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| J 01G NAL UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS In the Matter of: )
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| 349th ACRS MEETING )
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| Pages: 1 through 339 Place: Bethesda, Maryland Date: May 4, 1989 -
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| 10rie _l80f :10 003T35B I b HERITAGE REPORTING CORPOR'ATION opetat Reportas 1220 L Street, N.W., Suite 600 y$51ggg4 e90504 Washington, D.C. 20005 T- 1737 PNU (202) 628-4888 b . . .-
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| . UNITED STATES NUCLEAR REGULATORY COMMISSION I-ADVISORY COMMITTEE ON REACTOR SAFEGUARDS In the Matter'of: .)
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| )
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| '349th ACRS MEETING- )
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| Thursday, May 4, 1989 Room P-110, Phillips Building 7920 Norfolk Avenue Bethesda, Maryland The meeting convened, pursuant to notice, at 8:30 a.m.
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| BEFORE: DR. FORREST J. REMICK Vice Chairman, ACRS. .
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| Associate Vice-President for Research Professor of Nuclear Engineering The Pennsylvania-State University University Park, Pennsylvania
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| .O ACRS MEMBERS PRESENT:
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| MR. CARLYLE MICHELSON Vice-Chairmar.
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| Retired Principal' Nuclear Engineer Tennessee Valley Authority Knoxville, Tennessee, and Retired Director,' Office for Analysis and Evaluation of Operational Data U.S. Nuclear Regulatory Commission Washington, D.C.
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| MR. JAMES CARROLL Retired' Manager, Nuclear Operations Support Pacific Gas & Electric Company San Francisco, California (Continued on next page.)
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| ACRS MEMBERS PRESENT: (Continued)
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| DR.' WILLIAM-KERR Professor of Nuclear Engineering University of Michigan Ann Arbor,. Michigan DR.. HAROLD W. LEWIS-Professor of Physics Department of Physics University of California Santa Barbara, California MR. CHARLES J. WYLIE ,
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| Retired Chief Engineer' H Electrical-Division Duke Power' Company, Charlotte, North Carolina MR. DAVID A. WARD Chairman Research Manager on Special Assignment E.I. Du Pont de Neumours & Company C" -
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| Savannah River Laboratory Aiken, South Carolina
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| .(). DR. CHESTER P. SIESS Professor Emeritus of Civil Engineering University of Illinois Urbana, Illinois DR. PAUL G. SHEWMON Professor, Metallurgical Engineering Department <
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| Ohio State University Columbus, Ohio DR. IVAN CATTON Professor of Engineering Department of Mechanical, Aerospace &
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| Nuclear Engineering School of Engineering and Applied Science University of California (Continued on the next page.)
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| 'ACRS COGNIZANT STAFF MEMBER E. IGNE DESIGNATED FEDERAI- OFFICIAL RAYMOND FRALEY 1
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| l - NRC STAFF JIM LINVILLE I DICK CLARK 1.:
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| PRESENTERS F. CONGEL P. ROBINSON M. WILLIAMS l S. ISRAEL TOM NOVAK C. HSU J. ROSENTHAL T. SENTULA C.A. MCNEILL W.T.' ULLRICH G.M. LEITCH D.R. HELWIG
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| A.J. MARIE H.D. HONAN C.A. MCNEILL, JR.
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| ]o 1 E R Q Q E E p_ 1 E Q E 2 DR. REMICK: Good morning. The meeting will come
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| ; 3. to order.
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| 4 This is the second day of the 34Sth Meeting of the 5 Advisory Committee on Reactor Safeguards.
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| 6 During today's meeting, the Committee will hear 7 about and discuss the following. Radiobiological Exposure 8- Criteria; Evaluation of Operation Experience; NUREG 1150; i
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| 9 Severe Accident Risk; and Assessment for Five U.S. Nuclear 10 Power Plants; Limerick Nuclear Power Station Unit 2; and 11 ACRS Subcommittee Activities.
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| 12 Topics for consideration on Friday and Saturday 13 are listed on the scheduled posted on the bulletin board
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| -() 14. outside the meeting room.
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| 15 The meeting is being conducted in accordance with 16 provisions of the Federal Advisory Committee Act and the 17 Government in the Sunshine Act.
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| 18 Raymond F. Fraley is the Designated Federal 19 Official for the initial portion of the meeting.
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| 20 A transcript of portions of the meeting is being 21 kept.
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| 22 It is requested that each speaker use one of the 23 microphones, identify himself or herself, and speak with 24 sufficient clarity and volume so that he or she can be 25 readily heard.
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| O Heritage Reporting Corporation (202) 628-4888 C_____--_____________._
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| . l' 'And the first item on the agenda today is the~
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| 2 discussion'of radiobiological exposure criteria having to do 1
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| 3 with' hot particles.
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| 4 And J. Carroll is our Subcommittee Chairman.
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| 5' Jay, I turn the meeting over to you.
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| 6 .MR. CARROLL: Okay. Our Subcommittee on l
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| 7 Occupational and Environmental Protection Systems met on 8~ April 20th. We had two consultants, Dr. Mel Carter and Dr.
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| 91 Neal Wald.
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| 10 We also invited Dave Moeller to be here in some 11 capacity.- I guess we called him an " invited expert."
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| 12 At that meeting we met with the staff, the 13 National Council on Radiation Protection and Measurements 14 and NUMARC.
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| -15 And the issue, of course, is a pending draft 16 . Generic Letter which gives the industry some relief from the 17 existing limits on exposure to the skin from hot particles.
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| 18 During the past few years, most nuclear plants 19 have installed high-sensitivity personnel contamination 20 monitoring equipment to improve their Radiation control 21 Programs.
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| 22 A side effect of this has been the occasional 23 discovery of microscopic hot particles on workers' skin and 24 clothing. These are typically fragments of stellited 25 components containing Cobalt 60 and irradiated fuel Heritage Reporting Corporation (202) 628-4888
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| 1 fragments from fuel defects. The latter often referred to 2 as fuel fleas. Common to these particles is the fact that l 3 they are highly charged and, in fact, do jump around like 4 fleas.
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| 5 It's clear that hot particles have always been 6 around nuclear plants but were not generally detected. l 7 We've been told that there's no evidence that these hot j 8 particles have historically caused any adverse worker health 9 effects.
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| 10 The staff has concluded that the existing 10CFR20 11 limits which are intended for exposure of large areas of the j 12 skin are overly restrictive when highly localized exposure 13 results from a hot particle.
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| () 14 The staff's intention is to amend Part 20 to 15 provide a new limit for exposure of the skin by hot 16 particles. This process is expected to take at least two 17 years.
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| 18 In the interim, until the amendment becomes 19 effective, the staff is proposing to use a draft Interim 20 Standard, which is inclosed with their draft Generic Letter.
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| 21 Incidentally, it's Handout 5, and has that Generic Letter 22 and some other information in it.
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| 23 Industries representatives have been expressing a 24 concern about hot particles since at least 1987. Their 25 view, and I think the staff shares it, is that the current 1
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| 1 regulatory situation focuses an unusually high degree of 2 attention and emphasis on hot particles.
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| 3 This situation has resulted in unnecessary fear 4 and concern among nuclear plant workers, which I think, from 5 my own experience, is a very serious issue.
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| 6 Industry has also provided data that shows that 7 radiaLJon workers are receiving substantial full-body 8 exposure because of the hot particle situation. Most 9 licensees are removing people from work in hot particle 10 areas, such as steam generator platform work at intervals 11 like every ten or fifteen minutes to take them out to an 12 area where they can be surveyed for hot particles to avoid 13 overexposure with the present limits. And that, of course, I
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| () 14 impacts their whole-body exposure because it takes longer to 15 do the job.
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| 16 Other concerns expressed by industry are the 17 costs, that is, worker productivity and the need for more 18 health physics technicians, increased rad waste volume, 19 because of the difficulty in surveying for hot particles and 20 contaminated clothing that's often thrown away, for example.
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| 21 Although the NRC has used their regulatory 22 discretion in citing people on hot particle issues, the 23 industry has a concern about the impact of these NOVs on 24 their SALP ratings and also potential insurance and legal i 25 considerations.
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| (~)N
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| '' Heritage Reporting Corporation (202) 628-4888
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| ( 'i 1 Industry representatives have emphasized that a 2 change in the NRC position would not result in a decrease in 3 the protection of workers or the general public nor in the 4 controls that have been established to prevent hot particles 5 from being transported off site.
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| 6 The staff in March of 1989 asked NCRP to study the 7 health significance of exposure from hot particles on the 8 skin. And provide recommendations based on the findings of 9 this study.
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| 10 As you know, NCRP has an international reputation 11 for excellence in the field of radiation protection and has 12 been chartered by the Congress to work with federal agencies 13 and others in developing guidance in radiation protection y) f' 14 matters.
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| 15 We've been told that a very well-qualified five-16 person NCRP subcommittee performed this study and provided a 17 draft document entitled " Recommendations on Limits of 18 Exposure to Hot Particles on the Skin" to the staff on June 19 17th 1988.
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| 20 This draft report was subsequently reviewed and 21 approved by the full seventy .five member council. Both Mel 22 Carter and Dave Moeller, incidentally, are on that seventy-23 five member council.
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| 24 The NCRP recommendations are based on ensuring 25 that ulceration of minute areas of the skin do not occur.
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| O' Heritage Reporting Corporation l (202) 628-4888 i
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| O 1 The risk of' radiation-induced skin cancer from exposure to 2~ hot particles was not considered to be significant or 3 controlling by NCRP.
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| 4 Their recommended exposure limit--and it's very 7 5 specifically for particles less than 1 millimeter in 10 6 diameter--which typically is what is being found, is.10 7 beta. particles emitted from the surface of a hot particle.
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| 8 The caveat that any overexposed individual would be provided 9 with follow-up medical evaluation with respect to skin 10- ulceration.
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| 10
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| : 11. 10 betas I guess is also in the specific typical
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| '12 case, if 1 beta emission per disintegration is equivalent to i.
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| 13- 75 microcurie hours. You'll be hearing about those units in
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| ()'14 the later presentations.
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| 15 . Depending on particle size and isotopic 16 composition, this results in a dose limit ranging from 17 something like 300 to 800 rad.
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| 18 One bit of perspective for this is that the 19 radiation dose that's generally accepted as a limit for 20 radiotherapy treatments involving large areas of the skin is 21 something like 2,000 rad. But that's a different situation 22 than occupational exposure.
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| 23 In its June 17th '88 transmittal letter, NCRP 24 stated that their recommendations may be considered firm, 25 subject to final editorial changes, and may be used and Heritage Reporting Corporation (202) 628-4888 L___-__-__-_--_-____--___--__-__-_-_-__-_-_-_______-___
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| 10 1 quoted as appropriate.
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| 2 Their letter indicated that their report would be 3= published in final form in the fall of 1988.
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| 4 -The NRC staff subsequently raised a number of 5 technical and philosophical concerns with respect to the 6' NCRP recommendations. And these are currently in the 7 process of being resolved.
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| 8 'In February of '88, NCRP asked NUMARC to provide 9 comments, and in May the provided these comments and 10 supported NCRP's approach to'the hot particle problem, and 1
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| ' ll. pointed out a number of conservatism that existed in the 12 NCRP recommendations.
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| 13 So the situation is that the final NCRP report is 14 undergoing'some revisions and there is no firm schedule for 15 its final publication.
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| - 16 As I said earlier, the staff plans to revise Part 17 20'through rulemaking and have stated that they will
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| : 18. consider the final NCRP recommendations in that process.
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| 19 But this is, of course, going to take 20 approximately two years.
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| 21 The staff did consider implementing the draft NCRP l 22 report but for a variety of reasons did not think it 1
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| 23' appropriate to do that at this time.
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| l --
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| 24 Instead they've come up with an Interim Standard 25 that's enclosed with the draft Generic Letter in the package O Heritage Reporting Corporation (202) 628-4888 I
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| I L
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| (_) 1 which changes the limits for exposure to the skin from hot 2 particles from 7.5 rem per skin of the whole body or 18.75 3 rem for skin of the hands and forearm, feet and ankles per 4 calendar quarter, to 50 rad per hot particle exposure.
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| 5 It's of note that the current revision to Part 20 6 that is in the rulemaking process right now uses a 50 rem 7 annual limit for large areas of the skin, so the staff is 8 saying one hot particle per calendar quarter is the limit.
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| 9 The new Part 20 for large areas of the skin will be 50 rem 10 per year.
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| 11 Industry in its presentation has made a very 12 strong case that the proposed Interim Standard would provide 13 very little relief to them in addressing the hot particle
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| () 14 problem. And they believe that the Interim Standard should 15 be based on some conservative interpretation of the draft 16 NCRP report.
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| 17 The staff, on the other hand, has the obvious 18 difficulty in basing an Interim Standard on a draft report.
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| 19 There's a couple of other technical issues, but 20 the Interim Standard that--: think we' d like to hear more
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| ( 21 about. The Subcommittee had a lot of problems with the fact 22 that the Interim Standard does not specify how large a l
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| 23 particle is involved. And this is very central to the 24 determination as to whether the limits for large areas of 25 the skin should be used or whether the particle is a hot I
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| ~ O. 1 particle. As I said, NCRP says'1 millimeter is the 2 Appropriate limit.
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| 3 A second issue is one of regulatory philosophy, I 4 guess. It's in Section 4 of the Interim Standard. There 5 the NRC states they will not issue an NOV for a single hot 6 particle exposure to an individual-if this is less than.the 7 exposure limit and'in effect--well, one per customer per 8 quarter I guess is my way of saying it.
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| 9 And they indicate that if an. individual is exposed 10 to two hot particles in a single incident in a quarter or to 11 two or more hot. particles in separate events during a 12 quarter, they may issue an NOV.
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| 13 And I guess I'd like to hear more from the staff 14 on this, but I' find that a somewhat strange regulatory e( )
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| 15 philosophy. And in my mind it's also inconsistent with the.
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| 16 staff's position that hot particle exposures are not to be 17 added to skin exposure for record keeping purposes and are 18 not themselves additive unless they occur in the same i 19 location.
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| 20 I can see this causing problems, inhibiting people 21 from using an individual who has had one hot particle 22 exposure because of fear of an NOV.
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| 23 Well, that's kind of a summary of what we heard at L 24 the Subcommittee meeting and I guess what I'd like the staff 25 to do is to deal with those last two specific issues.
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| 1 k/ Heritage Reporting Corporation (202) 628-4888
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| 1 But more' importantly, the issue that I think the 2- Committee is most interested in' hearing about is'the 3- situation with NCRP. I am troubled by the idea that we j 4 would be putting out interim guidance that is not based on 1
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| 5 NCRP recommendations. j 6 My view has historically been that the Commission 7 has always based their rad protection regulations on NCRP 8 recommendations and I would feel much more comfortable if' 9 this Interim. Standard were based on that with some 10 appropriate level of conservatism.
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| 11 .You might end up with a 50 rad, but at least you'd 12 have the basis of having the best experts in the country as 13 your basis for the regulation.
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| ().14 So with that, I will ask--
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| 15 Yes.
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| 16 DR. KERR: Did the staff discuss how they measure 17 50 rads or 1 sq. centimeter and a depth of 7 milligram per 18 sq. centimeter?
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| 19 MR. CARROLL: Yes. I think people understand how 20 to do that.
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| 1 21 DR. KERR: I said " measure" not calculate.
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| : 22. MR. CARROLL: I didn't bring that up. But the 23 staff's Interim Standard, as Bill says, is 50 rad at a depth' 1 24 of 7 milligrams per centimeter squared average over an area 25 of 1 centimeter squared.
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| 'l There is a pretty well' accepted. computer model 2 that people use for that-purpose.
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| 3 DR. KERR: So what one measures is the activity of 4 the particle and from that deduces-- 1 5 MR. CARROLL: How long-it's been on a person's ';
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| 6 skin.
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| 3 7 DR. KERR: Okay.
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| 8 MR. CARROLL: Which often is a very conservative 9 assumpciva because timekeeping you assume the guy got the-
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| '10 hot particle--
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| f 11 DR. KERR: So the.50 rad is not a measurement. Of
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| ~ 1:2 course,. a whole-body 50 rad is not a measurement either, 13 but--okay.
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| _( ) 14 MR.-CARROLL: Any other questions?- I should ask 15 . Charlie.if he has any comments.
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| 16 MR. WYLIE: No, I think you covered it very well, 17 Jay. The only thing I.would just. call the members attention 18' to, the letters in there attaching from Dave Moeller and Dr.
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| 19 Carter of NUMARC I think. It would be informative to read 20 those.
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| 21 MR. CARROLL: Yes. I should comment on 22 particularly Dr. Carter's letter. I spoke to him on Monday.
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| 23 I guess it's page 41. And he, of course, has been very E 24 concerned about this hot particle issue and I guess feels 25' that it is not really a very significant contributor to Heritage Reporting Corporation (202) 628-4888 L______ ____ _ _ _ _. - - _ _ . - _ _ . - - - - - - - _ _ - - - - - _
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| '- 1 worker health risks.
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| 2 In his letter he does support the Interim Standard 3 proposed by the NRC staff. Says it's reasonable at this 4 time and relatively conservative and so forth.
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| 5 The question I posed to him was, "Well, would you 6 feel better, Mel, if we could wave a magic wand and had the 7 NCRP recommendations and a standard were based on those 8 recommendations?" And he said, " Absolutely. And'if we can 9 find some way to get the NRC and NCRP off of dead center and 10 get this standard on the street--or this recommendation on 11 the street, I would certain do my part internally with NCRP 12 to facilitate that process. And I'm sure Dave would do the 13 same thing."
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| () 14 So he would prefer, although the letter doesn't 15 say that, that the Interim Standard be based on an NCRP 16 recommendation.
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| 17 Any other questions or comments before we let 18 Frank Congel hold forth here?
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| 19 DR. LEWIS: I need just one bit of education. '
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| 20 Dade's letter speaks of stochastic versus non-stochastic 21 limits. And that's a new use of the word " stochastic" to 22 me.
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| 23 MR. CARROLL: No, it isn't. Not among--oh, for 24 you, okay. ;
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| 25 DR. LEWIS: For me it's a new use. So it i
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| ?>- 1 obviously has some meaning in this community.
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| 2 MR. CARROLL: The health physics community has 3 been using that terminology for eons-I-guess. Stochastic 4 .effect translate to a probability that a radiation exposure 5 - of.some sort may induce cancer, it may cause genetic 6 effects.
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| 7 Non-stochastic effects is one where particular 8 -radiation exposure will cause an effect. I 9 DR. LEWIS: I see. l 10 MR. CARROLL: X neutrons is going to'cause --
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| 11 X betas to a localized area of the skin is going to cause 12 skin reddening.
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| 13 MR. WARD: You mean stochastic is below clinical 14 .c t.dence, damage below clinical evidence?
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| ()
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| 15 MR. CARROLL: I wouldn't say that.
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| 16 DR. LEWIS: I think I just understood what is 17 going on. With some probability. I think the use of the 18 word " stochastic" intrudes upon but doesn't duplicate the 19 really--
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| 20 MR. CONGEL: Could I start off by one thing. You 21 mentioned Dade Moeller's letter. I talked with Dade Moeller 22 this week and you focused in on the one part of his letter 23 where he actually mixed stochastic and non-stochastic in his 24 reply.
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| : 25. I was going to let it ride. Dr. Moeller said that l
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| 1 I could mention to the staff that he indeed did mix the two 1
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| 2 and now that we're on that subject, I don't want to further 3 confuse that issue. But stochastic effects are those 4 effects that are delayed in manifestation and may or may not 5 appear at some future time.
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| 6 DR. LEWIS: Okay. The word " stochastic" in 7 statistics includes the "may or may not appear" but has no 8 reference to delay, to time delay.
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| 9 MR. CONGEL: No. In this context, it is used that 20 way. In the radiation protection cantext.
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| 11 DR. LEWIS: It's misused t'ais way, but you are 12 telling me to switch gears. I unoerstand. That's okay.
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| 13 MR. SHEWMON: You'll have to realize Professor
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| '( ) 14 Lewis it is not used the way he was raised using it misused.
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| 15 (Laughter.)
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| I 16 MR. CONGEL: My name is Frank Congel. I am the 17 Director of Division of Radiation Protection and Emergency 18 Preparedness.
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| 19 And this morning I am going to give an overview 20 that is based on the presentation that was given to the 21 Subcommittee by my staff people on April 20th.
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| 22 Unfortunately I was not able to attend that. I was at the 23 Regulatory Information Conference in downtown Washington.
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| 24 Nevertheless, I certainly spent some time talking to my 25 staff about the results of that April 20th meeting.
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| '/ 1 As I mentioned earlier, I had > rhone conversation 2 with Dr. Moeller and as a result of reading his letter and 3 Mel Carter's letter and other comments that have been fed 4 back to me, we prepared this morning's briefing. And what I 1
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| 5 hoped to do is to present once again with a slightly 6 different twist the perspective that we, the NRC staff, had 7 that led us to the recommendations that you have in front of 8 you.
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| 9 Just as an overview of what the Interim Standard 10 has stated or as it's stated in our Generic Letter, I' d like 11 to emphasize some points. It is indeed an Interim Standard.
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| 12 And we are gathering more information in order to come up 13 with what will ultimately be a final standard. This final 14 standard will be manifested in the form of a rule change, as
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| (~)T 15 reflected in Part 20.
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| 16 I'd like to also point out a couple of times 17 already this morning that a two-year time frame has been 18 mentioned. Well, two years is the clock that we have that 19 starts when we have a recommendation in hand. Something 20 that we feel comfortable with. And since there are studies 21 going on right now gathering information that we would use 22 for the formation of a final recommendation, it may be more 23 than two years before we come up with a final rule. In 1
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| 24 fact, I will say it will be more than two years.
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| 25 Consequently, the need for an Interim Standard is
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| ) Heritage Reporting Corporation (202) 628-4888 i
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| i 19 If -
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| 1 even greater.
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| J2 Let's go over a couple of the things. We have the 3 standard and it applies to the occupational exposure only l
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| l 4. right now of a hot particle. And I'd say of any size or l
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| l 5 activity on the body or clothing. We did not adopt a 1 6 . millimeter size standard.
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| 1' 7~ The definition of a hot particle is such that when 8 one does the calculation to determine what the dose from
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| : 9. that is, if you get dose significantly greater than the 1 ,
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| 10 cm 2. surface area, then it would indeed apply or be applied
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| 11 to the skin dose standard that presently is in Part 20.
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| 12 Yes, sir.
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| 13 DR. SHEWMON: hel Carter in his letter talks about
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| : 14. Are those both phrases
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| () hot particles and hot fragments.
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| 15 that are used? And can you comment here on the difference?
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| 16 MR. CONGEL: There is no difference. It's the 17 same concept, the same thing, that we' re talking about in 18 any cases. In some cases the particle might be a. piece of 19 material that comes from a stellite. And other times it may 20 be an actual fuel fragment.
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| 21 DR. SHEWMON: But Mel feels that somebody--that 22 the licensee presumably is called upon to make a distinction 23 between hot particles and hot fragments and he's not clear 24 how one can do it. So apparently the rule must be somewhat 25 different or he thinks they are.
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| \- 1 MR .' CONGEL: I don't know. Th'e only standard we
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| : 2. apply, as you know, the activity associated with the 3 particle and calculate the dose associated with that 4 particle using a method is approved.
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| , 5 MR. CARROLL: You also have to know the dimensions 6 of the particle.
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| 7 MR. CONGEL: 'That goes into the computer program, 1
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| 8 that's right. But in terms of the definition, I don't 9 understand that point.
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| 10 DR. LEWIS: Well, Paul, I don't know why you are 11 quibbling about the meaning of words.
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| 12 (Laughter.)
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| 13 DR. KERR: Excuse me. If there's no distinction j) 14 between the particle and the fragment, how does'it go into 15 the computer program?
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| 16 MR. CONGEL: In terms of the isotopic makeup, the 17 activity.
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| 18 DR. LEWIS: Do they guess a size or do they have 19 to find the particle?
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| 20 MR. CONGEL: No, define the particle, measure the 21 dimension of the particle, and know the isotopic makeup of 22 the particle. And that forms the input data for the code 23 that's used to determine the dose.
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| 24 DR. KERR: What part does the dimension of the 25 particle play in the code?
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| 1 O
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| k-) Heritage Reporting Corporation (202) 628-4888
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| 21
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| : 1 p c(:)1 1 MR. CONGEL: I don't know thatfoff the top of my L
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| 2 head except for a self-correction, self-absorbent 3- correction.
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| U 4 MR. CARROLL: It's more than that, Bill. It also
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| -5 determines-the--
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| 6 MR. CONGEL: But I don't know all the' details of 7 the code. Does any of my staff here know it enough to 8 answer thatoquestion?
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| 9- MR. WARD: The' dimensions do go into the code, 10' into the calculation.
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| 11 DR. KERR: No, I said what part.do they play. I'm 12 trying to find out if there's some way of telling a. fragment 13 from a' particle? The computer' code kicks off once you.put 14 the dimension in and it says, "This is a fragment" or "This
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| '()
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| : 15. ' is a particle"?
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| 16 MR. CONGEL: No.
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| 17 DR. KERR: Oh, it doesn't?
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| 18 MR. CONGEL: No.
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| 19 DR. KERR: It doesn't distinguish?.
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| 20 MR. CONGEL: No.
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| 21 MR. CATTON: They have to tell it what the 22 isotopic content is.
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| 23 DR. KERR: Obviously Mr. Carter i: ...; up to date 24 on computer codes. Okay.
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| 25 MR. CATTON: How do they find the particle?
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| Heritage Reporting Corporation (202) 628-4888
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| 22 I rh j
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| 'k '} 1 MR. CONGEL: Oh, with frisking. That's one of the 2 primary techniques.
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| I 3 MR. CATTON: They are going to miss some. :
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| i 4 MR. CONGEL: Conceivably and perhaps before we had l
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| 5 the more sensitive friskers, the argument is made we've been )
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| 6 missing them.
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| 7 MR. CATTON: So if it jumps on and jumps off, they 8 won't find it at all.
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| 9 MR. CONGEL: That's possible. And in fact, when I 10 discuss some case histories in a little bit, you'll see that 11 that probably has occurred a couple of times already.
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| 12 MR. CARROLL: I couldn't guess how many hot 13 particles I've had on my hide over the years.
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| 14 VOICE: You are probably sitting there retting
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| (}
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| 15- right now.
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| 16 MR. CARROLL: Yeah, I know.
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| 17 DR. REMICK: Let's move on.
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| 18 MR. CONGEL: As was mentioned earlier by Mr. ;
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| 19 Carroll, it applies to a single exposure of an individual in 20 a calendar quarter.
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| 21 We have the limit that's proposed. The threshold i 22 limit is to stay below 50 rads. It was calculated over 1 l 23 cm at a skin depth of 7 mg/cm . As I'll mention later, 24 though the data is consistent with almost the radiation 25 protection committees worldwide.
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| () Heritage Reporting Corporation (202) 628-4888 l-1 _ - _ _ _ _
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| 23 I~'t -
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| ''-? 1 No notice of violation with any dose below that 50 t
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| 2 rad. That's the purpose of having an Interim Standard.
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| 3 MR. CARROLL: But only one per customer per 4 : quarter?
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| 5 MR. CONGEL: That's correct. And I'm just saying 6' though, we want to have the flexibility to look at a 7 specific circumstance that may result in some single 8 individual getting more than one of these in any calendar 9 quarter. We don't want--we aren't in the position yet to 10 write off entirely on that eventuality.
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| 11' MR.' CARROLL: Yes. But you already have in the 12 regulations and in fact you've used it in hot particle 13 exposure incidents, a requirement that people have, quote, 14 " adequate surveys,"
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| 15 MR. CONGEL: Surveys, that's right.
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| 16 MR. CARROLL: That gives you all the enforcement 17 discretion you need, it seems to me.
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| 18 This other one, you know, the reaction of a 19 licensee is going to be, well, if Joe here, one of my best 20 workers, has gotton one hot particle, I'm going to keep him i 21 out of hot particles areas.
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| 22 DR. KERR: Well, now, is a hot particle a hot 23 particle even though the exposure is below 50 rads?
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| 24 MR. CONGEL: Sure. Yes, sir. ;
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| 25 DR. KERR: What is meant by "No Notice of A Heritage Reporting Corporation (202) 628-4888 1
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| m_.1__._._.__ ._ _ _ _ . _ _ . _ _ . . _ . _ _. _ _ . . _ _ _ _ _ _ . . . _ _ _ _ . _ _ _ . _ ___ __ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
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| 24 f)
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| \' 1 Violation for single exposure below 50 rads"? If the 2 exposure is a 10th of a rad--
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| 3 MR. CONGEL: No Notice of Violation. The point 4 is-- l 5 DR. KERR: No , wait a minute. You get a single 6 exposure for a 10th of a rad. Now, the second exposure at a 7 10th of a rad you enter the stochastic region where there's 8 a possible Notice of Violation and a possible violation of a Is that-- !
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| 9 failure.
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| 10 MR. CONGEL: That's a possibility, yes.
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| 11 I want to be able to determine what practices are 12 being followed, what the circumstances are at a particular 13 facility, that would result in something like that,
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| (-)
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| %)
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| 14 especially considering we haven't seen such a thing yet.
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| 15 Maybe it's an over conservatism on our part, but--
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| 16 DR. KERR: I'm not trying to determine whether 17 it's conservative or not. I'm trying to understand what the 18 possible Notice of Violation means. It means a licensee 19 beforehand can't really know whether he going to get a 20 violation or not, is that--
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| 21 MR. CONGEL: That's right. That's right.
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| 22 MR. CUNNINGHAM: Frank, Jay Cunningham, Branch 23 Chief, Radiation Protection Branch.
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| 24 I believe your question is--what you are trying to 25 get at is the 50 applies to that single exposure which is e
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| (m.) Heritage Reporting Corporation I (202) 628-4888
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| 25
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| _ p
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| , 'l~ l '. over the current Part 20 limits but is less than the 50 rad.
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| 2 That is the single exposure less than 50.
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| 3 Obviously, if.it is less than the current Part 20
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| '4 limits, there is no citation--
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| 5 DR. KERR: Well, there isn't anything obvious
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| .6 about that on the slide, and that's the reason I asked the 7 question..
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| 8 MR. CARROLL: So what you are saying, Jay, is that 9 for skin of the whole body, two of them between 7 and 50 10 might invoke that.
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| 11 MR. CUNNINGHAM: Might. That is correct. Because 12 obviously the Interim Standard does not change the 13 regulations. We are exercising enforcement discretion at
| |
| - 14 ' this point.
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| : 15. DR. KERR: As far as the licensees are concerned, 16 you will interpret "possible" as meaning "for certain."
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| 17 MR. CONGEL: You could.
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| 18 DR. KERR: And therefore his practice will be the 19 same as if instead of "possible" you said, " Notice of 20 Violation." I mean I think you ought to take that into 21 consideration if it makes a difference.
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| 22 MR. CONGEL: The point that I wanted to make is 23 that we're going to be carefully looking at these kind of 24 exposures. That was my only point.
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| 25 DR. KERR: But your careful looking has some
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| () Heritage Reporting Corporation (202) 628-4888
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| ,_ 26 ,
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| 'k) 1 implications as far as practice in the field, and, indeed, 2 could have implications as far as exposure of individuals.
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| 3 MR. CONGEL: That's correct.
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| 4 MR. CUNNINGHAM: May I? Jay Cunningham again.
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| 5 May I just add for clarification--rather than have no limit 6 'on the number of particles on an individual that are less 7 than 50 but greater than the current Part 20 limits, and 8 decided to specify an event and when it became more than one 9 event over the current Part 20 limits, we obviously have the 10 option not to impose the new enforcement discretion of the 11 proposed standard of 50.
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| 12 DR. LEWIS: At t he risk of again quibbling over 13 words, the term " enforcement discretion" sends chills down
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| [D
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| %)
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| 14 my spine. Because it suggests an environment in which 15 nobody knows what the rules are until the event is over and 16 then somebody will decide, namely you, whether or not to 17 cite somebody for violation of fuzzy rules.
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| 18 It's a general principle of regulation that a i 19 person ought to be able to decide whether he's violating a i
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| 20 rule while he's in the midst of the act. And are you 21 abandoning that general principle here?
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| 22 MR. CUNNINGHAM: No, certainly not.
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| 23 DR. LEWIS: Okay. Well, what does " enforcement 24 discretion" mean?
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| l 25 MR. CUNNINGHAM: It means that the current Part 20 Heritage Reporting Corporation l
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| (202) 628-4888 E_____________
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| l!
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| lt .n
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| ?! . 27 l- .
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| ~ -
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| . . 1 1' limits are still applicable, because we have not changed the, 2 rules.
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| 3 DR. LEWIS: Yeah.
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| 4 MR. CUNNINGHAM: Legally we are,still bound by the :)
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| 5 Part.20. limits that exist currently. j E E 6 DR. LEWIS: Then what.is this-- ,
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| 7' MR. CUNNINGHAM: And the staff is.saying, however, 8 that we will chose not to issue a violation for an event- l 9 dealing with a. hot particlo as long as it does not exceed- ;
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| 10 the 50 rad. ,
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| 11 DR. LEW.'S: I'm really confused. I thought that-12 the existing Part 20 is the set of rules. And you have no l 13 choice on.whether to enforce them. They are the rules. So .
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| 14 I'm really quite confused about- what this is adding to the l 15 situation here. j
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| '16 This is adding a domain in which people are in !
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| l 17' conformity with Part 20, but may still be cited by-you or j 18 not?
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| 19 MR. CUNNINGHAM: No.
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| 20 DR. LEWIS: No.
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| 21 MR. CUNNINGHAM: No, sir.
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| 22 DR. LEWIS: So is it adding an area in which they 23 are in violation of Part 20 but are not going to be cited by ;
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| I 24 you? j 25 MR. CUNNINGHAM: Absolutely correct, yes.
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| Heritage Reporting Corporation (202) 628-4888
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| . _ _ - . _ _ _ _ _ . _ _ . . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ - . . _ _ . _ _ _ _ _ _ . _ _ _ _ . _ _ . _.__.__._._____________._.-____m___ _ _ _ _ _ . _ _ . _ _
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| 28 1 DR. LEWIS: How do you have that option?
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| 2 DR. SHEWMON: Because of the carry over which they 3 get this radiation is small enough, they think maybe it's a '
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| 4 "no, never mind" even though it could be interpreted as 5 violating the rule, which was originally set up for the 6 whole-body 50 rem.
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| 7 DR. LEWIS: Yes, I understand. I understand that, 8 Paul.
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| 9 DR. SHEWMON: So why are you asking it?
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| 10 DR. LEWIS: Just because I'm slow.
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| 11 So this is to replace Part 20 then?
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| 12 MR. CUNNINGHAM: We will proceed with rulemaking 13 to change Part 20.
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| () 14 DR. LEWIS: Why not wait until then?
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| 15 MR. CONGEL: Well, we want to respond to a problem 16 that is occurring right now.
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| 17 DR. LEWIS: I see. Okay.
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| 18 MR. CONGEL: That's the essence of what we're 19 going here. We recognize the inapplicability in most 20 circumstances of Part 20 to hot particle exposures.
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| 21 DR. LEWIS: Okay. You are saying that Part 20 was 22 written sloppily because people didn't recognize the hot 23 particle problem?
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| 24 MR. CONGEL: You can use those terms--
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| 25 DR. LEWIS: Is that in effect what you are saying?
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| \_ Heritage Reporting Corporation (202) 628-4888
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| .i 29 I
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| ('\ l
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| (_) 1 MR. CONGEL: --but right now there's even a world- '
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| I 2 wide community that doesn't have a good standard on hot 3 particle exposure. So the sloppiness continues. f I
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| 4 MR. CARROLL: But just to finish this subject off, l 5 you will agree, Frank, that you really don't need this in 6 the sense that you do have already in Part 20 Section 7 whatever the heck it is, that in effect says that we make a 8 judgment as to whether you've done adequate surveys?
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| 9 MR. CONGEL: I agree with that statement. That's 10 correct, sir. If we weated to find another basis for 11 enforcing an aspect of a licensee performance that we don't 12 like, most likely we can find another portion of the rule to 13 use.
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| 14 DR. LEWIS: But when you exercise this regulatory
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| (^) I 15 or enforcement discretion, that means that somebody on the 16 outside can take you to court for not enforcing the rules?
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| 17 MR. CONGEL: Always. Courts are always open--
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| 18 DR. LEWIS: And they would win.
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| 19 MR. CONGEL: Well, I wouldn't go to that judgment.
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| 20 DR. LEWIS: Because you would have declared that 21 you were not enforcing the rule.
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| j 22 MR. CUNNINGHAM: If I may, Jay Cunningham again.
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| l 23 Part 2 of 10CFR identifies the enforcement policy 24 of the Commission and in that regulation, Part 2, it 25 includes the option and grants the staff certain enforcement Il
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| 'v Heritage Reporting Corporation (202) 628-4888 l
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| L-- - - --
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| 30 1 discretion, certain latitudes are spelled out. And that's 2 what we have used in the.past and that is also the basis for 3 the proposal of implementing this Interim Standard.
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| 4 DR. LEWIS: I'll have to reread that wording. I 5 didn't think it was quite that loose, but I'll reread it.
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| 6- MR. CONGEL:- And we certainly are completely 7 within the procedural requirements of making the 8 recommendations for enforcement purposes.
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| 9 The only other--thing we already talked about the 10 possible failure for meeting other requirements, 11 irrespective of the dose that's calculated for a hot 12 particle. And I want to point out that this approach does 13 not change in any way our record keeping notification and 14' other reports.
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| 15 DR. REMICK: One other question. Let me take the 16 hypothetical situation that in one quarter there are several 17 hot particles found on protective clothing, not on the skin.
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| 18; And that protective clothing is adequate to protect the 19 individual from the exposures.
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| 20 I assume there's no violation there.
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| 21 MR. CONGEL: That's correct. Because the dose--
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| 22 DR. REMICK: Well, I wasn't sure, from the first 23 bullet, it says " body or clothing." And I just assumed that 24 if it's on the body--
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| 25 MR. CONGEL: You are getting to something that I
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| () Heritage Reporting Corporation (202) 628-4888
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| = - - - _ - _ _ _ _ _ _ _ _ - _ _ _
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| 31 l' want to discuss that is really the basic essence of the l l
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| 2 problem that we have with the NCRP recommendations. Namely, 3 that it doesn't go far enough. And so when there is a ~ ;
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| i 4 particle in the clothing, if it's found obviously, you have "
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| : 5. three layers of clothing on and it's on the outside layer, l 6 and the activity is such that the betas won't even penetrate j 1
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| 7 the three layers, the dese'you calculate from that in this i
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| 8 hypothetical case is zero. And that's the number-you use to l i
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| 9 compare for enforcement purposes. ;
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| I 10 DR. REMICK: Thank God for rationality. .]
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| t 11 MR. CONGEL: Okay. Thank you. l t
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| 12 MR. CARROLL: Just so you can pace yourself, l 13 Frank, I guess you have until about 9:45. l
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| () 14 MR. CONGEL: Well--
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| 15 MR. CARROLL: To give industry theirs. ]
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| i 16- MR. CONGEL: I'll skip the next slide that you !
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| 1 17 have in your package and just go to the comparison of the i 18 exist Part 20 limits and the Interim Standard that we have
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| -19 as our proposal.
