is a dedicated sys tern, to substitute for the ge,p.ar.~ti.Qri.0!-,

• 13 14 15 requirements in the current criteria.

Therefore, it leads to the description that you have referred to, the one of last resort, when other safety 16 systems have failed; that is, some single failure could 17 wipe out or some fire could eliminate redudant safety 18 divisions in an operating plant; 19 If that is the case, then there has to be some 20 last res.art, some other system, in order to meet the same

. 21 failure kinds of considerations. And that would be the 22 dedicated system and, hence, it becomes a system of last 23 re sort.

- 24 25 Vic, do you want to add to that?

MR. STELLO= The plant at least has two independent

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• 9 19 systems. The degree of independence varies, depending 2 upon the age of the plant. If it becomes difficult to 3 show for specifically fires that a fire would not take 4 out both independent systems existing, then the way to 5 accomplish still having the redundancy is to put in a 6 third system.

7 So there would now be three ways in which you 8 could assure safety~ The third one you must show is 9 completely independent of the problem you're trying to 10 solve; that is, the fire. You have to put in a completely 11 separate electrical system so that the fire that you're 12 trying to protect against could not take out the two

• 13 14 15 systems you're trying to protect, plus this third.

If you did it, that is referred to as a dedicated system. The combination of these two will now 16 . meet the single failure.

17 Therefore, you need not make the dedicated 18 system by itself now meet the. single failure because the 19 fire could not cause both the new system and the dedicated 20 system you*'d be adding, depending upon the existing system 21 to be lost.

22 Hence, you come to the conclusion you don't need 23 that add it iona 1.

24 COMMISSIONER BRADFOROz What you're saying, I I I

25 think, makes more sense than the way it is put here.

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20 CHAIRMAN HENDRIE: I think it's also worth 2 noting that because the third system would be added 3 specifically to deal with the fire situation, its 4 qualifications are related just t that fire situation, 5 rather than the full range of possibilities, seismic and 6 whatever else.

7 DR. MATTSON: But the first two would have those 8 qualifications, the seismic and whatever else.

9 COMMISSIONER BRADFORD: Now is the system that 10 you described the system that is in effect in all operating l I pl an ts now ?

12 MR. STELLO: No, that is an option. They can

• 13 14 15 either find a way in which to add the fire protection so that the two existing systems would not be lost.

they can do that, that is acceptable.

If If they choose, 16 however, there is an additional way to go, and that is 17 to add this dedicated system that was chosen as an 18 option.

19 COMMISSIONER BRADFORD: But I gather from what 20 you say at this point in time they don't have to have done 21 either.

22 MR. STELLO: No. They must do either one or 23 the other.

24 COMM! SSIONER BRADFcrnD: They must have already 25 done it ..

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• 11 MR. STELLO=

21 They are in the process of doing

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4 it now. That is what our fire review, orqoing at the present time, is accomplishing.

COMMISSIONER BRADFORD: When does that process 5 have to be complete?

6 MR. STELLO: We will have our reviews finished 7 by December, 1978.

8 COMMISSIONER BRADFORD: When do they have to 9 have the system in place?

10 MR. STELLO= They are putting some of the systems 11 in now and depending upon the status of our review, which, 12 if it goes the way it usually does, we will require someth.ing

• 13 14 15 more. And they will be putting in systems past the time when we will complete our review.

Our decisions will have been made in terms of 16 writing off on what they have in the plant, plus what else 17 we want by December of next year.

18 MR. CASE: Can you give an idea of how typically 19 much longer than that the last plant might comply?

20 MR. STELLO: It is very difficult to pi ck a

. 21 particular dBte, but normally, there might be some activity 22 wh,ich would be most convenient to accomplish. And we would 23 agree that it is proper to wait that long for that 24 particular item, to cause that activity to be coordinated 25 with a refueling outage. And they might have to get

5881!1.12 22 I 9 - inside .the containment or. inside areas that we would not 2 want them to work in while the plant is operating.

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5 So we would have them install that equipment during their scheduled,refueling. So that could be any time, as much as possibly a year, to install sane 6 additional equipment.

7 So if I had to guess, I would guess it might 8 be as long as a year or so beyond the December date for 9 not all, but specifi~ pieces of hardware might be 10 installed.

11 COMMISSIONER BRADFORD: But I gathered from the 12 thrust of the report that the general design criteria is 13 that there's three or four of them?

14 MR. STELLO: Three is fire.

15 COMMISSIONER BRADFORD: Okay. In your estimation, 16 it is being met?

17 MR. STELLO: Yes , s ir

• 18 COMMISSIONER BRADFcrnD= Even though this 19 additional system is not in place?

t::.-,.,J--- 20 MR. STELLO: That is true.

21 22 23

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CR 5888 23 HEER pl COMMISSIONER BRADFORD: Could you explain again why

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that is?

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MR. CASE: Because the branch technical system, which is the ultimate goal, takes into account all knowledge th we have today and takes into account -- and the satisfaction 6 of general design criteria 4 on the basis of that, takes into 7 account the probability of fire and the number of plants. It 8 is a moving target, and today we believe that with their exist-9 ing equipment, plus the requirements that we put on for house-10 keeping,minimizing fires, administrative procedures, and the 11 requirements we are in the process of putting on with regard to 12 other administrative procedures,~ fire brigades satisfy the

• 13 14 15 minimum requirements of the general design.criteria 3 today.

on a COMMISSIONER BRADFORD: And that is based in part cohcusion having to do with L:the improbability of the fire?

16 MR. CASE: Yes.

17 MR. STELLO: One very important point -- all of 18 these plants, except for one who has got *some additional inform -

19 tion to submit, has submitted a program which has analyzed the 20 plant in conformance with the branch technical position 9.5.1, 21 which implements the requirements of fire protection.

-I, 22 So, in terms of the licensee's point of view, they 23 have submitted to us something that, in their view, meets our requirements. And we usually look, typically, to licensing, 24 Ac Reporters, Inc.

25 the licensing process. We look at what they give us, and we

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review it, and typically we have discussion and debate as to whether they are doing what we really want them to do, and we

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wind up adding some more. And that is the part of the review process where there is usual+/-y more and more added to what he already has committed. But they have done the first part of 6 this, which is, we sent them the branch technical positions and 7 said, "Do it," and they sent their response back to us with one 8 exception where there is some additional information coming in 9 on one plant. So, all, of the 65 have done that part of it.

10 COMMISSIONER.BRADFORD: What is the interrelationshi 11 between a branch technical position and a gen~ral design cri-12 teria*;. technical specifications and regulatory guides and

• 13 14 15 regulations?

down.

DR. MATTSON: Well, let's start at the top and work 16 The regulation, NCR part 50, is the regulation of 17 interest here. The general design criteria is something like 18 67, and they are contained in appendix A *to 10CFR part 50.

19 COMMISSIONER BRADFORD: You don't have to be meeting 20 the regulatory guide to meet the criteria?

21 MR. STELLO: That's right.

A < ~ R,portm, 22 23 7,!

regulation.

DR. MATTSON:

lesser step of formalism.

The regulatory guides would be the next They are one way of meeting the 25 MR. CASE:* And I should point out here, not

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• - 2 necessarily a minimum, since they are a staff way of meeting the general design criteria, hence are applicable to all plants.

3 DR. MATTSON: The generic nature makes them more 4 conservative.than a minimum way of meeting a regulation on a 5 specific plant, taking into account the design of that*piliant.

6 Now, the regulatory guides would be guidance to 7 licensees or applicants on how to meet the regulations~ The 8 branch technical position on the other hand is guidance to the 9 staff on how to. perform its review under the regulations. That 10 is.the procedures, the methods, the criteria, the findings"to 11 be used or thatjfiliow from the staff review.

12 COMMISSIONER KENNEDY: Which, in a sense, also

• 13 14 15 provides guidance.

DR. MATTSON:

that respect.

Yes, it does, and is widely used in It is a much-used document.

16 COMMISSIONER BRADFORD: And if the licensee is not 17 meeting the branch technical position, there may still be other 18 ways for them to comply with the general *design criteria.