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| 20 And the column that is of interest here, of 21 course, is the ratio of the limits. The skin of the whole 22 body is 7.5. Our proposed standard of 50 changes that by a 23 factor of nearly 7. And if you are talking about just the 24- skin of the extremities, and there's the hands, arms, feet 25 and ankles, it's a little bit less than a factor of 3.
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| Corporation j Heritage Reporting (202) 628-4888 )
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| 32 0 1 The issue of whole body exposure, of course, is 2 not applicable to this standard.
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| 3 Just for comparative purposes or for reference 4 purposes, that when you have particles in the microcurie 5 range, that clearly the dose from betas dominates strongly.
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| 6 And that the skin dose from any gamma component is very 7 small.
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| 8 That the whole-body dose,-thatJis, the' dose at the 9 'l em depth layer from such particles is typically very 10 small. And that the skin dose is definitely controlling.
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| 11 When you reach the hundreds of microcurie range as 12 the activity of the particle, you've got circumstances where 13 the 50 rad skin dose could easily be exceeded using the 14 accepted programs that we have for calculating those. And
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| ()
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| 15 that at that point you can also run the risk of exceeding 16 the whole-body dose, the 3 rem per quarter number.
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| 17 So that when you are having controls at the 18 ' licensing level, it has to consider both of those 19 eventualities.
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| 20 DR. KERR: What is the significance of the 21 parenthetical statement under whole body, 1 gram per cm 22 depth?
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| 23 MR. CONGEL: Just the fact that you have to 24- penetrate that far before you are in the domain that is 25 considered dose to the blood-forming organs and other organs Heritage Reporting Corporation (202) 628-4888
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| _ - _ _ _ _ _ _ _ _ _ _ . - _ _ _ -_______-____-__--________--_________-_-________________-_-_-_-___z
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| 33
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| \_/ 1 that comprise the total body.
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| 2 DR. KERR: So if you take a layer that's about a 3 centimeter deep around a body, that's considered a whole-4 body dose?
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| 5 MR. CONGEL: That's what the calculational 6 approach uses. Yes. As opposed to the skin depth, the 2
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| 7 active part, the skin layer, which is 7 ml. per cm .
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| 8 What was the basis for our change? Why did we 9 want it? Well, as we mentioned a number of times already, 10 the current limits are inappropriate simply because they 11 were based on exposure of significant areas of the skin.
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| 12 And the other thing is that we know that there's 13 the possibility of saving whole-body dose. It was mentioned r~ 14 by Mr. Carroll's summary that industry believes that with
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| (_-)
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| 15 the threat of enforcement actions hanging over them for hot 16 particle exposures, it would be compared to existing Part 20 17 standards, they may be more conservative in handling people, 18 workers, that are in areas where,they could receive hot 19 particle exposure. j 20 DR. KERR: What was the consequence that was used 21 as a basis for the existing rules? Was the consequence skin 22 cancer?
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| 23 MR. CONGEL: Yes, yes.
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| 24 DR. KERR: And the idea here is that if you have a l 1
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| 25 particle this small the likelihood of skin cancer is
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| () Heritage Reporting Corporation (202) 628-4888 l l
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| l l
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| l l
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| 34
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| 'l) 1- negligible?'
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| I i
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| 2 MR. CONGEL: Very, very small if not negligible. )
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| 3 I want to point out though that the 50 rem limit i 4 that is proposed by ICRP 26 is based on the non-stochastic 5 effects. Namely, that number was chosen to eliminate any 6 possibility of effects such as erythema of the possible skin 7 effects. It's not based on.the possibility of skin. cancer.
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| 8 DR. KERR: But if one is willing to go from 3 to 9 50, then does that mean the likelihood of skin cancer is 10 vanishingly small? I mean the.judgmentLis that that's-the 11 case?
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| 12 MR. CONGEL: Let me make sure we've got all the 13 number straight. The 3 rem is a whole-body dose.
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| (f 14 DR. KERR: Yeah.
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| 15 MR. CONGEL: That's based on the protection of the 16 individual worker frem all forms of cancer.
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| 17 DR. KERR: Yeah.
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| 18 MR. CONGEL: The existing dose of 7 1/2 rem that's 19 in Part 20--
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| 20 DR. KERR: Per quarter.
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| '21 MR. CONGEL: Yes, per quarter.
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| 22 DR. KERR: Which is 30--
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| 23 MR. CONGEL: Is based on the stochastic, the 24 possible stochastic effects. Namely, skin cancer.
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| 25 With the advent of ICRP 26 and the relative risk Heritage Raporting Corporation (202) 628-4888
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| 35 lL' factors'that are applied to doses, if you were going to base 2 protection factors for the skin solely on stochastic 3 effects; namely, on skin cancer, the calculated. dose that 4 you'could receive would be somewhat larger. I mean 5 probably, if I remember correctly, at least an order of 6 magnitude larger than 50 rem.
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| 7 DR. KERR: Okay.
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| < 8 MR. CONGEL: If they adopted that as the limit, i 9 they are then in the realm where people getting that number 10 would still have a small possibility of skin cancer in the 11 future but a very real possibility of prompt effects.
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| : 12. DR. KERR: Okay, thank you.
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| 13 MR. CONGEL: Okay.
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| 14 MR. CARROLL: One thing that was brought out in 15 the Subcommittee meeting with respect to skin cancer is 16 that, (a), it is a very common disease. 40 percent of the 17 U.S. population at age sixty-five has had skin cancer'in one 18 form or another.
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| 19 DR. LEWIS: Is this the same form? There are two 20 kinds of skin cancer.
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| 21 MR. CARROLL: Non-melanomas.
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| 22 MR. CONGEL: Yes. Non-melanomas.
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| 23 MR. CARROLL: And the other interesting statistic 24 was that only about 2,000 people a year die of skin cancer 25 and in general those are people that don't get any kind of
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| () Heritage Reporting Corporation (202) 628-4888
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| o 36 g
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| k-. 1 . treatment.
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| : 2. -MR. CONGEL: Totally ignore it.
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| 3 DR. LEWIS: Yes, but that's again a sloppiness in 4' words, because the one that's due to ultra-violet light is 5 usually a basal cell epidelioma and that's universally non-6- fatal. And so lumping those large numbers'in with the 7 really serious skin cancars gives I think a misleading 8 impression.
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| 9 MR. CONGEL: Okay. How are we going to make the 10- change?. What did we choose to do?
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| 11 Well, of course, the root that we have available 12 to us at all times.is rulemaking. I mentioned earlier that 13 the~one critical thing about rulemaking is that it takes 14 time. And it takes a substantial amount of time.
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| (}
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| 15 Two years is only when the clock starts do we 16 finish a rule within two years. The clock doesn't get set 17 until we have all of our recommendations and bases together.
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| 18 But when you have a rulemaking that has plenty of 19 opportunity for public comment and we have a very well 20 substantiated technical base.
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| 21 The Interim Standard that we are proposing can be 22 used--I chuckle a little--I wanted this out. I think 7 told 23 people, my people, that definitely November of ' 88 was the 24 drop dead date for getting this out. And it's now May of 25 '89 and we haven't got it out. But theoretically, in any Heritage Reporting Corporation (202) 628-4888
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| 37
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| (_) 1 case, an Interim Standard of this sort does take much less 2 time than a rulemaking procedure.
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| 3 And we can, of course, use it until the rulemaking 4 is complete, but, but, it will be more conservative than the 5 position we expect to be our final position after a formal ,
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| 6 rulemaking.
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| 7 I say that. I expect it. Ho guarantee.
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| 8 Now, the NCRP draft recommendations. We did get 9 the report, as was summarized by Mr. Carroll, in June of 10 last year. And the recommendations included a new unit of 11 exposure, and that was the 75 microcurie hours. And it 12 applied to a particle that is in contact with the skin.
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| 13 Specifically stated only in the case where the particle was 14 in contact with the skin. Because that is the primary
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| }
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| 15 database upon which they base that recommendation. Namely, 16 where a particle was placed on the skin of pigs, $n most 17 cases, and of the consequences evaluated from it.
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| 1B It also dealt with particles that were only Imm in 19 diameter or less.
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| 20 It was also stated explicitly in the report that 21 there is no safety factor in that estimate, That, in fact, 22 there is a statement in there that the regulatory agency may 23 choose a safety factor of something above and beyond the 77 I 24 microcurie hours.
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| 25 DR. KERR: What is meant by the statement that
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| () Heritage Reporting Corporation (202) 628-4888
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| 1 l'.
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| 38
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| 'l there isn't'.a safety factor?
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| 2 MR. CONGEL: That:that' was the number'that was 3 evaluated--they came up with that value as the threshold 4 .upon which effects would be observable on the skin.
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| 5 DR. KERR: So if you had 51 rads, you'd see 6 effects.- And if you had 50, you wouldn't, is that it?
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| 7 MR. CONGEL: Well, 76.
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| 8 DR. KERR: I'm sorry. 76. Yeah.
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| 9 MR. CONGEL: I don't know if you could call it
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| '10 that' closely,-but my answer to that would be yes.
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| : 11. 'MR. CABROLL: However, Frank,-I.think a fair 12 reading of what NCRP said is we have not put in an explicit 13 safety factor of 5 or whatever. But I think they also make
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| : 14. it abundantly clear that they have made a very conservative
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| {
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| 15 interpretation of the existing data which is a safety factor 16- in and of itself.
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| 17 MR. CONGEL: In and of itself. But as Dr. Kerr 18 pointed out,.it still was an extrapolated value above which 19 you would expect to see some effects. I think that's very
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| :20 important to point out.
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| 21 If you wanted to ensure that you would see 22 nothing, then you would take some multiples under that. 2, 23 5, 10, whatever you choose.
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| 24 MR. CARROLL: Yeah.
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| 25 MR. CONGEL: Also an estimate of uncertainty.
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| () Heritage Reporting (202) 628-4888 Corporation
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| 39 f) k/ L1 There was no estimate of uncertainty in the report.
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| 2 DR. REMICK: Just to make sure I understand, using 3 their' figures which I believe, Jay, you said works out.to 10 4 10 particles per second--
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| 5 MR. CARROLL: Correct. Particles.
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| 6 DR. REMICK: Oh, particles. .I'm sorry, yeah.
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| 7 So why can't what they give you be extrapolated?
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| 8 It seems to me they are saying that the limit works out to 10 9 10 particles in an area of the skin roughly a millimeter 10 in diameter. Because if it's on the skin, the exposure is 11 going to be pretty close to that diameter.
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| 12 MR. CONGEL: That's right. Yes.
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| 13 DR. REMICK: So it seems to me that if this is 14 removed on the outside of clothing and if you can accurately
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| 15 predict the number of particles that would get through that 16' protective clothing, for example, as long as you did not 10 17 exceed 10 particles in an area of roughly a millimeter or 18 whatever, that you would not be exceeding what they 19 proposed. Why--
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| 20 MR. CONGEL: That might be true. And it formed 21 some of the thoughts that we had in coming up with the 22 recommendation we did. Instead of using the number of 23 particles as a basis, we went to dose and we permit the 24 calculation of dose for a source that is removed from the
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| : 25. skin.
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| 40 k l. 1 DR. REMICK: Yeah. But something in the handout 2 says that you've gone back to NCRP and asked them to clarify-3 that.- To me it doesn't seem like'it's~a major clarification.
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| 4 required. Am I just being too simpleminded?
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| 5 MR. CONGEL: If it was an easy one, I think we 6 would have heard from them already. But we haven't..
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| 7 Let me go on. Perhaps some of your questions may E be answered by my subsequent--
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| 9 .MR. CARROLL: Isn't it fair to say that what NCRP 10 was specifically asked to do was to look at the hot particle 11 in contact with the skin?
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| 12 MR. CONGEL: Absolutely correct. Absolutely 13 correct. And they stated in their conclusion that their 14 results only applied to that.
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| 15 MR. CARROLL: But you are right, Forrest. It's 16 not a difficult thing'to remove the particle--
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| 17 D'R . REMICK: Yeah.
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| 18 MR. CARROLL: --from the area of the skin and--
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| 19 DR. REMICK: Sure.
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| .20 MR. CONGEL: And I could argue both ways. If it 21 was easy, then they could have said it. On the other hand, 22 if we had known it, we could have asked for it in advance.
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| '23 But it was stated in the report, this is the limit 24 of their applicability as they have interpreted the data.
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| 25 DR. REMICK: Well, it seems to me one can do that l ( Heritage Reporting Corporation (202) 628-4888 ,
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| ^Q'' .- 1 certainly as accurately as one can of measuring the activity 2 of a particle and then putting it in a computer program and 3 calculating dose. I mean there are all kinds of assumptions 4 and things in there and it seems to me that that's as about 7
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| 5 straightforward. I guess I can't see why--I don't-know.
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| 6- Maybe we're held up on asking NCRP for clarification on.that 7 point. It seems to me pretty elementary calculations.
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| 8 Go ahead. I'm sorry.
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| 9 MR. CARROLL: We're under time constraints.
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| 10 MR. CONGEL: Here was our thought process, and why.
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| 11 not implementing the NCRP draft recommendations.
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| 12 Well, we don't have a final report. yet and the
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| : 13. indications that we have is there are possfoilities for a 14 different final report, that is, some different conclusions
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| 15 in the final then exist in the draft.
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| 16 MR. CARROLL: Let's focus in on that for a minute.
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| 17 What are the hang ups to getting a final report? When are 18 you going to have a final report? You obviously need one to 19 move ahead with the rulemaking?
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| 20- MR. CONGEL: Alan, do you want to give--Alan 21 Rocklein is from the Office of Research and is managing the 22 contract with NCRP. Perhaps you can give a summary of that?
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| 23 MR. ROCKLEIN: We are placing an extension of the 24 contract with NCRP which includes as the end of this fiscal 25 year a deadline for the final report. We are negotiating J
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| (_). 1 that right now.
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| 2 MR. CARROLL: End of the fiscal year.
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| 3 11R . ROCKLEIN: September 30th.
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| 4 MR. CONGEL: September 30th.
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| 5 MR. CARROLL: And so the. report should be:out 6 before September 30th?
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| 7 MR. ROCKLEIN: We hope so, yes-8 MR. CARROLL: And what'are the present stumbling 9 blocks? Where.are you hung up? Or where is NCRP hung up? i 10 MR. ROCKLEIN: We're not. In my opinion we are 11 not hung up. It just takes some time to get this extension 12 through our own contracting process.
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| 13 MR. CARROLL: So I guess I understood that the 14 Subcommittee was going to meet again sometime in June?'
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| 15 MR. ROCKLEIN: The contract will include I believe 16 two additional meetings of the Subcommittee. The extension 17 of the contract.
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| 18 .161. CARROLL: And at that point this report will 19 be on the street in September, following that.
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| 20 MR. ROCKLEIN: I believe'so, yes. That's what 21 . we're discussing.
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| 22 MR. CARROLL: Okay. And you indicated that there !
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| 23 may be some changes? Do you--
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| 24 MR. CONGEL: You see that gentleman there with his l
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| 25 hand up who may be able to shed some light.
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| 43 1 MR. BECKNER: .My name is Bill Beckner. And I am l 2 staff scientist with NCRP.
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| '3 I'd like to address two or things that have been 4 brought up at this point. The NCRP report has been referred 52 to as a draft report. That isn't NCRP's position. The NCRP 6 forwarded the' report to the NRC in-June of last year for
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| * 7 contractual purposes to fulfill the contractual obligation 8 that NCRP had with the NRC.
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| 9 The report at that point in time'was an approved 10 report by the Council and under normal circumstances would 11 have gone ahead to publication.
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| 12 It did turn eut, and the reason it maybe can be 13 called an interim repor*.at this point in time, is that the 14 NRC staff did come back with many questions concerning the 4
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| 15 basis on which the NCRP draft report had been made.
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| 16 Being a scientific organization, we didn't go 17 ahead with publication. The NCRP decided that it would.try I 18 to attempt to.look at those questions that the NRC had 19 forwarded. That we are trying to do at this present time.
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| 20 But the number or the standard that has been put
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| : 21. forth by the NCRP at this point in time has not been i
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| 22 changed. It is under review. And if the Committee were to 23 recommend at change, then this report would have to go back f 24 to the full seventy-five member Council and it won't be 25 ready by September 30.
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| 'O neritaee Reverei e cereeraeie-(202) 628-4888
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| 1 If it turns out that the Committee in its meetings 2 this summer turns to support the position that the Council 5
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| : 3. has already approved, then it would be available by 30 l
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| 4 September.
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| 5 MR. CARROLL: Bill, would you care to make a 6 prediction as to--
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| .7 MR. BECKNER: I can't make a prediction other -j 8: than, you know, to address what my own. feelings would be. 1 1
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| 9 And_at this point in time I would guess that there probably 10' won't be a change. But I don't know. j 11 MR. CARROLL: It seems to me from what we heard at l
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| 12 the Subcommittee meeting that to the extent there may 13 ultimately be a change, it would be a change in the upward
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| () 14 direction or at least the elimination possibly of a Cobalt .
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| 15 60 concern because of its very-soft betas.
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| 16 MR. BECKNER: Yes. Now, I'd like to address a 17 second point and that.was that the NCRP recommendation-is 18 being criticized because it only addresses the hot particle 19 on the skin. In fact, that was what we were requested to 20 address. The hot particle on the skin. Not to-address hot 21 particles on some other location.
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| 22 And the data that's'available is for particles 23 that are in contact with skin. There's very little data 24 available with regard to particles that might be a 25 millimeter off or they are on top of some protective ,
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| \' / 1 clothing, et cetera. You know, you are going to have to 2 interpolate the data from on the skin to those other 3 circumstances.
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| 4 Then a third point has to do with the safety 5 factor. The NCRP didn't put a safety factor in its 6 recommendation for a single purpose, and that was that the 7 end point that was chosen of the non-stochastic effect of an 8 ulceration was considered, in fact, in itself to be a very 9 mind effect. And even if it occurred, it wouldn't be a 10 substantial detriment to the worker that it occurred on. So 11 it would be no more than like a hot pin making a small burn 12 spot on the skin.
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| 13 And from an overall health standpoint, this did
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| (~T 14 not seem to be a very serious end point. It's not the case xl
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| '15 of malignant cancer that ends up in mortality.
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| 16 MR. CONGEL: Thank you, Bill.
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| 17 DR. REMICK: Could I interpret your last comment 18 then that NCRP believes that perhaps there's no need for a 19 safety factor on that figure. Is that correct?
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| 20 MR. CARROLL: That was correct.
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| 21 DR. REMICK: All right. Thank you.
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| 22 MR. CONGEL: Let me offer just a small olive 23 branch. i am not here criticizing the NCRP report. I am l 24 talking about the report, the use of the report, and how we 25 could take the results of that report and translate it into l
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| : 1. an' interim rule. And I'm not doing any finger pointing. f 2 But when we went to make that translation we saw there are 3- some limitations. And perhaps we asked the wrong questions 4 or not enough questions when we had our first contractual j i
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| 5 obligation with NCRP.
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| 6 All I'm doing now is evaluating where we are and J 7 I'm aware of the problems that we are facing and the' answers' 8 we are looking for before we can come up with a more-9 definitive recommendation.
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| 10 MR. CARROLL: But didn't you, Frank, actually'the 11 original draft ofLthis Interim Standard, as I was reading 12 some of the correspondence, wasn't that original draft 13 actually based on-the NCRP recommendations and because of 14 some concerns others on the staff had?
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| 15 MR. CARROLL: The original proposal that my staff 16 brought up to me, yes, indeed. It was based entirely on the 17 NCRP' report.
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| 18 MR. CARROLL: And what was the limit in that first 19 draft?
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| l -20 MR. CONGEL: Well, the number was 75 microcurie 21 hours. We had adopted in our early drafts that value as our 22 proposed limit.
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| ;23 MR. CARROLL: With no' conservatism.
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| 24 MR. CONGEL: You asked me what the first drafts--
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| 25 I'm telling you what the process was like when it first came Heritage Reporting Corporation (202) 628-4888
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| 2' MR. CARROLL: 'Okay. .
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| 3' MR .' CONGEL:. I'm telling you, yes,_ indeed.
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| 4 MR. CARROLL: Well, could'I ask,-what changed-5 'that?- 'Were they legal considerations? Or were they-6 technical conservatism in the staff.that changed the draft 7 without getting--
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| 8 MR. CONGEL: There was'nothing. legal at all. It l
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| l 9: was technical exchanges.amongst staff members. ,
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| 10 Just quickly, if you'll run down. One of the.-
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| 11 . things that was brought up by technical staff members was 12 the difference in the basic data that are in the literature' 13 -that can be used to formulate a limit. And there is a 14 factor of 5 difference between two of the most prominent
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| 15- data in the literature.
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| 16 We had that in front of us. To my knowledge, it 17 has not been resolved. It could' result-in a difference in--
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| 18 DR. KERR: It must surely have-been resolved by.
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| 19 the NCRP because they gave you a report.
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| 20 MR. CONGEL: I don't know the answer to that.
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| 21 DR. KERR: Well, I mean clearly you have a report.
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| 22 They had the same data, didn't they?
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| 23 MR. CUNNINGHAM: This is Jay Cunningham. If I can 24 address that.
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| 25 The response from the NCRP was the draft Heritage Reporting Corporation (202) 628-4888
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| 48 T) % 1 recommendation and one of the concerns was the basis that 2 the Forbes/Mikhail data which is unpublished data that was 3 used by this subcommittee group of NCRP for this 4 consideration.
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| 5 And that led to some questions with the published 6 Hopewell data which they disagreed. They were not 7 consistent. And one of the questions the NRC gave back to 8 this subcommittee was why the difference?
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| 9 MR. CARROLL: Forbes is a member of the 10 subcommittee.
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| 11 MR. CUNNINGHAM: That is correct.
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| 12 MR. CARROLL: And I guess my understanding at our 13 Subcommittee meeting was that there was some plan for him to 14 publish the data.
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| 15 MR. CUNNINGHAM: I have heard that. I don't know 16 for sure certainly. But it was unpublished but available to 17 the subcommittee because he was on it, yes.
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| 18 DR. KERR: And so the subcommittee had the data 19 and all I'm saying is if they gave you a report, they 20 certainly must have resolved the issue as far as this 21 committee is concerned.
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| 22 MR. CUNNINGEAM: Well, I think that was one of the 23 questions when we talked to some of the representatives, and 24 they had not really looked at some of the other published 25 data such as the Hopewell and some of the English authors.
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| )- 1 MR. CARROLL:- Oh, they looked at Hopewell. I'm 1
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| 2 looking at their report right now.
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| 3 MR. CUNNINGHAM: But there were some'of the 4 English data that I don't think was looked at in any detail.
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| 5 DR. KERR: Well, if you have this little 6 confidence in what the committee did, I don't see how you 7- can use the report as a basis for anything.
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| 8 MR. CUNNINGHAM: It was not that we'did not have 9 confidence. We simply had a few questions that appeared to 10 be in conflict and before using that as a basis for action 11 by the NRC, we' asked the question of how can these apparent 12 differences be resolved?
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| 13 DR. KERR: So they are now in the process of 14 resolving or did the committee itself have'any feeling that
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| 15 it was an unresolved issue?
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| 16 MR. BECKNER: Bill Beckner, NCRP again.
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| 17 The committee did look at the Forbes/Mikhail and 18 they did.look at the Hopewell data at the time of their 19 deliberations.
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| 20 It was their opinion at that point in time that 21 the Hopewell data only had one or two data points that were 22- really applicable to hot particles. Those being a 23 millimeter in diameter or less. 1 24 The other data points that were in the Hopewell 25 reports really are not applicable to that kind of a source.
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| 50 7"')
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| (/ 1 And that was the opinion of the committee at that time.
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| 2 Now, there has been a dialogue between Hopewell 3 and some investigators in this country, principally Dr. Baum 4 from Brookhaven and Dr. Reece from Bechtel as well as the 5 Chairman of the NCRP Subcommittee, of trying to again look 6 at the small particles that were utilized in the Hopewell 7 studies to a if those could be made to look the same as 8 the Forbes/de, . ail data.
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| 9 Dr. Baum at this point in time says there's a 10 factor of 5 difference. The committee person that looks at 11 dosimetry is Dr. Resh. He will report to the committee this 12 summer on whether he really feels that the differences are a 13 factor of 5 or what it is. Dr. Resh is a very well known 14 dosimetrist and the committee has based its recommendation
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| ('/)
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| 15 from a dosimetry standpoint on his work.
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| 16 DR. SHEWMON: The draft recommendation--the NCRP--
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| 17 even though the NCRP says it's their report, because you 18 want them to answer more questions, is that why the draft 19 keeps coming up?
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| 20 MR. CONGEL: That's my understanding until--it has 21 not been issued as a final report. l 22 DR, SHEWMON: Is your understandir.g of the staff 23 position, is that what you are answering me?
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| 24 MR. CONGEL: No. My understanding of the NCRP is 25 that it's still a draft report.
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| )- l' DR. SHEWMON: Well, he just got done saying it was y 2 the final report that was put out by the body. You don't.
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| 3 think he understands the sit'uation, is that.it?
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| 4 MR. CONGEL: Clearly somebody doesn't understand 5 the-situation. I don't have a piece of paper in. hand that 6 says to.me that the NCRP has issued a final. report numbered 7 -101. Now, if he can point out a report to me that says 8 here's the NCRP report final 101, then I guess I'll say I'm 9 wrong.
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| 10 But in the meantime, let me hear it.
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| 11 DR. LEWIS: Final means " interim" you understand.
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| .12 MR. BECKNER: In our June 17th letter to you which 13 we've forwarded the report, we stated that the 14 recommendations were final and I think that's already been 15 brought up once today.
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| 16' And Mr. Rocklein's letter back to us with the 17 questions in September recognized the fact that the report 18 was final.
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| -19 MR. CONGEL: The recommendations I think are final 20 based on your letters. Has there been a report published by 21- the NCRP?
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| 22 MR. BECKNER: No. It has not been published but 23 it still is an approved report by the Council and it's been 24 delayed for the very purpose of looking at the questions 25 supplied by NRC.
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| '' MR. CONGEL: Well, then, maybe it's a' matter of-1
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| : 2. semantics. .The delay--
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| 3 MR. BECKNER: I think it is at that time because 4 at this point in time he obviously would say that if it was !
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| 5 a final report, how come NCRP hadn't published it.
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| 6 MR.'CONGEL: Yes.
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| 7 MR. BECKNER: And the reason we haven't published.
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| 8 it because you asked us additional questions. Now, that 9 doesn't mean the report is going to change.
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| 10 MR. CONGEL: It doesn't mean it won't change.
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| 11 MR. BECKNER: That's correct.
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| 12 MR. CONGEL: Okay. Do we want any more dialogue 13 on this or is the disagreement understood?
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| 14
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| () MR. CARROLL: You've run out o? time but we'll 15 give you a couple of minutes.
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| 16 MR. CONGEL: You can probably appreciate why we-17 didn't get this out in November.
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| 18 A quick summary here. We talk about the use of 19 the NCRP report and we looked at the seven principal cases 20 of overexposure that have occurred over the past few years 21 or so. What I wanted to do is just show use of the NCRP-22 report as it's presently constituted. And the use of the 50 23 rad limit as we propose in our draft standard, Interim 24 Standard.
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| 25 We have seven cases where the exposures exceeded O Heritage Reporting Corporation (202) 628-4888
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| ( 1 Part 20 which resulted in some various forms of enforcement 2 action on our part.
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| 3 DR. REMICK: Those are all the cases? Those seven 4 are all the cases that have occurred, okay.
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| 5 MR. CONGEL: Those are all of them. There are 6 some other cases that .< ave allegedly involved hot particle 1
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| 7 overexposure, but we were not able to' ascertain the manner 8 in which the exposures took place. So consequently--I can 9 go over those, but in terms of enforcement actions,~these 10 are the only.seven.
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| 11' . VOICE: If I may, Frank, those are the only seven 12 that are presently completed actions at this time.
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| 13 MR. CONGEL: Oh, okay. .Thank you. Completed
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| - - 14 ones. There are some others that are still being 15 investigated.
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| 16 Now, if you apply the NCRP standard, two of the 17 seven right off the bat were not applicable because the 18 particle was not in contact with the skin.
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| 19 MR. CARROLL: That's a little bit of sophistry 20 though, isn't it? You could use the standard as a basis 21 for--
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| 22 MR. CONGEL: I looked- you know, we go through the 23 discursion of accept the standard from NCRP, why didn't you, 24 a discussion of the final version of it. On the other handy 25 when we talk about using it as it says verbati my they said,
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| 54 i 1 well, you.can always back off and make assumptions on our.
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| '3 With the disagreement that I have, is that that's 4 where we'part. If you adopt the standard--when my staff 5 came up to me and said, if we adopt the standard, we are not l 6 going to have a potential solution to all of the exposures 7 that have taken place, for'the following reasons. I gave 8 .you a cite earlier that gave the reasons.
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| 9' Now, if you apply that standard, here's what you 10 run into. I don't think you can have it both ways.
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| 'll - MR. CARROLL: Well, all right.
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| 12 MR. CONGEL: That's my position.
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| 13 Now, these two are not applicable because they are 14 not on the skin.
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| 15 MR. CARROLL: Okay. Go ahead.
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| 116 MR. CONGEL: These are. And of all of them that 17 would be an exposure greater than a standard, one of the 18 two, either the 50 rad or the NCRP standard, you'll note I 19 that the case with Summer, where there's a calculated dose 20 of like 420 . rads, it would exceed either standard.
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| 21 The 50 rad standard yields no to all of the othere 22 with the exception of this fairly recent one at Arkansas 23 with a calculated dose of 61 rads. And it still would have 24 involved an enforcement action on our part.
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| 25 DR. KERR Just out of curiosity- How do you
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| '' E 11 determine how long a' particle has.been in contact with the 2 skin?
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| 3 MR. CONGEL: That is information that is
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| : 4. determined by--as near as people, the health physicists can 5 tell--be the work environment that the person was in.
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| 6 MR. CARROLL: It usually is conservative, Bill, 7 because you say, well, I-don't know--I kept track of the 8 time when the guy went into this area, I know that. And I 9 know when he came out to be monitored when I found the 10 particle, but I don't know when the particle got on his skin 11 through his clothing or whatever.
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| 12 DR. KERR: Okay.
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| 13 MR. CARROLL: All right. So you assume the whole 14 interval.
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| 15 MR. CONGEL: In any case, this quick summary shows 16 two out of seven of these instances would have resulted 17 still in enforcement action under our Interim Standard. Two 18 of the seven would not have been directly applicable to the 19 NCRP Standard.
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| 20 I looked at these data and with my staff decided 21 that the 50 rad standard would indeed give enough relief 22 until we gave more thought and consideration to the 23 theoretical anpects.
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| 24 IlR. WYLIE: Frank, let me ask a question.
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| 25 HR. CONGEL: Yes. 4
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| (_) 1 MR. WYLIE: You only go back to ' 85. Is that )
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| 2 because the sensitivity of the instrumentation was not 3 available?
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| 4 MR. CONGEL: That's a partial explanation. That's 5 as far back as we've had hot particles.
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| 6 DR. KERR: Just out of curiosity. Do you know 7 whether the Summer case resulted in ulceration, an 8 . observable ulceration?
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| 9 MR. CONGEL: I don't believe we've had any 10 evidence of skin effects whatsoever in actual incidents.
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| 11 DR. KERR: So he knows about nine times the 50 12 that you are recommending, the 50 rad?
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| 13 MR. CONGEL: Yeah. That's correct. Eight to nine 14 times.
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| 15 DR. KERR: Okay.
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| 16 MR. CONGEL: All right. Let me go quickly to the 17 other consideration. The NUMARC summary that asks the 18 question of how much dose facilities estimate their spending 19 just in potential responses to hot particle exposures.
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| 20 Let's see if you can see this. This is NUMARC data.
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| 21 At any case, it does range from zero to as much as 22 50 per outaget. The only thirig I wanted to say is to toll E3 you that no nemes were given to the facilities when we got l l
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| 24 this data, but the 50, my guess is the San Onofre. And San 25 Onofre has a hot particle problem. They've had i
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| > l 1 ' contaminations that have resulted in the proliferation of h
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| o 2 hot. particles in the plant. And I would believe that they y '3 .do.have to spend a substantial amount of effort in 4 protecting against potential exposure from those.
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| : 5. The rest of these, I could argue with,' debate
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| '6 with. There is a degree of judgment or arbitrariness.in my
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| 7 estimation-on how much is actually spent, but there's a fine 8 line between good radiation protection practices and a 9 practice that's specifically oriented toward one mode of 10 exposure.
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| 11 In any case, if you did a weighted average of 12 this, it comes out on the order of two person rem a year or 13 so. ' Something on that order.
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| 14 MR. CARROLL: Per year.
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| -15 MR. CONGEL: Yes. And two person rem a year is' 16 pretty much in the noise range when the averages are running 17 3 to 600 a year. But nevertheless, I regard it as a real 18 number.
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| 19' MR. CARROLL: It isn't in the noise range when 20 you've got the workers in the power plant very concerned 21 about the health effects and why am I taking this additional 22 exposure if hot particles aren't really e problem.
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| 23 I mean, you know, whether it's two out of the 400 24 and some odd man rem per year isn't important in their 25 minds. It's the fact that I'm receiving exposure that's
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| 2 MR. CONGEL: Okay.. But--
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| 3 MR. CARROLL: To the individual that does steam 4 generator work, it's important.
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| 5 MR. CONGEL: Okay. The conclusions, I think I've 6- stated a number of times, but our position is that there are 7 some differences in the scientific data that we'd like to 8 see a stronger resolution of. We recognize the 9 conservativeness of the 50 rad limit. But it does give a 10 relief factor of about 3 to 7, as I showed in one of my 11 earlier slides.
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| 12 .When we do look retrospectively at the experiences 13 to date, five of the seven would not have been violations 14 using this Interim Standard.
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| {'}
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| 15 If we used the 75 microcurie hours proposed, only 16 four of the same seven and our position, in spite of my
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| !.7 desire for last November to have it in place, I still think 18 we should implement it as socn as possible.
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| 19 MR. CARROLL: Well, let me ask a question in that 20 regard. Would you feel better in terms of being able to 21 defend what you are doing if you Interim Standard was 22 delayed and based on the, quote, " final" NCRP report, 23 delayed it three or four months, whatever it's going to be?
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| 24 And I'm not necessarily saying you should use whatever 25 number they come up with, say, it's 75. You might want to
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| x/ 1 put in some factor of safety, as you call it, on that. But l l
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| 2 would you feel better having that as a basis than the basis {
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| 3 rou are presently using?
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| I 4 MR. CONGEL: My personal opinion is that the l 5 standard as we propose it should be implemented right away.
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| 6 That settlement of the technical issues, and what I mean as 7 a true settlement, should be reserved for the rulemaking.
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| 8 It's more appropriate there.
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| 9 And I think it may take more than the next three 10 months to come up with something that I would have to defend 11 in various forms.
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| 12 I think that what we have is ready to g:..
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| 13 MR. CARROLL: Yeah, but the industry I guess, and 14 they'll be telling us this in a minute, doesn't think it
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| .( } ~
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| 15 gives them enough relief. And I don't know--
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| 16 MR. CONGEL: I understand that.
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| 17 MR. CARROLL: --what their answer to the same 18 question is, but it could be that we' d rather wait three 19 months and have more relief. Is that acceptable to you? Do 20 you feel more comfortable with that?
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| 21 MR. CONGEL: I want to point out something. I'm 22 not here to really give the industry relief. My scientific 23 group is here to give the best estimate in a short period of 24 time for an interim measure that we would feel comfortable 25 still protects the workers' health and safety.
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| 60 l
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| A/ 1 And I don't see, quite honestly, where three 2 months is going to make any difference in a final resolution 4 3 of the data.
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| 4 Just the issue of the particle being away from the 5 skin I don't think is going to be resolved in three months.
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| 6 Even if the NCRP report became final tomorrow.
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| 7 MR. CARROLL: Okay. All right. We're running 8 short on time.
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| 9 DR. KERR: Let me just ask one more question.
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| 10 Back to the possible issuance of a citation. Is that 11 language due to the fact that you don't want--that you are 12 afraid you'll run into some sort of legal hassle if you 13 don't put in "possible"? It still puzzles me that you are 14 unwilling to make that specific. So that a licensee will
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| {}
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| 15 know what the rule is. Or what the situation is, I should 16 say.
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| 17 MR. CONGEL: From what I've heard this morning, 18 I'll take another look at that cause. I certainly don't 1
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| 19 want to leave that as sort of a sword hanging over their 20 head that can be released at any moment.
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| 21 DR. KERR: Okay.
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| 22 MR. CONGEL: If that's the way it came across, and 23 clearly it did, I will relook at those words.
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| 24 DR. KERR: Thank you.
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| 25 MR. CARROLL: Tom, do you want to proceed?
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| 1 1 MR. TIPTON: Mr. Carroll, in the interest of time,-
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| 2.- since we are. running a little late and we have two j
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| .3- presenters here, what I'd like to do. I'm Tom Tipton, 4 Director.of.the NUMARC Operations Management and Support i-5 Services Division.
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| 6- We appreciate the opportunity to discuss with the 7 full Committee our position on the staff's draft interim 8 guidance on hot particles.
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| 9 With me today is Lynne Fairabin, passing out the 10 chronology that I will not go.through unless you have some -
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| 11 questions. Lynne is our NUMARC Project Manager on the 12 issue. Also with me is Mike Williams, Manager of Nuclear 13 Services, and Principal-Health Physicist for Union Electric.
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| 14 And also Chairman of the EEI Task Force on Skin
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| 15 Contamination.
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| '16 Pat Robinson is with me. She's Manager of the
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| 17 Low-Level Waste Programs within EPRI, and will be giving a-18 presentation.
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| 19 What I would like to do is, like I say, in the 20 interest of time, I had some thoughts, but I'd like to 21 reserve that until I conclude, if you don't mind, and go 22 right in with Pat talking about the studies that EPRI has 23 been performing.
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| .24 MS.~ ROBINSON: Good morning, gentlemen.
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| 25 My name is Pat Robinson. I do work for the I
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| r 62 f-1 l - t\ )s . 'l Electric Power Research Institute.
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| I am' responsible for, 2 managing the research area of Low-Level Waste and Radiation
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| [ 3 Protection Technology.
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| 4 Since we are short on time, I am going to'run 5 through an already abbreviated presentation over what'your L -6 Subcommittee has heard to even a further abbreviated 7 presentation. So we might make the more important salient 8 points here'without belaboring a lot on theory.
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| : 9. I do want to just fill the framework for you'a 10 little bit about where we are on hot particles. You have 11- heard some introductory words this morning that we really
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| .12 :are dealing with two types of particles. One Cobalt 60 or 13 activation product particles, fragment, particles from The other of fuel fragments which are released'
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| () 14' ~ stellite.
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| 15 from defects in the fuel.
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| 16 Several important points for you to keep in your 17 mind as I work through the discussion. Of all the particles 18 that we found in our industry, and before we started 19 ' detecting these, we probably would have just called them 20 ' general area contamination, because they in essence you 21 could think of general area contamination on a very 22 microscopic level as actually being the sum total of a lot 23 of very small discrete radioactive particles, which is the 24 nomenclature that we use. You'll hear hot particles and 25 fuel fleas, and so forth.