19 MR. CASE: Yes, as well as regulatory guides.

20 DR. MATTSON: And the branch technical positions in 21 the standard review plan are still just one way of coming at

- *22 the problem. We often find ways, designs that aren't treated by the standard review p1an, new ways of coming at a problem 23 that haven't been seen before in the licensing process, in whic Ace - 24 Reporters, Inc.

there are no we.11-developed review methods. Nobody has thought 25

pv4 26 about acceptance criteria in a general sense before. When an I 2 3

applicant proposes those, we are bound to review them. And so you can look at the standard review plan, also, as one way of e 4 meeting the regulations. It is often the acceptance criteria of 5 the standard review plan simply don't apply to a given design.

6 We have to come up with another criteria.

7 COMMISSIONER BRADFORD: The last one, then, was 8 technical specifications.

9 DR. MATTSON: Those are contained in the license for 10 a specific facility, and they1generally' set the limit and con-11 ditions of operation for the facility under the terms of the 12 license.

• 13 14 15 comply?

MR. CASE: In effect, it is a license condition.

COMMISSIONER BRADFORD: You do have to meet that to 16 DR. MATTSON: Yes.

17 MR. CASE: It is another name for a license condition 18 COMMISSIONER BRADFORD: So they would be sort of 19 supplemental t6 the general design criteria.that you had to meet 20 to get the license in the first place.

21 MR. CASE: Well, they are more limits on operating parameters as distinguished from the general design criteria 22 which are design requirements.

23 DR. MATTSON: The general design criteria would be Ac

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• 25 applicable to ey~ryb0dy. The license would be applicable only

pv5 27 to that particular facility.

I 2 3

CHAIRMAN HENDRIE:

a minute, Peter?

Do you want to take a break for e 4 COMMISSIONER BRADFORD: I do have some others, but 5 I don't want to jump around.

6 CHAIRMAN HENDRIE: Well, if you are ready to go ahea, 7 wp.y, go ahead.

8 COMMISSIONER BRADFORD: Okay.

9 With.regard to a couple of the Union of Concerned 10 Scientists' spedific requests, that is, the notifying of the 11 licensing boards and the hold on construction permits, would 12 it be a fair summary of your response.to that is not that what

• 13 14 15 they are after isn't necessary but that it* is already in effect, that the licensing boards are applying these considera-tions?

16 DR. MATTSON: They did not specifically ask us to 17 notify the boards, although that action has been taken. What 18 they asked us to do was to tell the boards to cease considera-19 tion of CPs and OLs until these general design criteria 3 and 4 20 and some failure criteria were met.

21 Our response is that they are being met in the'

-A<#, Roporta,s, 22 23 7,;

licensing process and there is no need to notify the boards to cease consideration of these matters.

Now, we have taken steps to notify boards that have 25 plants where electrical connectors exist or penetrations for

pv6 28 that matter of the ..-.existence of the UCS position and the status 2 of staff thought on the qualification of connectors for that 3 particular facility.

4 COMMISSIONER BRADFORD: Does that include connectors 5 and fire protection as well?

6 DR. MATTSON: Not on fire protection. As we:,:-reporte 7 earlier to you, the Sandia tests do not add new safety informa-8 tion beyond what we already presumed to be true in the fire 9 protection review for all plants in the licensing process, and 10 therefore it is not material, new information, and it has not:

11 been brought to the attention of the boards.

• 12 CHAIRMAN HENDRIE: I'm sorry, I missed the front end

• 13 14 15 of that. There was a question I was going*to ask, and I see Joe Scinto wanted to make a comment.

Shoulq I ask y,ou to repeat, and then to get your 16 comment?

17 MR. SCINTO: Yes.

18 DR. MATTSON: We have not informed the hearing boards 19 on the results of the Sandia fire,:::tests on the basis that it 20 is not material, new information. It is information of a 21 confirmatory nature which confirms a presumption which underlies 22 the current staff criteria applied to all plants now in the 23 licensing process, insofar as fire protection is concerned.

24 COMMISSIONER KENNEDY: That has been true since when?

Ac I Reporters, Inc.

. 25 DR. MATTSON: Well~,it flowed from the Browns Ferry

pv7 29 tt 2 fire and these were issued over a year ago and have been applied to branch technical positions for some time*. I can't think of 3 the specific date, but it has been ongoing.

4 Joe?

5 MR. SCINTO: I just wanted to ', .add that that is bein 6 done. We did do that for the McGuire board. McGuire had a 7 proceeding before the board, and there was a question about 8 whether this Commission should inform that board. I don't think 9 we have informed any other boards thus far. The information we 10 ha~e. gotten with respect to connectors, for example, the plants 11 on page 56, none of those are b~fore hearings.

12 I have on my desk that I got sometime last week the

• 13 14 15 package of responses from all of the licensees in response to bulletin 7705. I'll be going through that to determine whether any of those are pending before any board, and if there are 16 any others pending before boards, we will send that information.

17 COMMISSIONER KENNEDY: This would include all people holding construction permits?

18 MR. SCINTO: Yes.

19 20 DR. MATTSON: There is one other set of information, and that is that the people under construction had an additional 21 30 days to respond to 7705, by January 8, and we will be dealing 22 with that. The people under CP review, we have said in the 23 report that i t is not likely that we would see connectors at Ac

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this level or this stage of review, at the construction permit, 25

pv8 30 where we were reviewing design criteria and methods and what 2 have you and not looking at the detailed design.

3 CHAIRMAN HENDRIE: Although, with the circumstances, 4 the question may arise specifically and it may come up now here 5 with a petition.

6 COMMISSIONER KENNEDY: I just wanted to clarify that, 7 in fact, any plant now under con~truction will~have been 8 and the licensing will have looked at this and they will commen.

9 MR. SCINTO: I'm sure they will.

10 CHAIRMAN HENDRIE: Let's see. Let me try to under-11 stand, then, the notification situation. Your feeling is that 12 with regard to the cable fire matters that the tests -- the 13 issues raised following from the tests and.the UCS posi~ion are 14 not new information which should be taken to the boards, that 15 information is implicit in the staff's review for fire protec-16 tion and has been since at least the Browns Ferry £ire, and the 17 adaption of the fire protection action plan.

18 MR. CASE: Yes.

19 CHAIRMAN HENDRIE: With regard to connector matters, 20 such notification is occurring, as is occurring, is related to information coming in from licensees and applicants as to the 21 qualification status and the staff's conclusions about an agree-22 ment with or lack of agreement with those conclusions.

23 a

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MR. CASE: Yes, sir. If they are connectors, and the matter is p~nding before a board, that board is notified 25

pv9 3@..

• - 2 of the position.

DR. MATTSON: But we would notify them before we com-3 pleted the review of qualification for those connectors. We 4 would notify them immediately upon learning of the existence 5 of those;2connectors. That::_is material and relevant information 6 for that heaiing, and our instructions are to notify.boards 7 befoIEe we have completed our:::-review.

8 CHAIRMAN HENDRIE: So that if there were 9 DR.::MATTSON: Which is, in fact, what we did with 10 McGuire.

11 CHAIRMAN HENDRIE: So, if there is*a proceeding 12 underway and you learned that connectors either are being used

• 13 14 15 if it is an OL or may be used if it is a CP, you notify the board and this does not depend upon whether or not you think there are environmental qualifications -- adequate qualifica~

16 tions, documentation +/-n _hand at the moment.

17 DR. MATTSON: We would indicate to the board the 18 pp.ocess we have had underway to reach that conclusion, :i_ff,. in 19 fact, we did not have it at the same tim~ we had the information 20 CHAIRMAN HENDRIE: But you would notify either way?

21 DR. MATTSON: That's right.

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CHAIRMAN HENDRIE :

situation was.

DR. MATTSON: Yes.

So the board would:~.know what the 25 MR. SCINTO: Mr. Chairman, I want to indicate that

32 pvl0 we notify those boards for which there is some issue somewhere 2 near the subject. For example, there are two boards still, in a 3 sense, *,sitting on cases on this page 56. In Peach Bottom there 4 is still a question.before the appeal board relating to a 5 water quality certification matter. I don't think I~will send 6 a copy of that. It really isn't relevant to water certificatio.