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| r I
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| (_) 1 But these are extremely small particles. They are l
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| 2 not visible to the eye. The average size--or the majority 3 of the size that we found have been less than 100 microns, 4 so they are indeed small.
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| 5 The other important part that was briefly touched 6 on is that over 90 percent of the skin dose, and remember, 7 we are concerned about skin effects in this radiation i
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| 8 protection area, come from just the beta rays, 9 EPRI completed a survey to attempt to get some 10 definition around the occurrence of hot particles. We 11 surveyed sixty-one stations. I'm sorry you can't quite read l 12 the green shade here, but the overall survey showed that we 13 had about an occurrence of seventy plants of the sixty-one
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| (] 14 reported hot particles, and of those stations, 48 percent U
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| 15 reported 60 particles.
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| 16 And I'm going to draw for you a distinguishing 17 difference between Cobalt 60 and fuel particles. Because 18 they do have different endpoint beta energies, which is j 19 important when we get down to really talking about the l l
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| I 20 possible effects that could arise from these small hot 21 particle exposures on the skin.
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| 22 And the other point I want to drive home with this 23 slide is that PWRs are the only stations that we have 24 identified fuel particles in. BWRs have reported no fuel 25 particles.
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| ' 1 DR. LEWIS: I don't want to!stop you while you are I'
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| 2 rolling, because you are, but-the Interim Standard defines 3 hot particle--it says means a discrete radioactive fragment.
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| 4 I'm not quite sure what that means. But both of the types 5 that-you are describing would fit within that definition,~ or 6 is there a disagreement between you and the staff on this?
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| 7 MS. ROBINSON: Well, I'm not really sure what the 8 staff means by a fragment.
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| 9 DR. LEWIS: Good. We're in the same boat. Go on.
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| 10- MS. ROBINSON: So if you really want to know, we 11 can try again with them.
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| 12 The overall objective of what we are looking for 13 and what we always seek to do in our radiation protection at 14 our nuclear power plants is really to balance risk, and we
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| .15 know what risk or we know about the ballpark of the risk 16 that we're in when we talk about whole body exposure.
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| 17 And now we're dealing for the first time in our 18 radiological protection history an effect that is not based 19 on cancer induction. I'm going to touch on just the 20 stochastic word, even though we slightly misuse it a.little 21 bit here.
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| 22 But as all good radiation protectionists in our 23 industry believe, we don't consider ulceration to be an 24 acceptable effect for radiation workers. And, in fact, we 25 do consider ulceration to be the endpoint or the effective Heritage Reporting Corporation (202) 628-4888
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| 65
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| 1 imp'ortance in this case since it's not.a cancer-based L' 2 effect..
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| . 3 I'm putting this slide up for you as a little bit' j ..
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| 4 of a teaser. I want'to go through the impact cf having hot 5 particles and the response that the industry has had in-6 implementing controls, and what they've resulted in.
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| 7 I believe the NRC's mentioned that it has ;
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| 8 increased whale-body exposure. I consider increase in 9 whole-body exposure to be significant even if it averages 10 out to be on the order of 2 rem per year. i 11 Significant less in worker productivity. We'll 12 come back to all these issues. In' fact, if you don't ;
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| 13 understand every-one of these points that I have up on the
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| / 14 board by the time Mike Williams from Union Electri'c 15 concludes his presentation, please remember this slide and.
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| 16 come back to it so we can. answer your questions.
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| 17 We have had an increase in feet stress incidents, i 18 We have incurred an increase in manpower requirements. And 19 currently as the NRC has presented and' structured their q 20 Interim Standard, their interim guidance, on this issue, i 21 there is a further threat to adversely affect the quality 22 and assurance of maintenance work and to further remove i 1
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| 23 workers from our work force. ,
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| 1 24 That's the teaser. Now you have to pay attention j i
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| 25 to see if I can pull it altogether for you. l
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| i L .. .
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| -66 L .1 A little bit on hot' particles. We'do know
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| '2 actually quite a' bit about hot particles. We can assess.the_
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| .3' risk to workers. And we have a fair amount of research data
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| '4- that' supports this effect. The effects that we can measure.
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| 5 The research data largely comes from work on animals. And 6 EPRI is continuing to extend out knowledge on the effects of.
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| 7 hot particles by doing experimental work on pigs.
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| 8 There is some human data also'in the database.
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| 9 NCRP I know has reviewed all available literature that we 10 found to be of importance. As I have had my researcher 11 responsible'for this area, Dr. Reece, perform'the same kind 12 of literature search and analysis.over cvailable research-
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| ,13 information.
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| 14 MR. CATTON: Did anything come up in a foreign'
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| 15 country?
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| 16 MS. ROBINSON: Yes. There are several things that 17 I think that have been mentioned, largely by Hopewell in the 18 UK that have been done. There are other things that have 19 actually been done in the United States very early on in i 20 some of the work that was done up in Hanford.
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| 21 Just a few words on the difference between 22 stochastic and non-stochastic as we are using it here.
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| 23 Classically in radiation protection regulations, we've 24 always been regulated on the stochastic response. That is, 25 the probabilistic endpoint of cancer induction.
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| k/ 1 In this case, with discrete radioactive particles, 2 I think there is not any controversy in the scientific 3 community that the potential for cancer induction of these 4 very small particles is so small that it is in fact 5 negligible.
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| 6 Our threshold response and the effect that we're 7 concerned about is ulceration, and this effect can be 8 predicted based on several parameters of dose radiation 9 field fractionation and so forth, and I'll explain a little 10 further.
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| 11 So for skin exposures, particularly for non-12 uniform skin exposures, the non-stochastic effects are the 13 ones that we are concerned with.
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| 14 DR. LEWIS: I want to put on the record that I
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| (
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| 15 have no problem whatever with those definitions. You've got 16 it right.
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| 17 MS. ROBINSON: Thank you.
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| 18 Notice I left out the part about the time 19 dependency.
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| 20 Stochastic risk--I suppose this is a little--I'm 21 in a little bit of a repetition. In fact, I did say it.
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| 22 The important part off of this slide was that the risk from 23 skin cancer is very low and I think the bottom adds the 24 point that it's so low that there are essentially no good l 25 measurable data on humans.
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| 68 l' So now'a little bit on'with our effective concern' 2- here which is non-stochastic response. The non-stochastic t'
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| 3 response is dependent on these variables. The dose, the 4 size of the irradiation field, the beta energy, the depth of 5 the critical tissue that we are concerned about, and
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| ; 6 fractionation of that dose.
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| 7 DR. REMICK: Could you explain fractionation of ,
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| L 8 the dose? I'm not sure I understand.
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| 9 MS. ROBINSON: There's acute. exposures that you.
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| 10 can get'all at once, or'you could take that'same dose and 11 deliver it over a time frame..
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| 12 DR. REMICK: Okay.
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| 13 MS. ROBINSON: So there's a different effect
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| - 14 whether it's acute or distributed over what we call the 15' fractionated' dose time.
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| 16 The skin effects that one might see, the non-17 stochastic part of the response we're concerned about, the 18 very first thing you might see is skin reddening. If you 19 all have been out in the sun, I'm sure you've seen the 20 erythema on yourself.
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| 21 Further, if you've been out in the sun a little
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| .22- too long, you've probably seen the dry desquamation which is ~I 23- the white flaky dry appearance. And if you fell asleep out 24 in the sun, you are in real trouble. Because you may even 25 have put water blisters on yourself.
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| 15 / 1: The'NCRP'has-stated in their' draft report, their 12' draft final position report, that the effect of' concern is 3 . ulceration and they indeed' consider that to be a minor-4' effect.
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| 5 'This"is a little' bit of information I'm going 61 through very. fast.- Please stop me'if I'm too fast. That I 7- . wanted to point out about the size effect of irradiation.
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| L- 8 We have research-information data that shows that for an-
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| .9. irradiation field of.1 sq cm'or above, the dose relationship 10, is a constant--the dose effect relationship'is a constant ,
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| : 11. function.of' dose.
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| 12' For irradiation smaller.than 1 sq cm,.which'is 13 indeed where we are with'.all our DRPs, deliver: tremendous 14- ; doses but little damage.
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| 15 I'll explain'for you very simply what the. biology 16 schematic of the skin here in just'one second..
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| -17 The other important parameter I had on my list was 18 energy. Low energy beta spectra that don't penetrate the 19 bottom of the hair follicle and into the capillary beds"of 20 the dermis, do not produce as much damage as beta rays that 21 do penetrate deeply into the skin.
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| 22 So this is a real general schematic of what the 23 skin looks like. This area up on the top, of course, of 24- your skin are all dead cells. They move up or are 25 regenerated from the bottom to the top. Down in this area
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| 'O aeritae- a vereine correlation (202) 628-4888
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| 70 71 we have the capillary bed and here is what we call.the basal l 2 layer. This is about 70 microns in depth. And'this
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| -3 capillary bed can go as deep as 1500 micro:is or so.
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| l 4 We took the research information that we had from 5 Hopewell who uas looking at ulceration and several other 6 endpoints, which, by the way, the discrepancy that people 7 refer to between the Forbes/Mikhail data and'the Hopewell 8 data, according to Dr. Reece, is really a misinterpretation 9 of the endpoint that the two researchers use. And in fact, 10 when you correct for the endpoint, there's not the factor of - ;
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| 11 5' difference.
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| 12 These are reconstructed dose profiles of the 13 Hopewell work. And what I really want to show here is for i
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| 14 you to get.a sense of the depth of the penetration of beta
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| 15 rays and in this case 90 beta rays. This little black mark 16 up here is essentially the 1 mm diameter source that was i i
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| 17 modeled to reconstruct this dose profile. It's a little bit j 18 elongated here.
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| 19 Really this in reality would be a sphere. It q 20 would be, you know, equally irradiating from the source in l 21 the different directions.
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| 22 This 20 line, by the way, is in gray. For those 23 of you, like me, who have problems with gray, you multiply 24 by 100 to get rad. So this is the 2,000 rad area.
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| 25 And in the Hopewell data, everything in this area 1
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| - 1 here would be. dead cells. And this delivers a 27,000 or so 2f rad exposure at the surface.
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| 3 Now, if you remember my brief schematic'of a 4 -biology slide that the top layer of cells above the basal 5 areas is on the order of 70 micron, so.it's kind of in this 6 area. This.is penetrating deep into the' capillary beds, and 7 in fact, you can get ulceration by penetrating deep into the '
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| 8 capillary beds. But it is a function of size and dose.
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| 9 So I've shown you the Strontium 90 and now I'd 10 like for you to take a look at what the Cobalt 60 looks 11 like.
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| 12 The Cobalt 60 is a very low energy beta compared I 13 to Strontium 90. It therefore does not have the' depth 14 . penetrating power, so to speak, to really do significant
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| )
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| 15 damage in the skin to where you would get ulceration. And 16 as you can see, here's the 2,000 rad line is very, very 17 shallow in penetration to the depth of the skin.
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| 18 We worked on these dose--
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| '19 DR. KERR: What is the peak beta energy? Is it 20 300 KEV?
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| 21' MS. ROBINSON: Here are the energies of the 22 sources that we looked at. So the Cobalt 60 is--
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| 23 DR. KERR: 300 KEV.
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| 24 MS. ROBINSON: Yes. 300 KEV or so. And 2.2 MEV f 25 for the Strontium 90. Quite a bit of difference in the 8 Heritage Reporting Corporation l (202) 628-4888 1
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| (/ 1 energies of the two. l 2 Because ulceration is the effect of concern here l
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| 3 and because of the past research work that has been done has 4 not accurately characterized the type of particles that we 5 have in the industry, in either size or beta energy, and 6 there were considerable problems that researchers have had j 7 in trying to unravel the dosimetry question, nobody was 8 really terrible confident in how much dose was actually laid 9 down as an example in the Hopewell study.
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| 10 EPRI has undertaken a research effort to do one 11 thing and that is determine the ulceration threshold for 12 DRPs characteristic of our industry.
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| 13 And then by doing that we are going to study or 14 are studying the non-stochastic skin effects from the energy f-)N, 15 in the beta and the skin of the irradiated area.
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| 16 I only just flashed this slide for you once again 17 because it really does more or less define for you the study 18 that we are conducting. We are using pigs for this study, 19 which is the animal of preference for skin effects.
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| 20 And we have chosen a variety of sizes. But all of 21 our sizes are more in the range of where we need to be. In 22 fact, they are quite large. They are a thousand times 23 larger of what we really see.
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| 24 But there is some practical difficulty in trying 25 to deal with a 100 micron source or less. In fact, the
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| e_ I t^- 73 1 rwe i lssh ~ 1) ! difficulty is really manufacturing the source accurately; 2 enough that you can be confident of geometry in quantities 1 o l 3 .and so'forth. -
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| 1 1
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| i 4- We are using--I want to just mention--we have two l 5: low-energy betas. The calcium 45 and the Cobalt 60. And we
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| (: have the mid to high energy betas with the Strontium 90 4 7 cerium isotopes which are what you'll find in.the fuel 8 primarily.
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| 9 The reason we picked Calcium 45-instead of just 10 working with Cobalt 60 is that it's within 20 percent'of the 1:L energy of each other, but there's no strong gamma component-12 to Calcium 45 which makes my researchers'very happy because 13 they. don't have to pick up very much gamma exposure by
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| .14 dealing with Calcium 45. And they can lay down huge doses, 15 beta doses, in the skin without isotope.
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| 16= As I mentioned pig skin is the animal of choice 17 largely because it roughly matches our skin in both depths 18 and structure.
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| 19 How am I doing on time here?
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| i 20 MR. CARROLL: Charging. '
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| 21 MS. ROBINSON: Charging. Okay.
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| 22 I just want to kind of flash this up. It probably 23 doesn't mean too much. Doesn't mean a lot to me. But what 24 it does mean to me is that the research Jollars that I'm j 25 spending, and by the way, this is the most expensive hunk of Heritage Reporting Corporation (202) 628-4888 i
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| 74 1 pork ~I've ever purchased. In fact, I have a $600 a month 2 hotel bill from housing six pigs.
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| 3- I wanted to make sure we did things right. And.
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| 4 when we went back and looked at everybody else's past 5 ~ research protocol and so forti it was clear that Hopewell 6 is an excellent biologist but hs*s not a great health 7 physicist and his dosimetry was questionable.
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| 8 So we are spending a good deal of money on the 9 source characterization by using several methods of which we 10 are in fact using the VARSKIN model which is an NRC-11 developed codenas a predictive model to our test.
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| 12 Well, besides the fact that pork is really 13 expensive for me these days, just to give you an idea of 14' what this experiment might look like in reality, we do take
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| .15 ' sources and irradiate the flank ef the pig.
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| 16 And this is kind of a rough layout for you. We 17 had fifty-three irradiations all of different doses randomly 18 placed on the pigs and there were three pigs we were using 19 for the first phrase study. Multiple sources, of course, of 20 each to get some semblance of a statistical analysis.
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| 21 These irradiations are underway. And now what I i 22 want to do for you is just talk to you a little bit about 23 how much dose did we in fact lay down. l 24 Well, you have to talk in real big numbers because 25 one instruction that I gave to Bechtel Northwest as a l O Werie 9e aegerei e cereer tie-(202) 628-4888 i
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| 75 1 researcher was that I wanted to identify and be sure that we 2 found the ulceration threshold.
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| 3 So Dr. Reece has been working very'hard under 4 that. And in doing that we are doing the first phase 5 studies which are the larger particle size, and we started 6 with the larger to work smaller on the basis that if you 7 don't get ulceration from the large particle sizes, you are 8 certainly not going to get them from the small particle 9 sizes.
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| i 10 And the reason is which, by the way, was one 11 important point that I forgot and that is when you irradiate 12 a small area of the skin and you kill the cells directly 13 under or within the reasonable perimeter of that source, the
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| /"% 14 cells regenerate from the outside and from the bottom so you
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| 15 can pick a small enough source and in the case of Cobalt 60 16 where we don't believe you can get ulceration period. And 17 hence, it's important to recall that my efforts to 18 distinguish Cobalt 60 as a low energy beta emitter from the 19 mid to high energy beta emitter is important, when we think 20 about what we really need to regulate here.
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| 21 So these are some of the doses that we are laying 22 down expressed in terms that the NRC can relate with and 23 what the NCRP can relate with.
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| 24 But you see that we are in the 21,000 or so rad 25 level for the Cerium 144 sources or 3200 microcurie hours.
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| l 76 1 We do expect we will get ulcerations ultimately.
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| 2 DR. LEWIS: Have you gotten them yet?
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| '3 MS. ROBINSON: We have not-got ulceration. We
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| '4 have gotten some intermediate affects. You know, the' air ]
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| 5' semen, I think there has even been some wet disclamation, i
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| 6 There have been some very transient responses that weren't
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| : 7. noted before but they only lasted a day or two.
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| 8 And again, the mid to high energy beta you see-9 that for the strontium 90. These large sources that we'are 10 laying down, what really are tremendous skin doses.
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| 11 Now to the low energy betas, the' reason I use 12 calcium 45 is because I could lay down 64,000 RAD. Now I
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| .13 never really filled in the gap for you in my brief ,
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| 14 presentation to explain to you, that for low energy beta, we i
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| 15' 'only expect a first phase response and'that first phase 16 response will occur within the first 5 weeks after 17 irradiation. With those deeply penetrating mid to high 18 onergy beta, you can get a second phase response. In other 19 words, you can see an affect that may be reddening or it may c
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| 20 be dry disclamation and then it heals up and it goes along i
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| L. 21 and then all the sudden you may open up an ulcer and it's i
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| 22 because of the destruction of the capillary beds at a very ,
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| 23 deep level.
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| 24 But this is not the case that you get with very l
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| 25 low energy betas because they do not penetrate deeply into l
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| b b 77
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| -Q 1 the capillary beds.
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| 2' I am going to tell you what the results are here 3 in a minute as soon as I flash all this technical data.at 4 you.
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| 5 The Cobalt 60 radiations, I want.to slow-down for 6 just a minute and make sure we all grasp the amount of 7- exposure'that we have delivered.here. This is on the order 8 of 12 to 18,000 RAD. Recall that the NCRP was, you know, 9 really derived. There were 75 micro curies hours, I~
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| 10 believe, off of an exposure of 2000 RAD as conservative as 11 it is. And that brought them to the 75 micro curie hours.
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| 12 So you see that even the 75 micro curie hours is 13 extremely conservative and how would you say that she can 14 support that statement. Well, she can support that
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| ' (")
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| %) .
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| 15 statement because there are not now 28 days after this 16 research effort, we are now into the 5th week and we have no-
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| -l 17 ulceration, absolutely no ulceration from Cobalt 60 or 18 Calcium 45 particles 19 We had seen--on the cerium strontium 90, on some 20 of the very high end, large particle doses, we have seen dry 21 disclamation. In other words, it had gotten red and it j
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| '22 looked like a sun burn, you started to peel a little bit.
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| 1 23 But the cerium 144 and the strontium 90 research !
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| 24 results, we still have to follow the full 16 weeks to make 4 25 sure we see any second phase response, should there be any.
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| 7-6 e3 :
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| s78
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| '1;
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| .But.the important thing-is, thatias time goes on,-
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| 2: I grow more and.more confident that we cannot get 3- . ulcerations from the cobalt 60. particles of the size.
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| J4 - characteristic to our. industry.
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| 5 WhatLdoes that mean? Well, what it really means 6- is that',.in reality, at some point in time, I'm not sure 7 where it isL in time, that1we should think about some sort
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| :8 of exemption or some much higher, level for cobalt 60 so 9 that cobalt?60 is not--that we are'not sending real whole 10' bodyfexposure for an,effect-that we can't even get, i.e.
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| 11: ulceration.in this case.
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| 12 MR. .. CARROLL: In fact,- NCRP alluded to this:same-13 point in.their report, right?
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| ' J14 MS, ROBINSON: Yes, I believe they did.
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| 15 'Another interesting point is that we spoke to 16 Hopewell last' week and discussed our preliminary results and
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| : 17. he told.my researcher that they are now considering an 18- exemption 'in.the UK for low energy beta, as far-as 19 exempting from any regulatory control.
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| 20 I borrowed this slide from the NRC which they 21 - showed a couple of weeks ago which was the DRP exposure that L -22 had exceeded regulatory limits and had put up really 23 information on their NRC enforcement discretion.
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| :24 But I have a more important column in my mind 25 here and that is the type of DRP that all these exposures Heritage Reporting Corporation
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| 1 i
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| 79 l l' were. All these exposures, with the one exception of San 1
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| 2 Onofre, in' yellow, were activation Cobalt 60 type exposure.
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| 3 MR..SHEWMON: None of these exposures, even 4 including the assumption of the fuel, could you get 5 ulcerations from, nor has that been our observable affect.
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| 6' But now let me just point out San Onofre for a 7 little bit. San Onofre was kind of a mystery in this case 8 because it was on a finger ring of a badge radiation worker 9 and it was not discovered until that ring was sent off to 10 the laboratory for quantification of whatever that dose was 11- on the finger ring. It was reportedly on that ring, 12 however, Southern Cal Edison tells me that they were 13 unsuccessful at recovering the ring and so because o. *. hat, 14 they didn't have the opportunity to' characterize that
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| 15 particle to make the distinguishing characterization on what 16 it fuel or was it activation. So their worst case 17 assumption was that it was fuel, although this is not a 18 verified case.
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| 19 The point here is that there has been a lot of or 20 there has been the NRC enforcement discretion and you can 21 see they could have imposed much higher severity levels with 22 current regulations. But in all of these cases, there is 23 not any threat of ulceration with the one exception of San 24 Onofre.
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| 25 And this--
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| \ 1 DR. LEWIS: Is that one possible exception or one 2 real exception?
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| 3 MS.-ROBINSON: One'possible.
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| 4 DR. LEWIS: Okay.
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| 5 MS. ROBINSON: One worst case, if all things.
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| 6 happen. You couldn't get ulceration at that does level even 7 in the worse case calculation, but clearly.with CobaltL60, I
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| '8 am much more-confident in stating that, you know, you can't 9 -get ulcerations from Cobalt 60 in these small particles, as 10 supported by the-research results that we have to date.
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| 11 So~75 micro curie hours is extremely conservative
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| -12 for Cobalt 60. But as an interim guidance, I think that.it 13 is a good number if we're not going to distinguish between
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| : 14. exposures from fuel particles or Cobalt 60 particles.
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| 15 In the future, I think.it is critically important-16 that current'research results be factored into any final 17 rulemaking. Perhaps even if there is any delay in issuance 18 in the interim' guidance, that consideration of the recent 19 research results be included.
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| 20 I would conclude my presentation here and open it 21 up to whatever questions that you have by saying that EPRI 22 is in the process right now of establishing a research 23- workshop that will be conducted up at Hanford in the mid 12-4 June time frame, in which case, we have invited, in fact, 25 are paying the ticket for Hopewell, Charles and Wells who
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| 81
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| ' fM .
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| l (_/ 1 are the three' key researchers in the United Kingdom, to 2 . participate;in this workshop. At this point, I would like 3 to extend the invitation to the ACRS that they also 4 participate, if that be their interest and I encourage-Mr.
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| .5- . Carroll to pass that word on to the subcommittee to your 6 consultants or he himself. I also extend the same invitation 7 to the NRC.
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| 8 The focus.of this workshop is really to present,
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| 'fL formally,.the research'results on the first phase test for 10 Cobalt 60. Additionally I.would like to use it as an-11 opportunity to. resolve any open technical questions that
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| : 12. have come up in the areas of uncertainties around past 13 research work and further, I would.like to use that 14 expertise of that group to really provide input into what li ' 15 the second phase research work would look like so that once
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| -16 and for all we can use science to put an issue to. bed and
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| -- 17 get back to-focusing our. resources on the more important 18 part of what I think radiation protection is and that is-19 protection against whole body exposure.
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| 20 Now, we can take questions now Tom or we can wait 21 until Mike finishes.
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| 2
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| .2 MR. TIPTON: What I would suggest is, if the j 23 committee wouldn't mind, if we could go through Mike's very 24 quickly and then answer questions. He may have answers to 25- some of your questions you have right now.
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| 1 l 82 .l t'n
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| (/ 1 So if I could ask Mike to come up and show us his I l
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| l 2 St. Louis speed. Mike was one of our key reviewers on the f i
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| 3 NCRP draft recommendations, provided detailed comments. He 1 4 will present to you, first of all, some of the conservatism 5 that we have found within the NCRP recommendation of 75 6 micro curie hours and then he will explain some of the 7 activities that actually occur at the plant that are 8 causing us some of the expenditure of man rem that we have 9 talking about.
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| 10 DR. REMICK: Do you know, Mr. Tipton, how long his 11 presentation will be?
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| 12 MR. TIPTON: We were running about 15 minutes.
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| 13 Can you cut that down, Mike, do you think to about 15
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| (')
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| U 14 minutes?
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| 15 MR. WILLIAMS: It will be tight but we will go as 16 fast as we can.
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| 17 MR. TIPTON: Mr. Chairman, about 15 minutes.
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| 18 DR. REMICK: All right. Hopefully shorter, if you 19 can make it.
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| 20 MR. WILLIAMS: I appreciate the opportunity to 21 address you today on this issue and what I would like to do 22 is basically cover 4 major areas. First of all, I would 23 like to briefly go over some technical considerations with 24 regard to NCRs recommendation, as well as NRCs proposed 25 interim guidance. I would also like to cover how, from an A,
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| t 83
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| ,O k-) 1- industry point of. view, we would implement those 2 recommendations and what would be the impacts, 3 programmatically and as far as the ALARA goes. I would like
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| '4 to point out a few things to you with regard to regulatory 5 enforcement issues and then give your our recommendations.
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| 6 First of all, in referencing what I am going to' 17 say about the NCRP recommendations, I would like to say that 8 I have talked to Tom Giselle who was Chairman of the NCRP 9 subcommittee. Talked to him just before the-subcommittee 10 meeting a couple of weeks ago and Tom said, basically the 11 same thing that Mr. Beckner said this morning, that is, the 12 biological end point of concern is ulceration, it's 13 stochastic or cancer affects, it's only ulceration of the 14 skin and it's such a small ulceration that they felt that
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| (}
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| 15 was an extremely conservative biological end point in and of 16 itself.
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| 17 The other thing I would like to point out is that 18 while the note is in the NCRP recommendations, that there is 19 no arbitrary safety factor applied to their recommendation.
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| 20 It does not say that there were not conservative assumptions 21 in developing those recommendations and,indeed, there are 22 and that is what we would like to point out to you this 23 morning.
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| l 24 One of the first of those conservative assumptions 25 is the source size versus threshold and in NCRPs l () Heritage Reporting Corporation (202) 628-4888
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| 84 1 recommendations,'they stated it for a source size of one 2 millimeter in diameter, the threshold would, indeed, be 3 somewhere-between 7,500 to 11,000 RAD. We also know that 4 radio therapy, which is a uniformed radiation exposure to 5 very large areas of the skin produces ulcerations at about 6 2,000 RAD so when you look in terms of a hot particle in a 7 very .small area of skin irradiated, the fact that the 8 exposure is highly non uniform, then it seems obvious that, 9 indeed ulceration end point must be much higher--the 10 threshold must be much higher than it is for radio therapy.
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| 11 NCRP included a figure of 5 in their report. This 12 is the figure and it is put on paper that is lined so that 13 you can see it easily.
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| 14 I would like to point out that the recommendation
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| 15 of NCRP is based on a one millimeter. particle size and, 16 again, here is the point. 7,500 to 11,00 RAD'is the 17 threshold for ulceration. Indeed the 2,000 RAD threshold 18 occurs for an 11 millimeter size particle, so there is an 19 ' extremely large amount of conservatism in backing the 20 particle size off, but yet applying the same threshold size 21 to an 11 millimeter size particle. And, indeed, you can see 22 that 2,000 RAD continues--this is a-best fit curve, but 23 actually 2,000 RAD continues to be the threshold even out 24 for particles as large as 80 millimeter in size.
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| 25 The other area of conservatism I would like to
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| I 85 l''
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| 1 address is what NCRP covered in their report as a critical l 2 radius. Basically what they did is define the critical 3 radius and I will refer you to the next page in your handout j 4 as being the maximum distance in which cells can migrate in 1
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| 5 from the peripheral area of he basil layer of the skin of I
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| 6 the skin and thus fill in the void of the cells that have '
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| 7 been killed and prevent ulceration and they defined that 8 radius as being 1.8 rail 11 meters and I am quoting from the 9 NCRP report. They said, "An acute exposure will not produce 10 ulcerations virtually regardless of dose." As long as that 11 does is confined within that radius of 118 millimeters.
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| 12 There is also another researcher named Krebbs who 13 sometime ago said that the threshold at the critical radius 14 should be based on 4 millimeters instead of 1.8 millimeters.
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| }
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| 15 Now, to put this in practical terms, here is how 16 the dose varies with respect to distance from directly under 17 the particle a radial distance out and at a critical radius 18 of 1.8 millimeters for fuel particles that are 75 micro 19 curies hours, which is NCRPs recommendation, you can see 20 that the dose, indeed, is 300 for point source cnd 500 for a 21 disc source, well below the 2,000 threshold of ulceration, 22 so there you have a significant factor ranging from a factor 23 of 4 to a factor of 6 and a half, just due to the fact of 24 the range of the beta particles and the critical radius.
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| 25 Another thing I would like to point out is, again, (em) Heritage Reporting (202) 628-4888 Corporation
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| l --
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| 86 1 this is an isotopic distribution within fuel and it is based 2 on the fact that the isotopes above this line and it's not 3 so important that you read all of these, but that you see I
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| '4 the break point. The isotopes below the break point are 5 those that have a range and this is the range. 'The range is 6 such that it cannot irradiate beyond the critical radius of 7 1.8 millimeters, above the isotopes can.
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| 8 So the conservatism here is, if you will note, it 9 -takes a total.of almost 200 micro curie hours in order to 10 get 75. micro curie hours of isotopes that can irradiate 11 beyond the critical radius.
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| 12 NCRPs recommendation is a total of 75 micro curie 13 ~ hours, so what that means is at least a factor of two and a 14 half to 3, conservatism, because only 38 percent of those-
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| 15 isotopes can indeed, irradiate beyond the critical radius.
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| 16 If Krebbs is right and the critical radius is 4 17 millimeters, then it drops back top 34 percent.
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| 18 And in this slide, it will confirm basically,-what 19 Pat has said and that is for 75 microcurie hours, and this 20 is the dose profile that was run using varskin for cobaJ t 21 60. What you'll see is cobalt 60 cannot get anywhere close 22 to the critical radius of 1.8 millimeters and that is why 23 the researchers are saying it's virtually impossible to get 24 ulceration with cobalt 60.
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| 25 Additional considerations. NCRP defined particle
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| j 87 l 1 size as generally unknown because it's microscopic, but -
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| .2 certainly less than 1 millimeter in size. Also they defined-l 3 it as being a beta hazard not a gamma hazard because they.
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| 4 said' basically the gamma component doesn't contribute much 5 at all. You can read that quote for yourself. ;
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| 6 They recommended a total of 75 micro curie hours.
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| 7 They did not relate that to any specific isotope and what 8 that means is that if a dose is going to vary, for'the 9 different isotopes, and that depends on the particle range 10 as well as other factors. So the 75 micro curie hours can 11- cover a range of doses even as high as 800 to 850 RAD 12 averaged over 1 square centimeter. However, they did not 13 relate it to a dose and they didn't relate it to a specific 14 - volume or area of skin and you can red the quotes there as
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| 15' to what their limits are based on.
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| 16 With respect to stochastic risk, I think that Pat 17 covered it pretty well. Stochastic is cancer induction and 18 these are the risk numbers in the NCRP report and basically 19 if you take 75 micro curie hours, which equates to about 300
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| :20 RAD, then you get a lifetime risk of cancer induction of 3 x 21 10 -6.
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| 22 And basically NCRPs conclusion in their 23 recommendations was that stochastic effects are so small;l 24 and the risk is so small that they should not be considered 25' as the end point of concern, only the ulcerations should be.
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| l 1- 'And.that is basically what this slides says., he 2 effects are of no more consequence..." and this is-a quote, 3 ...than.a small burn or cut." It is based on the; frequency.
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| .4' -and the arer_ exposed and then a key point,.is that the 5 multiple hot particle exposures'to the same' point of.the-6 -skin and are a large number'of. hot particle: exposures to the 7 same individual are. extremely.unlikely. And' based on"this, 8 .they came up with a recommendation of 75 micro curie hours.
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| 9 Also another conservative assumption and this is a-10 ' quote'from the subcommittee meeting a couple of weeks ago, n
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| l 11 it said, "NCRP recommendations assumed a zero or 1 cell.
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| 12 diameter ulceration," and it was their opinion that that 13 was, itself, a conservative approach.
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| 14- MR. CATTON: Why are they concerned with such a
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| 15 minimal amount of exposure 16 MR . WILLIAMSON: Basically NCRP-is-not and I think 17 that is what Mr. Beckner indicated this morning, that they 18 felt that they chose that as the' biological end point but--
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| 19 MR. CATTON: It's nothing.
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| 20 MR. WILLIAMSON: It's nothing. Indeed, that's 21 ' correct. As they say, no more consequence than a small burn 22 or a paper cut.
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| 23 And I quote to you, again from the committee 24- meeting and Mr. Beckner has already indicated several times 25 this morning, that the recommendations are firm. that here 1
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| 89~
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| -(_) 1 is what was said at the previous meeting. There might be 2 minor editorial changes made to the report, as it goes 3 through the publishing process, but the recommendations 4 would not change.
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| 5 Tom Gissell, when I talked to him said the NCRPs 1
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| 6 approach is going to be take their time and to basically do !
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| 7 it right. Their contractual obligation was to produce the 8 recommendation that they came out with within the time 9 period required and now they're going to sit back and 10 incorporate new experimental evidence as well as reviewing 11 additional information and questions and they're going to 12 take their time and Tom wouldn't even hazard a guess as to 13 how long it might take for h is committee to do anything 14 else in this area.
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| f-)
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| %J 15 I would like to turn now to the technical 16 considerations with NRC recommendations. They're 17 recommending 50 RAD average over a 1 square centimeter area 18 at a depth of 7 milligram per square centimeters. The basis 19 for the one square centimeter and the 7 milligram per square 20 centimeter is ISRP 26. We certainly don't have any argument 21 with that or disagree with that.
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| 22 They quote a British journal of radiology as well i 23 as the Society or Journal of Society Radiological Protection 24 of which we have both articles and the article that is .
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| 1 25 quoted in justifying the 50 RAD really says that this 50 RAD
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| 90 r~s q
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| () 1 prevents any microscopically visible non stochastic affects l 2 other than possibly point erythema. 3 1
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| 3 So the 50 RAD is not applied to ulceration, as 4 we're talking about it. It's a completely different 5 biological end point and that's why we believe 50 RAD is 6 extremely conservative.
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| 7 NCRP is talking about one hot particle exposure 8 per incident.per quarter and that exposure is not 9 cumulative. If you had two hot particle exposures, you 10 wouldn't add one to the other and we certainly agree with 11 that.
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| 12 But, we have real problems with the one incident 13 per quarter and I'll address that in just a moment.
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| g3 14 DR. LEWIS: Out of curiosity, how do we 15 distinguish point eryth'ema from ari erythema at a millimeter 16 or something like that?
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| 17 MR. WILLIAMSON: From all that Doctor Reese has 18 presented and what Pat has said, it is extremely difficult 19 to even identify it.
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| 20 DR. LEWIS: I see.
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| 21 MR. WILLIAMSON: Point erythema.
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| 22 DR. LEWIS: So it depends on the sensitivity of 23 the naked eye or--
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| 24 MR. WILLIAMSON: That's right. Based on visual 25 observation.
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| i 91 f 4
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| ,-, I km 1 DR. LEWIS: Gotcha. I understand.
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| 2 MR. WILLIAMSON: The next slide that you have and 3 this is drawn to scale and I drew it up yesterday and I have !
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| 4 to apologize for the second dot. The first dot is the NCRP 5 defined particle size and on your paper, it's the true size 6 even though it does not appear on the screen and that is one 7 millimeter diameter particle. That is the maximum size that 8 would be allowed.
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| 9 The typical size found in industry is 100 microns 10 or less which you couldn't even see as a dot on your paper.
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| 11 That's why you don't see anything there.
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| 12 The second size is the critical radius and you 13 need to correct this. This is 1.8 millimeters in diameter
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| ('} 14 and the 1.8 millimeters is actually the radius so this
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| %)
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| 15 should be twice that size to show the critical radius. It's }
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| 16 actually 3.6 millimeters diameter.
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| 17 But this is the correct size and this is 11 18 millimeters and this is the 11 millimeter size of which that 19 2,000 RAD threshold was based, on the figure that I showed 20 you previously.
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| 21 Also this is approximately, if you look at the l
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| 22 outside diameter and that's the difference there, the 23 thickness of a line width. That represents 1 square 24 centimeter of area. So in your handout you can see what 25 size we're talking about irradiating.
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| 92 e
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| k 1 How do these recommendations compare with one 2 another? This slide shows the dose versus the different 3 recommendations. What we would like to show you, the point 4 .is in green or the left side bar and the right side bar is 5 for a disc source and this is for fuel particles.
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| 6 We would like to show you that the NRC.
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| 7 recommendation of 50 RAD is here. NCRP recommendation'for 8 fuel, this comes out to be 425 RAD, I think is the number 9 and'then if you look at the 2,000 RAD threshold for 10 ulceration, what you can see clearly here is that there is a 11 very significant factor of conservatism. There is a factor l'
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| 12 of 5.3 conservatism between the threshold for ulceration for 13 a large area versus NCRPs recommendation.
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| 14 There is also a factor of 7 and a half difference 15 between NRCs recommendations and NRCPs recommendations. !
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| 16 That is why we feel that NCRPs recommendations are extremely 17- conservative and NRCs recommendations are unreasonably 18 conservative beyond that.
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| 19 Here is the same slide for Cobalt 60. It shows 20 you basically the same thing, a factor of 6 difference 21 between the threshold versus NCRPs recommendations.
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| 22 So to put it in other terms, I converted this to 23 micro curie hours and this showed the same thing. This is 24 fuel particles micro curie hours and it shows the 25 relationship and this is cobalt 60 micro curie hours
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| 93 p)
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| (, 1 relationship. Again you can se a big factor conservatism 2 there relative the threshold for' ulcerations.
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| 3 Going back again, NRCs recommendations, as 4- mentioned already before, it would be interim guidance.for 5 at least two years, possibly longer. That's why it's of 6 great ~ concern to us, as an industry. What we get now, we 7 will have to live with for a good while and so we are very 8 concerned that we get good solid guidance to use.
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| 9 We have concern over'their definition of a 10 fragment. We had not heard that definition until the ACRS 11 Subcommittee and basically some quotes from the transcript-
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| .12 are given here and from reading all of this, we have a real 13 problem, from a practical application in the field of 14 determining what a fragment would be. There is no. clear 15 definition and we don't know how we would do that.
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| 16 With regard to enforcement, the NRC's interim
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| -17 proposal is that if it's greater than 50 RAD and lese than a 18 100 RAD, it would be a level 4 violation.- If it's greater 19 than 2,500, it would be a level 1 and we don't believe 20 that's. reasonable. I'll address this again in just a 21 moment. But there is no guidance either given that we know 22 of as to how that would be placed in the individual's record 23 from a practical point of view, as far as recording that.