7 I will be talking to a lawy~r on the case to be sure that is 8 true. And Oyster Creek --

9 CHAIRMAN HENDRIE: I don't know, Joe. Let me say 10 I have a very sensitive feeling about cases in which proceedings 11 are open pending the receipt of water qualifi-ca tions data. And 12 the other one was --

13 MR. SCINTO: Oyster Creek. And*that had to do with 14 the matter of shipworms in Barnegat Bay, ahd we would look at 15 the case to see whether they would all be deemed in any sense 16 relevant to the subject matter of the proceeding. We still 17 have that obligation, although we are not supposed to evaluate 18 a significant item. We should send them *only relevant material.

19 I don't think it is relevant, but I will be discussing ,that 20 with the particular lawyer on the ease.*

CHAIRMAN HENDRIE: Okay. I am fighting desperately 21 to make -- to not make some remark about shipworms, and I think 22 I am succeeding.

23 Peter, you were -- this discussion interrupted a Acf

- 24 I Reporters, Inc.

line ot questions that you had underway.

25

pvll 33

• - 2 COMMISSIONER BRADFORD:

dignifies it somewhat.

Well, calling it a "line" 3

$taying with the question of notification, on the 4

UCS request, arri I, in looking at that, at least that No. "D~"

5 it seems to me to say -- unless there's another way to read it 6 that in effect the license and appeals board should be asked 7 to doublecheck in:areas that they pught to be checking thoroughl 8 anyway.

9 MR. CASE: Could you give me a clue to the page, sir?

10 COMMISSIONER BRADFORD: Well, page 2.

11 CHAIRMAN HENDRIE: And your summary discussion is 12 on page 10 .

• 13 14 15 COMMISSIONER BRADFORD: In other words, what they are asking those applicants to demonstrate to the boards -- the compliance with the regulations, including specifically --;-1and 16 then it goes on -- why wouldn't that be routine?

17 DR. :*MATTSON: It is routine for an applicant to have 18 to show that, and what we have said is that, given that that 19 is done routinely before the boards, the only thing new is 20 the possible consideration to call to the attention before the 21 boards and has gone somewhat peyond the request of the peti-Ac -

22 23 a I Reporters, 24 Inc.

tioner, is the materiality and the relevance of the Sandia test results. But, given our conclusion that the general design criteria and the single-failure criteria are being met and that 25 that is a matter before the boards and discussed and documented

34 pvl2

• - 2 3

before the board, that there'.~;s nothing flowing from the Sandia tests that would change that, except~in thbse cases where there are connectors identified in plants pend'ing bef6re boards.

4 MR. CASE: I guess we *could say, "Yes, do that,"

5 because that is the present instructions. Is that what you're 6 driving at?

7 COMMISSIONER BRADFORD: I was trying to understand 8 whether there was more than appeared on its face.

9 MR. CASE: Well, frankly, yes. I interpret it to 10 mean there is a problem, therefore tell them to halt until 11 something is done. It is the implication, rather than the words.

12 COMMISSIONER BRADFORD: But there's something being

• 13 14 15 done is the meaning of criteria.

MR. CASE: Yes, but the.:.implication that what is being done now in showing satisfaction that these criteria is 16 inadequate, therefore halt that process until some other more 17 adequate proof is given.

18 MR. NELSON: It is the phrase *"demonstrate compli-19 ance." You say, "Yes, they have." UCS says, "No, they haven't. '

20 MR. CASE: Yes. We are showing that now~

MR ...*NELSON: So, you say you've complied with them.

21 DR. MATTSON:. We are saying a little bit more than 22 than. We have.said.that what the staff has done complies with 23 the request, indeed, that is before the Commission and we have

• 24 A c . I Reporters, Inc.

described to yo-µ_ why-we think "D" need not be done, because it 25

pvl3 35

• - 2 3

doesn't accomplish anything beyond what has *already been done .

done?

COMMISSIONER GILINSKY: What is it that need not be 4 DR. MATTSON: To halt-licensing activities pending 5 before boards until a, 4, and the single-failure criteria are 6 met, and the reason for recommending that it need not be done 7 is that 3, 4, and the single-failure criteria are, in fact, met.

8 COMMISSIONER GILINSKY: But aren't you saying that 9 no construction permits or~operating licenses are to be issued 10 unless ..:compliance with these regulations is demonstrated?

11 MR. CASE: Yes.

12 COMMISSIONER GILINSKY: So, what you're saying is

• 13 14 15 you don't think additional notification or additional drawing new attention to this item is necessary?

DR. MATTSON: That's right.

end#3 16 COMMISSIONER GILINSKY: But it might be useful.

17 18 19 20 21 22 23

36 DR. MATTSON: Drawing attention to whether 2 that is useful or not, it"s a separate question from whether 3 or not the Commission,would take an action to cease 4 activities. The petitioner doesn"t askJyou to simply 5 in form the boards. He doesn't, in fact, speak to the 6 question*of just informing the boards in these six requested 7 actions.

8 MR. CASE: But I think reading that request 9 should be done in the context of the other ones. It 10 doesn't all say keep on doing what you are doing.

II COMMISSIONER GI LINSKY: But aren't you saying 12 that we are, in fact, doing that. So it comes down to --

• 13 14 15 MR~ CASE: If you pull it out of context and look at it, yes, you could say that we are doing that, because we believe these criterion regulations are being 16 met now and it is demonstrated to the satisfaction of the 17 boards_ before th.ey issue CPs.

18 COMMISSIONER GILINSKY: Well, in saying that 19 you are recommending -- in Iowa, the request~ you simply 20 are saying that you don't think any additiQ"lal notification 21 is necessary.

22 MR. CASE: Yes.

23 COMMISSIONER BRADFORD: There is a funny *s_emi3.pt-ic 24 at work here. That is, at the time D was filed with us,

, 25 you were not routinely notifying licensing boards of, for

37 I

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• 2 I

& example, connectors, and having problems with them.

- 2 3

4 Since then, we are, in fact, notifying licensing boards.

Whether you say that as a result of that, we are denying D, or have, in fact, already granted the use of Ds.

5 DR. MATTSON: Well, you will recall that our 6 initial response was we did not know of the existence of 7 connectors, where we have found a plant in the licensing 8 pr oc es s wi th c onne ct ors

• 9 MR. MC GUIRE: We notified the board forthwith.

JO We know of no others at th.is point, so we have not ll not i fie d other boa rd s.

12 COMMISSIONER BRADFORD: Now as to fire protection

• 13 14 15 in thatc_on;tex-Jt.:,., I think you *... nci!d*;.*

timetable as to existing plants.

the licensing pro.c ess?

0 *** 'i out before me the What about plants in 16 Are they supposed now to be meeting a condition 17 consistent with the branch technical positions?

18 MR. STELLCJz In the case of plant?

19 DR. MATTSON: Yes, sir~

20 MR. NELSON:

• Now you' re not suppressing any

. 21 di ss en t th ere

• 22 MR. CASE: I don't th.ink so.

23 CHAIRMAN HENDRIE: We will have to wait and see.

-, 24 25 If it is professionally done, we are prepared to accept it.

DR. MATTSON: Yes, they are required to meet

38 the review criteria, 9.5-1, and the regulatory guide 2 l. 120.

3 Plants at the operating stage are required now 4 to come into conformance with those guid_elines also.

5 Is that responsive to your question or was 6 there something more to it?

7 COMMISSIONER BRADFORD: I guess what I'm after 8 is to be sure that we are not licensing plants today on 9 the basis that we would then be invalidating it at the 10 end of 1978.

11 MR. CASE: Why donJt you try it this time, 12 Dick. It is a moving target as well as for the operating

• 13 14 15 plants. Let me see if I can say it and then you can disagree with me.

As of January of next year, '78, no operating 16 licenses will be issued unless the staff has completed 17 its review in accordance with branch technical position 18 9. whatever. Having completed its review does not necessarily 19 mean that the plant implementation of those requirements 20 agreed upon will be done. There will be this implementation 21 period.

22 So starting in January, every plant will be 23 reviewed completely against the new criteria for an operating

- 24 25 license and they will have a time.

Now the ones, before that time have been turned ii I

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39 over to Vic in the operating reactor__s, and he fits them 2 in with his program for implementing the branch 3 technical position on operating procedures.