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| 24 Now, I would like to get down as to how we 25 implement these. Most important of all, in understanding
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| 'l the implementation is the controls that we'_use in setting.up
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| '2 zones for a worker. What I would like to do is show you is o 3 how we set up our zones.
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| 4 Basically when we have hot particle areas, we rope 5 off and establish a separate boundary and a separate step 6 off pad and we have a buffer zone between the hot. particle 7 area and what is normally a contaminated area. The buffer 8 zone, there are several reasons for that. One is so that'we.
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| 9 can bring an individual out and monitor him and then send
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| , 10 him back in wit yut him having to completely undress and 11 redress again.
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| '1:2 Another reason is that because of the nature of-13 hot particles, they are highly charged and that is how they 14 got the name fleas, they jump _from place to place and you 15 never know where you're actually going to find the. In 16- fact, many hot particle contamination incidents occur within 17 the radiological controlled area outside of contamination 18 areas and they're not directly related~and necessarily found 19 only in contamination areas.
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| 20 So we put a buffer zone there to assure that when 21 we bring workers out and monitor them, that if they do have 22 hot particles, we're also not going to get those spread out 23 into other places in the plant.
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| 24 Some key points are the fact that we increased low 25 level RAD waste tremendously because of the additional !
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| fs): 1 protective clothing that we use. Why do we use that 2 clothing? Typically we use one pair of cloth coveralls and 3 we cover that with tyvec coveralls and the reason is that we 4 don't'have to slide, but if you see a blow up of the weave 5 of the fabric of cloth coveralls and you look the size 6 -
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| particles that we have'actually found, they can go through-7 the cloth and, indeed, lots of them have and in many cases, 8 hot; particle exposures have resulted from contaminated 9 laundry and the fact that it comes back to the worker on the 10 laundry. So'tyvek we use, and it has a very small weave and 11 the particles can't get through. Also Tyvec does not tend 12 to attract the particles because of static charge. So that 13 is why we use an outer set of tyvec.
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| 1' I 14 By using all that, it increases a little RAD 15 waste, but another. thing that increases our low level waste 16 is the fact that a lot of things that we normally would take 17 time to decontaminate when we move from a contaminated area, 18 if we remove from a hot particle area, we just bag it and we 19 throw it away as waste. Because in opening it up and trying 20 to decontaminate it, we' re liable to spread hot particles 21 all over the plant.
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| 22 And also, it results in tremendous loss of 23 productivity and also a tremendous increase in whole body 24 exposure which we will show you in a moment.
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| l 25 MR. CARROLL: But the workers like tyvec clothing
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| (_) 1 because it is so comfortable? 3 2 MR. WILLIAMSON: Right. In fact, I would like to 3 point out the fact, I'm glad you mentioned that. In the 4 last two weeks, we're in a refueling outage in Calloway 5 right now and in the last two weeks, we have had 5 cases of 6 heat exhaustion, all had to be treated by ENTs within the i
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| i 7 plant and one person had to be sent to the local hospital 8 and this was because of increased protective clothing 9 requirements in hot particle areas.
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| 10 There is actually a greater physiological hazard 11 due to the clothing requirements as well as respiratory 12 protection requirements to the workers than there is due to 13 the hot particle exposure itself, even if it resulted in rx 14 ulcerations.
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| Gl Mr. Williams, unless there is an 15 ,
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| DR. REMICK:
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| 16 objection from the members of the committee, I wonder if you 17 could jump to your final conclusions or recommendations.
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| 18 MR. WILLIAMS: Okay. If you don't mind, I would j 19 like to n.ention the fact that based on our recent survey of 20 31 plante and the data in the survey that up had earlier was 21 done in June of ' 88 and this survey was done in the last two 22 weeks, we are expending and arrange from 10 to 50 man rem 23 per year, per reactor for hot particle controls.
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| 24 If we had a limit of 50, which NRC is proposing, 25 the 50 RAD, then we figure that we would haver a whole body i
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| )' 1 savings of somewhere between zero to 10 man rem per year per
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| : 2. reactor, so we agree there would be some benefit to 50, 3 however, with MCRPs recommendation, we would save between 5' 4 top 45 man rem per year per reactor and we think that when !
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| </ 5 you look at the risk related to whole body exposure versus R 6 the risk related to hot body exposure, that you have to, 7 from an ALARA perspective certainly take the greatest 8 exposure benefit.
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| 9 I guess our biggest pitch would be this slide l'
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| 10 here and that is--this is how often we have to monitor based' 11 on the particles we find in the areas in which we have hot 12 particles. We don't base it on it on hot particles on 13 individuals, we base it on the particles that we actually 14 find. For 10 micro curie sized particles, we will have to
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| 15 pull the worker out. This green line is the 50 RAD limit 16 proposed by NRC. We have to pull the worker out, at least 17 every hour and monitor him. With the existing limits of 7 i 18 and a half and 18 and three-quarters, we have to pull the 19 worker out more frequently than an hour and right now, Palo 20 Verde, they are pulling workers who are doing primary 21 coolant pump work every 5 minutes to monitor for hot 22 particles.
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| 23 With the NCRP recommended limit, the worker could 24 work 7 and a half hours maximum, on a practical aspect, 25 because of the clothing a worker normally wears, we don't i
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| 98 i L 'l keep him in zone more than 4 hours anyway,.normally, so we ,
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| 1 L 2: could clearly keep a worker in for his normal work period-3, without ever pulling him out and monitoring him, if we.had 4 the NCRP limit.
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| 5 And'here is the 2,000 RAD limit which shows, this-6 is log scale, that even a 100 micro curies of the 2,000 RAD 7 limit, the 2,000 RAD threshold limit, we could do the same.:
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| 8 I'll skip over those and down to this slide here 9 and that is, do we~actually have particles in those size 10 ranges and.you can see--again this.is a survey of 31 plants.
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| 11 Here.are about 230 particles in'the 10 to 20 micro curie 12 range. This goes on up-to a 100 micro curies. This is one 13 millicurie range. This is one curie and this is greater than: "
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| - 14 a curie so, indeed, we have a lot of particles in that range-15 and so the monitoring frequency is very critical to.us.
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| 16 You increase that frequency and you increase whole 17 body exposure. How many individuals get multiple hot 18 particles on them and this is the key and I guess I would 19 have to.say that if NRC is offering this interim guidance to 20 us, in terms of the 50 RAD coupled with the one exposure per 21 quarter, then we say we would rather have what we have now.
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| 22 If you would give us the 50 RAD alone, we would have to say 23 that is better than what we have now, but if you only allow 24 us one incident per quarter, as someone suggested earlier, 25 once an individual gets one incident and let's say we're O seriease aegerein, (202) 628-4888 cergeration
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| 1- starting a 60 day outage and we have a nuclear certified 2 welder who is costing us a lot of bucks and he gets one j 3 incident. We pull him out for the rest of the outage 4 because we're not going to run the risk of having him have 5 two incidents and these do indeed occur.
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| 6 Per quarter we had an average of.31 plants ranging i
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| 7 from 2 to 15 individuals who get multiple hot particle
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| 8 exposure. Not in excess of the limits and that is why you 9 haven't had them reported to you that they are getting 10 multiple exposure and-annually, these 31 plants range a 11 total of 5 to 77 individuals who had multiple hot particle 12 exposures. So they are occurring.
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| 13 I would like to go to our recommendations. We 14 recommend that we use NCRPs guidance of 75 micro curie 15 hours. We do not believe that a limit should be applied on 16 the number of incidents or the ti' , period allowed for those 17 incidents because NCRP did not apply such a limit. We also 3 18 believe you should allow correction for self absorption, 19 .which NCRP also agreed to and we agree you should allow for 20 particles directly on-the skin and we say that that is very 21- easy to do.
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| 22 In our previous presentation to NRC staff,.we 23 showed them that it is a very simple matter to apply NCRPs 24 recommendation by just means of a relative absorption 25 factor. It's very simple to find out the absorption factor Heritage Reporting Corporation (202) 628-4888
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| [) .1 for'the protective clothing and apply it through the varskin 2 _ code and do the dose calculations which is a perfectly valid 3 way to do'that. So that is not a problem 4 applying the 75 micro curie hours that is not directly on 5: the skin.
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| 6' Also we recommend that if you find it necessary to 7 express it as dose,-then it should be from 300 to 500 RAD L 8 averaged over 1 square centimeter. The 300 RAD is what we 9 calculated as the most. conservative case NRCs' presentation 10' to this ACRS subcommittee last time said they had calculated 11 '500 but at either rate, whichever and of that you choose, 12- you're still going to be.very conservative. About 75 micro 13 curie hours can apply to a wide range of doses up to over 14 800 RAD.
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| 15 And then finally on enforcement, we don't believe 16 that if you exceed 75 micro curie hours that that should be 17 greater than a level 5 violation, just based on, again, the 18 risk to the individual and the total impact and then we do 19 not believe you should ever have greater than a level 3.
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| '20 even if you exceed the threshold dose for ulceration as a
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| - 21 critical radius.
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| 22 And I'll conclude with that and encourage you to 23 review the handouts that you have for the slides that we 24 skipped.
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| 25 MR. TIPTON: Mr. Chairman, we basically have three rh Heritage Reporting Corporation {
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| -1 concerns as Mike alluded to. One isLthat feelf the 75 micro-2 curie hours, although conservative, would be a very good 3- interim guideline until we get the final rule in place.
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| 4 Secondly, we are very concerned about this one 5 particle per employee per quarter because we may think it's 6 not too bad in Washington, but when it gets out in'the 7 field, we'll have to start tightening up what we're'doing in 8 some of these plants. It's a function where you're at on
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| '9 the SALP rating, where you are on other things.
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| 10 The third point is the enforcement and that is the-11 level-of enforcement, the violation rather of 2,500 RAD 12 level 1. I just want to repeat something that was said at 13 subcommittee that.I found was very interesting from Mr.
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| 14 Beckner. Quote, "Even though acute ulceration, in'itself,
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| -15 was considered to be a relatively benign affect, its higher 16 probability of occurrence, as compared to the other 17 potential affects caused the committee to recommend to.the 18 counsel'that acute ulceration:be the affect of concern for 19 radiation protection purpose."
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| 20 And the second was, quote "The affected individual 21 should be aware that the risk of skin cancer from such 22 events is extremely small. Now,.if we are cited, we haven't 23 had a situation where we have 2,500 RAD, but we could have 1
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| L 24 situation like this and the level 1 violation with a fine, l-25 it's very difficult to explain to this individual that it is
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| /'T ft.f 1 relatively benign and the risk is extremely small.
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| 2 With that, I'll conclude.
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| 3 DR. REMAK: Thank you, Mr. Tiptoe. Questions from 4 the committee.
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| 5 MR. SHEWMON: I would like to ask Mike one 6 question, if I could. _I read this phrase from Mel Carter's 7 letter where he distinguished between fragments and whatever 8 the other words was, particles, I guess. When I asked 9 Congel about this, he didn't know what I was talking about 10 or at least couldn't tell me what was concerning Carter.
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| 11 Can you explain what you heard at the subcommittee that 12 caused you concern?
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| 13 MR. WILLIAMS: That is where it came up and 14 basically we heard fragment definitions and there was
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| 15 repeated conversations but we heard fragment definitions are 16 going to be somehow based on the gamma, the beta ratio and 17 that if it is a very high gamma component, then that would 18 somehow call it a fragment.
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| 19 We also heard that, depending on high the activity l
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| l 20 is,. that could be defined as a fragment. We also heard I
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| 21 things such as size would be a fragment.
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| l 22 MR.-SHEWMON: Why am I--is a fragment worse, the 23 different ground rules apply there? Are they supposed to be 24 bigger or what?
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| 25 MR. WILLIAMS: What they said is that if it is a
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| 103 I: 1- fragment then it would'be covered under existing regulations 2 and the generic letter would not apply. That is what they 3' said it is. The' generic letter would only apply to hot 4 particles and if its a fragment then we would live under 5- whole body exposure rules of the 7 and a half 18 and three-6 . quarters.
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| 7 MR. SHEWMON: Did you get.the impression it was
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| .8- the staff's feeling that a fragment was bigger than a
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| '9 particle?'
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| 10 MR. WILLIAMS: I would say they felt it was bigger j
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| : 11. than a particle, at least activity wise and probably
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| .12 physical size wise, but we couldn't come up with a good 13 definition 14 MR. CARROLL: But the one problem is that if you 15 look at their definition and the interim standard, Paul, 16 they define a hot particle as a fragment.
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| 17 DR. LEWIS: As a discreet radioactive fragment, 18 whatever that means.
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| 19 MR. CARROLL: That is what I think was bothering 20 Mel and I think, you know, we ought to give some attention 21 to this.
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| 22 MR. TIPTOE: Mr. Chairman, my Project Manager just 23 punched me in the ribs to remind me that I need to emphasize 24 we do not have the draft generic letter, so we're working 25 from what we heard at subcommittee.
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| , .1' DR. REMAK: Any further questions?
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| '2-
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| ''(No response) 3 > If not, I suggest we take'a 15 minutes break, 4 returning'at-10. minutes past the hour.
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| 5' -(Whereupon-the committee-took a brief. recess.)-
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| 105 yn
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| (./ 1- DR. REMICK: Gentlemen, may we reconvene.
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| 2 The next topic on the agenda is the discussion of 3 Evaluation of Operating Experience by AEOD staff.
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| 4 The Subcommittee Chairman is Hal Lewis.
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| 5 DR. LEWIS: Okay. I will make my contribution to 6 getting us back on schedule by not saying a word except to 7 eay just that you're right. This is a presentation about 8' Operating Experience from the AEOD staff. You got it Jack.
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| 9 MR. ROSENTHAL: Thank you.
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| 10 This is an information meeting and we thought we 11 would just fill you in on what we have been doing recently.
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| 12 I am proud of our AEOD work products. When I look 13 back over the last year, virtually everyone of our reports 14 has resulted in a generic letter or an IN or some industry
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| 15 action so, in that sense, we are doing very well.
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| 16 You' re well aware of the struggles over air 17 systems. Let me just point out that a generic letter did go 18 out. Licensees are looking and are reporting back that 19 they are finding problems and they are fixing the problems 20 and that is surely a measure of closing the loop when it 21 finally gets out to licensees and something happens.
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| 22 Service water, you were briefed on. The last time 23 we were down her^e about 6 months ago and we're in the final 24 stage--NRR is preparing a general letter on Service Water.
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| 25 The last time we were down here, we briefed you on
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| - - _ _ - _ - - - - _ _ _ _ _ _ _ - __ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ ____ ___. A
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| -106 1- the LaSalle event and re-licensees have now changed lthe way l
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| 2 they-run'the plant, in terms of power to flow mapping to 3 avoid those instability regions, so something actually i i'
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| 4 happened. That.was good.
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| .5 MR. MICHELSON: Let me ask you'a question before
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| '6 you get started on this.
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| 7 You have a tracking system that. keeps track of 8 what happens to you, the recommendations that you make and 9 the case studies that you issue.
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| 10 MR. ROSENTHAL: Right.
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| 11 MR. MICHELSON: How far back does that tracking 12 system now go?
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| 13 JMR. ROSENTHAL: Day one.
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| 14 MR. MICHELSON: It starts from the first case 15 study issued?
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| 16 MR.-ROSENTHAL: Right. In the annual report, 17 you'll see tabulated every outstanding recommendation that L 18 came out of a special study or a case study and--
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| 19 MR. MICHELSON: The annual report is the best 20 place to go to see the status of the recommendation?
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| 21 MR. ROSENTHAL: Right. And we have just prepared 22 another one-and it'will be out shortly.
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| 23 MR. MICHELSON: Okay. Thank you.
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| 24 You said you just prepared another one. Is that 25 available to look at?
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| 1 107 'l 1 MR. ROSENTHAL: In a month or-- -
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| 2 MR.'NOVAK: I would hope in the next two weeks l
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| 3- you'll it. We'll make sure you get a copy as soon as it is 1 4 off the press.
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| 5 MR. MICHELSON: Okay. Thank you.
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| 6 MR. ROSENTHAL: Let me just run down what we are 7 doing now and then you will be hearing from Sandy Israel on
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| .8 two classic systems type looks that we do. One from Ted l 9 Cintula, a little bit different. It's a good news story but 10 rather'than--it's more of a passive system and then Chuck 11 Hsu is going to talk about a very different kind of work !
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| I 12 that we do and that is to look at component at some depth.
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| 13 So what is going on now, we have got many things 14 on the books, and I thought I might just touch on these for
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| 15 a minute.
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| 16 As an outgrowth of the air systems study, Hal i 17 Ornstein is going a follow up study, it's a case study, it 18 should be out shortly, on solenoid valve problems. We hit 19 lots of manufactures, lots of systems finding problems.
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| 20 There has been an awful lot of work done on a 21 Station Blackout, diesels, A-44, et cetera and we thought we 22 go back and take one more look and simply, at common mode 23 failures of the diesel system itself, not the reliability.
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| 24 We will tabulate that and play that off against what we 25 think is going on with the rulemaking--with the rule.
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| ( I 1 We have seen a few fuel oil--lube oil common mode 2= ' problems and we'll.either incorporate that into the first l3 study or break it out.
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| 4 We have seen a number of situations. permitted by 5 the Tech = Specs in which licensees, in shut down modes, are 6 ' permitted to take lots of trains--engineered' safety features 7 out of service because they're in Modes 4, 5 and 6, a'nd they 8 .can put themselves in precarious situations where.just one 9 more fault. puts them in a tizzy and they have far less than 10- the compliment to VSF that they would have in the high loads 11 to cope with that event.
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| 12 Another way of looking at this is to say, what is 13 the prudence of operations in these high modes. There were 14 two reports down by INSAC, which were PRas for b's and p's 15 in high modes which argued that the risk was comparable to 16 at power because so much of the equipment is out of service 17 at the initiator of the event. We're taking another look at 18, that.
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| 19 We've got, maybe aa 100 specific events in that
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| '20 study.
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| 21 MR. WYLIE: Are you approaching that from a 22 probabilistic standpoint when the core melts?
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| : 23. MR. ROSENTHAL: We're compelled to attempt to put 24 a risk perspective on our work. We're surely not doing PRA 25 work, per se.
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| .,r)
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| (> 1 I think what we'll attempt to do is balance the 2 operating experience, but it up against those two INSAC 3 PRAs.
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| 4 MR. WYLIE: Does that mean increased risk to core 5 melt by being in these various modes, is that what you end 6 up with is a--
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| 7 MR. ROSENTHAL: Well, you'll end up with an 8 incremental risk, sure, and we ought to somehow address that 9 and be able to relate the safety significance to other,s.
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| 10 And, if we can't do that, we can't get action, so somehow 11 we're compelled to do it. Now he degree that we do that, 12 will vary from study to study.
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| 13 MR. WYLIE: Pretty interesting. Thank you.
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| 14 MR. WARD: To follow up on that a minute. If the 15 risk perspective you take in the higher modes is committed 16 to core melt risk, I mean use that definition of risk, might 17 be missing something important because the containment 18 conditions can also be very different in these modes.
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| 19 MR. ROSENTHAL: Surely--right. and a generic--
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| 20 MR. WARD: It has to go away to--I don't mean a 21 full blown PRA, but look at risk in the Level 2 PRA or Level 22 3 PRA perspective. I mean, are you planning that?
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| 23 MR. ROSENTHAL: AEOD is not planning that. We'll 24 have to work with the rest of the staff on that.
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| 25 MR. WYLIE: Because you're going to look at it in
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| I 110
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| (,f 1 a risk perspective. Do you mean just core melt risk or--
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| 2 MR. ROSENTHAL: In a core melt perspective.
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| 3 Let me point out that earlier AEOD had concerns 4 about loss of decay heat removal and a generic letter went 5 out on that over a year ago and one of the things that was 6 pointed out in that letter, two licensees, was that in those 7 modes the containment was often open and one of the 8 recommendations was to minimize the time of the containment 9 hatches is opening.
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| 10 We're looking at a flooding of safety related 11 systems and not getting too much, but it is an interesting 12 area but it is an interesting area to try and pursue.
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| 13 I'll hit two aspects and one is to look at large 14 ingresses of water where you get forced flooded, a fair b'N 15 amount of water and also a totally different aspect is 16 dripping, where you have something that drips on something 17 else which drips on a cabinet which causes something to 18 happen.
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| 19 With the solenoid study, I'm talking about over 20 500 LERs as a data base for the effort. We're looking, 21 we're not finding that level of data.
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| 22 MR. MICHELSON: Somewhat related to the external 23 event of flooding is the question of the inner system LOCA 24 which represents a potential release outside of containment.
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| 25 MR. ROSENTHAL: Yes.
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| l 111 ~i
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| () 1 MR. MICHELSON: What are you doing on inner system 2 LOCAS?
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| 3- MR. ROSENTHAL: We're doing relatively little.
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| 1 4 Let me get to that in a second. Here I am talking about 5 internal flooding, Carl.
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| 6 MR. MICHELSON: Well internal means within the 7 plant?
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| 8 MR. ROSENTHAL: What?
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| 9- MR. ROSENTHAL: Internal flooding means within the 10 plant, but external to the system.
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| 11 MR. ROSENTHAL: Yes. And internal flooding--it's 12 within the plan and caused by a fault within the plant.
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| 13 MR. MICHELSON: Yes.
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| MR. ROSENTHAL: I'm now looking hurricanes and--
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| O . 14 15 MR. MICHELSON: Precisely.
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| 16 MR. ROSENTHAL: Okay. NOR has a fairly large 17 initiative on Event B and their defining Event B in a broad 18 scope sense to talk about leakage between the primary 19 system and an outside, where the original Event B really is, 20 you have an initiating event which both causes the LOCA and 21 takes out ESF as well. They're looking far more expansively 22 at leaks across the containment boundary.
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| 23 Given that large effort, I am not going to do it, 24- but--
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| 25 MR. MICHELSON: But generally the consequence of
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| 'l an Event B is some kind of release and/or steam which, in 2 turn, starts flooding out equipment.
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| 3~ MR. ROSENTHAL: Yes, i
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| 4 MR. MICHELSON: That's how I understand it and you :
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| 5 said you were doing some flooding of safe related equipment 6 and I was just trying to see whether that, in any way, 7 related to the event.
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| 8 MR. ROSENTHAL: If it is in the data base, yes.
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| 9 MR. MICHELSON: But we haven't had event.B's very-10 much--
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| 11 MR. ROSENTHAL: Right.
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| 12 MR. MICHELSON: --of any consequence so it's not 13 in the data base.
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| ' 14 MR. ROSENTHAL: And we will pay attention to--as I
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| 15 say NRR has got an activity going that way and we will focus 16 on things supported by the operating experience.
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| 17 Electrical bus box failures. We have seen several 18 failures due to poor housekeeping, of major electrical buses 19 and we have got problems with--there is a short report on 20 normal installation.
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| 21 Now a bigger problem is that we have seen several 22 events in which electrical power was available to the site 23 but not to the actual plants. You had yourself--and, in 24 turn, you had demand diesels. So you're giving yourself the 25 problem right in your own switch yard.
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| - - _ - - _ - _ _ _ _ - _ - _ _ - _ _ _ _ _ = _ . _ _ - _ _ - _ - _ _ . _ _ - . - - _ . _-- _ - _ _ _ _ - _ - _ _ _ _ _ -- __-_
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| 113 L ()' l' It's very different from A-44, which considered 1
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| 2 what is the probability of a loss of off site power and 3 then the probability the diesels would work.
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| 4 There'are just any number of events where, because-5- of the switch yard configuration,. breaker' failures,
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| '6 breaker coordination, whatever, they end up in a situation 7 where there is the power at the. site bound'. J, but you can't 8 get it in the building and they seem more probable and so 9 we're starting a study of them.
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| 10 MR. WYLIE: This is restricted then to the switch 11 yard bus bar failures, is that what that is?
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| 12 MR. ROSENTHAL: Yes.
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| 13 MR. WYLIE: Not all bus bar failures?
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| 14 MR. ROSENTHAL: No. This will be the -from the 15 election of start of transformers and what provides the 16 power, down to the 4160 process, 17 MR. WYLIF:. Okay, so you do include the auxiliary 18 system them?
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| 19 MR. ROSENTHAL: Yes.
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| 20 MR. WYLIE: Okay. Like the Oconee failure?
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| 21 MR. ROSENTHAL: Yes.
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| 22 MR. WYLIE: M sy.
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| 23 MR. ROSENTHAL: We h? te a review study on 24 thermostratification. We hu, got it--of there was an 25 earlier work that you are well familiar with, with
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| () Heritage Reporting Corporation (202) 628-4888
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| 114
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| (
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| s . 1 feedwater nozzle' cracking. Recently there have been issues
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| ~
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| 2 on a pressurizer, search line, stresses due to thermal 3 stratification. There is a bulletin that went'out that 4 talked about ingress of cold water to the primary. system, 5 We see leaky check valves could give you a problem with f
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| 6 egress of water from the system ar.1 so we're trying to 7 integrate all of this and stick it together.
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| -8 And then the last, we have published one version 9 and we're about to come'out with a revised version, is a 10 look at LERs that we categorized as maintenance related 11 LERS. Say, what are the problems, a look at an attempt to 12 trend those as a function of time and then a look at case 13 studies and other reports that we have'done, ins and 14' bulletins, SOERs and OMRs and try to get some picture, from 15 that aspect, of what has been reported of maintenance at 16 plants and how it seems to be going.
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| 17 MR. MICHELSON: Since check valve failures seem to 18 be a contributor to thermal stratification as well as the 19 inner face LOCA and so forth--
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| 20 MR. ROSENTHAL: Right.
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| 21 MR MICHELSON: --what are you doing on check 22 valves as opposed to the motor operated valves which I am 23 fairly familiar with what you did there.
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| 24 MR. ROSENTRAL: Well the motor operated valves are 25 progressing although agonizingly slow--
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| () Heritage Reporting Corporation (202) 628-4888
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| 115 r^
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| ( )g 1 MR. MICHELSON: I understand that.
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| 2 MR. ROSENTHAL: I don't have an active study on 3 check valves now. We did do some quick MPRDS type searches 4 on check valves and what you should have seen was an 5 improvement in the reported failure rate of check valves in 6 the last couple of years because there was all this 7 attention paid to them in prior years 8 At least on a preliminary basis , I don't see that !
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| 9 improvement, so it is a ripe study--topic study, but we're 10 not doing it at this minute.
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| 11 MR. MICHELSON: Do you have any underway or intend 12 to have one underway anytime soon?
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| 13 MR. ROSENTHAL: We have discussed it with my 14 management and it looks ripe now. I can't say I have one 15 underway now.
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| 16 MR. MICHELSON: That's an answer but it doesn't 17 help me much.
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| 18 MR. NOVAK: Carl, I think it's a balance. We'll 19 look at what NRR is doing and we'll look at what industry is 20 doing, we'll look at what we can contribute.
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| 21 These case studies , and you know it, it's a 22 commitment, once you make it, you're going to follow through 23 and it's going to take a full year and it's going to take a 24 fraction of your staff. So, if we go ahead, we want to make 25 it clear that we are--
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| () Heritage Reporting Corporation (202) 628-4888 L--___________
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| ; 116 L l' MR. MICHELSON: So right now, you haven't decided 2 what 1you're--
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| 3 HMR. NOVAK: We have not decided yet and we'll get 4 back. You're absolutely right, but it is'a topic that is 5 ripe.
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| 6 DR. KERR: Jack, what was it you said about the 7 observation of check valves? Did you say failures or LERs 8 or what, that you weren't seeing a decrease.
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| 9 MR.'ROSENTHAL: If you look at reported failures 10 of_MPRDS--of check valves to the MPRDS system'and you search 11 on failuresHas distinct from incipient failures--
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| 12 DR. KERR: Yes.
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| 13- MR. ROSENTHAL: You know, the licensee --I haven't 14' read through each record. You just do an automated search--
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| 15 DR. KERR: Yes.
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| 16 MR. ROSENTHAL: --and the licensee says, hey, here 17 is my check valve failure.
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| 18 So if you plot those as a function of time, over 19 the last couple of years, given all the attention that they 20 received since the IIT, you would have expected to see, 21 first an up swing in the reported failures, because people 22 would have gone out and looked found it fixed. And then 23 over time, a decrease in the failure rate, if they had fixed 24 their problems.
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| 25 And we're not seeing that. I'm seeing, but it's Heritage Reporting Corporation (202) 628-4888
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| 1 preliminary, a. flat line. I am-not seeing that increase 2' that'I would have-expected to see and that means it's a ripe 3 , subject to be--
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| l 4 DR. KERR: Well, the flat line could suggest that 5' that is a failure rate one should expect to see. I mean 6 after all you're going to get failures. And I guess--
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| 7 MR. ROSENTHAL: I know you have to.ask about the 8 level of failure rate, right.
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| 9 So, for example, we play the MOV failure rate 10 reported to MPRDS'or up against what is used in 1150 as the 11 failure rate and say if that is acceptable or not. The-12 answer.is that it is not.
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| 13 MR. MICHELSON: Have you determined--
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| 14- MR. ROSENTHAL: With the check valves, it's a 15 little bit different story, because the licensing basis for 16 the plant assume that those check valves wouldn't fail. For 17 right or wrong, we modeled those as passive components that 18 wouldn't fail when we postulated different events and so 19 licensees often had to put in more than one MOV because you 20 would postulate that this one would fail or that one had to 21 work. On the check valves, it's a bigger problem.
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| 22 As I said, because of the licensing basis was 23 because they would fail like pipe, as passive and they're 24 not that reliable.
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| 25 MR. MICHELSON: Have you attempted to estimate
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| ' () Heritage Reporting (202) 628-4888 Corporation j i
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| c7 - ,
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| , 118 b
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| .1? failure rates from.the MPRDS somehow?.
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| t2 MR.--ROSENTHAL: You1can--I-don't have the numbers,-
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| : 3. .but-there are some routines and so you could sit at~your 24' ' machine and it will look up'the number of engineering i :.
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| I 15- records, the number of components--
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| 6- MR..MICHELSON: You have done some of this--
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| 7 MR. ROSENTHAL: --and it spits it out for you. It 8 spits out the failure rate.
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| 9 MR. MICHELSON: Could you send us the results of.
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| 10 the searches that.you did do to find the failure 11 estimates?Did you actually get some reliable data?'
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| : j. -
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| 12 MR '. ROSENTHAL: .We_got numbers for.the check 13 . valves. I don't remember the numbers for'the check valves.
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| 14 MR. MICHELSON: No. .You did get the--
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| }
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| p 15 MR. ROSENTHAL: We got numbers of.the MOVs.
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| 16 MR. MICHELSON: Could you send them.to us, please 17- or send them to me, ,please?
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| 18 MR. ROSENTHAL: Sure.
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| 19 MR. MICHELSON: Thank you.
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| 20 MR. ROSENTHAL: Okay. Sandy-Israel.
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| 21 MR. ISRAEL: The next two reports that I am going
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| , 22 to discuss deal with a recurring theme that we have.seen,
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| ,y 23 deficiencies in design fabrication installation of various 24 systems.
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| 25 The first one deals with emergency ventilation Heritage Reporting Corporation (202) 628-4888
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| l 119 i 1
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| ("'/
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| k- 1 systems,.the control room. These systems are very i
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| 2 complicated and are designed to provide protection against )
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| i 3 the epolent contamination, either from radiation or toxic j 4 materials. They're very complicated and so far they are 5 usually combined with general buildings ventilation and 6 therefore, sometime this compromises their functionability.
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| 7 Let me show you a diagram of a ventilation system 8 for a control room. And, basically for the emergency 9 ventilation, what you really want to do is you want to 10 pressurize the control room relative to its environment so 11 that you have out leakage of controlled air.
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| 12 Under normal ventilation, you have air intakes 13 coming into the duct work and you have a recirculation 14 system, air movers that essentially pressurize the duct
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| ['v}
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| 15 work, provide air to the control room, but also may provide-16 air to other offices or areas in the building, in this case 17 this is a tech support center and computer room and a 18 kitchen, rest room and managers room.
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| 19 What happens is that you have control leak off 20 from these various areas, control room and these other 21 areas, so that as you are recirculating the air and 22 pressurizing the control room, you're also drawing in air 23 from the outside to make up for the leak OFF.
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| 24 In the event of an event LOCA or a toxic gas 25 event, essentially it would close off the air intake or
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| () Ileritage Reporting Corporation (202) 628-4888
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| 120
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| !) 1 reduce the air intake, start up your pressurizing fans which 2 then draw air thorough the filter system and provide air to 3 the system. You would close off the various exhaust systems 4 as well, presumably.
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| 5 The whole purpose is,.obviously, to provide a 6 controlled atmosphere in the control room. That is, again, 7 I say, higher pressure than the surrounding rooms.
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| i 8 DR. KERR: Excuse me. Did you say that would 9 occur in the event of a LOCA?
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| 10 MR. ISRAEL: That's right, in case of a LOCAS, you 11 get emergency ventilation system--
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| 12 DR. KERR: Automatically?
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| 13 MR. ISRAEL: Yes.
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| 14 DR. KERR: No matter what the size of the LOCA?
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| .(
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| 15 MR. ISRAEL: That is correct.
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| 16 DR. KERR: That doesn't seem very reasonable to 17 me, but I won't pursue it at this point. f 18 MR. MICHELSON: You're not locked in now to that l
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| 19 recirculation, are you?
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| l 20 MR. WYLIE: You can manually realign, but you can l
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| 21 automatically aline until you think about it.
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| 22 MR. ROSENTHAL: Correct. Obviously there has to 23 be some manual over ride. The LOCA condition is probably a '
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| 24 longer term situation than a toxic gas situation where l
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| i 25 things may be more immediate.
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| () Heritage Reporting Corporation (202) 628-4868 1
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| 121' ,
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| ( /. ' 1 MR. WARD: You said a LOCA, but I guess that means 1
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| 2 the pumps are on line?
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| 3 MR. ISRAEL: That's right. When you have an ESF !
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| 4 signal, it sends the system into its emergency mode. I t
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| 5 MR. MICHELSON: If it once goes in--if you 6 realigned the manual, is there then the radiation detection 7 or something that puts you back into recirculation mode?
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| 8 MR. ISRAEL: Yes. On the diagram, you'll see that l I
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| 9 at the rear intakes there are radiation monitors and toxic 10 gas monitors, et cetera. That would put it.back into the ,)
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| 11 automatic recirculation mode.
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| ]
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| 12 And basically I started looking for events that i
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| 13 dealt with this subject and I was looking for events that l
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| .s i
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| 14 dealt with the system as opposed to the events that have
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| {)
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| 15 been reported before in a previous and older information 16 notice dealing with in leakage, in leakage being a lot of-17 holes in the cystem so that the envelope is not very well y l
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| : i. 18 controlled and I have a few of them identified here.
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| 19 One event they had a single air limit damper so l
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| 20 that in the event of going to emergency mode, if.this fail
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| ]
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| 21 close, they would not be able to pressurize the control 22 room. j 23 Another event where the normal ventilation for the 24 rest of the building continued even though the control room 25 went into an emergency mode and as a result, the room ,
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| 1
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| ) Heritage Reporting Corporation (202) G28-4888 1
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| 122
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| () . 1 pressures--the pressure in the rooms surrounding the control 2 ' room'were higher than the pressure in the control rooms.
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| 1 3 So you get in leakage of uncontrolled air into the 4 control room.
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| 5 Another situation, this goes back to Ornstein's 6 air systems. The dampers that control the system are air 7 operated. The air systems are not safety, so they usually 8 have.a bottled gas back up with a check valve in the line so 9 .that if they lose normal air, that the back up would provide 10 the air. 'In this case, the check valves were improper for 11 use in this situation and they didn't provide isolation like 12 they were supposed to.
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| 13 Another situation, you had dampers on the same 14 power supply sop that loss of a single power supply would-15 defeat the system. This situation, no back draft dampers, 16 was a situation where you have redundant air circulators.and 17 if one of their circulators is~not operating, and hese 18 redundant circulators run parallel, you would essentially.
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| 19 just keep recirculating air from the operating air mover 20 through the idle one in a loop not to ventilate the control 21 room door.
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| 22 The single power switch, this dealt with the 23 temperature control and the air control system for the 24 ventilation system and it would have a power switch that-I 25 would move to change power supplies.
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| . ( )- Heritage Reporting Corporation (202) 628-4888
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| 123 r
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| t 'Y .
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| !N_) 1 -It the power supply went down and it would move, <
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| ~2 in'this case, a single power switch failure would result in 3 losing the air conditioning and the air movers as well.
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| 4 There were several instances of disposition
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| -5 dampers, such that they would not be able to pressurize the 6 control rooni because of the damper arrangement.
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| 7 one of these was very interesting was that if the 8 exhaust fan continued.in the rest room, it would end up with 9 a negative pressure in the control room, so that was a 10 problem.
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| 11 And this last one, one utility has a very 12L complicated automatic isolation arming procedure. It has 4 13 or 5 steps to it and they essentially were--well, the plant 14 wasn't operating at the time, but they had essentially spent 15 a long time in a mode where they automatic isolation was not 16 on.
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| 17 These were the types of events that have occurred.
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| 18 These will be the follow-ons to work that has already being 19 done by NRR, you're probably aware of, in this general area.
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| 20 And our report came out at about a time that NRR 21 was wcrking on an information notice, so this work was 22 incorporated into the information notice that went out last 23 summer,. 88-61.
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| 24- A more interesting report came out last fall that 25 this was a contractor for NRR, Argonne issued the report
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| *( ) Heritage Reporting Corporation (202) 628-4888
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| 124 n'
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| (_,l 1 where they surveyed 12 plants and in all the plants, I 2' believe they found deficiencies in single failure aspects of 3 the system, in addition to a litany of other problems that 4 they found with the systems.
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| 5 Consequently, NRR is now in the process or is 6 moving through the concurrent system, a generic letter, 7 dealing with emergency ventilation system for control rooms, 8 essentially asking the utilities to go back and confirm that 9 the control rooms ventilation systems will perform the way 10 they said they would in their FSARs.
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| 11 The second topic deals with NPSH for high pressure 12 safety injection systems during recirc.
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| 13 I stumbled on to this because, oh more than a year
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| (~% 14 ago, I had written a similar report for low pressure systems V
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| 15 during recirc, inadequate NPSH and within a period of two 16 weeks, the two LERs showed up dealing with problems, 17 potential problems of MPSH in this mode.
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| 18 Let me show you a diagram. of what I am talking 19 about. In PWRs, in the recirc mode, water is drawn from the 20 containment sump through the low pressure pumps and for a 21 large LOCA, this would then be discharged directly to the 22 reactor vessel. For smaller LOCAs, where the pressure hangs 23 up, probably above a about a 100 psi, you have to use the 24 high head injection pumps to maintain cooling to the cooler.
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| 25 In this case, the high pressure cooling pumps are piggy
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| () Heritage Reporting Corporation (202) 628-4888 l
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| l l
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| i 125 l
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| '~
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| backed off the discharge of the low pressure pumps and I ]
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| (_)T 1 j 1
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| 2 have shown that. It's cutin over here and comes through !
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| 3 here and goes to the high pressure pumps which the inject 4 into the vessel.
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| 5 In addition to which, at this plant--in fact, at 6 both plants, the low pressure discharge was also used to 7 provide suction to the containment spray system. ,
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| 8 What the utility discovered--one u'tility 9 discovered, when they looked--when they went back and locked 10 and tried to reconstitute their safety analysis, was that 11 they weren't sure they would have adequate NPSH, both at the 12 containment spray pumps or at the high pressure injection 13 pumps and the reason for that is that there are a couple of f3 14 throttle valves that are in the discharge of the RHR lines.
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| U 15 There was no control over whether those were throttled or 16 not.
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| 17 In addition to which, evidently the length of 18 piping that was run was larger than--was longer than 19 originally used in the calculations and the piping size had 20 been changed from 6 inches down to 3 inches.
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| 21 As a result they had larger pressure drops in the 22 interconnecting pipings than some original calculation had 23 anticipated.
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| 24 MR. WARD: You just sort of casually said the 25 piping size had been changed from 6 to 3 inches?
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| () Heritage Reporting Corporation (202) 628-4888 L _ _ ___-__-____ ____ _ _ _ -
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| l 126 l
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| (_) 1 MR. ISRAEL: Correct.
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| 1
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| .2 MR. WARD: That's a pretty major change.
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| 3 MR. ISREAL: I can't deal with the inner workings I I '
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| 4 of how the utility and the architect engineer dealt with one 5 another and why this came about, but there must have been a i
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| 6 miscommunication along the line. Originally it was 6 inches l 7 and then somebody did new calculations when he plant was 8 built. We're now talking 10 - 15 years ago and they said, n 9 o, we can get by with 3 and--
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| 10 MR. WARD: Did they rip out the system?
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| 11 MR. ISRAEL: No, they didn't rip it out. Before it 12 was built--before it was built. That was one plant.
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| 13 The other LER dealt with, they had a throttle 14 valve in the line to the high pressure injection pumps in
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| (^)
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| 'a 15 the inner connect line that was throttled by 309 percent or 16 throttled to 30 percent and initially when they looked at 17 it, they said, gee, they weren't really sure they would have 18 adequate MPSH and though subsequently they went back and 19 they discovered that it was all right, they were able to 20 calculate themselves out of the problem.
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| 21 MR. MICHELSON: Are the fixes on all those pumps 22 at low MPSH7 i
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| 23 MR. ISRAEL: No.
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| l 24 MR. MICHELSON: No?
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| 25 MR. ISRAEL: No.
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| Heritage Reporting Corporation
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| (") (202) 628-4888
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| _ _ _ _ _ _ _ _ _ _ .. .. }
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| 127 (n-_) 1 Ultimately, this ended up in an information that 2 was issued last summer also.
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| 3 MR. CATTON: How would something like that get 4 mixed in the review process?
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| 5 MR. ISRAEL: I don't know Ivan.
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| 6 All of these problems represent things that are 7 missed in the review process. Obviously we' re not talking 8 about something that requires higher mathematics. It's 9 pretty straight forward hydraulic type calculations and yet 10 it was missed in the review process?
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| 11 MR. CATTON: It's possible that the pipe shrunk 12 MR. ISRAEL: I was told, in changes the pipes from 13 6 inches to 3 inches, the problem there was that they made 14 different assumptions about the number of pumps that would
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| ' (_r^)'
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| 15 be driven off of the low head pumps.
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| 16 In other words what I showed you there, if you 17 look, I had one containment spray pump and I had 3 high I 18 pressure injection pumps, driven off of one--
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| 19 MR. WYLIE: Let me ask you as question. The j 20 drawings--what did the original drawings show, 6 inches?
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| 21 MR. ISRAEL: I was told that originally the 22 calculations were 6 inches. Now whether those whose--
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| I 23 MR. WYLIE: Oh the drawings--what did the drawings i
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| 24 show? l 25 MR. ISREAL: I don't know what the drawings
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| l u_____ __ _. _ _ - _ .
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| 128 fA. V)' 1- showed.
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| l 2 MR. WYLIE: I mean, that's the key.to the thing is 3 whether or not--
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| 4 MR. ISRAEL: What was told to me was that the 5 original calculations indicated 6 inches and then subsequent 6 calculations said no, they.could get by with 3 inches.
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| 7 Now whether the original calculation ended up in a 8 drawing showing 6 inch pipe or the evolution of how the 9 plant is designed--
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| 10 MR. WYLIE: This plant was designed in the ' 60's--
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| 11 MR. ISRAEL: Right.
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| 12 MR. WYLIE: for a QA program, Appendix B and all 13 of that came about an so there was a lot of latitude by the 14 designers at that time. That wouldn't happen today because 15 :you got to have independent reviews, but--
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| 16 MR. ISRAEL: But the problem is that today we're 17 dealing with about a 110 operating plants and they have 18 whatever they have and--
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| 19 MR. WYLIE: I think you'll find in the ' 60's--
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| 20 early ' 60's, when those plants were designed, you're not 21 going to find the same reviews that took place in the later 22 plant.
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| 23 MR. ISRAEL: Let me just mention, in my previous 24 talk about the containment ventilation systems, many of 25 those plants are plants that were licensed, one was Limerick
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| () Heritage Reporting Corporation (202) 628-4838 l
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| L, 1 i 129 3 f , '1 and there.was Calloway. ' They were' licensed in 'the ' 80's.
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| 2 MR. WYLIE: The pipe change was done in the ' 60's, 3' that's my point.
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| 4 '
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| MR. CATTON: But the air conditioning systems, 5- some of.those things were--this was done later. ' Don't~
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| : 6. people even look at flow diagrams?
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| 7 .MR. NOVAK: On this pump, on this configuration, I 8 think, normally when you look at the high head safety n
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| 9- . injections, they're gravity fed and people'would just look '
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| 10 at see that you could accommodate.the single failures and 11 - again, it was just the motor operated valve. Check valves 12 were assumed to do what they were supposed to do.
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| 13 And then when you went into recirc, the idea was, 14 well, with-a pump you ought to be able to provide enough L '
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| ; 15 flow such that if you were accepting something based on h 1 46 gravity feed, from a refueling water storage tank, you 17 shouldn't have any problems.
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| 18 So those kinds of analysis never show up in an 19 FSA. All you're doing is looking at a P&ID and you're 20 looking-at the typical flows.
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| 21 I, in fact, when Sandy and I talked about this, I 22 was surprised that the shut off head is as low as it is. In 23 other words, it's no more than--if you got more than a 100 24 pounds to work against, you got to go piggy back and I 25 thought, these RHR pumps could do more, but that is what O Heritage Reporting Corporation (202) 628-4888 1 _ _ _ ________ _ _
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| l 130 g
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| ~V 1 Sandy said.
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| 2 Now, this is not, of course--some designs use the 3 same pump for high pressure injection and recirc, so they 4 don't have a piggy back mode and that is the combustion 5 design.
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| l 6 The Westinghouse design is and I guess the B&W 7 design have this configuration. And all we're looking at is 8 the operational experience. ;
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| 9 MR. MICHELSON: In another arena, at the present 10 time, there is an MOV generic letter, as you're well aware.
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| 11 In that generic letter, the staff is attempting to 12 deal with the so called position changeable valves in which i 13 they, for whatever reason, the valve changes position and r~3 14 you like to make sure you can be re position the valve.
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| V 15 If you study these in dealing with the 16 probabilities that valves on the suction that pumps are 17 indeed position changeable and you take the finite time to 18 discover they have been closed, the finite time to get them 19 open and in the meantime, what has happened to the pump, 20 especially if you have no MTSH trip on it.
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| 21 Have you looked into that issue and whether or not 22 you're really--
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| 23 MR. ISRAEL: No, I haven't looked at that problem.
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| 24 MR. MICHELSON: Okay. But you know other people l 25 worry about the valve. I just hope somebody is integrating
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| Heritage Reporting Corporation (202) 628-4888
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| 131
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| ,~
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| ()s 1 the valve with the pump to see if the system is in troubic, 2 for instance.
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| 3 We're pushing this position changeable thing real 4 hard on valves, but we don't seem to worry quite so much 5 about the other equipment that is being now directly 6 affected by the positions changeable valve.
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| 7 I was just kind of curious. I thought'I knew what 8 the answer would probably be. Thank you.
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| 9 MR. WYLIE: I might just say one other thing about 10 this particular one where the pipe changes.
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| 11 Those pumps are 300 percent pumps. It only takes 12 1 of 3 to do that. That may have been--I don't know--that 13 change, the original design, they were going to use 2 of 3, em 14 but those are 300 percent pumps in there and you only need U 15 one of them 16 Now they may have went back and recalculated mon 1
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| 17 one pump, I don't know.
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| 18 MR. ROSENTHAL: Several years ago, I took a course 19 by a guy named Haas, who was teaching an early PRA course 20 in which he talked about the numerical theory of PRA.
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| 21 We surely did a lot of focusing on, you got two 22 pumps and one has failed and will the other one deliver the ,
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| l 23 flow. j l
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| 24 But the reality is that more often than not, both I
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| 25 are going to work and the plant has got to be in that l
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| 1321 1L configuration and that's no time for the guy to;. figure it?
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| '2- out that some~ damper,._which'is a flow control' valve that'.was-3- ' adjusted and then wedged or something, has to be. changed.We 4 'just' keep . finding..these : things.
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| L5 You just' heard two bad news studies:and Ted a
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| ~
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| 61 Cintula is going to give you a: good news study to give us 71 some balance here.
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| 8- MR. CINTULA: Thank-you.
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| 9 .This is my.look at large openings in containments 10 when the containment should not be open. It.was published.
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| '11 as E-808. For a data; source, we.used LARs and.the time' span-12 is from 1980 until.early 1987 and we used-the sequence #
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| 13 coding system to find these breeches in the containment.
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| : 14 -vessel.
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| 15 What.we were looking for were. events of really 16- excessive leakage through~the primary containment where it i
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| 17 would be likely or.certain to occur during an accident with
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| ' 1Ef a probable release to.the' environment. )
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| 19 In other words, we were lookingLfor.more'than one 20 failure in the system or something beyond the tech spec 21 reporting requirements for LERs.
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| 22 There are three methods that the LERs seem to 23 report for rather large breeches in containment.
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| 24 The first one is both doors of a large penetration 25' being opened simultaneously. The second one is a reportable
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| ()' Heritage Reporting (202) 628-4888 Corporation
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| '!, ^> l l
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| 133 L e/~g ;
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| V 1- ; event performed in accordance with Appendix J, the. Type B- I 2 and C leak: rate measurements where'the licensee actually ,
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| 3 takes a measurement through penetrations of the containment, 4 sums:them together. . This would be a-type of test where all 7
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| -i 5 the. equipment, valves-and so forth are in their proper r 6 position and it will be leakage through these components 7 when they are in the proper position.
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| 8' The third type is the failureLof the containment 9 isolation valves, both of them, the inner and.the outer, to 10 ~close during a valid containment iso).ation signal or unknown 11 or undetected pass through containment.
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| 12 Going back to the three of these, the first one 13 that we looked at were'both the inner and the outer door of 14 a large penetration or open when the tech specs say they V''N .
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| 15 should not be open.
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| 16 Both doors being open represent a massive-17 containment leakage, probably in the magnitude of thousands 18 of square inches.
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| 19 20 We found 34 events' reporting both doors being open 21 and the 34.LERs had 39 separate occurrences of both doors ;
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| 22 being open. Fortunately, only 8 of these events occurred 23 during power operations.
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| 24 Secondly, these events seem to be of very short
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| : 25. duration, 15 events for less than one minute; 14 events for
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| () Heritage Reporting Corporation (202) 628-4888
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| E-134 h '1; -less that 15 minutes'.
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| 2 In reviewing the LERs, it seemed the licensee
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| ;3 personnel had salve,.they knew if both doors were open,
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| :4' something was-wrong and one of the 2 doors was secured 5 quickly.
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| 6 .MR. WARD: Ted, you commented that fortunately 7 only 8 of these occurred during power operation, but a 8 little while ago, we had a discussion about'the risk of core 9 melt might be as high as during shutdown condition, shutdown
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| /- 10 modes at power.
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| 11 MR. CINTULA: That might be true, but I think with 12 both doors open, I would rather be shut down. I'm not sure 13 of this, but as I recall, the 8 events of power operation,
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| , es. 14 it's my recollection is that they were at very low power, 15 say less than 10 percent.
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| 16 The longest event was both containment, air lock 17 doors were open for 21 and a half hours.
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| 18 MR. CARROLL: Open meaning wide open or there was !
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| 19 a leakage factor. ;
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| 20 MR. CINTULA: Open that much, it's a tremendous 21 amount of leakage taking place. IF it's wide open, you 22 know, it's more, but it's definitely to me, at least, a 23 significant breech of containment even if it's just--
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| 24 MR. CARROLL: What was the circumstance there? ,
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| i 25 MR. CINTULA: The circumstance for what? The one 1
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| ,A]f Heritage Reporting (202) 628-4888
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| 135 L1 ;that.was open for.21'and a half hours?
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| 2 Let me make one additional point. I'm. jumping 3 ahead of myself.but the total. time'for all containment doors D "4 .being open was 43 hours so this.one represented half.the 5 time'of all the LERs that I reviewed.
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| 6 As I recall, the event happened at San Onofre Unit 7 I in 1985. They were at zero percent power. They requested 8- a non license person to unlock the containment doors and he 9 thought he would help them out and he opened them after 10 unlocking them.
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| 11 In'looking at the failure data of why containment 12 doors-arecopen, it's predominantly component failures or 13 personnel errors. Component failures basically involve the 14 latching mechanism of the door or the latching mechanism f{
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| 15 failing to grab the door, a rebound affect.
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| 16 MR. MICHELSON: When you looked at the door 17 failure mechanisms, did you consider the inflatable--the 18 case of the inflatable seals?
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| 19 MR. CINTULA: No , sir.
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| 20 MR. MICHELSON: You didn't include those?
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| 21 MR. CINTULA: Not at all.
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| 22 MR. MICHELSON: How many of those have been I
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| 23 involved? They also constitute a leakage, but I've seen i 24 various claims and in some cases it's apparently a very 25- large leakage once you lose the air pressure--
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| '( )' Heritage Reporting (202) 628-4888 Corporation l
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| P ,,
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| h-136 l , jf f L1 MR. CINTULA:- This is a rather new development,
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| . '2 'isn't.it, Mr. Michelson?
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| l 3 MR. MICHELSON: No, not really new.
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| 4- MR. CINTULA: The LERs are just as important as 5 containment. doors.being open.
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| 1, 6 MR. MICHELSON:. Beg pardon.
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| 7 'MR. CINTULA: The LERs, at least in the time 8 period I. looked at, are just reporting the containment doors.
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| 9 being open.
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| 10_ MR. .MICHELSON: I have seen LERs in which they 11 reported the loss of the air pressure on the inflatable seal a 12 and there have been several of those, particularly on some 13' boiling water reactors but also on some PWRs, but I don't know how--I don't recall how they---it was in an LER,.but O - 14 15 how the.LER was quoted, I don't recall.
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| 16 MR. CINTULA: Those would not be included in the 17 information I am presenting here.
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| 18 MR. MICHELSON: But you searched for failure of 19 the doors, but it apparently wasn't recorded as a failure of R20 the door then, It was probably reported as a failure of the 21 air system backed into, telling you what the affect was.
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| 22 MR. CINTULA: Probably. Those types of failures 23 would not be in here.
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| 24 MR. MICHELSON: Didn't you search, as a component, 25 being the door itself and it would have picked up as one of O Heritage Reporting Corporation (202) 628-4888
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| 137
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| ..w/ ('~) I 11 the branches in the sequence coding?
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| 2 MR. CINTULA: Basically, I searched for LERs on 3 ' containment failure and then reviewed them myself.
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| 4 MR. MICHELSON: Oh, okay, then you could
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| '5 potentially miss it because it probably came through the air 6 system route.
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| 7 MR. CARROLL: How about the equalizing valves, are
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| : 8. they in this body of statistics?
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| 9 MR. CINTULA: There were no failures of the 10 equalizing valves. After the report was concluded, a 11 failure of the equalizing valves came in very directly in 12 the LERs. but I might have made a cut off on the data and 13 that's a good size. failure. That's like a three inch 14 opening, I believe.
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| )
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| 15 MR. CARROLL: Yes indeed.
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| 16 MR. CINTULA: No, that one is not in here and if 17 there were others, I have missed them, but they're not in 18 here.
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| 19 MR. CARROLL: That's a fairly common problem, that 20 they leak at least a little bit.
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| 21 MR. CINTULA: Not both though. I was really 22 looking for an opening, not a loss of redundancy.
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| 23 MR. CARROLL: All right, okay.
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| 24 MR. CINTULA: You do some simple statistics on 25 this data and we're basically saying if there has been 39 Heritage Reporting Corporation (202) 628-4888
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| 138
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| ~1 events in 500 reactor years of operation over the time-span 2 in this-study, we're talking somewhere in the range of 10 -2 3 probability of both doors of an occurrence of both doors 4 being open when they should not be or not permitted by the 5 tech specs.
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| 6 Or if we look at it from the time. standpoint, the 7 39 event represented 43 hours and that comes out to a ,
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| 8- probability of 10 -5 of both doors being open when the tech 9 specs require them being close and this is consistent with 10 previous safety assumptions.
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| 11 The second type of excessive containment leakage 12 as reported by the LERs was a type B and C leak rate 13 measurements tests which are done under Appendix A, Jay and
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| , 14 they're done during refuelings.
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| 15 We found 10 events of significant containment 16 leakage. Tliis would be the type of event where all of the
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| . 17 valves, components in their proper position and it's just 18 plain leaking through. ,
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| 19 It's rather difficult to quantify the amount of 20 leakage. If you look at it from one standpoint, there was
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| ;21 one plant that measured 19.3 percent late per day. Another 22 one at 8.7, 3 others above 6 percent or if you look at it 23 from a tech spec standpoint, one plant was 22.8 times the 24 tech spec and a couple others, another big multiple.
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| 25 Or if you look at it from a flow rate, we had one
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| 139
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| ( 1 over 4,000 cubic feet per hour and another one over 2,000.
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| 2 These numbers here are not nee.essarily, say the 2 or 3 worst 3 cases presented in the order. The numbers hop around 4 depending on the particular containment volumes, the FSAR 5 design pressures and so forth, tech specs.
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| 6 However, there was only one containment that was 7 leaking at above 10 percent late per day. Those other two 8 numbers would be less than that.
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| 9 You take this one and extrapolate it to the 110 10 operating plants, so if we shut down all the plants today 11 and done a Type B and C leak rate test, there is probability 12 of 10 -3, that one of them would be leaking above 10 13 percent.
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| 14 Also, I would like to point out that this test, in
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| (.
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| 15 my opinion, is very conservative. In an accident condition 16 I would not expect the rates of the measured leakage to be 17 leaking at that rate. One thing that struck me while 18 looking at the LERs on this, is although some of these are 19 what I would call fairly significant leak rates. When the 20 licensee repaired and adjusted the defective components, the 21 leak rates reduced almost to zero.
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| 22 But unfortunately, the next time they came by, 23 there was no guarantee that the same component would not be 24 leaking again at a significant rate.
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| 25 The last category was undetected or open pathways
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| k 140 e
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| . () 1 in the containment or the simple failure of both 2 containment--two or more, at least the inner and outer, 3 containment isolating device failing to isolate on a valid 4
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| 4 containment isolation signal.
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| 5 We thought there were 8 events worth remarking 6 about. The largest was a 3 inch diameter opening. Both 7 containment isolation valves fail to close. System went 8 from the containment sump. We considered it to be a valid 9 . leak of about a 100 percent per day.
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| 10 MR. MICHELSON: What kind of search did you do to 11 find these events?
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| 12 MR. CINTULA: This is all going through the same 13 search of containment problems and just reading each LER.
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| 14 MR. MICHELSON: Well that's not--well okay.
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| r-)
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| V 15 You didn't search again the air system and when 16 the air system had problems in the LER then they talked 17 about it branched out into all the valve problems they had 18 because they lost the air or the air degraded.
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| 19 Would you pick those up in these 8 events?
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| 20 MR. CINTULA: Once again we' re looking--I'm not 21 sure I'm answering your question directly. If I'm not, stop 22 me.
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| 23 We were looking for events where containment 24 leakage would be likely to occur in an air system that is a 25 pressurized system and I--
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| 141
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| ,y
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| (,) 1 MR. MICHELSON: The air system is not the concern.
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| 2 The concern is the isolation--the containment isolation 3 valve which, as a result of the loss of the air system may 4 now not function properly if called upon. That's the 5 problem.
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| 6 MR. CINTULA: Once again we're looking for both 7 inner and outer to fail.
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| 8 MR. MICHELSON:
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| 9 MR. WYLIE: Yes.
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| 10 MR. MICHELSON: 7t would take- you're saying a 11 single failure due to the lack of air?
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| 12 MR. MICHELSON: Yes.
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| 13 MR. CINTULA: These valves should be fail closed.
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| . 14 MR. MICHELSON: Look at that carefully. Some are 15 and some aren't. The spring assist is not sufficient to 16 close them in the event that you have a rapid 17 depressurization in the containment. For some valves they 18 even require the air pressure to get them closed, in 19 addition to the spring.
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| 20 MR. CINTULA: The highest design pressure during 21 an accident during an accident, at least from the FSAR--
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| 22 MR. MICHELSON: You answered my question. You 23 didn't search for those kind of failules, at least as a part 24 of the air system reports. Okay.
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| 25 MR. CINTULA: Yes, sir, l
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| () Heritage Reporting Corporation (202) 628-4888 i
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| l 142 I 1 We found three additional events with three-2 quarters of an inch diameter openings and this would be 3 about a 60 percent per day leakage and one other event, 4 there was 8 one quarter inch holes drilled through the 5 containment liner. This would be a much smaller leak rate, 6 but I thought I would mention it.
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| E 7 Our conclusion in doing this study or at least my 8 conclusion is that, from the time span that I looked.at it, 9 containment integrity has been maintained by the licensees.
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| 10 MR. MICHELSON: One other question now. Certain 11 plants still operate with containment ventilation, they just 12' can't stay totally bottled up, so they have routinely both 13 valves open.
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| 14 Then in the event of an accident, you have to
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| )
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| 15 insure closure.
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| 16 MR. CINTULA: Right.
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| 17 MR. MICHELSON: Have you looked for the potential' 18 of those valves not to close upon demand as a part of this 8 19 event study?
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| 20 MR. CINTULA: No, sir, this would not be an LER 21 unless--
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| 22 MR. MICHELSON: Oh yes it would be.
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| 23 MR. CINTULA: Unless they failed to close.
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| 24 MR. MICHELSON: No, no. It would be an LER if the l 25 utility found that they, for whatever reason, could not 1
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| 143
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| ~
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| . 1. - 'close if' called upon and that is a reportable event, if it's 2 a: loss of containment, particularly if it's both valves.
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| 3 MR. CINTULA: I saw no.LERs of that nature.
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| 4- MR. MICHELSON: .Did you look for'them or you just 15 didn't see them?
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| 6 MR. CINTULA: I looked'for them and I didn't see 7 them.
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| 8 MR. MICHELSON: Okay. Thank you.
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| 9 MR. CINTULA: The other conclusion I would draw ,
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| 10 that my looking.at the containments says what has been 11 ongoing is certainly no worse than what has been assumed in 12 the safety analysis. Thank you.
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| 13 MR. MICLELSON: The real question here has to be 14 though,fI believe if you have got a problem a$ all, it's 15 with the containment isolation valves that are venting the 16 containment to the atmosphere.
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| 17 Did you do a search of the operability of those 18 valves under potential accident conditions and look, through 19 the LER system to see what kind of experience people were 20 having with problems with those air operated valves?
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| 21 MR. CINIULA: Yes.
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| 22 MR. MICHELSON: I'm not convinced yet that this 8 23 event--I've got some--I'll send them to you. I've been 24 collecting some of these on containment isolation, just 25 because I was a little concerned. I'm not sure whether you
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| ([ Heritage Reporting Corporation (202) 628-4888
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| 144
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| ( ,) 1 looked for them here or just didn't find them because of the
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| .2 search system.
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| 3 MR. CINTULA: I do recall that the sequence coding 4 gave me something like 650 LERs and--
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| 5 MR. MICHELSON: These 8 events came from 650 LERs, 6 is that what you're saying? That sequence coding should t 7 find it.
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| 8 MR. ROSENTHAL: I told Dr. Remick that we would 9 try to give you a respectable lunch time so we're just going 10 to take 5 or so minutes to go over the last part, but we do-11 want to show you this pump problem.
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| 12 MR. HSU: The pump damage is caused by low flow 13 operation. In this diagram you find operation of 73 14 centrifugal pump, the flow, with the design creates full V 15 recirculation inside the pump. This circulation--this kind 16 of full circulation induces some cavitation, hydraulic 17 pressure and sometimes vibration which can da.nage--which can 18 cause damage to the pump.
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| 19 I have another picture here that will help us to 20 explain how this internal circulation works against the pump i 21 operation.
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| 22 This is a cut out drawing here with only half.
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| 23 The other half is missing. So this is essentially is half 24 and this is the impeller. This is the case.
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| 25 When this is essentially operating at very low 1
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| /")
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| O Heritage Reporting Corporation (202) 628-4888 f
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| if p p L 145 I b * 'l flow, some of the flow will go through. . It action here
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| '2 'causes it to come back which creates a low pressure draw.
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| 3 We are very low, lower-that the breaker pressure of the 4 water, you know. That would cause water to vaporize.
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| 5 When the you see the high pressure here again, 6 then it will crack. That will create a so called 7- cavitation.
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| 8 Another thing that this recirculation will also 9 create a voltage force and the pressure comes back down.
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| 10 This kind of pressure surge will create some direct force 11 which may be high enough to vibrate the pump. That's called 12 vibration.
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| 13- Also we are creating an even force around the 14 impeller created through the pump.
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| 15 This is the circulation cap depend on the design 16 of the impeller. Every impeller design must begin to 17 recycle at some point of the flow. This recirculation- will 18 become more pronounced as the pump-as the flow is decreased 19 away from the design flow.
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| 20 As to the percentage of the design flow which the 21 circulation will begin depend on many factors. The size of l
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| 22 the pump, suction speed and some other items.
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| 23 MR.'MICHELSON: But the point is that the 24 . manufacturer specifies what these minimum flow requirements
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| : l. 25 are as a part of the pump specification. He tells you how
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| () Heritage Reporting Corporation (202) 628-4888 w__________________-. _ _
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| 146
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| ~ much you must-flow.
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| f) ll
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| )
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| 2 1G1. HSU: Wait, wait. This phenomenon--this type 3 of phenomena is not fully recognized by the industry until-4 1985.
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| 5 MR. MICHELSON: Well MPSH requirement of a minimum 6 flow has been recognized for the last 30.- 40 years, but l[
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| 7 think the manufacturers perhaps haven't recognized the 8 extent to which damages are occurring when you do have 9 minimum flows and as a result they started raising their-10 minimum flow requirements over the years quite:a bit.
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| 11 Now the question I have in my mind which I 12 wondered'if you hadsfound is, have you, indeed found that i 13 even now the minimum flow requirements are still too low as g go 14 specified by the pump manufacturer?
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| V 15
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| ~
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| j MR. HSU: We found 6, that is low.
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| 16 MR. MICHELSON: That's still to low.
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| 17 MR. HUS: Yes, still too low.
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| 18 MR. NOVAK: What we have seen is that the 19 manufacturers revised the minimum flows.
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| 20 MR. MICHELSON: Yes, they have. That's been going 21 on since 1965 and--
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| 22 MR. NOVAK: Well, and also as late as 1985.
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| 23 MR. MICHELSON: They're still changing them.
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| 24 MR. NOVAK: That's right. So the feedback is L 25 getting back and it's too bad we're short of time, but I
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| () Heritage Reporting Corporation (202) 628-4888
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| 1 147 .
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| I) 1 think what Chuck should do is just show you--it's a variety 2 of different kinds of failures. People, I think, were too i 3 quick to judge certain other reasons for lack for MPSH and 4 so forth because these failures have been going on for 5 years.
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| 6 MR. MICHELSON: Yes.
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| 7 MR. NOVAK: I think all that Chuck is saying is 8 that a half a dozen or so events we have'seen and it's been 9 recognized that it's due to the operating conditions that 10 they're putting these pumps under and even flows as low as 11 half flow can be too low to--
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| 12 MR. MICHELSON: There's also a problem of too high 13 a flow with the resulting drop in the suction head available
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| ,f- 14 to the pump such as during a run out and then you have to go V) 15 back--
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| 16 MR. NOVAK: That's possible as well.
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| 17- MR. MICHELSON: --and then you had to go back and 18 start orficing close to pull it back in line.
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| 19 MR. NOVAK: All we're saying is and we're not t
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| l 20 trying to--we have seen this and we're just trying to
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| )
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| 21 caution industry on the way they're operating these pumps l 22 and the amount of by pass flows they are permitting.
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| 23 MR. CATTON: Are there any tests being run?
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| 24 That's a complicated flow problem. You're not going to do 25 that by analysis.
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| 148
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| ( 1 MR. MICHELSON: This is not a new problem. They 2 have run flow tests. Bingham has run big loop tests in the 3 past.
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| 4 MR. CATTON: Normally you just accept the wear and 5 then replace the impeller now and then.
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| 6' MR. MICHELSON: Well, not quite. It's a little 7 more complicated than that. The vibration-might catch yout 8 first. Have you found any cases where the minimum flow by 9 pasa valve has failed to open on pump start and therefore 10 the pump had no flow and what happened?
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| 11 MS. HSU: I don't quite follow you.
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| 12 MR. MICHELSON: Have you found any events wherein 13 the minimum flow valve failed to open, any reported events?
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| 14 MR. HSU:
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| No.
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| (
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| 15 MR. MICHELSON: It seems incredible that that 16 hasn't happened some time or other on just a simple 17 probability basis. This wasn't reported then. Apparently 18 it's not sufficient to damage anything or it was recovered 19 quickly enough.
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| 20 DR. REMICK: Jack, could we summarize, perhaps?
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| 21 MR. NOVAK: Just to close it up here for you, so 22 that you can get on.
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| 23 I think what Chuck has found is kind of a good 24 example of what we should be doing when we do review some of 25 this operating experience and that is to look at these Heritage Reporting Corporation
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| 149
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| , 1 failures and to kind of recognize that operating conditions 2 can abe significant and go unnoticed for-awhile.
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| 3 I was surprised.that if you looked,at the slides, 4 there's a variation depending on the pump design, the 5 failures weren't the'same, but it just suggested that the
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| .6 minimum flow is not~something as low as 10 percent. It may 7 be greater than half flow for the configuration and in the.
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| 8 multi purpose pumps, where they try to operate over a wide 9 range of flows, any sustained period of operation can result 10 in what you don't recognize to be a problem developing and I 11 think that was what we passed on to industry.
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| 12 There was an information notice that went out this 13 year and I think we're going to continue to' watch and see 14 how this problem is handled. I think it is a very practical 15 approach and I think Chuck did a good job in looking at it.
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| 16 Thank you very much for the opportunity of coming 17 down.here and talking about these studies and if things work 18 .out-right, we'll be down next month and talk to you'about 19 some of the work we are doing on performance indicators.
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| 20 DR. REMICK: Thank you very much. Those were all 21 interesting presentations and we are sorry that you were 22 pushed for time but we appreciate your trying to help us get 23 back on schedule.
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| 24 Bill Kerr, will you need your full 2 hours? I 25 assume you will,
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| 150 1" 'DR. KERR:
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| It sort of depends on what the staff
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| ;2' has to tell us. -l I
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| t 3 DR. REMICK: I wonder if we could cut our lunch 4 hour by 10 minutes and come back in 50 minutes which*would 5 be 10 minutes after 1:00 o' clock.
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| '6~- .(Whereupon, at 12:20 p.m., the committee 7 . recessed for. lunch to reconvene at 1:10 p.m. the same day _.)
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| 1 AFTERNOON SESSION 2 DR. REMICK: Good afternoon, ladies and gentlemen.
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| 3 The next topic on our agenda is a discussion of the revised 4 NUREG-1150, particularly from the standpoint of the 6 appropriateness of its interim use, particularly in the IPE 6 process. Dr. Kerr is Subcommittee Chairman, so now I turn 7 the Meeting over to you.
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| 8 DR. KERR: You recall that we reviewed a draft of 9 NUREG-1150 and prepared a report dated July, 1987. We have 10 within the past couple of weeks received a copy of a new 11 draft, the main report and several appendices, but not a 12 large number of supporting documents. We plan to review 13 this draft in some detail using our normal subcommittee r^s, 14 meetings to precede consideration of the report by the full V
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| 15 committee. However, the Commissioners have asked us to 16 offer whatever suggestions we can, based on the limited 17 contact with the draft, and to give them a report if we can 18 do this, prepared during this meeting.
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| 19 one of the things that they have asked us to give 20 advice on is the appropriate use of this draft in the 21 interval during which this draft will be subject to peer 22 review by a Committee that has been set up by the Commission 23 for that purpose. The NRC staff members associated with the 24 preparation of the report have agreed to spend the time 25 allocating this afternoon giving us some of the conclusions
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| 152 1 of this new draft.
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| 2 I've asked that in so far as feasible, they 3 emphasize, in so far as they can within the time 4 limitations, differences in the method used in this draft 5 and differences in the results and conclusions of this draft 6 .of the report, compared to those of the original draft.
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| 7 I will turn over the rest of the time to them and 8 to us, unless there are some of you that want to raise 9 particular issues.
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| 10 (Slides being shown.)
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| 11 DR. ROSS: We will have a two part discussion.
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| 12 I'm going to give some introductory remarks.
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| 13 Mark Cunningham, Chief of the PRA Branch in the l'4 Office of Research, will do what Professor Kerr just said, 15 which.is highlight some of the differences-between 1987 and 16- 1989.
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| 17- The outline for this afternoon, shown on page 2.
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| 18 So we'll discuss where we are as of the fifth of May --
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| 19 discuss a little bit about the very large amount of
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| : 20. supporting documentation. Professor Remick mentioned uses, 21 and we're certainly here to elaborate on that as needed.
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| 22 The last half of the differences, method, 23 differences and results and summary is the part that Mark 24 Cunningham will give. And I think that's the substantial 25 portion of the presentation.
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| l 153'
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| 'l DR. LEWIS: Denny, on the front it says this was
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| '2 . presented to ACRS, May 3, 1989, which was yesterday. Is
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| -3 that a measure of the kind of uncertainly associated with. .,
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| 4 the other numbers in the draft?
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| 5 ' DR, ROSS: I knew this was going to happen.
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| J Before the meeting started, we considered consulting _an 7 -astrologer as the most appropriate kind to give this 8 presentation.
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| 9- DR. LEWIS: And he said yesterday?
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| 10 DR. ROSS: Yes, I'm sorry. You know, you go with 11 the flow.
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| 12 DR. LEWIS: Okay. I'm willing to pretend that 13 today is yesterday.
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| 14 DR, ROSS: If the Committee wasn't ready to meet
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| (}
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| 15 at 3:00 in the' morning, what could we do?
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| 16 DR. LEWIS: But 3:00 in the morning was already 17 today.
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| I 18 DR. ROSS: They assembled the report and delivered 19 it to the commission almost on schedule, the 17th. As 20 events have unfolded the last several weeks, our principle 21 contractors and NRC staff are doing a final QA. And we're 22 going to meet early next week in New Mexico. And then 23 hopefully any residual errors of arithmetic and so on were 24 corrected. We send it to the printer, and in due course, a 25 couple of thousand copies will come out. It will be labeled (f Heritage Reporting Corporation (202) 628-4888
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| l 154
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| /~)
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| (, _j 1 "second draft for peer review," the 'S7 version being the i 2 first draft.
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| 3 It will get the same wide distribution. We had a l
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| 4 little bit of discussion a minute ago on the peer review --
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| 5 I'll give a little more in a minute -- the organization 6 proceeding more or less smoothly. And I hope to have the 7 first meeting, July 10th.
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| 8 There's a couple of other reviews that are going 9 to take place. The American Nuclear Society had a special 10 committee two years ago on the draft. They're going to have 11 another one on this version, and they'll start getting some j 12 briefing as to the methodology next week. And then when the 13 report issues, they do not have it; this report is pre-l l 7~ 14 decisional at this time. They'll start their substantial l k.
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| 15 review in June or July, and presumably be approved around 16 the end of the year. So that's the second review, the 17 external peer review, the NS Special Committee.
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| 18 The third one is the ACRS itself. And before this l 19 meeting concludes, we probably will have some discussion as 20 to how the substantial review by the Committee is 21 accomplished.
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| l 22 I want to highlight something on external events.
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| 23 The study has in it external events on two plants, Surrey i l
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| 24 and Peach Bottom. And, in particular, you' re going to find 25 some things in there that are of technical interest and, l f) Heritage Reporting Corporation l \/ (202) 628-4888
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| F 155
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| ~).
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| 1(s./ - 1 perhaps, concerned on seismic.
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| 2 What we've found in this study was that, depending 3 on the hazard curve, some of the low probability 4 earthquakes,.but with high intensity, high acceleration at 1'
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| l 5 the site, not only can damage the plant, but also.could have 6 significant.non-nuclear consequences; you know, buildings 7 falling down and bridges and so on.
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| 8 We did not at the time we finished this study have 9 the expertise, the analysis methods, to calculate this non-10 nuclear seismic loss in terms of injuries, deaths and 11 property damage. We didn't want to present the nuclear 12 consequences out of context with the non-nuclear, so we 13 carried the seismic review up through core-damage frequency.
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| 14 and containment performance, but we do not present off-site
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| }
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| .15 seismic nuclear consequences.
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| 16 Our contractors are working on some sensitivity 17 studies. And in the next, oh say, 12 to 18 months, we'll 18 try to get a better handle on what we think a reasonable 19 thing to do is for seismic consequences. We like the final-20 version, which probably we'll issue near the end of calendar 21 '90, to have seismic risk analysis, but in perspective.
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| 22 DR. SIESS: Denny, does that include looking at 23 what the seismic event might do to the emergency plan? Take 24 out bridges, put people under piles of bricks so that you 25 couldn't evacuate --
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| 1 156 l
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| '(). 1 DR. OSS: We made some estima. Nns as to what 2' would' happen if evacuation-speed had a certain seismic d
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| 3: exitation, we built that in to some of the work we were 1 4 looking at; yes. But I think the whole thing should be-5 coupled ~into some larger studies.by FEMA, and they're 6- looking at the issue broadly. j 7 We did have, in the last several days, received a 8 National Academy report. I showed a copy to Professor 9 Siess, entitled " Estimating losses from future earthquakes."
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| 10 It's a National Academy Report; it was sponsored by FEMA.
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| 11 They go quite a bit into, not only the philosophy but some 12 of.the. nuts and bolts on how to do this, this being
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| -13 estimating the injuries and deaths and property damage from 14 seismic events.
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| 15 One of the things we'll be doing in the next year-16 or so is studying that report and seeing what application, 17 if any, it has to our work. My initial view is it has a lot 18 of applicability, and perhaps the ACRS might want to 19 consider it in its detailed review of 1150, also.
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| 20 I mentioned we had an external peer review, we 21 have a charter which is in the final stages of approval.
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| 22 The Committee, the Peer Review Committee, will of course 23 have fairly wide latitude in exploring the document and 24 setting its review. There are some questions that we would 25 particularly like answered, but these questions do not O Heritage Reporting Corporation (202) 628-4888
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| m t *3 157 q'
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| T s/ 1 rest $ict or.otherwise limit the. ability of the Peer Review 2 Committee to get into whatever-it thinks is appropriate.