4 MR. STELLO: I agree with everything Mr. Case 5 said, except I would like to make January, February.

6 COMMISSIONER BRADFORD: Let me ask it s_lightly 7 differently.

8 If Browns Ferry came in for an operating license 9 today, would they get it?

10 MR. STELLCH On the one they have now?

11 COMM! SSIONER BRADFORDz No.

12 MR. STELLO: No. We would require more of them

• 13 14 15 than we did originally about what they have now.

MR. CASE: But no more than what they have now, except for the implementation, which is-not done yet.

16 COMMISSIONER BRADFORD: And what is it that 17 specifically has changed since then? A regulation? A 18 reg guids? A branch technical position?

19 MR. STELLO: It began with the branch technical 20 position.

21 COMM! SSIONER BRADFORD: The general design criteria 22 and the regulations are the same?

23 MR. CASE: Yes. And the basis for the change 24 in the branch technical position or the reg guid.e. Our

, 25 idea of what will satisfy, or-more than satisfy, the general

40

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• 5 design criteria is the increasing knowledge that has

- 2 3

4 developed and, in particular, with the Browns Ferry fire.

COMMISSIONER BRADFORD: On page 37, you refer to an interim fire protection technical specification that 5 has already been proposed.

6 I take it being proposed is not the same as 7 being implemented.

8 MR. CASE= That is .correct. The way it goes is 9 we write a 1 et ter to the 1 ic en sees, and we have on a 11 of 10 these operating plants, and say we propose to amend your 11 technical speLifications in the following manner. Dot, dot.

12 And then it lists, unless we hear from you within 20 days,

• 13 14 15 this will be done. So we are in that phase.

COMMISSIONER BRADFORD: Why would it take whatever it is, 2 plus years since Browns Ferry, to go through that 16 part of the exercise?

17 MR. STELLO= The Browns Ferry fire started a 18 process where we reviewed what we were doing and that took 19 us a substantial period of time, nearly a year, for the 20 study group and for the staff to eventually come up with

. 21 what changes would be required, and they evolved in that 22 period of ti me.

23 And then we had to develop the specific guidance,

-, 24 25 which we did, and send it to the licensees. They, in turn, had to have sufficient time to look at their plants and get

41 the plants-to conform to these new requirements. And 2 then they sent them in to us and we had to have some time 3 to review them and agree with what they have done, and 4 with the number of plants you.have and the administrative 5 process and the limited resources.

6 MR. CASE: Let me say it another way.

7 We have completed now, we have gone through 8 enough of that and gone through at least, I believe, two 9 plants where we have finally decided what we want in 10 light of this new branch technical position, including, 11 most specifically, the administrative requirements in terms 12 of fire brigades and things like that, for me to conclude

• 13 14 15 that for all of the other reviews yet to be completed, we'll come out essentially in the same way as the administrative

.requirements. Given that, now let's impose those 16 administrative requirements on the rest of the operating 17 pl an ts~

18 We have now enough of the review process to 19 understand how it is going to come out essentially on al 1 20 plants on the administrative side.

21 So let's apply that now as it can be done 22 without waiting for new equipment .and lengthy exchanges or 23 evaluation by the staff.

24 COMMISSIONER BRADFORD: But the reason you would 25 not put out -- I guess the part that is puzzling me is you

42

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1 actually go through a process of getting plants up to 2 speed. before you .put out the technical specifications.

3 That doesn-'t go out. The interim technical specifications 4 did not go out until we knew everybody, or almost everybody, 5 to meet it.

6 MR. STEUC>= We have confidence that everyone 7 can generally meet these interim technical specifications.

8 Then when we are finished and all of this equipment is in, 9 then we will have to develop a final set of technical 10 specifications that relate to all of the equipment that 11 is there and that will take place after the review is 12 finished *

• 13 14 15 fash.ion.

These, you realize, are being done in an interim The reviews are .not complete on all of the plants.

we are taking some of the more significant items and 16 formalizing them through the technical specification process.

17 And they will be enforceable because there will be license 18 conditions.

19 And then when our review is complete, we will 20 need to go through and then come up with, we will-go from 21 these interim technical specifications to a set of final 22 technical specifications at the time we write off, literally, 23 on the design of the fire protection program.

24 COMMISSIONER BRADFORD: Okay. It may not make a 25 big difference, but when the interim technical specif i ca ti on I

43 takes effect at the end of that 20 days, it is 2 effective immediately. There's no further time period 3 involved.

4 MR. CASE= Unless the 1 icen see chooses to 5 disagree.

6 MR. STELLO= Even if he agrees, we have to 7 allow the time to go through the review process and revise 8 his procedures which are required by us to implement them.

9 There will be some time needed to n0t1, once 10 we have agreed on what they are, to actually write them 11 in to the procedures in this plant.

12 So immediately effective is the wrong

• 13 14 15 characterization. It is a very formal process that he has to follow, which is required by a license condition in implementing them.

16 So there will be some time after.

17 COMMISSIONER BRADFORD: Why is that a better 18 way than after the end of the first year when we have done 19 the review of what we are doing and had some idea of where 20 we had to go than putting out a document, I guess, which 21 would not look very different with specific time dBadlines 22 in it, instead of waiting that second year and then putting 23 something out that is subject to further negotiations?

24 MR. STELLO: I don't think we could have done it 25 a year ago.

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COMM! SSIONER BRADFORD: Because we need.ed to I

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4 know more?

MR. STELLO: Yes, because there is enough differences in individual plants where they needed to be 5 individualized. You're dealing with a spectrum of plants, 6 some of which are nearly 20 year.s old, and at the time, 7 the arrangement of that plant was different. And if you 8 look at each individual plant, there is enough differences 9 to Where you need to at least have some understanding of 10 how you can generalize them to the plants.

11 I think a year ago I just don't think we could 12 have done it. That is my judgment.

• 13 14 15 CHAIRMAN HENDRIE: Could you make sane comment about .such things as housekeeping measures and so on with regard to flammables in the operating plants?

16 My impression is, and I would appreciate 17 clarification, that the situation is not quite that nothing 18 has been done in any of the operating plants, that years 19 have gone by and years will go by~* but rather, that there 20 has, indeed, been a rather substantial concern from the

. 21 operators of the plants that are ii) operation about this 22 poss i bi 1 it y.

23 I would think that there would have been a

-, 24 25

. review of the procedures so that operators could try to assure themselves that they did not have sane sort of

45

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• l 0

& maintenance procedure that they were using routinely,

- 2 3

4 like TVA's candle proc.edure, which was an obvious fire hazard. And I would suspect that good operating staff, in fact, would have doubled up its attention to house-5 keeping matters and the cleaning out of inflammable 6 materials from areas where there is a sensitive need 7 to a fire, and particularly with regard to disabling 8 redundancy of these systems. And I would appreciate some 9 comment.

10 Am I too cheerful in th.is view, or what?

l1 DR. MATTSON: No, sir, you are not. too cheerful.

12 You can re fer back to page 37, where Commissioner Bradford

• 13 14 15 was reading about the interim technical specifications on fire protection. There is a list of es,sentially the items that you have just enumerated. Administrative 16 controls on the handling and storage of combustible 17 ignition sources, areas that contain safety-related systems 18 modification have been and con.tinue to be made, retardant 19 fire detection, fire-fighting capability, operating procedures, 20 to develop the licensees to assure safe shut down in the 21 case of a fire, and the additional modifications being made 22 to operating plants to decrease the severity of a fire 23 and the increase the plant's ability to cope.

- 24 25 We refer elsewhere in the report to the inspections and subsequent inspections by the Office of

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• 11 Inspection Enforcement following the Browns Ferry fire

- 2 3

4 and the study group report to speak to the control of comb us ti bl es.

COMMI SSIODR BRADFORD: If I understood the 5 legal framework correctly, it wasn't until the technical 6 specifications came that you actually had an enforceable 7 document; that is, the better operators have done this, 8 and you've encouraged all of them to do it. And one 9 would hope they all have~ But if you actually wanted to 10 crack down, the first time that you have the legal 11 basis to do it, given the general design criteria and 12 the regulations are the same, that these would be in the

• 13 14 15 technical specifications.