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| .3 And these I think are some' fairly standard questions and I' 4 don't want to waste your time by reading them. I want to 5' point out the third billet,.that~is of particular interest.
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| c6' to some of us, is the use of expert elicitation.
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| 7 We were criticized in the ' 87 version of the
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| '8 report as,to the methods of calculating and displaying the 9- uncertainty. We made some extensive changes involving the 10; fairly wide-spread use of expert opinion to calculate some 11 uncertainties, and they're appropriately displayed just 12 about every graph in the report. And we'd be interested in 13 comments cni whether or not that makes good sense of not.
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| 14 Here's a list cf the Peer Review Committee. All
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| -{}
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| 15 of these people'have been contacted and are willing to 16 serve. As I said, we hope to get started in a couple of 17 months. ,
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| 18 DR. CATTON: What's.the background on --
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| 19 DR. ROSS: Lars Hoegberg?
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| 20 DR. CATTON: Yes.
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| . :21 DR. ROSS: He's been in -- SKI being the 22 regulatory organization. His current title is Director of 23 Research and Regulations and he's been associated with that
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| ~24 regulatory body for at least 11 years. That's as long as 25 I've known him.
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| ,' '; q. 1 MR. BECKJORD: Is it'not the incumbent director --
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| g,j.
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| 2 DR. ROSS: He's been very prominent in T 3 international. committees in both the CS and Nuclear Energy 4 Agency and the IAEA.
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| 5 MR. CATTON: And Leo LeSage?.
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| 6 DR. ROSS: Leo LeSage was the. Chainman of the ANS -
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| 7 Special Study Committee,.and I believe he's a physicist.
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| 8 DR. CATTON: These are all big picture people. Do:
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| 9 you have anybody.that's going to give you peer review'of the 10 nuts and bolts?
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| '11 DR. ROSS: Are'you talking more of a peer of an 12 expert review? I don't know if George Apostolakis would .
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| 13 agree with that characterization. He does a lot of nuts and-s~ 14 bolts work.
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| A 15 DR. CATTON: He's my. colleague. I know him well.
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| 16 DR. ROSS: Yes, that's what I thought.
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| 17 DR. CATTON: I didn't make the statement without 18 thinking a little bit about it.
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| 19- DR. ROSS: Well, he does a lot of very detailed 20 work.
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| 21 DR. CATTON: Yes, but he doesn't understand 22 phenomena very well. That's not his game.
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| 23 DR. ROSS: No. But these are not Renaissance 24 people. They don't all know something -- but George is l
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| 25 very, very well informed on expert opinion, for example.
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| w 1 DR. CATTON: That's true. j 2 DR. ROSS: I think collectively they have the 3 expertise. As far as nuts and bolts, we got a lot of -l I
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| 4 independent review. l l
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| 5 DR. KERR: Let me suggest in view of the time we 6 have available, I think we probably -- you may have a good 7 point, Ivan, but I think we ought to try to --
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| 8 DR. CATTON: Well, they got the answers.
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| 9 DR. ROSS: For the purpose, I think it's an :
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| 10 outstanding team.
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| 11 DR. LEWIS: Just one more second on the same 12 point, forgive me. Will these people have a staff available 13 to them?
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| j'~} 14 DR. ROSS: We'll provide administrative assistance
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| %)
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| 15 through Brookhaven Lab. What we expect is they will be very 16 demanding and ask for lots of calculation or whatever. To 17 the extent they need technical support, we'll provide it 18 through our contractor. But they won't have a staff as 19 such.
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| 20 DR. LEWIS: Okay. But that was in response to 21 Ivan's question who's going to do the --
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| 22 DR. ROSS: If they work anything at all like the 23 APS study group, they'll be very demanding as to wanting 24 more and more and more. It will be up to the Research 25 Office through its contractors to provide it.
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| j J 'l 160
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| : 1. -DR. LEWIS: .I' don't'know which APS group you're' 2 talking about'.. '
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| 1 3- DR.~ROSS: An-approximate chronology -- well, 4 : April'up here somewhere, but it's already'come and gone.
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| s 5 Don't worry about.that.- We're right here. We' hope to get i
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| 6 these things. formally settled and do.all-of the politics q
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| . 7. that we have to do and-then have the first committee meeting 8: on July 10th. And we don't know how long it's going to' 9- take, but I hope in the vicinity of 9 to 12 months, closer-10' to 9, I hope. But then, we don't know.
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| 11 Now, NUREG-1150 is~600-700 pages long. There's a 12 whole bunch of. supporting reports,.perhaps more than a meter 13 tall. I don't:know. Mark, going to guess? More than a 14 meter? More than a meter tall.
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| 15 -
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| There are three broad categories. The level 1 16 support after the frequency which has a broad number, 45-50, .
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| I 17 but there's a number of volumes, seven volumes. One of the 18 . criticisms in the draft was there wasn't enough supporting
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| -19 rationale. So these reports are quite a bit thicker than 20 .they used to be.
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| R21 ' Then getting over to the back-end accident 22 progression.and risk analysis; again, seven volumes, again, 23 being thick; and then supporting reports on external events; 24 methodology, altogether should be about 20 backup reports.
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| '25 Now, these are the generalities. If there's no Heritage Reporting Corporation (202) 628-4888 I
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| L 161 7'Y ,
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| .l' questions Mark Cunningham is going to proceed with the main 2 topic Mr. Kerr asked about, which is differences between '87 3 and ' 89.
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| 4 (Slides being shown.)
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| ! 5 MR. CUNNINGHAM: As you're well aware, we had a 6 large number of comments on the draft report. Based on 7- these comments and our own knowledge of what we-wanted to-8 change from the draft report, we made a-tremendous number of 9 changes in the methods that have been used for~this version 10 of the report.
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| 11 We thought we would try to pick on four today that 12 seemed to be relatively more important to the overall 13 results. These are the, as Denny mentioned, the expert
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| '14- -elicitation. process that we're using now is substantially 15 different, involving a larger number of panels, more 16 specialized panels, training, and what they call the 17 normative skills for the experts and increased 18 documentation.
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| 19 We have worked to expand the amount of technical 20 information that we've brought into the report, particularly 21 in the area of severe accident phenomenological research.
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| 22 Again, the quality of it depended on making use of the 23 documentation on expert elicitation to explain better how 24 the experts interpreted the data, what data they used, 25 etcetera.
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| 162 1 As Denny mentioned also, we'added external events l
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| 12 for two plants, Surrey and Peach Bottom. And we've modified j
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| '3 thel evacuation and warning time assumptions that we've used,
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| .i 4 using data from the licensee emergency' plans. I'll go into 5 each of these in a little more detail now, m
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| 6' DR. LEWIS: .Are you getting a new group of 7 experts, or just reviewing the way the original group was:
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| 8 used?
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| 9 MR. CUNNINGHAM: We have used new panels, q
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| 10 DR. LEWIS: You're forming new panels.
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| 11 MR.LCUNNINGHAM: We did form new panels.
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| 12 DR. LEWIS: . Okay,.very good. And with overlapping 13 membership or completely independent?
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| 14 MR. CUNNINGHAM: Some overlap.
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| 15 DR.' LEWIS: I see.
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| 16 MR. CUNNINGHAM: The number -- let me put this up.
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| 17 At-this point we -- in effect the overlap between expert 18- groups was -- we-didn't start out with the assumption that 19- owe wanted to overlap the group.
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| 20 When we set this expert elicitation process shown
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| : l. 21 here, we went out and asked people in various parts of the 22 industry, indicating we're interested in looking for experts 23 on this type of issue, and this set of issues. Please 24 provide who you think experts would be in each of these i 25 areas. That was the selection of experts, and the selection I
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| 0 163
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| ') 1 'of~ issues went along with that.
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| 2 We got probably 100 names or more. We went in'and 3 tried to cull then down to look for experience based on 4 publications and so forth. Also, we're looking for a; 5 diversity of opinions. One of.the comments on the draft was 6 that we used, we emphasized too much, the opinions and 7- judgments of staff members of national labs. And so in this 8 set of experts we looked for contributors from national 9 labs, from the industry, from academia, and what have you.
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| 10 I'll show you an example of the composition of a group in a 11 moment.
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| 12 The experts went through a half a day of training 13 in the normative techniques, understanding the concepts of 14 probability, how to provide subjective opinion, how to 15 quantify subjective opinions. At the same time the staff, 16 our contractor staff, were working on the preparation of 17 issues. We wanted to provide to the experts what we knew of 18 as to the available data base with references, with 19 published papers, and what have you, on the individual 20 subjects that we wanted them to consider.
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| 21 At that time that we brought them together and we 22 had a meeting, the second meeting. The first meeting 23 covered elicitation training. We had a second meeting then 24 'that discussed the issues we wanted to cover, make it clear 25 to the experts what the definition of these issues, why we
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| p 164 f
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| i_)/ 'l chose-those particular issues, and then tried to provide the 2 -technica1' evidence that we have, which we were aware of,
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| : 3. that addressed that particular issue. In those meetings --
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| 4 DR. LEWIS: Did they in general look for more 5 evidence, or did they work from the package that'you gave 6 them?
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| 7 MR. CUNNINGHAM: In general, they took it upon.
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| 8 themselves to look for more information, do their own 9 calculations, and in some cases perform experiments.
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| 10 The experts also had the' opportunity to either 11 indicate that an issue that we wanted to consider that they 12 believed was not necessary to consider because there was 13 enough data available already; they also had the opportunities to add issues that they thought were
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| {~ ) 14 15- important. They also had the opportunity to decline to even 16 deal with an issue. In the case of the accident frequency 17 analysis, our first panel indicated on one particular issue,
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| .8 that they believed that specialists should be brought in on 19 one particular area, and those experts used to develop the 20 information that we needed.
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| 21 DR. SIESS: Have you ever had an opportunity to 22 validate this process? By that I mean has there been a case 23 during this long time we've been working on this, where the 24 information was not available. An expert panel was formed 25 to provide the information, and subsequently the information
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| 165 p)
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| (- 1 became available as a result of research, to check out how 2 good the expert panel was?
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| 3 MR. CUNNINGHAM: I can't think of a case in our 4 particular work with the experts. There have been cases in 5 other places, other circumstances where this has happened.
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| 6 DR. SIESS: And it proved that the experts, that 7 the system worked.
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| 8 MR. CUNNINGHAM: The system works reasonably well, 9 perhaps. One of the things we told the experts early on in 10 the elicitation training was the literature on the subject 11 clearly shows one trend. The experts tend to be more 12 confident in the results than they should be, that 13 subsequent data tends to indicate large uncertainties than I
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| (~N 14 these experts would have given you. We try to sensitize
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| 15 them to that type of information to say, " Consider this as j 16 you're developing your information."
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| 17 DR. SIESS: Have you ever tried to experiment with 18 two groups of experts to see if they came up with --
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| 19 DR. LEWIS: They just did because they formed new 20 groups on this same issue.
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| 21 DR. SIESS: Yes, but they gave them different 22 ground rules.
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| 23 DR. LEWIS: I can provide a partial answer to your 24 question check, because I've been involved in this kind of 25 thing for 30 years or something like that, and in particular
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| 7z . . .
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| 166 t' i(T .
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| .A 7 1 in a domain I could only elude to. But in trying to I
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| 2 ' understand-something.about.other countries, very often one 3 ' forms a group of experts and elicitsLtheir. opinion'by these c 4 delphic or modified delphic' techniques'and then subsequently-51 'the.information you were trying-to guess becomes available,-
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| 6~ and there's no evidence that the expert pane 1~is any. worse.
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| : 7. than just picking people off the street and asking them for l- 8 their views. No statistically significant evidence.
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| 9- DR. KERR: Please continue, Mark.
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| 10 DR. LEWIS:- I,was going to add one more thing.
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| : 11. And that.is than when the Germans did their risk study on 12 the. breeder reactor, they added one extra dimension to'this 13 game, which is to ask'each expert to rate the expertise of the other experts that were involved, which produced, after
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| ) 14 15 all, more data.
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| 16- MR. WARD: Mark, you mentioned that in some cases 17 the experts actually performed experiments.
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| 18 MR. CUNNINGHAM: Yes, that's right.
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| 19 MR. WARD: Can you give me an' example of --
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| 20 MR. CUNNINGHAM: I'll get to that in a -- get 21 these slides down, that's right.
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| 22 I won't say that was a frequent occurrence. I 23 believe at least in one case something like that happened.
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| 24 A frequent result was that they would go back and perform 25 calculations, either with computer models or hand O erieeee Ree-eine c-e-ati-(202) 628-4888
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| 167 rx k J' - 1 . calculations, what have you. That' happened a great deal.
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| 2 Experiments happened a few times, I would say.
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| 3 MR. WARD: I wonder what the budget is for this 4 activity.
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| 5 MR. CUNNINGHAM: Not very much in those cases; 6 that's right.
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| 7 One thing I should mention that I neglected before 8 was in the elicitation training and the preparation of 9 issues and what have you, we tried to make'use of people 10 outside the nuclear business who had experience in this type 11 of decision analysis to help us avoid some of the pitfalls.
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| 12 that you can get into very easily in this sort of thing, and 13 in fact some of the pitfalls - we ran into in the draft 14 report.
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| 15 After this first presentation and discussion of 16 issues, the individual panel members went away and spent 17 anywhere from one to four months deliberating on their own, 18 considering the issues, performing the calculations and the 19 experiments that they wanted to perform. In some cases they 20 came back together as smaller groups and met with each other 21 to talk about information. That falls into this box down 22 here: the expert preparation of the issues and the 23 analysis.
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| 24 Following this period of, I guess, a few months, 1,
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| 1 25 the experts were brought back together to discuss the
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| 168 5
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| ~1 analysis that they had performed. This was intended not so 2 nuch to sway people, or to drive people to one person's 3 opinion, but more. ensure.that the information base the 4 people were working from,'to ensure that the. issues they 5 'were trying to answer were consistent among the experts.
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| # 6 It's very easy in these circumstances to get into a 7 situation where one issue, one expert, will have a slightly-8- different definition of an issue, and he will go off on a 9 -- different track. One of the purposes of the meeting is to.
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| '10 get them back focused on exactly what we were trying to.
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| 11 obtain-'from them.
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| 12 DR. LEWIS: You may have said it, and I may missed 13 it; typically, how many experts were there on-a given
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| : 14. subject 15 MR. CUNNINGHAM: Typically, three to four --
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| 16 DR. LEWIS: Three to four.
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| 17 MR. CUNNINGHAM: -
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| per issue. We had on the
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| : 18. order of six to eight on a panel, but they were split up.
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| 19 into subcommittees, if you will.
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| 20 Following the discussion, which lasted typically 21 one to two, three, four days, we obtained the elicitation 22 of the experts, what their results were for the particular 23 issue and the rationale; equally importantly, the rationale 24 for coming to a particular conclusion. These were done.
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| 25 individually in private, so that the expert was there with 1( ) Heritage Reporting Corporation (202) 628-4888
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| l-169 ry
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| .(_j l' one of our technical experts, if you will. And one or our 2 normative experts, the normative expert being there to help 3 pull the information out from them in the format that we 4 were seeking; the technical expert there to help make sure i 5 that what was being said made sense, was logical and 1.
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| 6 consistent and what have you.
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| l 7 The individual expert opinions or judgments were 8 then combined, aggregated, whatever you want to call it. We 9 didn't go into the type of thing, as you mentioned before, 10 of waiting. individual experts. That was brought up as a 11 possibility. We said, no, we don't want to get into that.
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| '12 So what we did then was simply say each expert is equal.
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| 13 All of them were treated equally in the aggregation process.
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| 14 We then drafted initial documentation of the 15 rationales based on tapes and the notes that were taken in 16 the elicitation sessions. This information was provided by 17 the -- to the experts, the individual experts. Let me back 18 .up. One expert's rationale, his conclusions, was provided 19 back to that expert for review. They did not see, at this 20 point, other people's information, or conclusions. They 21 know the information; they did not see the individual 22 conclusions. Again, to avoid potential -- or having one 23 person bias the results of others.
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| 24 And at this point, once the review of the expert 25 was completed, we considered that; we took the information Reporting Corporation
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| () 1 then and made use of it in the risk analysis.
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| 2 What I'm going to do is go through and show now an1 3 example of some of ;he panels that we had, some of the 4' information, some of_the members, what have you. Most of 5 the elicitation information was obtained in the. area of 6 severe accident phenomena, containment response, containment 7 loads and source-term information..
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| 8 In the area of accident progression and structural 9 issues, we had four panels: in-vessel accident progression; 10 containment loadings; the molten core-containment 11 interaction panel, which was basically looking at 12 interactions from a molto . core after it has left the
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| :13 vessel, was in the reactor cavity and the potential impacts 14 there; and then a different set of experts on containment 15 structural performance.
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| 16 Again, as an example in the area for the panel on 17 molten core-containment interactions, this panel considered 18 two issues: the potential for drywell shell melt-through in 19 the Peach Bottom Plant, and the potential for pedestal 20 erosion causing pedestal failure in core-concrete 1
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| 21 interactions in Grand Gulf Plant.
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| 22 In this case there were six members of the panel, 23 two from National Laboratories, two from universities and 24 two from what we would call the industry representatives.
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| 25 DR. CATTON: That's kind of a captive group.
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| 1 Corra'dini is your contractor. Kajimi is EPRI contractor..
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| 2 This'is tricky transfer problems. I don't see a single 3- person there who's a recognized expert.in the country.
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| 4 MR. CUNNINGHAM: The particular issue they were considering here was' heat transfer, was the chemical
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| 5 6 reactions that can occur, all of that type of stuff.
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| 7- That's right. One thing I should say is in order 8 to keep the number of issues to a manageable level, we had 9 to keep-them at a fairly high level. One way to deal with 10 this is to.go in.and have experts dealing with.the heat 11- transfer-aspects of a problem or the chemistry of a problem 12 and then combine that information.
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| '13 maat we:were looking here for were people who-were' somewhat more generalist than that, but could deal with'the
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| 15 issue at the level of what is the probability of containment-16 failure due to direct melt through by the core.
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| 17 DR. CATTON: You're looking at molten core-l 18 concrete interaction. And supposedly you chose a group of 19 experts.
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| 1 L 20 MR. CUNNINGHAM: Yes.
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| 21 DR. CATTON: There's complicated processes. They 22 have to decide on what's happening based on experiments that L 23 may or may not be scaled properly. It's all sorts of l
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| l 24 questions that I don't believe this group could really 25 address. That's just a comment. Exception, maybe, of
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| l 172 !
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| ; '~h V 1 George Greene.
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| 2 MR. CUNNINGHAM: In this particular case, I'm 1
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| 3 going to provide an example of what type of information was 4 brought to bear as these people work on the problem. I 5 should back off, also. In this case, all six members of the 6 panel worked on each issue. So there's six elicitation for 7 the issue of dry-well shell melt-through.
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| 8 All members of the panel used codes, such as 9 CORCON, to calculate the characteristics of the melt as a 10 function of time if you will. I won't read all these 11 things. The point here was a number of types of 12 calculations were formed. This was the case I was thinking 13 of. I believe that was Dr. Greene --
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| DR. CATTON: That's right.
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| } 14 15 MR. CUNNINGHAM: -- who performed some additional 16 experiments back at Brookhaven to help him improve his 17 information base. As I said before, after all these l
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| 18 calculations were done, the experiments were performed by <
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| 19 Dr. Greene. The panel was brought back together. They 20 shared this information, discussed over, I think, about a 21 two-day period. And then using that information base, they 22 developed their own elicitation -- they developed their own 23 probability distributions. That's what we're looking for in 24 this case. And we elicited the information on what that 25 probability of distribution looked like and why they (q)
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| \/ 1 developed it in the particular way that they did.
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| 2 MR. WARD: So the experiment that Greene series 3 ran --
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| 4 MR. CUNNINGHAM: Yes.
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| 5 MR. WARD: BNL was supported by this program.
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| 6 MR. CUNNINGHAM: It was supported by the research 7 program. We didn't fund it directly, but it was funded 8 under the general auspices of the Office of Research.
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| 9 DR. ROSS: We've had this type of research going 10 on at Brookhaven for quite some time. And we've been 11 refocusing in the last year or two towards some of the more 12 immediate problems. As you know, George has done some of 13 the small-scale modeling work. The likely flow
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| /~h 14 characteristic of melt is a function of a variety of
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| 15 conditions. And this is part of a standard statement of 16 work for this. If he had a special experiment, it would 17 have come out of our serious accident research budget, not 18 out of any 1150 budget.
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| 19 MR. WARD: Okay. But 1150 inspired him to do a 20 couple more t ests.
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| 21 DF. ROSS: Evidently. As a member of this group, 22 if he had the desire to run, we certainly would have paid 23 for it, sure.
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| 24 MR. CUNNINGHAM: If there are no other questions 25 on the expert elicitation process, we're going to move on to 1
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| 174 (3
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| \J s 1 some different subject.
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| 2 We have incorporated external events analysis into 3 the study of Surrey and Peach Bottom. This was a fairly 1
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| 4 detailed analysis of accidents initiated by seismic events 5 and by fires within the plant using methods that are 1 6 described in a reg that will be out in -- I guess it was in 7 the list that Dr. Ross showed. It will be out in a few 8 months.
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| 9 One of the particular things that complicated the 10 analysis of the seismic events was the existence of two sets 11 of hazard curves for eastern U.S. sites, for both the Surrey 12 and Peach Bottom sites. We'll come back to that in a 13 minutes.
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| ('}
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| v 14 Other types of external events, we had some 15 bounding analysis performed to screen, to see if we would 16 have to pursue them, particular events any further. In 17 general, these things didn't show up as significant relative 18 to the seismic and the fire.
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| 19 The next three slides in your handout look like 20 this. These are the hazard curves, seismic hazard curves, 21 in this case, for the Peach Bottom site. That by itself 22 probably doesn't tell you much.
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| l 23 The next one is -- I'm sorry. Back up a second. .
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| f 24 This curb was based on work done for EPRI, published, I l
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| : 1. parhicular t'o the. Peach Bottom site. .I-believe it was done:
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| : 2. for all of the. East Coast sites.
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| L :3- .DIL LEWIS : _Let me just-understand one thing 4 about -- I don't want to go into detail, but these, it says 5 ~hore, 15, 50 and 85 percentiles?
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| 6 MR. CUNNINGHAM: 'Yes..
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| 7 DR. LEWIS: And the middle one, the 50th -
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| / 8 percentile, is therefore a mean.
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| 9 MR. CUNNINGHAM: Yes,:that's correct.
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| 10 DR. LEWIS: It's a mean. And yet the 15 andL85 11 percentiles seemed to-be about equally spaced on a 12 logarithmic ' scale, which is a little ' odd.
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| 13 DR.-ROSS: Fifty's the median.
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| L 14 DR. LEWIS: It's the median.
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| '15 DR. ROSS: Yes. The dotted line's the median.
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| 16 DR. LEWIS: I have no dotted line in mine. . kn I 17 looking at the wrong curve?- Ah, the previous one. Okay,-
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| 18 fine. I understand. So you're plodding medians and n 19 percentiles, then. These are not really percentiles. These 20 are percentiles on a log scale. Okay, so they' re not 21 percentiles. Now I understand. But that's true, then, 22 throughout, including the next curve. So you've abandoned 23 the Commission policy of using the mean to characterize 24 hazard.
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| 25 DR. ROSS: We use the mean. He's trying to show
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| i 176 1 it's the nature of the uncertainty at a given acceleration.
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| 1 2 1 51. CUNNINGHAM: What we used in the analysis is-3 'the probability-distribution, the entire distribution, not _
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| 4 just the mean, or the median or what have you.
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| 5 The third slide in this group is cimply a 6 comparison of the two mean values. The principle point of 7 this is to'show that for the Peach Bottom site, they're very 8 different based on the two sets of work.
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| 9 DR. SIESS: You qualified that. Is that the only 10 site at which they were very different?
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| 11 MR. CUNNINGHAM: I'm sorry.
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| 12 DR. SIESS: You said for the Peach Bottom site, 13- they were very different. Does that mean they are not 14 different at other sites?
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| 15 MR. CUNNINGHAM: They are also different at other 16 sites as well .
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| 17 DR. SIESS: That's what I would expect.
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| 18 MR. CUNNINGHAM: That's right. They are more 19 different at the Peach Bottom site than the Surry site which h 20 are the two we were particularly concerned with. So I put 21 this up as more of an extreme example -- that in this case 22 you see quite a bit of difference between the two. This 23 will reflect right through the analysis, the analysis of the 24 frequency of core damage, given one of these curves.
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| 25 DR. SIESS: This does not represent a difference
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| 177 h-L1! - in' expert opinion. 'We're off the expert panel business now..
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| 2 .This~ represents a difference in technique for arriving at 4
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| .3 these things.
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| 4 MR. CUNNINGEAM: Both of these curves, both of 5 these' sets of' curves, the Livermore set and the EPRI set,
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| 6 were developed using expert judgment.
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| 7 DR.'SIESS: But by a completely different process.
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| 8 .MR. CUNNINGHAM: -By different processes. Again,
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| .9 -this was done --
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| '10 DR. SIESS: It was grouped differently.- <
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| 11 MR. CUNNINGHAM: Yes. -Different sets of panels, i L12 They also had different' assumptions on --
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| 13 MR. WARD: Different assumptions on:what?
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| MR. CUNNINGHAM: The EPRI panel considered, I
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| { j ' 14 "15 'believe,Jthe initiating event frequency, if you will, didn't 16 consider as a panel the transmission of a seismic energy 17 source through the ground.. Whereas the Livermore curves had 18 panels considering both sets'of issues. There was a 19 difference in method in that sense here. iney are a lot of 20 other differences.
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| 21 MR. WARD: They subdivided the --
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| 22 DR. ROSS: The zonation --
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| !- '23 MR. WARD: -- differently there, too.
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| 24 DR. ROSS: The EPRI zonation was much higher. Our 125 Appendix, C-11, goes into this in a bit more detail. The
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| ,a kJ 1 review of the EPRI methodology has essentially been )
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| i 2 accomplished by the licensing office of NRC, I believe with l 3 a few exceptions of not a cataclysmic nature. They're 4 prepared to accept its use. 1 j
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| S MR. CUNNINGHAM: Licensing is prepared to accept I l
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| 6 the EPRI. ]
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| I 7 DR. ROSS: With some exceptions, that I don't 8 thing big, but I don't have them with me. Leon Ryder is 9 responsible for preparing the evaluation. It isn't written 10 off on that.
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| 11 DR. SIESS: But keep it in context. They accept 12 it essentially for the seismic margin studies. i 13 DR. ROSS: True, except how you would use this in
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| (~} seismic margins is not yet revealed, because you don't need v 14 15 a hazard curve explicitly for margins.
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| 16 MR. WARD: You say these two are derived by 17 different methods. I see they're also derived by different 18 institutions, 19 MR. CUNNINGHAM: Different institutions.
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| 20 MR. WARD: And I guess I might explain the 21 difference in che curve if you consider the institutions. I I
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| l 22 don't know if I'm being cynical or not, but is there some I
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| 23 sort of similar explanation you can -- difference in 24 methods. I mean, would methods used by EPRI tend to give 25 you a different -- from methods used by Livermore.
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| ( f 21 DR. SIESS: What:you're saying that if Livermore 2 had organized their expert groups and-run it in the same way 3 as EPRI would, they would still come out with this much 4 difference.
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| 5 MR. WARD: Yes.
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| 6 DR. SIESS: Would the regulatory basis have still 7 been in there.
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| 8 DR. ROSS: One thing, I' d urge the Committee to, 9 in the future when you're doing your detailed substantive 10 review of the report, to allow a bit more time. But there's 11 a message that you can't get from looking at the slide.
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| 12 Comparing means may be a fairly poor way of looking at the 13 problem. The story is deeper-than just one means higher
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| =cg 14 than the other.
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| L) Did the uncertainties that they 15 DR. LEWIS:
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| 16 generated differ a great deal?
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| 17 DR. ROSS: I'm sorry, Hal.
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| l 18 DR. LEWIS: This just shows the means. They each 19 produced a full curve, including uncertainties.
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| 20 DR. ROSS: There is an uncertainty depiction. 1 21 don't know i f we put it in this graph, due to seismic.
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| 22 There's a rectangle. And core damage frequencies ere l 23 computed at different percentiles, if that's what your 24 question is.
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| 25 DR. LEWIS: No, not. I'm wondering Livermore and E Heritage Reporting Corporation I ~
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| .(Q _/ 1 .EPRI produced different uncertainties in their curves.
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| 2 Because this sort of thing can come about if.they even had 3 .very similar medians, but big difference in uncertainty. 8 4 'That would make the means separate by a great deal.. I'm 5 sort of_ groping through. q 6 DR. ROSS: At the risk of revealing.the punchline, 7 -the Livermore mean value curve is driven by one of five 8 ground motion experts whose equally weighted assessment 9 brings the whole mean value way up. That's the story you 10 need to spend a bit more time on.
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| 11 DR. SIESS: But that sounds bad until you realize 12 that that-expert did a far superior job of predicting ground 13 motion from-that last earthquake in Canada.
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| { 14 DR. ROSS: That's part of the presentation that we 15 have prepared to show you. I'm not trying to discredit him 16 in any sense. I'm just trying to say this is one of the i
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| 17 penalties you pay when you use expert opinion and use t 18 arithmetic mean of their assessments. My colleague to my 29 le f t , who is one of three people on one of these accident i
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| 20 frequency panels, sell the same thing when the thing is i i
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| 21 b2ing summed. The tails of his distribution are being l 22 influenced by the tails of the other expert. It's juvt part 23 of the price you pay.
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| 24 DR. SIESS: There's also the probability that that 25 expert was right. His values shouldn't be pulled down by l
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| 181 h .rN O '1; the other four.
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| 21 DR. LEWIS: That's the point I was going to
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| : 3. emphasize.
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| 4 DR. ROSS: We've seen graphs that could persuade 5 you to that end. But I'm telling you that the Butler did it 6 at the end of the book. Maybe you better wait and read the 7 whole book first.
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| 8 DR. SIESS: Actually, I wonder if this Committee 9 shouldn't look at that seismic issue somewhat separately 10 from 1150. You could almost separate the sides, and not 11 clutter up the 1150, 12- DR. ROSS: You sort of have a forum coming up 13 within the next 12 months. It's called the IPEEE Commission policy, which I'm sure the Committee will review.
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| (}.14 15 DR. LEWIS: The point that Chet is raising about 16 the expert elicitation processes, is really a deep and 17 fundamental one. Because these equally weighted delphic y
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| '18 techniques tend to give everybody equal weight, although we 19 know in our hearts that that isn't right. And the German 20 method of asking experts to rate each others expertise is a 21 way to try to get around that. And the other extreme way is 22 just not have experts, just find the best person you can and 23 take his word for it. And somewhere in there, there's a 24 good track record, and I don't think it goes with either 25 extreme.
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| 182 I
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| \4 1 DR. SIESS: It is, however,'of getting the 2 uncertainties broadened.
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| -3 DR. LEWIS: It's a.way of~getting an uncertainty.
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| 4 DR.EKERR: Gentlemen, we've used'up about half of 5 our time, and I doubt if the presentation is half finished 6 yet. .I think this is an important issue, but I would like 7 for us to go ahead with whatever we can out of this session 8 toward possibly writing a letter to the Commission.
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| 9' DR. SIESS: Of what?
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| 10 DR. REMICK: As we mentioned at the beginning, 11 it's to look at possible -- uses, while peer review process 12 is going on, the same thing we told the Commission 13 yesterday.
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| 14 MR. MICHELSON: Could you tell me in just a few
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| 15- words your position or approach on the fire initiated 16- external events. That's one of the two items on your' slide.
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| 11 7 They talk seismic ,and fire initiated events. And your 18 saying your using NUREG-4840. Just sammarize in a few 19' sentences what you're doing about fire.
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| 20 liR. MURPHY: The methodology we~use is basically 21 the same that was used in the station backup studies.
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| 22- MR. MICHELSO!I: But that methodology doesn't 23 reflect some of our understandings, or potential 24 understating, of how a fire and the fire hazards might 25 really behave. How will those eventually be factored into
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| ?. ; f1 - an appropriate fire PRA? Perhapslthes homework hasn't even L 2 >
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| been done yet with which to do the factoring in. But what's your plan.as.far.as 11507 'Are you going to use the old way.
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| i: 4 .of'looking at it?. Or is there any intention of.trying to 5- bring it up to date or use expert' opinions ~or do something?
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| 6 MR. MURPHY: I think this represents basically the, 7 state of'the art as to thentime'it was initiated, which was--
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| 8- roughly a year to a year-and-a-half ago. There's a 1
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| 9 continuing. problem in these areas where we'have a lot of 10 methodological development going on. You~can never catch up 11- to the state of the art. I'd rather publish'1150 using what-1:2 we have unless we find egregious faults on it, and then look
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| '13 at later~research-programs-to.make the' changes that are
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| 14 necessary.'as we learn more.
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| 15 !@R . MICHELSON: Thank you.
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| 16 MR. CUNNINGHAM: Joe's last point'there was 17 actually relevant to all the information we've been talking 18 about here. We've indicated in the report that.the 19 phenomenological data base and the medels, the methods, that 20 we're using were frozen as of about a year ago.
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| 21 m. MICMLSON: l'm not sure all of our Enowledge 22 was even factored inte those models of a year ago.- I think 23 the -- on fire are quite c. bit older than a year ago, hey
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| > were last frozen a year ago, but didn't reflect the latest 25 thinking a year ago, they reflected thinking considerably -
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| 2 DR. KERR: Please continue, Mark.
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| 3 MR. CUNNINGHAM: The last point on this slide is k
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| 4 'the approach that we've taken in the 1150 in analyzing 1 5 frequency of core damage from seismic events is that we've 6 done it twice. We've done in.using Livermore curves and 7 we've done it using the EPRI curve. You'll see the results 8 like that in a little bit.
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| 9 One last difference in assumptions, or methods, 1 10 that I should talk about is assumptions on offsite 11 protective actions. This figure shows essentially the l 12 assumptions that we made in terms of immediate response and 13 long-term interdiction of crops and land.
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| rx 14 The principle difference between this and the
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| 15 draft is that number right there. In this analysis we're 16 assuming that one-half-of-one-percent of the people are not 17 involved in the initial evacuation. In the draft report, we 18 assume that five percent of the people would not be 19 involved.
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| 20 We've received considerable criticism that five 21 percent was not justi fi ed, it was too very, very 22 conservative. A half-a percent was based on analysis of I 23 event where at the Waterford Plant, I believe, where the 24 Waterford nuclear emergency plan was used in response to a 25 chemical accident near the plant. !
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| 185 We went back to look at see how many people did 1?
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| '2' not participate in the-initial evacuation. That came out to 3 .be quarter or a half-a percent. That's the basis that we 4 have here.
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| 5 The results that you see in early fatalities can 6 be very sensitive to that assumption of how many people 7 don't evacuate immediately. It also can be very sensitive 8' to the warning times that you have. So you'll see 9 . differences between plants because of difference in the 10 types of accidents that we think are going to be most 11- probable, and warning times association with it to.get the 12 evacuation started.
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| 13 DR. REMICK: There's something I don't understand
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| (^ 14 .there. Are you assuming that evacuation is called for? Or
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| 15 if the plant calls for sheltering, would you assume 16 sheltering? I'm not sure what you're saying here.
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| 17 MR. CUNNINGHAM: We're assuming that if the plant 18 goes into a general emergency, that this evacuation will 19 start with seme delay time; there's a warning time.
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| 20 DB. REMICK: You're assuming that evacuation would 21 be called for in contrast to sheltering.
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| 22 MR. CUNNINGHAM: That's right. In the report in a 23 couple of places, we have sensitivity studies on the 1 24 effectiveness of the evacuation, on the relative l
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| 25 effectiveness of evacuation versus sheltering, what have j i
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| 186
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| .1 you. So the risk is shown, I believe, in the plant specific 2 chapter three through seven. I'm sorry it's not in there 3 now; It will be for the published version. But there is 4- some information in chapter 11, I think it is, on different 5 evacuation assumptions.
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| 6 Again, we are sensitive. The risk results, in 7 general, are going to be sensitive to some of these things.
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| 8 DR. LEWIS: Am I wrong-in believing that NRC 9- policy does not provide for automatic evacuation.
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| '10 MR. CUNNINGHAM: That's correct. It's not 11 automatic; it's recommended.
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| 12 DR. LEWIS: No, it's --
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| 13 MR. CUNNINGHAM: I'm'sorry, it's not.
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| 14 DR. LEWIS: It's a judgment matter.at the time of 15 the event.
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| '16 MR. CUNNINGHAM: It's a judgement matter, that's 17 correct.
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| 18 DR. LEWIS: So this is a fairly radical 19 assumption.
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| 20 MR. CUNNINGHAM: I wouldn't say it's a radical 21 assumption.
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| 22 DR. LEWIS: I would.
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| 23 MR. CUUNINGHAM: When the licensee gets to the l-1 24 point of having a general emergency, there's a decision that 25 has to made on their part and on the part of local and state i
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| R Ts/ 1 officials as to whether or not to call for'an evacuation.
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| 2 What we assume is that, yes, in the cases that where they 3 'get to a general emergency --
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| 4' DR. SIESS: It's always an evacuation.
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| 5 MR. CUNNINGHAM: It's always an evacuation.
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| .6- DR. SIESS: 'No sheltering permitted by the U 7 Commission' ruling?
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| 8 MR. CUNNINGHAM: I'm sorry,.what?
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| 9 DR. SIESS: It is-not possible simply to shelter 10 people?
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| 11 MR. CUNNINGHAM: Yes, it's possible to shelter.
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| 12 DR. LEWIS: But that's not assumed here.
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| 13 MR.- CUNNINGHAM: In the analysis here it's assuming that evacuation is the preferred --
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| } 14 15 MR. WARD: Do any utilities actually'have plans 16 that involve sheltering?
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| 17 DR. ROSS: We had a drill last wtek, a w(iek 18 before, involving South Texas, and we got the general 19 euergency and the drill. And they had a precautionary 20 evacuation in the drill out to five miles, but there was 21 some sheltering, I think in the-keyhole, from five to ten.
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| '22 I think there's a lot of flexibility.
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| 23 MR. CUNNINGHAM: Again, we tried to acknowledge 24 that in the report by showing the consequence and the risk, 25 assuming different protective actions, early protective
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| li R 1 188
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| ( 1 actions be it sheltering or a complete evacuation or'an 1 -p 2' incomplete evacuation.
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| '3 MR. WARD: Mark, you said the Waterfor'd 4 experience, or the near Waterford experience and: actual- '
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| 5 evacuation confirmed 99,5 -- 'Isn't that.what'you saidla few- ?
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| k 6 minutes ago. !
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| 7 MR. CUNNINGHAM: I wouldn't put it'quite that way.
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| '8 DR.'KERR: He said the Waterford plan was.used in
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| : 9. ' evacuation'in connection with a chemical release.
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| 10 MR. WARD:- Yes.
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| 11 MR. CUNNINGHAM: I won't say that justified.that.
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| .12 That was'the basis for that 99.5.
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| 13 MR. WARD: That-was the basis for 99.5.
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| 14 MR. CUNNINGHAM: That was the basis; that's right.
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| }
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| 15 DR. REMICK: Did'you look at the Susquehanna case?
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| 16 There.was a similar evacuation here. The Susquehanna Plant 17 with a chemical fire about two years'ago. Do you have any 18 data on that?
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| 19 MR. CUNNINGHAM: The data we have was just for the 20 Waterford event. >
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| 21 DR. REMICK: I see.
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| l 22 DR. KERR: Mark, I'm sorry. Would-you put that 23 last slide on. I didn't understand what was meant by those.
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| 24 When you said to avoid doses of, does that mean doses of 25 more than or does it --
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| l ', 1 189 dr' 1 MR. CUNNINGHAM: Yes.
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| 2 DR. KERR: Thank you.
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| 3 MR. CUNNINGHAM: I will discuss for basically the
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| -4 remainder of the presentation here, some differences in
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| 'S results. I'm going to shore that in terms of core damage 6 frequencies. containment performance, risk and then 7 ' comparisons with the safety goals.
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| 8 This slide compares the core damage frequencies 9 for the five plants, the 1987, the original draft of 1150 10 versus the current second draft. For some of the plants, 11 you'see essentially no difference. Surry, Sequoyah, are not 12 very different between the two drafts. Grand Gulf is 13 probably the most dramatic in the sense that it dropped by l- 14 perhaps, roughly in the order or magnitude, something like
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| ~
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| 15 that, in the mean. That was principally driven by 16 modifications to the plant that were taken on by the i 17 licensee after seeing the draft results. They went in and 28 nodified the fire water system, I believe, so that it could 19 be used in emergency core cooling system. And it was an 20 emergency core cooling mode.
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| 21 MR. WARD: So that's not a differencs in 22 methodology.
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| 23 MR. CUNNINGHAM: That's not a difference in 24 method; that's right. Embedded in these are differences in ,
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| l 25 methods and difference in plant design. It's al mixed
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| 190 j 1 together here. So in that case it was principally 2- differences in design and operation.
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| 3 In the Zion case, core damage' frequency went up i
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| .I 4 somewhat. This was based on, I would say, more analysis,-
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| 5 that the dominant accident sequence in the Zion plant 6 involves loss of pump and cooling water, and reactor. coolant 7 pumps seal failure. And the modeling for reactor coolant 8 pump seal failures was considerably changed from the draft 9- of the final -- to draft to the final, to draft to the 10 present version. And that had somewhat of an increase --
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| 11 led to somewhat of an increase in core damaga frequency.
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| 12 I should note, though, that since, well, in the-13 last month or two, Commonwealth Edison had indicated that 14 they intended to make modifications to their plant that will
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| : 15. eliminate-the dependency that was identified in 1150. We 16 expect, depending on how they make those modification, the 17 core damage frequency will come down; the mean will come 18 down roughly a factor of two to six.
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| 19 DR. LEWIS Could you help me understand these 20 displays. These are 5th and 95th percentiles according to
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| .31 whatever distribution came from concatantting the 22 distributions of everything that went into the calculations, I 23 which can be done on a computer. Presumably, it ends up 24 something approximating log normal, but it isn't precisely, 25 because you've done it right.
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| h L , 191 1 MR. CUNN'INGHAM: Some cases it is and some cases li L 2' it's'not' '
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| 3 DR. LEWIS: Now if the 5th to 95th percentiles
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| .4 differ by-less than an order of magnitude, which is the case l
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| 5 for many of these things, that's approximately four sigma in
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| '6 the logs, so that's a very, very high claim for accuracy, 7 really quite remarkable.
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| 8 MR. CUNNINGHAM: Yes.
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| 9 ~ DR. LEWIS: Do you believe.that it's true, that 10 these results are good to better than a factor of two?
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| 11 MR. CUNNINGHAM: Do I?
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| 12 MR. MURPHY: Let me give a personal view.
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| 13 DR. LEWIS: Factor of two. They've got four sigma 14 in less than one order of magnitude.
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| 15 MR. MURPHY: I think as long as you've recognized 16 the things the PRA does not do well, and the things that 17 are, therefore, not part of the analysis.
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| l 18 DR. LEWIS: I've heard something about the 19' subject.
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| 20 MR. MURPHY: I think for the analysis of what was 21 done, these are correct representations. I think you can 22 notice, as we've gone from the '87 version to the present 23 version, in almost every case the uncertain band has 24 increased a little bit. Again, that comes from better 25 modeling and looking for more things.
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| l 192 l' ,DR. LEWIS: But I'm talking about the actual.
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| l-l 2 representation of the uncertainty. I. notice that it's gone 3 up a little bit. But when you fit an order of magnitude in 4 between the 5th and 95th percentile, on' roughly a log normal l-L 5 curve, and I'm not-going to quarrel, it's bound to come out 6 something like that. That really is a small sigma in the 7 log. In particular, it's far better than what was claimed 8 by WASH-1400, example. Okay, I'm just noticing. l n 9 MR. CUNNINGHAM: I would tend to agree with Mr.
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| : 10. Murphy in the sense that biggest --
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| 11 DR. SIESS: Why does Zion keep getting worse every 12 . time you do a PRA?
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| 13 MR. CUNNINGHAM: That's what I mentioned before.
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| J In this case, in the Zion case, it was a difference in the
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| } 14 15 way that.the failure of the reactor pump seals were treated 16 in the analysis.
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| 17 DR. SIESS: The PRA they did on Zion, they didn't 18 even have that; did they?
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| 19 MR. CUNNINGHAM: I'm sorry.
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| '20 DR. SIESS: The first PRA they did on Zion, they 21 didn't even have reactor coolant pump seals.
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| 22 MR. CUNNINGHAM: That's correct.
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| 23 MR. MURPHY: The First PRA did not identify their 24 dependency. One of the things that happened here is in the 25 expert elicitation process, we were faced with the question
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| )
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| l 193 l
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| ) 'l .of'the. likelihood of failure of low-pressure piping in the
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| : 2. l conforming cooling water system. The result of theLexpert 3 elicitation was to cause that failure ~ rate to go up from the 4 '87? report, by roughly a factor of two in terms of the mean 5 value for that.
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| 6 DR. SIESS: The failure of low pressure piping is 7 an area where we don't have enough data. You have to use 8 experts?
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| 9 MR. MURPHY: We felt that that was the case,.and' 10 that there's very.few failures reported. But we do know 11 that --
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| 12 DR. SIESS: It's not how many failures are 13 reported, it's how many years of -- how large the data base 14 is. If'there are no failures, you've got a large enough 15 data base, you've got a pretty good information --
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| 16 DR. KERR: Professor Siess, can I ask:one area 17 because'it's very short. I think the whole ---about 10 18 pages long, the summary of the elicitation. It's a good 19 example to read as to what the procese was. It goes into 20- the question of presence or absence of data.
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| 21 MR. SHEWMON: What he's concerned about is why you 22- won't have better data --
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| 23 MR. MURPHY: The problem is that we're talking 24 about numbers in ten to minus four to ten to minus six per 25 year range. That's the area in which the experts had most
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| 194 i 1 of their distributions. It takes a lot of light years to 2 give you date that ends in that area. And the experts were 3 worried about' unusual mechanisms, an example being the 4 erosion of the piping in the feedwater systems ~that wo've 5 experienced recently, that we might not have thought.of yet.
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| 6 The experts generally had a feeling that they hated to get 7 down into the ten to minus seven, ten to minus eight per 8 year range, because they didn't think those numbers made a 9 heck of a lot of sense. I was one of the panelists and I
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| ' 10 - think all of us on there felt that way. At some point the 11 numbers approach theology rather than science.
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| 12 So the upper ends of the distribution tend to be-13 driven by the possibility that those mechanisms that we j ) 14 haven't thought of yet would cause failure of component, 15 including water piping. And it made an allowance for such 16 an occupance.
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| 17 The end result of this was a highly skewed 18 distribution. The difference between the mean and medium 19 was well over an order of magnitude. For some experts, the 20 mean fell outside of the 5 and 95 percent spread because of 21 the skewness of the distribution. And because one of the 22 experts-had a high total, when you're aggregating three 23 people and grading them equally, the aggregate mean can't be 24 less than one-third of the highest member. And he tended to 25 drive that up.
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| 195 )
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| ) :1 I think it's important to note, though, as Mark
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| '2 said, that Commonwealth Edison has reacted to this by 3' providing -- by making a commitment to providing independent s 4 cooling for the charging pump, oil coolers, which is one'of 5 the problems associated with this. And that will U 6 effectively lower the frequency of the sequence failure a 7 substantial amount. approaching -- well, I guess you said a 8 factor of two to six.
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| 9 DR. LEWIS: So they're responding in hardware to a 10 skewed expert opinion distribution.
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| 11 MR. MURPHY: That's true.
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| 12 MR. CUNNINGHAM: They're responding in hardware to 13 a dependency of a system where they can have one failure 14 leading.to a small LOCA and defeat of the emergency core 15 cooling system that's required to respond to it.
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| 16 DR. ROSS: I asked their Executive Vice-President 17 more or less the question you just asked. I~said, "Are you 18 just trying to get out of the pickle you' re in with respect 19 to 1150 or is this a good idea?" And he said that he 20 thought the fix was a good idea and 1150 had never been 21 published; but he had done an IPE, which he was going to do.
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| 22 He would have proposed this as part of his IPE submittal.
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| -23 DR. LEWIS: I was not suggesting that it was a bad 24 idea just because it came up in connection with 1150. So 25 I'm prepared to believe it's a good idea. I'm just
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| 196 m
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| (-) 1 impressed that the time connection makes it look like a 2 cause-effect relations in which case one wondered --
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| 3 Let me just add one other thing, and that is the ;
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| i 4 difference between the mean and the medium. I understand l 5 that. One of the reason, I think, that you're getting such 6 apparent extraordinary accuracy is that the process, which 7 takes a batch of things and which there are orders of 8 magnitude on certainly and adds them up, automatically gives 9 you the effect of, in effect, the square root of N. It 10 keeps reducing the apparent uncertainty. That's known as 11 the Emperor of China syndrome in statistics. And I think 12 that's why it's given you the apparent claim to factor of 13 two accuracy. There's a difference between precision and accuracy, as you know. I think I understand that here.
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| ( } 14 15 DR. ROSS: Dr. Remick, we want to make sure we 16 have enough time to discuss uses. I'm wondering if at 2:30 17 we shouldn't just interrupt this technical presentation and 18 make sure we have --
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| 19 DR. REMICK: I would think, scanning through the 20 slides, people can, I think without even --
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| 21 DR. ROSS: I understand.
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| 22 DR. REMICK: They can go through themselves, and 23 if they have questions, then 24 DR. ROSS: Maybe we should pick out in the next 10 25 minutes, maybe the more provocative things, and skip to I
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| 197 b 1 them.
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| '2 DR. REMICK: Right. 'Because what comes later on-3- this afternoon,Lwe must: keep on schedule of being finished 4' here.at 3:10.
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| 5 DR. KERR: Let me ask about one' thing which may be
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| ' fi - one of the provocative things you're going to talk about.
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| 7 In our discussion of the first draft, I believe the 8 statement was made that the staff had concluded that one
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| '9. -could really not tell anything, or certainly not very much l'0 about plants that have not had'PRAs by looking at these five 11 plants that had careful analysis. In effect, there was so 12 much difference that one could not draw general conclusions.
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| 13 Is that still the staff position after having done the work leading to draft 27 And if you're going to answer that
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| { } 14' 15, later, I will wait.
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| ~16 MR. MURPHY: I answered it last time. I'll answer 17 it again.
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| 18 lt think the results are very highly plant 19 specific. I don't think it's as black and white as you can 20 .say there's nothing you've learned from these PRAs as 21 applicable to any other plants. That clearly isn't true.
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| 22' But also clearly the numerics are very, very plant specific 23 and they deal with design details.
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| 24 I think we have found a number of insights that 25 are scattered throughout 1150. There is a lengthy Heritage Reporting Corporation (202) 628-4888 L-______-____________. - _ _ . - _ _ _ _
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| 198 t
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| '1' discussion, I'believe in chapter 8 dealing with the accident 2 frequency analysis. The kind of interactions we have found 3 to be.important, the kind of dependencies that, for one of a.
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| 4 .better word, .had the potential to bite you. I think those 5 are basically generically applicable .. They're the kind.of 6 thing that says if you're looking for dependencies, at least 7 -look for the.ones that we've found before to-make sure,they; 8 don't exist in your plant. To that extent, they're very 9 applicable across the board. But you just can't look at the
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| ' 10 results of one plant'and assume the same-number'will apply 11 to another.
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| 199 (m
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| ! ,) 1 DR. LEWIS: I don't think you anyone has taken the 2 really dumb position that you used as your extreme that one 3 plant's PRA applies, you know, lock stock and barrel for 4 another. But it's also true that the commonality doesn't 5 have to be sought by looking for sequences which are coumon 6 to the two plants.
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| 7 The statistical commonality comes from the fact 8 that you've got one sequence for one plant, one for another 9 plant, one for ability at one plant, and one for another, 10 and statistically they add up to a picture of the plant. So 11 that there's some information you get about the population 12 from two plants, as was the case in WASH 1400, and even more 13 you get from five.
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| l es 14 And the point is to not throw extremes around but
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| 15 to be quantitative and deciding just what it is you do 16 learn. I think the Commission is very interested in what 17 you learned about the population from this study. So I 18 think it pays to do some serious work to try to do more than 19 just identify common sequences.
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| 20 MR. MURPHY: Well, I agree with that completely.
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| l 21 MR. CUNNINGHAM: What I will do is put up the next 1
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| 22 couple of slides and then skip over a number of them.
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| 23 We talked awhile ago about the Livermore EPRI 24 hazard curves. This picture shows the impact of the 25 different curves on the core damage frequency distributions
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| 200
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| ) 1 for whichever and whichever. Peach Bottom is at the bottom-2 and Surry's at the top.
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| 3- MR. MURPHY: If I may, Mark, there's an important
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| : 4. -point'tolbe made as you look at the two hazard curves. In 5: thatfif you look at what sequences are driving the risk, 6 what type of failures are driving the risk looking at both 7 sets of curves, it's driven by the same thing. So the
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| -8 vulnerabilities-identified are the same although the 9 numerics are different.
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| 10 MR. CUNNINGHAM: I' won't pursue that one further,
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| 'll then.
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| 12 This slide shows you the conditional probability L 13 ' of early containment failure given a core melt at each of
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| ' 14 - -
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| the plants. The ones that are partially shaded here, if you 15 will, tend to be on the left, are from the present version 16- of the report. The open ones are from the draft' report.
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| 17- The biggest changes occur in Surry where we have seen now a 18- substantially lower probability of early containment failure 19 than in the draft.
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| 20 This is tied in'in the draft report.
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| -21 DR. KERR: The one on the left is the second 22 draft?
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| -23 MR. CUNNINGHAM: Yes, the one on the left is the l
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| 24 present draft.
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| 25 DR. KERR: Thank you. j i
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| 1 MR. CUNNINGHAM: In the 1987 draft, direct 2 containment heating was identified as a major threat to the l
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| l 3 Surry containment based on analysis performed since then, l
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| l 4 analysis of the containment structure and containment loads, 5 and analysis of the potential for the reactor coolant system 6 being depressurized before the reactor vessel lower head 7 fails have led to the conclusion that direct containment 8 heating is not as significant a threat to the Surry 9 containment as it was in the '87 draft. t 10 DR. KERR: And I could conclude from that that the 11 conditional probability of failure for Peach Bottom and 12 Grand Gulf is somewhere between zero and one?
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| 13 MR. CUNNINGHAM: That's what this is saying, yes, fw 14 In the case of Peach Bottom, where I showed you U
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| 15 the six experts before, the six experts considered the issue 16 of containment performance and the potential for dry well 17 shell melt through at Peach Bottom. that's the physical 18 mechanism that's occurring that's causing this containment 19 failure, hypothetically, that Peach Bottom is dry well shell 20 melt through.
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| 21 In the dominant cases for station blackout and 22 others, you had six experts. Three believed that dry well 23 shell failure would occur essentially every time, you had 24 three experts believe that it would occur never. So this 25 distribution is bimodal. There's a great deal of
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| '202 h : 1' distribution up here, a great deal down here, almost none in' 2 the middle. It was either going to occur or.wasn't going to 3 occur.
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| .4 DR. CATTON: What side of the fence was George 5 Greene on?
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| 6' MR..CUNNINGHAM: I'll let you guess on that.
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| 7 MR. WARD: Mark, what's the -- let's see, this is-8 the conditional probability of failure. And how is the i- 9 challenge-defined? I mean, conditional probability.given 10 what?
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| 11 MR. CUNNINGHAM: Given a core melt.
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| 1 12 MR. WARD: What kind of core melt?. I mean, that's 13 what Ifm driving at. How do you get that?
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| 14- MR. CUNNINGHAM: This is based on in'a sense of we 15 took there's a conditional probability of core melt given a 16 station blackout or given a large LOCA, what have you. This 17 is the frequency rated average of those. So that it's --
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| 18 MR. WARD: This is a core melt that is proceeded 19' to melting through the bottom?
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| 20 MR. CUNNINGHAM: Yes, that's right.
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| 21 DR. ROSS: The elicitation is.in the form of a CDF 22 as an ordinate and the time after vessel failure is the 23 abscissa. So there's a vessel failure in the elicitation.
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| 24 MR. WARD: So the low probabilities aren't because u 25 it didn't even get out of the vessel?
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| 6 L 203 q 1- MR. CUNNINGHAM: That's right. In this case, it's'
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| '2 ' assuming essentially'that you've gotten out of the vessel.'
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| : 3. DR. CATTON: But it didn't get all the way across 4' the floor. This is highly sensitive. Whether it's going to 5 fail or not is very sensitive to the amount and temperature 6 rate?
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| 7 MR. CUNNINGHAM: -Yes.
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| 8 DR. CATTON: What did you give your expert panel?
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| '9 MR. CUNNINGHAM: We gave them a series of case 10- studies with different assumptions on amount of mass 11 involved, amount of superheat in the melt, zirconium content 12 in the melt. I think there was high pressure low pressure 13 in the reactor pressure vessel at the time of failure.
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| () 14 There may have been other. parameters. And they were to 15 define these conditional probabilities for each of those 16 . cases individually.
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| 17 DR. CATTON: Is this just for a particular one of 18 those cases?
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| 19 MR. CUNNINGHAM: This is for the frequency 20 weighted average of all those cases. Each of those cases 21 ended up with a particular --
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| 22 DR. CATTON: Then don't you have to weight the 23 initial conditions and then weight ~what they do with it?
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| 24 MR. CUNNINGHAM: Yes. That's right. They are 25 weighted. All of that weighting is embedded in this. This
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| 204 1 is a very simplified display.
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| 2 DR. ROSS: Well, now look, this discuesion could 3 take hours, and we just don't have time to get into it.
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| 4 'DR. CATTON: No.
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| 5 MR. CUNNINGHAM: If you go into Appendix C --
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| 6 DR. ROSS: We' d be ' glad to do so. We just don't 7 have time this afternoon.
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| i 8 DR. CATTON: It's not necessary.
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| r 9 MR. CUNNINGHAM: Appendix C in 1150 discusses --
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| 10 Section 8 of Appendix C discusses how, what information was 11 used in the drywell shell failure, who considered it and the 12 different cases, and the conditional probabilities for the-13' different cases. That's where the information is,-at least-14 in.1150.
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| 15 DR. KERR: Mark, on a different subject, the 16 contribution of the interfacing LOCA seems to be 17 significantly greater for the second draft than it was in 18 the first draft if I'm interpreting things correctly.
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| 19 MR. CUNNINGHAM: For Surry? Yes, for the PWRs.
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| 20 Surry and Sequoia.
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| 21 DR. KERR: And this appears to be driven by, among 22 other things, a greater frequency of occurrence on the part 23 of --
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| 24 MR. CUNNINGHAM: No.
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| 25 DR. KERR: Well, you tell me what it is driven by, O aerie 9e aeverti 9 cerror eio=
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| 2 MR. CUNNINGHAM: Two things: one, the impact of 3 containment bypass is greater today because this impact is-4 -so much less, especially in Surry. If you had the early 5 containment failures occurring with high probability, the 6 impact of the bypasses is relatively diminished.
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| 7 DR. KERR: Oh, I see. So it was affected, the DCH 8 is out which contributed.
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| 9 MR. CUNNINGHAM: That makes the bypass more 10 important.
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| 11 DR. KERR: That's one of the things.
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| 12 MR. CUNNINGHAM: There's a second aspect. There's 13 a set of accidents involving an' initial steam generator tube 14- rupture which is a bypass with subsequent human errors 15 leading to a core melt that was, it's in this. version of the 16 report, it was not in the draft report. So there's another 17 accident sequence that comes into.that containment bypass.
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| 18 Today, the most important risk important accidents 19 in Surry -- not Sequoia, are --
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| 20 DR. KERR: How did one get at the frequency of
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| 21 that event? Was that' expert opinion?
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| 22 MR. CUNNINGHAM: The frequency of the?
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| 23 DR. KERR: Steam generator tube bypass?
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| 24 MR. CUNNINGHAM: The tube rupture was based on the 25 limited data that were available. The rest is a series'of
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| : 1. . ' l' human errors. I don't believe -- they were not expert l 2 panels, they were using'some of what I call standard human i
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| 3 reliability models. u 4' DR. KERR: Thank you.
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| 5 MR. CUNNINGHAM: There are a large number of 6 figures'in here that show different risk measures for the 7- individual. plants from 1987 to 1989.' What I propose to'do
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| : 8. is just skip towards the.end where the show the comparisons.
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| 9 This is the comparison with the individual latent cancer 10 fatality safety goal. The. safety goal is the horizontal
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| .'11' line here. In the '87 draft they were well below. In-the 12 '89 version they dropped perhaps'even somewhat more.
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| 13 This is a similar figure for the early fatality 14 safety, goal. It's not new to see that the early fatality 15 safety goal, risk from plants tend to be closer to the 16 safety goals for the early fatality measures than the latent 17 fatality measures. That's not an unusual thing.
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| 18 Again, wo see decreases from '87 to '89. You see 19 Peach Bottom and Grand Gulf that have dropped rather 20 considerably. From what we can tell at the moment, that's a 21 combination of the decreased core damage frequency,- and the 22 assumptions on the non-evacuation fraction.
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| 23 DR. REMICK: And what's the effect in Surry and 24 Peach Bottom with the external initiators?
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| 25 MR. CUNNINGHAM: As Dr. Ross said, we didn't Heritage Reporting Corporation (202) 628-4888
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| (-) 1 consider seismic risk at this point. ;
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| 1 2 DR. SHEWMON: -- five minutes ago on core damage i 3 frequency that has gone up on the risk to the public it's 4 gone down between '87 and '89. Is the -- more comforting 5 now than it was?
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| 6 MR. CUNNINGHAM: Yes, that's the difference. J 1
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| 7 MR. MURPHY: Yes. But one other aspect is that in i;
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| 8 Zion, the one that went up had to do with the loss of j 9 component cooling water and the sealed LOCA. You have 10 containment sprays available in that type of sequence so 11 that while it was a dominant sequence from a core melt 12 standpoint, it wasn't very important from a risk standpoint.
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| 13 DR. REMICK: Denny, are we going to switch to uses
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| /~T 14 at this time?
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| U 15 DR. ROSS: Do you see the probability of a large 16 release?
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| 17 MR. CUNNINGHAM: Yes. A probability of a large 18 release. Using the definition of I guess it's at least one 19 early fatality, potential for at least one early fatality, 20 the goal here in ' 87 and the ' 87 --
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| 21 MR. WARD: Are you calling that a large release? !
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| 22 MR. CUNNINGHAM: That's, that was the definition 23 in '87 that was believed by the staff to be the most 24 (;ppropriate. It's my understanding that the Staff has 25 considered that a lot over the last couple of years, and [
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| l 208 h
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| 1 they've come back to basically that same definition as a l
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| 2 definition.
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| 1 J
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| 3 DR. LEWIS: We'll have something to say about 4 that.
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| 5- But what is meant by " potential"?
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| 6 MR. CUNNINGHAM: To me, it's the probability of 7 one or more early fatalities in there.
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| 8 DR. LEWIS: I'm sorry. The potential for an early 9 fatality means an early fatality?
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| 10 MR. CUNNINGHAM: To me it does, yes.
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| i 11 MR. MURPHY: As we've defined it for this study, 12 it's the probability of one or more -- l 13 MR. CUNNINGHAM: Early fatalities.
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| ~N 14 DR. ROSS: You're talking about the implementation (d
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| 15 paper uses the word " potential"?
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| 16 DR. LEWIS: Yes, it does, and I don't understand 17 the word. Because a power plant sitting out there working 18 has the potential for one fatality.
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| 19 DR. ROSS: To quote the late Saul Levine, it may 20 be a distinction without a difference.
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| 21 DR. LEWIS: I'm just quibbling about words.
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| 1 22 DR. ROSS: Yes, well it wasn't much of a response, 1
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| 23 either. I admit that. But I mean, -- on to uses.
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| 24 DR. KERR: Okay, on to uses.
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| 25 DR. ROSS: We can turn the lights on now if you'd
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| 209 1 like. The' summary isn't necessary to go into.
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| 2 I've got one thing to say on Uses. Chapter 13 3 unfortunately has 13 pages in it which dwells a little bit 4 more on uses. But I think the best thing we can do is see 5 do you have some questions you'd like to ask us on uses, 6 that is.
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| 7 MR. WARD: How do you plan to use it?
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| 8 DR. LEWIS: What are you' going to do with this 9 mess of potage?
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| 10 DR. ROSS: There's been a lot of dialogue back and ;
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| 11 forth. I think in the last few months, we've been fairly 12 consistent on the subject of uses. And the blurbs that are 1
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| 13 on page 13-1 are the same as in a status report we sent to the Commission on March 14th. And in fact, it's also h } 14 15 included in the Charter to the Special Peer Review. And we 16 list -- I assume that the Committee has this. I hope you l 17 do.
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| l l 18 Do you have anything in writing at all from us or 19 the Commission on this topic? l 20 DR. KERR: I gave at the last meeting we had.
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| 21 DR. ROSS: Presentation, okay, on uses.
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| 22 DR. LEWIS: I can't swear I don't have it.
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| 23 DR. ROSS: We would have received it, what, in the 24 last week or so?
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| 25 Well, Dean's going out there real quick to make l
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| 1 I
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| j 210 ;
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| _1 some copies. But by and large, it's connected with the 2 Commission's integration plan. A lot of this is extracted 3' .directly from the Commission's Severe Accident Integration l l
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| 4 Plan which is referred to at SECY 88-147, and we talk about 1
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| 5 using the report to help to develop guidance for IPE, both l l '
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| 6 internal'and eventually external IPEEE. Using it to develop 7 the containment performance improvement program and the 8 accident. management program as input'to safety goal policy.
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| 9 And then there's some subsidiary uses about 10 prioritization of research prioritization of generic issues.
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| 11~ That's a real broad picture of the uses. Now, I think l
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| 12 there'll be an additional uses, which is really not what '
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| 13 we're asking for. I suspect that one or more of the i
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| -(T v 14 utilities will use this in part, and maybe in large part as 15 a submittal, a resubmittal back as an IPE. But that's not 16 our, we didn't care whether they did that or not.
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| 17 DR. KERR: Denny, let me see if I understand. You 18 say that these can be used in IPEs. And I can see that in a 19 sense that they are PRAs, if one chose to do a PRA, one 1
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| 20 might use these.as a method of learning how to do a PRA or 21 knowing what to look for.
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| 22 But I can't see that these would be any more-23 useful than any other well-done PRA in determining how one 24 goes about doing a PRA for a plant. So you apparently don't l 25 mean that. What do you mean when you say --
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| 211 1 DR. ROSS: I think that's a true statement. If 2 we'd had five recent PRAs that we were comfortable with and 3 understood well, and thought they were pretty good stuff, 4 they would have done just as good.
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| 5 DR. KERR: Oh, okay. So.
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| 6 DR. ROSS". Now, the one thing that is different, I 7 think, is the updated methodology, severe accident 8 phenomenon methodology. You know, some of the older PRAs
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| '9' don't take into account recent phenomena.
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| 10 DR. KERR: Yes, but I thought, my impression is 11 that the way the source term is treated in 1150, for 12 example, is still rather arbitrary. And indeed this method 13 was-adopted as a matter of convenience because of time and 14 resources.
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| 15 Isn't that the case?
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| .16 DR. ROSS: Well, that may be just a tad bleak.
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| 17 Certainly, you know, the driver code, the MARCS code has got 18 some very crude approximations in terms of key accident 19 times, you know, such as vessel boils dry and so on. Coarse 20 lumps, that sort of thing. And there are more advanced L 21 exotic codes that do it better. But I think it represents 22 the state of the art in PRA assessment. And some of the 23 other codes, like the SPRC code for suppression pool credit 24 is I think is more than just approximate. If that was the 1 25 sense of your question.
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| l 212 l r ^. 1
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| (_) 1 DR. LEWIS: Denny, on this page 13-1 that's being 2 distributed here, it says that the information provided --
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| 3 it's quite explicit, I'll give you credit for that -- it 4 says the information provided and how it will be used 5 include the following: It says, probabilistic models of the 6 spectrum of possible accident sequences, containment events 7 and offsite consequences of severe accidents far use in.
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| 8 And then there follows the stuff about guidance for IPEs and 9 containment performance and operations and safety goal 10 implementation.
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| 11 Now, the probablistic models of the spectrum, you 12 know, are really the end result of a PRA. That's all the ,
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| 13 information you get out, probability versus the event. So 14 if you want to use those in developing guidance for all
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| w 15 these things, you're assuming that the peer review will make i
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| 16 no major changes or will induce no major chan99s in 1150. l.
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| 17 Is that an unfair comment?
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| 18 DR. ROSS: Well, if you qualify it a bit, I'd 63v, 19 no, it's not unfair. Any cosmic changes.
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| 20 DR. LEWIS: I don't think " cosmic" is a pejorative 21 term.
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| 22 DR. ROSS: You know, I think we're approaching the-23 mentality of approaching the boiling water reactor, for 24 example, is that with redundant and diverse water make-up 25 systema probably station black out and ATWS are the two big Heritage Reporting Corporation
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| 213 1- things I should be worrying about.
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| 2 What if that assumption.got completely overturned 3 and Sequence X, not heretofore identified, I should be 4 worrying about? And IPE ignored it. That's a cosmic.
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| :5 change. But I think that's such a degenerate postulation, 6 that I'm not sure it.should affect our dealings.
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| 7 DR. LEWIS: Yes. ~Well,1 the thing I'm groping for 8 is that if you were to have said that you know, we've 9 learned a lot doing that. And of course, as we learn 10 things, we get better at-our jobs, and we're going to use 11 the information in helping to formulate our strategy, that 12 would be almost unexceptionable in the other direction. But 13 instead what it says is that you're going to use the 14 ~ detailed probabilistic curves to formulate policy, and those J( )
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| 15 are the things most likely to be changed by a decent peer 16 review.
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| 17 I would think those were, to borrow terminology' 18- from another world, these are the weakest outcomes and the l-19 least likely to survive a tough review.
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| 20 DR. ROSS: Well, you're just asking an opinion. I 1
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| ~
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| 21 don't'think any logical outcome of the peer review would 22 overturn the IPE letter, for example.
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| 23 DR. LEWIS: Would overturn what?
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| 24 DR. ROSS: Would not overturn the IPE letter.
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| 25 See, one could have read this a bit different. We could
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| l l
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| 214 e Il
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| (> 1 have written it this way, say, hey, if we're. smart enough to l 2 do these five, we're smart enough to write guidance to the 3 industry. That's another way to write this, but we didn't 4 write it that way for obvious reasons. I i
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| .5 DR. LEWIS: No ,. you didn't. l l
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| 6 DR. ROSS: But that's what we meant. ]
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| 7 DR. LEWIS: Well, that's what I'm groping for. j 8 Because if you had said that, I might not have had any l
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| 9 problems. .Because I think everyone will agree that you're ?
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| 10 smarter than you were a year ago.
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| 11 MR. MURPHY: We don't have the intent of saying 12 that you use the bottom lane distributions.
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| 13 DR. LEWIS: Well, that's what it says here.
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| /~N 14 MR. MURPHY: I don't read it that way.
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| 'd 15 DR. ROSS: I don't see that either, Hal. Where 16 does it say that?
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| 17 MR. MURPHY: All right. It says the probabilistic 18 models are to be used in the development of guidance.
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| 19 DR. LEWIS: The probablistic models of the 20 spectrum of accident sequences. Doesn't that mean the 21 probability versus event curves?
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| 22 MR. MURPHY: No, to me, that means the physical 23 models of the plant, the fault trees, the event trees, the 24 understanding of the interactions of the systems and 25 components of the plante That information -- not so much
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| 215 c n i_)
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| l' the quantitative as the. qualitative information gained
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| =2 there.
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| 3 DR. LEWIS:. That's what some experts.would call rr 4 the Master Logic Diagram?
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| 5' MR. MURPHY: _ Comething of.that order, yes.
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| 6 DR. LEWIS: I see, okay.
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| 7 MR. MURPHY: An example. :We made a mistake on one 8 of the plants that we assumed that~a component needed 9 external cooling when it didn't. But the' fact that -- and-10 we were later corrected by the utility who showed us that we 11 ' did not need such cooling. But that insight told us that if 12 such a component existed in another plant, it did need
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| =13 cooling. So it showed what we had to look for.
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| 14 So it's not bottom line. That's not the intent
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| ~ 15' here. If'you got that impression, we said it poorly.
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| 16 DR. LEWIS: Okay,.so I should read that and just 17 ignore the word, probabilistic, and I'll be in pretty good 18 shape.
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| 19 MR. MURPHY: Yes.
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| 20 DR. LEWIS: Okay.
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| ' 21 DR. KERR: Any further questions?
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| 22 (No response)-
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| ' 23 DR. KERR: Mr. Chairman, I see no additional 24 questions. So I think.we should thank the staff for a 25 succinct presentation and I turn things over to you.
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| 216 1 DR. REMICK: No questions from the Committee, no ;
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| : 2. further questions?
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| o 3- Staff have any additional-comments you'd like to
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| .4 make?
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| <5 DR. ROSS: Yes. We' d like, and we can do.this 6 with Professor Kerr,- we'd like to engage upon some long term 7 substantive discussions on thiscreport and maybe take 8 ; upwards of a year.for the committee to finish. But we'can 9 do that with Professor Kerr.
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| 10 DR. REMICK: Sure.
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| 11 DR. LEWIS: I don't think there's any way either-12 of us can avoid that eventuality, much as each of us would 13 probably like to.
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| 14 DR. REMICK: All right, nothing further on that.
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| }}
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| 15 Surprisingly, we're ending up a little bit early.
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| 16 Bill, do you know if we'll be ready to go on the 17 next issue before 3:157 18 DR. KERR: From the people I see in the audience, 19 I would just that we could start at 3:00 o' clock.
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| :20 DR. REMICK: 3:00 o' clock. All right, let's take 21 then-a 15-minute break and return at 3:00 o' clock, taking up-22 the Limerick Unit'2.
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| 23 (Whereupon, at 2:45 p.m., a brief recess was 24 taken.)
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| 25
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| 217 O ?x-lq) 1 DR. REMICK: The meeting will reconvene.
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| 2 The next agenda topic is the Limerick Nuclear
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| : 3. Power Station Unit-2. . We have had a request from a member 4' of the public, Mr. Lewis. We are. starting-early and he is 5 not here and I'm sure that's because we are starting early.-
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| 6 So I suggest that assuming Mr. Lewis arrives at the 7 appropriate-time that perhaps we could have his presentation 8 after the. staff presentation and before that of the 9 Applicant.
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| 10- So withoat'further comment from my standpoint, Dr.
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| 11 Kerr, I turn the meeting over to you.
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| 12 DR. KERR: In a report of November 1984 the ACRS 13 commented on the application for an operating license for g 14 Unit-1 of the Limerick Generating Station.
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| J 15 At'that time the Applicant, Philadelphia Electric 16 Company, had asked for an operating license for both Units-1 17 and 2. We, however, chose not to comment on Unit-2 at the 18 time because it was felt that the schedule for construction 19 and operation were rather uncertain.
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| 20 Unit-2 is now being' considered for an operating 21- license, some four and a half years after approval of the 22 operating license for Unit-1. However, the two units have 23 the same rated power level. Use the same nuclear steam 24 supply system and are generally very similar.
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| 25 on April 25th a subcommittee visited the Limerick
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| 218 i
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| k/ 1 site in the morning, and then in the afternoon met with the j 1
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| 2 NRC staff and the Applicant at a cite near Philadelphia to 3 review the materials associated with this application for an ,
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| 4 operating license. I S You will recall that we have performed a review of 6 the Philadelphia Electric Company new management in l
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| 7 connection with our consideration of Peach Bottom restart.
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| 8 We looked more specifically at the personnel 9 associated with the management of Limerick No. 2 in our 10 subcommittee meeting. We observed that the NRC staff 11 recently completed a SALP rating and gave what I have come 12 to believe is an unusually high rating to this group on the 13 basis of their most recent review.
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| 14 In our review I think it reasonable to say that
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| }
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| 15 the subcommittee found no reason to question this rating, 16 although certainly our review is not nearly as thorough as 17 that of the staff.
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| 18 We mention in our report on unit-1 that 19 Philadelphia Electric had performed a PRA in connection with 20 consideration of unit No. 1 for licensing. Philadelphia 21 Electric has a staff of people who were involved in the 22 formulation of that original PRA, and then updating that PRA 23 and also applying it to unit No. 2.
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| 24 Interest ingly enough their recent calculations 25 based on some experience and some changes, and maybe better
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| 219 f''
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| ,1 methods-of calculations indicate a somewhat lower core 2 damage frequency for the two units than-was.the case in
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| .3 their original calculation 1 1
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| 4 The actual number is about seven-times 10 to the j 1
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| 5 minus six per year; although that does not include any' )
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| 6 contribution from seismic events. . And you recognize that at 7 least in some units that has proven to be a significant 8 contributor to core damage frequency.
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| 9 It also appears that the licensee for unit-1 is 10 using the insights from PRA not only in plant design and in
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| -11 testing but in training and in the planning'of their 12 maintenance program.
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| 13 In the course of preparing operating organization in the plant for operation, and this will be elaborated on
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| [ } 14 15 in more detail, the Applicant has performed a readiness 16 program assessment and readiness verification program. And 17 the staff has reviewed those.
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| 18 I think a great deal about the plant and its 19 organization has been reviewed, re-reviewed, and re-20 rereviewed, and the conclusion seems to be that, as far as 21 the applicant and the staff are concerned the plant is ready 22 for startup.
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| 23 I think that is enough comment from me. I will be l
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| l 24 glad to try to respond to questions. And I would ask if 25 there are any comments from the other subcommittees?
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| 220 )
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| ) 1 Mr. Remick I see is here. Did you have any 2 additional comments, Mr. Remick?
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| I 3 DR. REMICK: No additional comments.
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| 4 DR. KERR: Any questions or comments before we go 5 to the presentation?
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| 6 (No response) 7 DR. KERR: I see none so I will call on Mr. Clark 8 of the NRC staff who I think will open the staff's 0 presentation.
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| 10 Mr. Clark.
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| 11 (Slides:being shown.)
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| 12 MR. CLARK: Thank you, Mr. Kerr.