DR. MATTSON: I think that is true, except thE ability of an inspector to cite the licensee for 16 failure to comply with gen era l design er it er ia 3 that is, 17 if, in the inspector's view, the licensee is not in 18 conformance with adequate fire protection equipment. On 19 the other hand, you can't lay down detailed technical 20 specifications on the operation of a plant, lacking knowledge

. 21 of what should be in those specifications.

22 And that is what Mr. Stello has said, that he 23 could not issue these interim technical specifications a

-, 24 25 year ago. He had to know what to put in them, which required study of th.e plants.

47 I

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• 12 MR. SHAPAR: And also, he had to have a legal

- 2 3

4 basis for shutting down to show that they had a safety problem.

COMMISSIONER KENNEDY: Karl, did you want to 5 add somet~ing to that?

6 MR. SEYFRIT: I thought I might talk a little bit 7 about things that we in INE have done. And immediately after 8 the Browns Ferry fire and long before the special study 9 group's report was finished, we had done .a couple of things.

10 We issued some .bulletins to licensees to look at specific 11 facets of their fire protection program, which included 12 the procedures, not to use handles to make sure that any

• 13 14 15 welding operations and that sort of* thing were properly supervised and monitored.

We also within our own 9rganization set up 16 additional inspections in the area of fire protection. And 17 it might be worth noting that prior to the Browns Ferry 18 fire we, tightly or wrongly, in INE relied heavily upon 19 the inspections that were being performed at that time 20 by the various insurance companies, and we, as such, were

. 21 not really making much effort to do specific fire protection 22 inspections

• 23 .Following the Browns Ferry fire we recognized

-, 24 25 that was not sufficient. So we now have incorporated into our inspection program specific fire inspections which we

48

.h sss * . 13 do once per year. And in addition to that, I think it

- 2 3

4 is once a quarter, or perhaps even more frequently.

On our routine in spec ti ons, we do walk-throughs of the plant where we 1001< specifically for things that 5 ~ight be related to fire hazards, piles of rags, the kinds 6 of things that the insurance companies used to do.

7 So we have taken some fairly significant steps, 8 I think, in our programs to assure that the plants' fire 9 protection capabilities have been improved.

10 The bulletins that we put out requested that they 11 do a number of things. Among them was to do some checking 12 on. those areas where they used fire protective coatings to

• 13 14 15 make sure that those coatings, or the integrity of those coatings, was being maintained.

That was one of the things at Browns Ferry, where 16 apparently that integrity had been there once in some cases, 17 but had been damaged by subsequent work.

18 So those are the kinds of things that we have.

19 DR. MATTSON: There is a list of those things 20 in specific at page 16.

21 CHAIRMAN HENDRIE: One other-note of a semi-22 te chni ca 1 nature.

23 I recall that classically, in my limited fire

-, 24 25 protection education, going back more years than we ought to discuss, one did noLput water on electric.al fires. It

49

.h 88 *

• 14 was the conventional wisdom of the day.

- 4 2

3 I suspect that conventional wisdom had a lot to do with the reluctance of the operators at Browns Ferry, to put the hoses into the cable spreading rooms.

5 As I remember it, and . tell me if I remember 6 correctly, when they finally decided to get some water in 7 there, or at least some fog nozzle-delivered water, why, 8 it helped things considerably, and my impression has been 9 that i f they had done it a number of hours earlier, there JO would have been a considerable improvement in the situation.

11 And I wonder if that is a correct impressicn. And our 12 people have gotten over the old drivel that you should not

• 13 14 15 put water on electrical equipment.

MR. STELLO: I think a direct answer is it is generally now accepted that you need to use water on 16 electrical equipment.

17 CHAIRMAN HENDRIE: Or at least it is not the 18 worst possible thing that you can do.

19 MR. STELLO: Right. I think the problem they had 20 is the hea.t that was retained within the fire was intense

. 21 enough that after they would put it out with chemical means, 22 it would start up again, and until they, in fact, cooled it down with the water, which is what the water did do, and 23 24 th en they had it under control.

25 It is my opinion, and there is some speculation

50 in Browns Ferry, if they had done it earlier, would it 2 have made a real big difference? I think that is 3 subject to a lot of debate. I think there are enough 4 people that would argue either sidE of that one.

5 6

7 8

9 10 11 12

• 13 14 15 16 17 18 19 20

. 21 22 23

- 24

, 25

51 COMMISSIONER BRADFORD: This is the reason that you 2 just put Regulatory Guide 1.120 out for another year? But 3 there is some difference between the staff and the ACRS on 4 among other things, at least the water on electrical fires?

5 MR. CASE: I don't think that is the primary basis 6 for the staff-ACRS disagreement. I think the ACRS' view, at 7 least in some of these fires, are that one ought to require the 8 so-called dedicated system, and not to go through all of the 9 other measures that are required by Reg Guide *.1. 2, and we 10 don't agree with that, at this point in time, at least.

11 COMMISSIONER BRADFORD: But one of.the bases for 12 that is, you do feel that water is an acceptable use?

• 13 14 15 MR. CASE:

dedicated system.

And we do provide as an alternative the Some of these ACRS views would make it a requirement rather than an alternative.

COMMISSIONER BRADFORD: But is their view in any 16 way bottomed on the undesirability of putting watter on?

17 MR. CASE: I don't think so.

18

• MR. *FERGUSON: Your surnrna:i;:y:L is:. correct.

19 COMMISSIONER BRADFORD: I'm about done with fires.

20 CHAlIRMAN HENDRIE: Well,-while we are on the 21 cables, we could see if anybody else has questions?

22 COMMISSIONER KENNEDY: I have one question, and 23 that goes to the first request of the petition that is, to

• 24 A c . a l Reporters, Inc. permit and direct the staff to accelerate the programs for the

• 25

52 physical separation. And the staff sees no immediate need to 2 go to the physical separation. And I understand the reasoningi 3 which was very clearly outlined, and has been stated here, that 4 there is no need to do this.

5 The question is: would it be in any sense 6 desirable to do it, aside from me. I re~lize that you don't 7

have to do it. The question is, would there be any benefit of any consequence derived if you did accelerate the testing?

8 MR. CASE: Just the separation part of the testing?

9 10 COMMISSIONER KENNEDY: That is what the proposal says.

11 MR. CASE: The request is limited tothe separation.

12

• 13 14 15 MR. FERGUSON: With:cregard to some of the fire pr0tecti6ri programs we have going, we would like to see the confirmatory tests run as soon as we can have them; i t would be helpful to us.

16 MR. CASE: But what about just the separation part?

17 MR. FERGUSON: No.

18 COMMISSIONER KENNEDY: Why would there not be any 19 benefit?

20 MR. FERGUSON: From separation?

21 MR. CASE: From accelerate separation?

22 23 operating plants, and we are not relying on separation in the 24 Ace

, al Reporters, Inc. operating plants, we are relying on the other protective 25 measures which are going in, and we would like confirmatory

53 tests of those measures. We believe they are satisfactory, 2 but the sooner we can get the confirmatory tests run, the more 3 solid our position will be.

4 COMMISSIONER KENNEDY: What you are saying then is 5 you would rather devote the resources that would be required 6 for the confirmatory test on the new procedures, rather than 7 on a separation which you are not relying on anyway?

8 MR.-FERGTJSON: .. Yes, sir.

9 COMMISSIONER KENNEDY: Thank you.

10 COMMISSIONER GILINSKY: But it did sound like you ll would like to have the program speeded up.

12 DR. MATTSON: We might ask the Office of Research

• 13 14 15 whether they can speak to that about the desirability methods of the contract. Ron, can you speak to that?

MR. FEIT: Well, taking up a program, in a test-type program, takes a certain amount of time. You have to have 16 the right people, and you have to get the facilities built.

17

.And we are operating now at Sandia Laboratories with what 18 we consider full cycle or full-scale. It will probably be a 19 matter of getting an additional test facility. And in any 20 event, we probably could not get that program going inearnest 21 for about six months.

22 DR. MATTSON: And that is a time frame consistent 23 with quite a lot of progress at Sandia in the next six months, 24 Ac , al Reporters, Inc.

I and as I described, tpey're in the second phase of the program 25

54 and moving in to the -:fourth phase of the program by February, 2 and moving right along.

3 ~~- FEIT: The present facilities right now are being 4 run full time. We also have an additional contract which 5 probably has not been discussed in conjunction with this 6 hearing, .at Underwriters Laboratory, and we have revamped 7 rescheduled some of that work to take into account so many 8 additional separation questions that have been asked, particular y 9 with regard to heretically oriented cable trays, so we have 10 tak~n some steps in answer to the allegation in the petition.

11 Both laboratories now, insofar as the contracts go, we are working full time on these issues.

12

• 13 14 15 COMMISSIONER GILINSKY: The staff response here says that the staff does not believe that the fire protection and research program should be accelerated. Now, is that because it is going as fast as it can? Is that the way I should 16 understand it?

17 DR. MATTSON: The staff is saying here that there 18 is no need to accelerate it. As Mr. Kennedy went tothe 19 desirability, and I took desirability to. the question of 20 possibility. I think we have addressed all three points, and 21 they come down to the kind of summary recommendation in the 22 staff report which ~ays, "Don't accelerate them."

23 MR. CASE: The first sentence goes to need rather

• 24 A c . a l Reporters, Inc. than desirability as written here, although it is not completely 25

55 clear.

2 COMMISSIONER KENNEDY: But it does as well later.

3 I t .says,* "The .staff sees no immediate need to devote resources 4 to physical separation beyond those presently in the test 5 program." I just wanted to be sure that as contrasted with 6 need,that it might not be desirable, if you suggested that 7 you would not get that much from it.

8 COMMISSIONER BRADFORD: I was having a little 9 trouble with the distinction of need and desirability. And 10 that relates to the word "desirability", and that is, does 11 aybody want it? Normally, I would think desirability and need are pretty close together.

12

• 13 14 15 the two.

MR. CASE: I draw a very strong distinction between There i~ hardly anything that I can program -- any research program that I can think of that the staff would not desire more money be spent on or be done faster. I think 16 this is close to -- that you ever get to a question.that::

17 s1ch as Commissioner Kennedy posed.

18 COMMISSIONER BRADFORD: Well, you are, I think, 19 agreeing though more or less with what I said, that desirability 20 as you were using does relate to whether or not someone on the 21 staff would desire to do it?

22 MR. CASE: Yes.

23 COMMISSIONER BRADFORD: But you just said in the 24 Ace, al Reporters, Inc. abstract i t .is somet_hing that is desirable.

25

56 Well, that's not very different from saying it is 2 necessary.

3 COMMISIONER KENNEDY: It's a difference between, it 4 would be nice to have --

5 DR. MATTSON: Versus I've got to have it.

6 COMMISSIONER KENNEDY: . That Is right.

7 COMMISSIONER BRADFORD: On the connector question, s the second of the UCS requests directed the staff t6 accelerate 9 the testing program for environmental qualification connectors.

10 I understand your description of the. program.

11 actually in effect, we don't know have a program inthe 12 environmental qualification standards. What we were doing was

• 13 14 15 testing the test, and the connectors happen*to be what we w~re testing at the test.

MR. CASE: Yes.

16 COMMISIONER BRADFORD: Would it be useful, inlight 17 of the experience we've had, to actually qualify -- do we have let me *-put it another way, do we have a task program that 18 ever sort of double checks the qualifications of items that 19 the industry has qualified?

20 DR. MATTSON: As a matter of testing, no. As a 21 matter of analysis, independent assessment, independent 22 evaluation, most certainly.

23 COMMISSIONER BRADFORD: You explained that one to 24 Ac , al Reporters, Inc.

me Monday, but we don!t have a test program that backs it up 25

57 I

7 on any kind of spot-audit basis?

.kw

• 2 3

DR. MATTSON: No .

COMJl/lISSIONER GILINSKY: Do you have any plans for

- 4 5

such a program?

MR. CASE: Not to my knowledge.

6 MR. SEYFRIT: I'm sorry; I did not hear the 7 question.

8 DR~! '111ATTSON: An independent audit by tests.

9 MR. SEYFRIT: No we don't do an independent audit 10 by ~est. However, we do do a great deal of observation, and 11 tests that are being done in the various laboratories. For 12 example, we've had our people at Franklin Institute who have

• 13 14 15 done a great deal of environmental testing,-electrical equip-ment, including connectors. And we have observed the tests that they have run; some of the private industries run their own tests. And again, we have our inspectors in and observe the 16 tests in progress.

17 While we don't run them ourselves, we go a lot 18 further than looking at the paper that says the test has been 19 run satisfactorily.

20 CHAIRMAN HENDRIE: Just as a matter of curiosity, 21 is some of that inspection under the vendor inspection program?

22 MR. SEYFRIT: Presently it is. However, even before 23 the vendor inspection program was initiated, we did some of

' 24 Ac , al Reporters, Inc.

this. We would do a great deal more of it if the vendor 25

58 inspection program is fully funded.

2 COMMISSIONER GILINSKY: Can I interject a question 3 here?

4 COMMISSIONER BRADFORD:- Please do.

5 COMMISSIONER GILINSKY: Sandia seems to have 6

used connectors which were not otherwise qualified in their 7

tests. What conclusions do we draw from the Sandia tests on these connectors?

8 DR. MATTSON: That they were evidently unqualified 9

unconnectors, and they would not meet IEEE 323 insofar as 10 their purchase specifications, insofar as the~r advertised ll performance requirements, or performance capability, or insofar 12

• 13 14 15 as the tests at Sandia. They failed the tests; the tests-were designed to see if there was a synergism of environmental effects. In that sense, the test failed, since the connectors weren't qualified. It is hard to say whether they failed by 16 synergism, or some other reason.

17 COMMISSIONER GILINSKY: Do the _tests in any way 18 sort of make you wonder about the qualification of connectors 19 in general?

20 DR. MATTSON: We have looked at the test. Even 21 recent tests of connectors, where connectors claim to be 22 qualified. And we found they were qualified, the ones in the 23 that were put in the autoclave and tested at Sandia were not 24 Ace al Reporters, Inc. qualified, and were found not to be qualified.

25

59 COMMISSIONER GILINSKY: They have not tested any 2 connectors.that were qualified?

3 DR. MATTSON: No, sir.

4 COMMISSIONER KENNEDY:

• Will they?

5 DR. MATTSON: I don't believe there are any plans 6

to.

7 MR. FEIT: As I said last time I was here, one of the connectors that was tested had some previous qualification 8

testing. The t~sts were done to a previous IEEE 323 standard 9

test, which called for a single LOCA peak and somewhat 10 reduced LOCA temperature. In addition, there .was no pre-aging 11 condition applied on the connectors before the test. The 12

• 13 14 15 Sandia test profile used a '74 version of IEEE 323 which to the best of my knowledge has not yet been tested, or at least tested and reviewed by the staff, because plants have not come down through the mill with this standard.

16 So the current version used an aging cycle. The 17 Sandia version used an aging cycle which has not been used 18 previously, and used a double LOCA peak which h~d been put in 19 for conservatism, which was not in the original '71 version.

20 So we're talking about different test profiles, and 21 different test sequences. Now, there are differences, and I 22 think the Sandia test perhaps showed a tendency toward certain 23 generic problems, with different connector designs, which 24 Ac , al Reporters, Inc. I think has been adeq~ately addressed with the bulletins, and 25

10 I think these problems have been looked at, and will continue 2 to be looked at.

3 .The main objective of the Sandia test, however, 4 was not to uncover generic problems. It was simply to study 5 the synergistic effect compared between the sequential test 6 mode and the simultaneous mode which actually would be present 7 during a LOCA accident.

8 COMMISSIONER GILINSKY: Did they independently test 9 them in a sequential manner?

10 MR. FEIT: Yes, two sequential test, a sequential 11 and simultaneous.

12 COMMISSIONER GILINSKY: And the ones that failed on

• 13 14 15 the simultaneous test, did they pass the sequential test?

MR. FEIT:

to connectors.

No, there was no difference with regard COMMISSIONER GILINSKY: They failed all of them?

16 MR. FEIT: Yes, five of the twelve connectors did 17 pass a similar version from '71 in that they did live through 18 the first LOCA peak. They were the connectors that did in fact 19 have previous qualification testing by a.nother testing labor-20 atory, so it did check out.

21 I might add, there were other components tested in 22 this series that did test out well, the splices being one of 23 them. The splices that were tested at Sandia did very well 24 Ace al Reporters, Inc.

in the sequential an~ the simultaneous mode.

25

61 11 COMMISSIONER GILINSKY: Are these expensive tests?

2 Or as such things go,. relatively inexpensive?

3 MR. FEIT: They are expensive to run in a testing 4 laboratory, yes. They are somewhat cheaper at Sandia Laboratorie 5 because other things are going on. Some of the support efforts, 6 of course, are spread across other programs.

7 Are you after an exact number?

8 COMMISSIONER GILINSKY: Well, I guess I'm surprised 9 at the resistance to some sort of audit program here, just some 10 selective testing of various components to see whether in 11 fact they do meet the qualifications.

12 DR. MATTSON: I don't think you are getting

• 13 14 15 resistance. I think you are speaking in an.area where we don't do testing to confirm a lot of things: hydrostatic testing of pressure vessels, for example; testing of motors::

testing of pumps; testing of valves; testing -- in a radiography 16 sense; testing in the system's interaction sense. There is a 17 lot of testing that is done before a nuclear power plant goes 18 on line. The environmental qualificatiois 0£ a little piece 19 of electrical equipment like the connector is probably a 20 minuscule fraction of that total te5ting, probably an 21 unmeasurable fraction. You're looking at a very fine level 22 of detail, and a very small component. And so any resistance 23 you detect is the resistance of a regulatory program that has 24 Ac , al Reporters, Inc.

I been built and structµred without independent testing by the 25

62 12 government.

2 That is why we have vendor inspection programs, that 3 is why we have lots of inspection things, and licensing review 4 things, in lieu of independent testing here.

5 CHAIRMAN HENDRIE: I think it is fair to say, 6 however, that these connector -tests have reminded the staff 7 that several hundred degree steam is a fairly rigorous 8 condition for electrical equipment to sustain and continue to 9

be operable in.

10 DR. MATTSON: Staff is aware of that problem, yes, 11 sir.

12 CHAIRMAN HENDRIE: It {s certainly worth keeping

• 13 14 15 in mind.

Peter, were you --

COMMISSIONER BRADFORD: Running down? Yes.

_On page 4 of the summary of the safety aspects of the 16 petition, under electrical components, you say, on the basis 17 of the information and action to date that staff has concluded 18 that there is reasonable assurance that electrical connectors 19 and containment penetration would perform the required 20 functions in a LOCA environment.

21 Yesterday, in a very different environment, we 22 were talking about high assurance, medium assurance, and low 23 assurance safeguards._ Does "reasonable assurance "here -- is 24 Ace al Reporters, Inc. the term of art, does it go back to the law or the regulations?

• 25

63

• kw 13 MR. CASE: I think more regulations than the law .

2 MR. NELSON: Regulators as it is construed by the 1e 3 court.

4 COMMISSIONER BRADFORD: But the legal requirement is, 5 you have to have a reason~ble assurance that things will work 6 the way they are supposed to.

7 MR. NELSON: Meaning less than absolute; clearly so 8 held.

9 MR. NADER: Ask Nader vs. the AEC and Nader vs.

10 the Nuclear Regulatory Commission.

11 CHAIID/1..AN HENDRIE: If there is at l_east a temporary 12 pause in the questions that the commissioners have, this might

• 13 14 15 be an opportune time for me to note that at the last meeting on this subject we heard from Mr. Pollard of the Union of Concerned Scientists. The Commission subsequently agreed to consider possible requests for appearance from other parties, 16 in particular, we. have inquired with the the Office of the 17 General Counsel has attempted to inquire of parties opposed to 18 the petition whether they might want to appear and make some 19 sort of summary statement, and has added in making those 20 inquiries that the Commission has high interest in. a consoli-21 dation, if such efforts are desired, in order that the time 22 devoted to such response might be reasonably within the 23 Commission's capacity to hear this morning.

24 Ac , cl Reporters, Inc.

25

I understand from the General Counsel thatmost 2 of the parties so coritacted have indicated that they do not 3 wish to appear, but I believe the canvass has not been 4 100 percent.

5 I, therefore, inquire if there are parties opposed 6 to the petition present who would like to make a brief summary 7 statement, and if you could let me know, if there are any, 8 who you are, I will ask the Commission if they would like 9 to hear you.

10 (No response.)

11 CHAIRMAN HENDRIE: I declare that no parties have 12 thus identified themselves. And, good, that matter is closed .

• 13 14 15 Now, during that respite, some more questions, or items for discussion may have occurred to members of the Commission.

end. 5 16 17 18 19 20 I 21 Ace 22 23 24 ol Reporters, Inc.

25

CR 5888 HEER 65 pv#6

• - 2 3

COMMISSIONER BRADFORD: I have one other, on your appendix B, which basically relates to the systematic evalua-tion program on page 5 of that. You run through alternatives 4 to be considered in the event that environmental qualifications 5 did not exist or equipment considered during the SEP.

6 Let's just look at item ~C" there, for a minute. If 7 important safety, equipment is not environmentally qualified, 8 consideration will be given to alternate ways .. of performing the 9 safety function by using different systems, including the use 10 of.nonsafety-grade systems.

11 Now, this is not the time, bbviously, to pursue the 12 systematic evaluation program, but I wonder if we are not get-

• 13 14 15 ting -- if.that is the sort of standard th~t gets applied when equipment turns up unqualified, aren't you at that point getting pretty far from whatever reasonable assurance it was upon which 16 the plant was permitted to commence operation in the first place?

17 That is, you are now talking about --

18 MR. CASE: Well, it says "consider." So, this is 19 no more than we will look and see what other equipmeilttthey 20 may have which is not safety-related to see if it would perform 21 as reliably as the so-called qualified -- expected qualified 22 safety equipment would. So, you would have to look for its 23 environmental qualifications of this nonsafety equipment, its 24 reliability, and all of the other characteristics that you Ace al Reporters, Inc.

25 would look for in the safety-related. It's just that we mi~ht

67

• • 2 3

or not to let it continue operating?

MR. STELLO: That is the issue .

COMMISSIONER BRADFORD: This is more or less kind of 4 the test?

5 MR. CASE: The thought process you go through.

6 COMMISSIONER BRADFORD: I think I'm done.

7 CHAIRMAN HENDRIE: Okay.

8 Other comments from the staff?

9 COMMISSIONER GILINSKY: I wonder if I could ask the 10 gentleman from the research office whether Sandia intended to ll use qualified connectors in this test.

12 MR. FEIT: Well, the intent of the program was to

• 13 14 15 get typical equ:Lpment that was used in the plant without any regard to going into a plant and lifting a specific piece of equipment. The reason that that line was drawn, .in our view, 16 is that NRC. is not in the:_business of qualifying existing plant 17 hardware or putting a stamp of approval on, it. That is our 18 judgment and the laboratory's judgment right now.

19 So, with this fine line, they did riot go through 20 NRC, pick out ,- a typical plant, pick>out a typical connector 21 that was in the plant. Rather, they went another route. They contacted a number of different suppliers.

22 23 COMMISSIONER GILINSKY: I understand that they ended Ace I 24 al Reporters, Inc.

25 up with connectors that weren't qualified.

MR. fEIT:- It ~as the intent, though, to get equipme t

66 pv2 I

• - 2 3

have a different label, but you would require the same quality of that other equipment.

MR. STELLO: I might mak~ a couple of points, and 4 the first is, the use of nonsafety-grade equipment does not 5 and should not h~ve:the connotation that it is bad stuff. It 6 is the equipment that is used for the normal operation:*6f :::.the 7 plant, such as, for example, the feedwater system. So, the 8 quality is certainly high. It just doesn':t get that special 9 label of "safety equipment" and have some special things that 10 are attached to it.

11 And a second, maybe more important, point is I don't 12 think it is app:r:opriate to read any.)on.e of these in isolation .

• 13 14 15 It is all of them together that will be considered in making the. judgment. And where a specific piece of equipment can perform a safety function, that will be considered.

16 These are the general concepts which you recall are 17 being used. for -_the overall systematic evaluation program and 18 for convenience they were repeated here a:s:'.the types of things 19 that would be considered in making these judgments, and no one 20 of these is all of it. It is all of them together.

21 COMMISSIONER BRADFORD: Are these i terns "A" thrm.J.g:h

- 22 "E" basically the framework within which you evaluate circum-23 stances in which you discover*:*there is something about a plant

.I I Ace 24 ral Reporters, Inc.

25 that is in operation that would not pass muster; if-you-are now about to grant it an*operating license, the question is whether

lpv4 68 I

• • 2 3

that would have been typical of what is in a plant without any regard to maki:ril.g sure that a particular_ connector would be --_

- 4 5

COMMISSIONER GILINSKY:

originally intended to be done?

MR. FEIT:

Well, why not do what was You're saying redo it?

6 COMMISSIONER GILINSKY: With qualified co.nnectors.

7 That's what we were going to do or they were<'~going to doi And 8 are they not, perhaps, even obligated to do that by the terms 9 of the contract? I don't know what they are.

10 MR. FEIT: The contract was'made with the suppliers.

11 And the response that they did get from the suppliers verbally 12 was that all three connectors should meet the LOCA tests. This

• 13 14 15 was the verbal communication. The purchase orders specifically called for class lE connectors did not spell out a sepcific LOCA environment.

16 COMMISSIONER GILINSKY: I understand, but we must 17 have'had some discussions with them about the tests they were 18 going to perform, and did they indicate that there were any 19 connectors which.were typical of those used in the plants?

20 MR. FEIT: That was the understanding we had.

21 COMMISSIONER GILINSKY: Well, they have not met the

-I Ace al Reporters, 22 23 24 Inc.

terms of that agreement.

out those tests?

MR. FEIT:

Are they not now obligated to carry In tpat regard, you can say they have 25 not met the terms of"the agreement. They have contacted the

pv5 69

• - 2 suppliers to see just why the connectors1 .did not nass case there have been different neg6tiations.

~ In each 3 CHAIRMAN HENDRIE: That isn't quite getting to the 4 point. The point is, it was out *intent and their intent to 5 run a certain series of tests. In fact, a somewhat different 6 series of tests have been run. They have been very interesting.

7 COMMISSIONER KENNEDY: But they don't answer .the 8 questions we asked.

9 CHAIRMAN HENDRIE: And there .remains -- what about 10 the test we had intended to run? Would~it be useful to go and 11 run those?

12 MR. FEIT: This issue was discussed with the labora-

• 13 14 15 tories. As a matter of fact, it was discussed again last week, and it is our feeling that the question of synergism -- is there a synergistic effect in considering the sequential and 16 simultaneous test mode -- has been answered to our satisfaction.

17 And when one looks across the board at different types of 18 materials and interface designs, there pr.obably is not a major 19 synergism.

20 Now, the particular facility they.were working with 21 has been retired .. They are modifying a new facility that shoul

- 22 be ready by the end of the fiscal' year. At that time it is our 23 intent to redo some of the synergistic effects tests.

CHAIRMAN HENDRIE: With connectors qualified with I Ac al Reporters, Inc.

' 24 the current versions-of 323?

25

pv6 70 MR. FEIT: With components and materials that we feel 2 is typical of what is in the plant.

3 CHAIRMAN HENDRIE: No, no. Let me go back -- with 4 connectors qualified to 323.

5 MR. FEIT: We have not committed to ourselves within 6 the staff and to the laboratory. The two specifically test 7 connectors, certainly, we could do that. We:': have not reached 8 that agreement at this point. Certainly we could do that. It 9 would be no problem.

10 CHAIRMAN HENDRIE: If I said I suspect it would not 11 displease the Commission substantially if you- did that, with-12 connectors qualified to the 323, would that be a sort of gentle

• 13 14 15 gUI:idance?

COMMISSIONER KENNEDY:

Chairman, if you did say that.

I think it would be nice, Mr.

16 MR. FEIT: The guidance is accepted and received, 17 and I will pass it on.*

18 MR. SEYFRIT: Mr. Chairman, I don't want to engage 19 in a discussion or argument, but I believe -- at least it was 20 my understanding -- and to try to be more responsive to the 21 specific question that was asked, that the original contract 22 and the arrangements for the tests did not specifically say any-23 thing about testing connectors in this test that was being, brought. That was not really a part of the purpose of the test, as I understand .. it. -Sandia made a decision to use connectors

71 as a part of this synergistic test, just because it was a simple 2 thing to do. But testing connectors, as such, was never really 3 an intended _part of the test?

4 Is that true, Ron?

5 CHAIRMAN HENDRIE: That is fair. And in fact, if I 6 thought about it, I would have understood that, Karl.

7 MR. FEIT: The original 189 that set up the contracts.

8 CHAIRMAN HENDRIE: Ron, thank you very much. I'm 9 afraid that any -further clarification will confuse me. But I 10 recognize the point you make, Karl. However, the fact that 11 connectors were selected as a handy size of typical componentry 12 to put in the chamber, the fact that events have flowed as they

• 13 14 15 have flowed raises considerable inte~est, ~t least over here, on this side of the table, in what would have 1 happened if there had been a set of connectors specifically which were alleged 16 to be fully qualified components. And it is in that sense that 17 I express an interest in how that would have come out.

18 Let's see. Let me ask my colleagues -- do you feel 19 a need for any immediate Commission action:w+/-th regard to the 20 matters raised in the petition? That is, there are six requests 21 made by the petition. The staff recommends denial of all six, 22 for reasons expressed in their report and discussed otherwise 23 throughout this series of meetings.

We have heard from the Union:.of Concerned Scientists at the last meeting; and from the staff today.

pv8 72

~* 2 together?

COMMISSIONER GILINSKY: Are you lumping all six Or are you simply talking about any immediate actio?

3 CHAIRMAN HENDRIE: Well, I'm thinking in terms of 4 whether any of us feel a need to.take some action, immediate 5 action now, in the context of today or the rest of this week.

6 COMMISSIONER KENNEDY: As contrasted with what the 7 staff is recommending?

8 CHAIRMAN HENDRIE: Yes, as contrasted with what the 9 staff has recommended, and as contrasted with having an appro-10 priate draft order prepared which would deal with each of these 11 ite~s ~raised in the~petition, which draft material we would 12 consider, and consider the points of view and the wordirigaas

• 13 14 15 we normally would, by circulating them. And then we might*::,or might not need a subsequent meeting of the full Commission.

COMMISSIONER BRADFORD:. That is not the same as 16 saying we are necessarily denying the petition.

17 CHAIRMAN HENDRIE: That is correct. Nor does it 18 commit to any particular language.

19 COMMISSIONER BRADFORD: And I take it does say what 20 we said already, and that is that there is a petition filed in 21 October asking that more reactors be shut down and that one would not be considered.

22 CHAIRMAN HENDRIE: Just so.

23 A<' ~~-

S9, I will ask the counsel's office to begin to al Ropart,~,

draft a suitabl~ order from the Commission dealing with the 25

pv9 73 petition, and we will see that draft language directly, and 2 each of us can make marks uponnit~ and alte~nate versions, and 3 we will see where we go from there.

4 Does that seem reasonable?

5 MR. NELSON: To deal with the whole petition? All 6 of the issues?

(

7 CHAIRMAN HENDRIE: I would think so.

8 MR. ~;NELSON: The so-called emergency allegations, 9 as opposed to long run?

10 CHAIRMAN HENDRIE: I think I would like that. I 11 think we may as well attempt to deal with that.

12 MR. NELSON: From our viewpoint it's easier to write

• 13 14 15 one than two, Mr. Chairman.

MR. SNYDER: We seem to have everything here in front of us in order to do that.

16 CHAIRMAN HENDRIE: Very good. Thank you*very much.

17 The Commission will have .a few minutes' recess.

~nd#6 18 (Whereupon, at 11:30 a.m., th~ meeting was adjourned.)

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• 20 21 22 23

. 24 Ace rel Reporters, Inc.

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