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| 13 My name is Dick Clark. I'm'the licensing project 14 manager in the Office of Nuclear Reactor Regulation for-
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| .O 15 Limerick Units-1 and 2. We have requested that you and the 16 committee review the Limerick Unit-2, as Mr. Kerr, today.for
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| '17 a full power license.
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| 18 The first slide is just a chronology and I guess L 19 .the only thing I wanted to point out here is that the l
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| 20 construction was resumed on unit-2 in February of 1986. So t
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| 21 in just a little over three years they have brought it from 22 less than 30 percent or about 30 percent to construction is 23 essentially finished.
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| 24 May I have the second slide, Jim.
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| 25 Mr. Kerr mentioned to you that the Applicant has Heritage Reporting Corporation (202) 628-4888 l
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| 221 g.
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| \-) 1 conducted a very comprehensive assessment and arrayness 2 verification program. And as part of this they have also 3 conducted an extensive independent design and construction 4 ansessment.
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| 5 And we on the NRC have sent out teams on a number 6 of inspections with some of our contractors and have 7 assessed both-the design aspects and the construction part.
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| 8 In fact the team just came back last Friday from San 9 Francisco at the Bechtel offices wrapping up the last of the 10 design assessments. j 11 And from this we have drawn some conclusions that 12 they have a very thorough design documentation and 13 verification program.
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| 14 And more importantly, that they FSAR reflects the
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| {}
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| 15 as-built plant and that plant was actually built and 16 constructed in accordance with the design.
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| i 17 May I have the next slide.
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| 18 We're doing some other conclusions from these 1
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| 19 multiple inspections in addition to the one that Jim will be 20 talking about from Region 1. That their construction 21 activities have been controlled. We found that they had 22 experienced PEPCO and Bechtel management on site. Bechtel 1
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| l 23 pulled together better people that they've had on some of 24 the other project such as Hope Creek, Susquehanna.
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| l l 25 We found that the people there and that things l \
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| 222 1 I
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| s\
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| (_/ 1 were well planned and executed and that they adhere to their 2 procedures. And they've have extensive quality assurance, 3 quality control organization.
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| 4 It seemed that every place you turned there was 5 somebody from quality control or assurance looking over 6 their shoulder.
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| 7 And based on this we feel that based on their past il performance we have a high confidence that the plant is 9 ready for safe operation.
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| 10 Jim, may I have'the next slide.
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| 11 Now we've had two cycles of operation of unit-1 to 12 be able to assess the readiness of Philadelphia Electric for 13 operating the plant. We've had, like I say, in that four years to look over and see about the site organization. How
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| } 14 15 they've been doing. And we found that based on the SALP and 16 the other documented records that they do have a strong 17 orientation toward safe plant operation.
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| 18 They have demonstrated their ability and 19 willingness to proactively identify and predict problems, 20 and critically self-evaluate the performance.
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| 21 I've sat in on a number of their PORC meetings and i 22 -to see just how they do work unannounced. In operations as 23 well as construction they have had a strong QA/QC 24 organization in the programs.
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| 25 And as Mr. Kerr was mentioning on that, he I
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| l Heritage Reporting Corporation j f (202) 628-4888 i l
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| L 223
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| ) 1 mentioned -- talked about the SALP ratings on-construction, 2 which Jim will talk more about later. But so far as 3 operations the SALP. ratings are some of the best in the 4 region, anyway.
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| 5 Can I have;the next slide.
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| 6 Mr. Kerr also mentioned to you that you had an 7 occasion just recently to review the Philadelphia Electric 8 . corporate organization in connection with the Peach Bottom 9' operation. I'll just mention that they have had some. major 10 reorganizations, which I think most of you are aware of.
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| 11 And one of the more important parts of this is 12 that they have~ consolidated their QA/QC functions into.a-13 single organization. That they have strengthen and l 14 increased the scope of their.ISICs programs.
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| O 15 I think you've already favorably commented on that 16 reorganization.
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| 17 Jim, the next slide. ,
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| 18 I just show this list. We have very few open 19 items. In fact since this was made up yesterday we have 20 dropped a couple off of that, like the turbine system 21 maintenance program. So that we really have very'few open 22 items insofar as our licensing review is concerned.
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| 23 The next slide.
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| 24 On the generic issues we only have two that we 25 have to resolve. The non-conforming materials and the Heritage Reporting Corporation O' (202) 628-4888 l
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| 224
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| ,~
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| k- _1 molden case' circuit breakers. And I think we're-close to
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| :2 resolution on those.
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| 3 'And our last slide, Jim.
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| 4 What we conclude from this is subject to the 5 satisfactory resolution of the pending issues we conclude 6 'that Limerick Unit-2 can be operated safely by Philadelphia 7 Electric and without any undue risk to the health and safety 8 of the public.
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| 9 I'm willing to take your questions.
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| 10 MR. CARROLL: I'm curious about what the turbine 11 system maintenance program open item consisted of?
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| 12 MR. CLARK: We're closing our review or their 13 submittal'on that. Because they had an unfavorable 14 orientation on the turbine.
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| (}
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| 15 MR. CARROLL: So it's limited to turbine missiles.
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| 16 MR. CLARK: Yes, the turbine missile program.
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| 17 It's a GE program that we have approved for Hope Creek and a 18 number of other plants.
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| -19 DR. REMICK: Mr. Clark, the committee is aware of 20 Appeal Court decision, Limerick Ecology Action versus the 21 NRC on the possible need to consider severe accidents 22 alternatives under NEPA.
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| L 23 Has the staff given consideration on what effect, 24 if any, this might have on this licensing action?
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| 25 MR. CLARK: Do you want to take that, Walt?
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| 225 1 DR. REMICK: Without getting into the details of 2 it.
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| 3 MR. BUTLER: Yes.
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| 4 At this point in time the staff does not believe 5 it has a direct impact en the low power licensing. We 6 believe that a portion of the court's order having to do l 7 with the Gradiford prisoners is something that likely will 8 need to be closed out before full power licensing.
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| 9 The issue dealing with severe accidents is 10 something that we await guidance from the Commission on.
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| 11 And we are gearing up to undertake a program to be 12 responsive to that aspect of the court's order as well. l 13 DR. REMICK: Has that issue of the prison personnel been remanded back to a Licensing Board?
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| { } 14 15 MR. BUTLER: Yes, sir.
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| 16 A Licensing Board has been convened for that and a 17 prehearing conference already scheduled. j 18 DR. REMICK: Thank you.
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| 19 MR. McNEILL: If I might interject, Mr. Chairman.
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| 20 DR. REMICK: Yes.
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| 21 MR. McNEILL: There was a Supreme Court decision 22 this past Monday which I think will have a great deal of 23 relevance to this case. And I'm not a lawyer, but in 24 essence, I think there was -- the Department of l 25 Transportation appealed a similar type of finding earlier.
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| ' l~ And the court has basically said'that under the National.
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| , 2 Environment Policy Act you need not consider all low.
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| 3 probability events _in the mitigationlof-accidents that might f 4 result from that' low probability event.
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| '5- I think that's going to have a significant impact.
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| 6 on this~particular case, if I have read it right. And our 7 lawyers are in fact reviewing that decision for its
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| : 8. implications on'this case and will be consulting with the 9 staff, Commission staff on that issue.
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| 10 DR. REMICK: Thank you..
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| 11 For the record that was Mr. Corbin McNeill.
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| 12 DR. KERR: Are there'other questions for Mr.
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| 13 Clark?
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| , 14- -(No response) 15 DR. KERR: -Thank you, Mr. Clark.
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| 16 MR. CLARK: Thank you.
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| 17 (Slides being shown.)
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| 18 MR. LINVILLE: Good afternoon.
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| 19 I'm Jim Linville, the Project Section Chief in 20 Region 1 responsible for the oversight of the Philadelphia
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| -21 Electric Company's nuclear power plant inspection program.
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| 22' -Prior to assuming that role I-was a section chief 23 of another facility that was about the same stage of 24 construction nearing licensing, another boiling water 25 reactor in Region 1.
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| 227.
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| 1 Prior to that I served as a resident 1 inspector at L 2 both boiling water reactors and pressurized water reactors 3 in Region 1.
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| 4 And I worked for an architect engineer on a.BWR in 5 Region 1.
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| 6 Next slide, Dick.
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| 7 These are the things I would like to cover briefly
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| ~8 this afternoon.
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| 9 First, a brief chronology. The results of the 10 Region 1 construction inspection program. Preoperational 11 testing program. Recent SALP results. The readiness of the 12 : facility for operation as viewed by Region 1. Summary and p 13 our conclusions, f
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| /g 14 Just to put the construction.of this plant in
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| .O 15 perspective. I mentioned that I was responsible for the 16 oversight.of an' inspection program at another BWR in the 17 region. I took over that project about the same phase as 18 this one was.
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| 19 In about the same period of time, three years, 20 this plant has come farther with better quality results and 21 it has done it with about half the number of people that 22 that other facility did.
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| 23 So our view is that this has been a very well 24 managed project.
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| l 25 Chronologically the construction permit was issued V
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| 228 l 'l in '7,4:and construction suspended at 3'O percent for unit-2' 2 in 1983.1 3 We're going to be focusing in this discussion on-4 what's occurred since the resumption of construction in.
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| 5 February 1986. At that time we reassigned construction 6 senior resident inspector and a resident. inspector and 7 they've been'there through March of.this year. Now we have 8 four resident inspectors who are more oriented towards 9 operations and startup testing. That includes the ones 10 responsible for the inspection program at unit-1 as well as 11 two for unit-2.
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| 12 Next slide, Dick.
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| '13 The inspection program at Limerick is virtually 14 complete. The construction program rather and the 15 inspection of that program. Roughly 99 percent. The last 16 activity is in progress, the structural integrity test.
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| 17 During the three years since the resumption of 18 construction of the project we have invested a comparable 19 number of hours to inspection of that facility that we have 20 at other facilities. Something over 6,000 hours.
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| 21 We've had a number of team inspections included in 22 that. Dick mentioned the independent design and 23 construction assessment oversight performed by inspectors l
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| l 24 from both headquarters and Region 1.
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| 25 We also had a regional construction team Heritage Reporting Corporation I)
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| ' 229 A
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| (_) 1 inspection in July of 1987 which was about 10 percent of 2 those hours, focused on the high pressure coolant injection 3 and core spray systems. And had no significant problems on 4 that inspection. ,
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| l 5 Also in September of ' 87 our mobile NDE lab 6 performed an inspection of the NDE program at Limerick, and 7 our findings in that team inspection were in agreement with 8 the results of the licensee with respect to NDE with one 9 exception there.
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| 10 The overall results of the program, there's been 11 on escalated enforcement. And the number of violations has 12 been comparable to that of other plants. There's been about 13 20 violations since the completion of construction or since (g 14 the resumption of construction in 1986.
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| V 15 Reporting construction deficiencies has improved 16 since the resumption of construction and is consistent with 17 that of other facilities. By that I mean that they have j 10 been quick to report things that have potential significant 19 deficiencies. In some cases they have evaluated them to not 20 be reportable, but the licensee has done a good job of 21 keeping us appraise of anything that was a potential 22 significant deficiency.
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| 23 Lastly, there's been relatively few allegations.
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| 24 None with major safety significance. We attribute that to j 25 the well managed project as well as to some other programs l
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| f) Heritage Reporting Corporation (202) 628-4888 l
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| i 230 r"%1 ]'
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| . (_) 'l the licensee has.put in place to assure that employees have 2 an avenue to address their concerns. !
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| 3 One of those is a QA hotline where they can go the
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| 4 licensee's QA organization if they're not comfortable with 5 going up'the line'or don't get the answer that they would' 6 like to hear.
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| 7 Also, there's an exit interview and: letter program
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| '8 to assure that employees who are leaving.the site identify 9 any concerns they might have relative to construction.
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| 10 So as I said, there's only been about 20, 25 11' allegations since the resumption of construction, which is a 12 very small number.- That's.to the NRC that is.
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| '13 Preoperational test program. .The region has 14 completed-about 75 percent of.the result review. There's
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| '{
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| 15 only one major test-remaining and that's a' containment 16 integrated leak rate test which will follow shortly after 17 the structural integrity test which is in progress now.
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| 18 There have been relatively few test exceptions.
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| 19 And no major problems identified within the preop test 20 program.
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| 21 We attribute that to the licensee's efforts to 22 incorporate the lessons learned during the unit-1 startup 23 program. And to incorporation of the startup experience 24 from other recently licensed facilities in the region such 25 as: Susquehanna; Hope Creek; and Nine Mile.
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| 's) 1 The most recent SALPs were very good, as was l
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| 2- ' mentioned earlier. The one covering the. period from January
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| : 3. of ' 86 to June of ' 87 had seven areas rated category 1; .two !
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| l 4 areas rated category 2. j o i 5 The only area of concern there was the 6 coordination of engineering control of design interfaces 7 between General Electric, the architect engineer, Bechtel, 8 and the licensee. The licensee worked hard to address that 9 ~ concern in the subsequent SALP period, as you can see.from 10 the slide.
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| 11 And in the most recent SALP which ended in 12 December of 1988 all areas were rated category 1. The 13 reason for the difference in the number of areas is that the 14 1986 SALP there was a lot of construction activity and we 15 had a number of construction arean such as mechanical 16 components, electrical componenta, I&C, structural.
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| 17 In 1987 their construction progras was nearing the 18 end. The period that just ended in December of '88'rather.
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| 19 So all the construction areas were lumped into one and then 20 there was also added the preoperational test area which 21 wasn't included in the previous SALP.
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| 22 And our results is that they were all viewed very 23 well.
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| 24 I might also add that the results of the unit-1 --
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| 25 recent unit-1 SALPs have also been very positive with Heritage Reporting Corporation (202) 628-4888 !
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| . 11 respect.to the. operating organization,. operating performance 2' 'at Limerick l'. f
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| ~ 3 .- N e x t s l i d e ,:. Dick.
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| 233-1 MR. LINVILLE (Continuing) : _
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| This brings us to the 2 readiness of the facility for operation.
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| i- 3 (Slides being shown) 4 MC. LINVILLE: Some of the principal strengths we 5 see are the nuclear dedicated organization which occurred 6 subsequent to the Peach Bottom shutdown and in our view 7 enhances the organization at Limerick'which was already 8 performing quite well.
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| 9 Also the-site management has extensive nuclear 10 operating experience of BWRs, since 1984, and a number of 11 people who have operated the BWRs earlier.
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| 12 Six shifts are fully staffed for two-unit 13 operation. All the operators are licensed on both units at-this point and they are manning tha staff position which.
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| { } 14 15 will be required by tech specs after the license is issued 16 for the pre-operational test program at Unit 2.
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| 17 A number of the programs associated with Limerick i 18 are common to both sites. An emergency preparedness program 19 has been exercised several times. They have common 20 emergency operating response facilities -- the emergency 21 operating facility, the technical support center and the 22 operations support center.
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| 23 The radiation protection program and rad. waste 24 programs are common. programs, common facilities, and the l-25 performance at Unit 1 has been very good in terms of low 1
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| 234
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| $()~.1 ' exposures, as'the licensee will point.out during their 2 presentation.
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| 3~ The security program has incorporated the entire .
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| 4 protected area now including both units as of March and it
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| 15 is fully staffed to support two unit operations.,
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| 6 DR. REMICK: How about the maintenance program?
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| 7 Is that common?
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| 8 MR. LINVILLE: Yes. The maintenance and 9 surveillance program is also, is a common group within the 10 facility.
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| 11 Now, there would be procedures for Unit 1 and Unit
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| : 12. 2 just as there are operating procedures, but they are very, L 13 very-similar.
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| : 14. We have completed our review, the proof and review- !
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| s 15 of. technical specifications, which are very common, very 16- similar to Unit 1.
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| 17 Probabilistic risk assessment and its use sa 18 mentioned earlier. It is also used by the staff in the 19 operating inspection program at the facility.
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| l L 20 We have a risk inspection guide developed by I-21 Brookhaven National Lab which helps us focus our inspection 22 attention on systems that are important from a risk 23 standpoint.
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| 24 And this slide indicates that the startup 25 procedures are 76 percent complete. As of yesterday we had l
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| :1: all the startup procedures, and we are completing our review 2 .of the. procedures for.the startup test program.
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| 3 In summary, there have been no major construction
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| .l
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| '4= deficiencies. Pre-operational tests and results reviei for 5 fuel load are in progress as I indicated earlier abou, three 6 quarters of the way through ' our review of the test.hig.
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| 7 And the-licensee has many years of nuclear BWR 8 experience.
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| 9 In the future, we intend to have augmented 10 inspection coverage during the fuel loading. activities, as 11 we typically do, and during startup testing. And we will 12 have an operational assessment team inspection sometime 13 between fuel load and the issuance of a full power license.
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| 14 .Overall, the region has found that the 15- construction program at Limerick has'been effective. Our 16- review gives us confidence that PECO has built a quality 17 nuclear plant.
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| 18' In addition, our review of the pre-operational 19 test program and the licensee's EWR operating experience
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| : l. 20 with Unit 1 indicate that PECO is capable of safe operation i 21 of the facility.
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| 1 22 Are there any questions?
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| 23 DR. REMICK: During our tour of the facility the !
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| I 24 Subcommittee were particularly impressed by the attention 25 that had been given to what I call human engineering l '
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| 236
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| (_) 1 considerations, particularly the painting of the facility, 2 the --
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| .3 MR. LINVILLE: The which?
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| 4 DR. REMICK: Painting.
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| 5 MR. LINVILLE: Painting. Okay.
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| 6 DR. REMICK: -- marking of pipes with layman's 7 terms of what was in those pipes rather than just code 8 numbers, and so forth, the valves indications, the direction 9 of flow.
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| 10 My own reaction sa it is perhaps the best job I 11 have seen in the U.S. of the facilities I visited.
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| l 12 Does the Staff have any comment on that point?
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| 13 MR. CLARK: Yes. They went out on this and 14 actually visited most all of the other plants who had any
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| (~)
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| L./
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| 15 real strong effort toward identifying the wrong train, wrong 16 unit, one of the human factors concerns. And we agree with 17 you. We feel that it did probably have one of the best 18 programs to try and prevent that potential problem. They 19 had greens and yellows and procedures are the same color as 20 the unit. Everything was identified. They can tell you how 21 many tags, it's in the thousands of tags.
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| 22 MR. LINVILLE: We have seen a number of other !
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| l 23 facilities in Region 1 anyway that have very good programs, 24 but it is as good certainly as any that I have seen i 25 recently, i l,
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| 237 f% '
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| A j 1 DR..REMICK: Thank you.
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| 2 MR. LINVILLE: 'Other questions?
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| 3- (No response) 4 DR. KERR: I see none.
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| 5 DR. REMICK: If not, I wonder if Mr.. Lewis is 6 here? ,
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| 7 Let us proceed then with the --
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| 8- DR. KERR: May I, before we proceed, point out to 9 the Committee'if you have not already seen it that you have-10 available a ' transcript of that part of the meeting in 11 Philadelphia at which presentations were made. You also !
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| 12 have copies of written presentations in your folder. !
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| 13 And I told the people who made presentations that 14 these.would be made available to the Committee. .)
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| 15 Mr.'McNeill 16 MR. McNEILL: Thank you, Mr. Kerr. ,
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| '1 17 (Slides being shown) 18 MR. McNEILL: I.am Corbin'McNeill. I am the 19 Executive Vice President-Nuclear of Philadelphia Electric 20 Company.
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| 21 We had the pleasure of briefing you on our 22 organization and structure during a Peach Bottom 3
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| 23 presentation earlier this year, and I will not go through my 24 own introduction since I was introduced at that time.
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| 25 The presentation that we are making today is a
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| ) Heritage Reporting Corporation (202) 628-4888
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| I e .,
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| 238 I n-N ]
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| i-) '1' condensation of a presentation that we gave to the )
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| 1
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| ~1 2 Subcommittee on April 25 in Philadelphia. .]
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| I 3 our agenda today will follow with a presentation ;
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| 1 4' on the design, construction and startup by Mr. Ullrich, who t
| |
| 5 is our Startup Manager; a review of the Unit-1 operating {
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| 6' experience end the readiness of the plant staff for 2-unit s
| |
| 7- operation which will be presented by Mr. Graham Leitch, who 8 is the Vice President and Site Director for Limerick.
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| 9 .Mr. Dave Helwig, who is the Acting General Manager 10 of Nuclear Services and was just recently the General 11- Manager of Nuclear Quality Assurance will discuss our self-12 assessment process?
| |
| 13 Mr. Al Marie, who is the Branch Head in our PRA 14 'section in Nuclear Engineering Department will give a review i( )
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| 15 of our probabilistic risk assessment study for Limerick and 16 the updates that have happened since the last presentation 17 to the Committee.
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| 1 18 Mr. Dave Honan, who is the Branch Head for Nuclear l i
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| 19 Licensing will provide a status of the licensing from our 20 viewpoint in the activities that remain.
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| 21 And I will have a brief conclusion at the end, 22 Additional Philadelphia Electric People from ;
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| 23 ' senior management that are in the audience today include Mr.
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| '24 John Kemper who is the Senior Vice President for Nuclear 25 Construction who has been responsible for the construction
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| () Heritage Reporting Corporation (202) 628-4888 1
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| 239 t
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| /~')
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| (_/ 1 activities at Limerick, both Unit-1 and Unit-2,. for many, j 2 many. years; Mr. Joe Kowalksi, who is the Vice President of -
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| 3 Nuclear Engineering; and Mr. Marty McCormick who is the 4 Plant Manager at Limerick.
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| 5 To refresh you for just a minute on our 6 organization, we do have a dedicated nuclear organization.
| |
| 7 It has a Senior Vice President of Nuclear Construction as I 8 mentioned, Site Directors at both Peach Bottom and Limerick, 9 a dedicated Nuclear Engineering Department of about 400 10 people.
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| I 11 We have a Nuclear Services Department that }
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| 12 includes the oyriad of activities such as licensing, {
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| l 13 chemistry, corporate chemistry and radiation protection, ;
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| i 14 radiological health, and rad. waste.
| |
| (V3 15 It also includes a computer department and has a l 16 large mobile maintenance force who does corporate 17 maintenance not only at our nuclear stations but at our 18 fossil facilities. ;
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| 19 And we have a separate Nuclear and a combined 20 Nuclear Quality Assurance Department headed by a General .i 21 Manager.
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| 22 We also have a full time Chairman of our Nuclear 23 Review Board and a Bueiners Unit and Human Resources Support 24 Units in the organization.
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| 25 You had heard earlier et an earlier presentation a f[ ) Heritage Reporting Corporation (202) 628-4888
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| p -
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| a 240
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| .f
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| ' i, y/ 1 discussion.of Peach Bottom. And.I will not go.back through; 2 .that.
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| 3 I do want to review very quickly though why we 4 believe.that Limerick as an organization is vastly different 5 than the: culture that had developed at Peach Bottom in the 6 years prior to shutdown.
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| 7 First of all, Limerick had developed in the 8 culture of the Engineering and Research Department rather 9 than Electric Production, which was very fossil-oriented.
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| 10 For the years of construction, the licensing 11 activities, the organizational structure that was put 12 together, the support of the construction and operation and
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| : 13. ' free startup operation was in fact under the control of the Engineering and Research Department, was much more' cognizant.
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| ; p\ J . 14 . .
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| 15 of the developing criteria and standards in the nuclear 16' industry and therefore set a tone.that was quite a bit 17 different than the fossil driven production organization 18 under which Peach Bottom developed in the years following i f 19 its licensing.
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| 20 And we have been able to retain that culture i 21 through the early years of the operation of Unit-1 at 22 Limerick.
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| 23 We have strong site management. One of our j 24 weaknesses at Peach Bottom sa a lack of good managerial i
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| 25 talent and the development of that talent, and good strong
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| 241-(); 1 leadership at the station.
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| 2 We have in fact had our best people at Limerick 3 and they have produced quality results in the operation of .)
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| l p 4 the Limerick Unit 1 station.
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| 5 Obviously, Limerick has developed in the post-TMI 6 era where the increased demands and standards are well 7 understood and have been implemented as a part of the i'
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| 8 licensing process'for the plant.
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| 9 And finally, we did have key Peach Bottom 10 personnel-that had transferred to Limerick.
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| 11 As with almost all companies that I know of, when 12 you have a large investment such as a new generating 13 station, you tend to put your principal, your best people
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| /cs 14 at that station. And we have done that in this company.
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| . t.
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| 15 For those reasons, we have quite a different 16 operating record at Limerick than we had at Peach Bottom, 17 and you will see that in some of the ::esults that are :
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| 18 presented today in the various presentations.
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| 19 That concludes my remarks. Are there any i
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| 20 questions, before we bring the next speaker up, who.is Mr.
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| 21 Ted Ullrich?
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| l 22 (No response) 23 DR. KERR: I see none. Thank you, Mr. McNeill.
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| I-l 24 (Slides being shown) l' 25 MR. ULLRICH: My name is Ted Ullrich. I am the 1
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| i o - .
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| 242 fy l%sb 1 Startup Manager for Limerick Unit-2. 1 2 That means that as construction completed-3 components'and systems, it sa turned over to my organization )
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| J 4 for component testing, electrical che:kout and then finally 5 for dynamic operation pre-op testing and mechanical work.
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| 6 I was assigned in 1986 and was somewhat 7 -responsible for developing the startup program as well as 8 implementing-it.
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| 9 Before I get to the startup phase, I want to go 10 back and talk about some of the construction and design 11 'information just to get us on. board.
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| 12 The construction effort restarted in February.of 13 1986 and the philosophy at that time was to build two plants j } . 14 that would be nearly identical as we could make them.
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| 15 So at the restart, all those modifications that 16 had been put into Unit-1 as a result of their startup !
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| i 17 program were' included in the Unit-2 design as well as the l 18 modifications which were scheduled to go into Unit-1 were 19 also put in the Unit-2 design and during this last Unit-1 20 outage most of those modifications were put into Unit-1, 21 So today, with Unit-1 coming out of its second 22 refueling outage, and Unit-2 ready to license, we have two 23 duplicate plants that are as close together as we can make 24- them.
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| 25 Because the design continued during the time the
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| 243 !
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| !s_). 1 construction was halted, the design sa relatively complete 2 at the time construction restarted. And that permitted us 3 to better manage the construction program.
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| 4 4 The work areas were cut down into manageable 5 sections, each section provided with a construction manager 6 for that area.
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| 7 ,
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| We work packaged every work item. There were some 8 70,000 work packages developed that gave the craftsman all 9 the tools he needed to do the work, and in some cases the 10 Midnight shift would bring in the components, so that they j 11 would be there for him in the morning.
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| 12 We were able to negotiate Union contracts so that 13 we were able to construct on a two-shift basis with about 70
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| (~') 14 percent of the people being on day work and about 30 percent v
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| 15 being on afternoon shift.
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| 16 All this completed construction and the management 17 things we put in place resulted in minimum construction 18 interfaces, almost no rework and craft productivity sa very 19 high.
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| 20 We experienced about 30 percent higher craft 21 productivity on Unit-2 than we did on Unit-1.
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| 22 All that got us to completing the construction 23 about eight months ahead of schedule, which was the target 24 schedule, and during that time we were able to maintain the 25 quality of the ccustruction because our QC and QA people 1
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| 244 1 m
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| 1 For comparison purposes we plotted the recent j 2 history of second unit BWRs as well as Hope Creek from the !
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| 3 time that those plants experienced a 30 percent complete 4 status to fuel load.
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| 5 And you will notice the dark orange line on the 6 slide shows that Limerick was able to go in 42 from 30 I 7 percent complete to what we hope is fuel load in June or 8 July.
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| 9 The next best was St. Lucie which was the industry 10 leader for many years. They've done it better than anybody 11 else. And then you see Hope Creek is in there as first unit 12 BWR but it's a recent one. And then you see Susquehanna and j 13 LaSalle, and they got hung up a little bit in the TMI 14 modifications which delayed them. I
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| s-15 But all together it was an expeditious schedule l 16 and we maintained quality. 4 17 Now this next slide again shows our SALP ratings.
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| 18 I think the NRC has covered that. And unless there's l 19 question I go by it. But it does show that we have had a 20 very high quality program.
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| 21 Design features: Limerick is a BWR-4 and rated at 22 3293 megawatts thermal. It has direct injection of the RHR I
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| 23 LIPSI mode into the reactor vessel by its own nozzles and 24 the HPCI does inject both the core spray and feedwater, so 25 it's a little bit beyond the BWR-4 that we have at Peach 1
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| - 1'~ Bottom.
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| 2 Limerick has mark II pressure containment system 3 with a steel liner. The'ILRT for that facility is scheduled ]
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| '4- for-this weekend. The structural integrity test is in i 5' progress:and the'. engineers told me that they only got.10 6 percent'of the expansion than they had predicted in.the [
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| 7 model. So it's a good structurally very sound hunk of
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| -8 . concrete.
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| r, 9 There are five incoming transmission lines to i 110 Limerick. Three at 500 kv and two at 220., Those come into-11- two different substations on' opposite sides of the plants.
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| 12 'The' generators feed out on those and those lines are' capable b
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| 13 of=providing power to our. auxiliary transformers as well as
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| ' 14 - to our emergency buses.:
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| 15 DR. REMICK: Ted, how many different corridors do
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| : 16. those transmission lines come in on?
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| 17 MR. ULLRICH: There's four.
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| 18 DR. REMICK: Four.
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| 19 MR. ULLRICH: Two 500 are dual lines going to wet 20 pane. So the other four go to-other locations. 1 l
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| 21 DR.'REMICK: Thank you. I 22 MR. ULLRICH: Four diesel generators per unit, and
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| , -23 of course, one natural draft cooling tower. The cooling 24 tower has some ability to provide service water from one 25- cooling tower to both units. And fire water comes from both
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| ,- 247 1 fl ; cooling towers to other plant.
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| 2 MR. MICHELSON: Is that a three divisional
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| b 3. electrical system with four diesels?
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| 1' 4 MR. ULLRICH: I'm sorry 1 didn't understand'the 5 question.
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| 6 MR. MICHELSON: Is that a three divisional.
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| 7 electrical'or four divisional?
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| 8 MR. ULLRICH: Four divisional electrical system.
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| 9 MR. MICHELSON: Four divisional.
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| 10 MR. ULLRICH: Yes.
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| 11 MR. MICHELSON: Thank you.
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| 12 MR. ULLRICH: Major shared systems of course at 13 Limerick are the control room and the control room 14 ' ventilation system. NRC staff already said that the "f"'f
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| l15. radwaste system is common to both units.- And unit-2 now 16 drains. The unit-2 facilities will be tied in by the middle 17 Hof next week, so that all the drains from unit-2,. turbine 18 and reactor buildings, will be going to the radwaste system 19 next week.
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| 20 MR. WYLIE: Excuse me, could I back up to Carl's 21 question of four divisional.
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| 22 Is the safeguards basically an N plus two 23 arrangement?
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| 24 MR. ULLRICH: One out of two twice, if that's what 25 your question is. Logic throughout.
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| 1: 'Does that help?
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| 2 DR. REMICK: No.
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| 3 MR. WYLIE: They're 100 percent safeguards --
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| 4' MR. ULLRICH:- Excuse me.
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| 5 MR.' WYLIE: Basically they're four 100 percent 6 pumps.
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| 7 MR. ULLRICH: There are -- no. No , that's not-8 true.
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| 9- MR. WYLIE: Four 50s.
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| 10 MR. ULLRICH: There are four -- well, RHR there's.
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| 11- 10,000 each. So, yes, there's two 50s in the RHR. There's 12 two.50s in-each core spray loop. There's two loops.
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| 13 Emergency service water, there's two 1-00 percent pumps in
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| ,{) 14 .each loop'but there's two loops. You-need both to maintain 15: all your ECCS operable.
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| 16 MR. WYLIE: I guess what I was getting at, if you 17 take any one of those'out of service can you still meet your 18 -single failures?
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| 19- MR. ULLRICH: If you take anyone.of those out of 20 service.you can still -- yes.
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| 21 MR. McNEILL: This is a relatively early design 22 even though it's in late construction. And I'm not sure it-23 is designed with those concepts of N plus two in the l
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| 24 original design. {
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| l 25 MR. MICHELSON: Which product line?
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| '(,) 21' MR. McNEILL: This is a' General' Electric product.
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| 2 MR. MICHELSON: ENo, no. Which, four or five?
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| 3 MR. McNEILL: It's a- mark IV.
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| 4 MR. MICHELSON: No , nor.BWR.
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| 5 MR. McNEILL: It's a BWR-4.
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| 6 -MR. MICHELSON: With a mark II' containment.
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| 7 MR..McNEILL: With a mark II containment. -But it-8 has some enhancements to the mark IV design.
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| 9 DR. SIESS: The new bold island enhancements,.
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| 10 basically.
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| 11 MR. McNEILL: It's very similar to Hopa Creek.
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| i Somebody 1l2 DR. SIESS: Yes, that was new bold.
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| 13 called it the four and a half.
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| 14 MR. McNEILL: That's probably true.-
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| ' pJ 15 MR. ULLRICH: The shared system'again are the 16 standby. gas treatment system. That serves both the 17 ' refueling floor which is common to both units; and the two 18 reactor buildings. Preop test on that system is completed 19 and the draw down tests were successfully run last week.
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| 20 The emergency service water system which provides 21 cooling to the eight diesel generators as well as to the 22 ECCS room coolers and ECCS equipment is shared by botn 23 units. It comes from the common spray pond which is the 24 ultimate heat sink, as well as the RHR service water system l 25 is shared by both units. It basically has one pump for each l
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| _j 1 RHR heat exchanger, 100 percent capacity pump. Two RHR heat J 2 exchangers per unit. {
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| 3 We talked about the refueling floor, I said is 4 common as well as the refueling floor crane. That's not a 5 safety concern but it has been a difficult scheduling i 6 problem from the standpoint of trying to get all the work 7 done on the refueling floor by construction the preop test 8 in one unit and having a refueling outage on the other one.
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| 9 The condensate and refueling water transfer system 10 which provides water for back wash. And provides water to 11 some of the staple systems. It's common to both units. And 12 since it's in-service on unit-1 and slightly contaminated it 13 has not been tied into date. The schedule for us tying that
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| v 14 into unit-2 about the third week in May. And that will then 15 bring the contaminated fluids into unit-2 at that time. !
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| 16 As I said, the plants are almost identical. There {
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| 17 are a couple of differences. The design incorporated a j 18 snubber reduction program with the restart of 1986. That 19 was instrumental in eliminating some 566 snubbers. Half of 20 those were in the drywell. So that should be an ALARA 21 benefit in the future.
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| 22 We also did stress analysis for small piping. And 23 that eliminated some thousand small pipe hangers. 1 24 The elimination of the arbitrary intermediate pipe 25 break criteria permitted us to reduce some of the pipe whip i Heritage Reporting Corporation (202) 628-4888 l
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| i f%) _ .1 : restraints during the construction period.
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| 2' We made a conscious effort to --
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| 3 - MR . MICHELSON: Excuse me. Did you apply that 1
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| l 4 only inside a containment?
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| 5 MR. ULLRICH: I think it was only outside of I
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| L 6 containment. The pipe break is-inside.
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| 7 MR. MICHELSON: Did-you take any leak before 8 break?
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| 9 DR. SHEWMON: I don't think they allow that on 10 BWRs. Let me --
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| -11 MR. MICHELSON: No, I didn't know if they had 12 .something that might qualify it in carbon steel.
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| 13 DR. SHEWMON: Do you have 304-L piping or what do 14 you have for your research?
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| ' 15 MR. ULLRICH: I believe it's 316-L.
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| 16 MR. McNEILL: 316-N.
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| 17 DR. SHEWMON: Any stress adjustment on it?
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| 18 MR. McNEILL: That I do not know. But we will 19 attempt to find that out.
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| 1 20 DR. SHEWMON: Is it a mechanical or --
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| 21 MR. McNEILL: Oh, yes. We did -- on unit-2 on the 22 nozzle wells we have done-mechanical stress improvement, on 23 those. On most of the others, that has not been 24 accomplished.
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| 25 We only have on that unit a handful of wells that
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| Js ' fall out of the lowest. category of susceptibility.by the s '2 recently issued -- I don't remember what'the document was --
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| 3 but you~ categorize your wells --
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| 4 DR. SHEWMON: The 316-N is not susceptible.
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| F 5 .MR. McNEILL: Right. Not susceptible. And we did-p 6 the nozzle wells because they still had some. overlay 7 material in them that is susceptible to cracking and we were 8 trying to eliminate the potential for cracking in that 9 material.
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| 10 DR. SHEWMON: Thank you.
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| 11 DR. KERR: Please continue, Mr. Ullrich.
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| 12 MR. ULLRICH: The control rod blades were shipped 13 to GE in early '86 to remove all stellite and high cobalt material. That GE believes will reduce our cobalt content
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| ( } 14 15 in the primary coolant system by about 12 percent.
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| 16 There were some differences which were identified 17 during the procedure writing effort and durinT the review of' 18 the design which were of some importance to t'ae operator.
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| 19 They were relatively minor and were covered in the operator 20 licensing training and examination courses.
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| 21 The most significant of those was really,-unit-2 !
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| 22 has its own independent process computer which includes all 23 the SPDS functions. Does the core calculations and does the 24 dynamic transient analysis work for us.
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| 25 It's also heavily used during the power ascension
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| 253
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| (,) 1 program to gather data.
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| 2 The rod worth minimizer on unit-2 is also a little L 3 different in that it's a Numac microprocessor and receives 4 hard wired input from the rod position indication system.
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| 5 And it has some advantages over the'old style in that it 6 will stop the operator before he makes a mistake; not stop 7 him after he makes a mistake. Go it's a little bit of 8 improved model.
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| 9 There are some differences in our startup program.
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| 10 Specifically we're going to use the source range monitors to 11 monitor count rate during the fuel loading process. And 12 instead of using previously irradiated antimony beryllium 13 sources we're going to use californium 252 and unirradiated 14 beryllium sources.
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| 15 DR. KERR: Mr. Ullrich, just out of curiosity, how 16 does this computer stop an operator before he makes a 17 mistake? It somehow knows he is going to make a mistake.
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| 18 MR. ULLRICH: It will not let him select the rod.
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| 19 In other words, if he selects the wrong rod out of sequence 20 the rod will not be selected.
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| 21 DR. KERR: Oh, okay.
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| 22 bE. ULLRICH: All right, startup, my favorite 23 topic.
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| 24 Back in 1987 we took a look at all the systems 25 that had to be brought from construction into an operational ;
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| 254
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| ) -1 phase and laid out'those activities. Things like' writing of 2 the preoperational test, doing component testing, flushing 3 -
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| flow balancing preoperational testing, looking at the 4 results review and getting those approved, and, turning the 5 system over to the plant were all weighted with respect to 6 that system.
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| 7 And then we took all the systems and weighted that 8 and we came up with a total work scope for startup which 9 ended up to be actually 97 percent. We kept three percent
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| ;- 10 in our pocket in case we'needed.it.
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| 11 ife looked at all those and then developed the 12 critical path through all those systems. And_the critical 13 path said that we could make June 1st,.1989 for fuel load.
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| 14 We then took the float in those various l
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| 15 activities, and if we said everything went perfect we had 16 the early finish. curve. And if everything didn't go our way 17 then things could end as late as the late finished curve and 18 still make our June 1st date.
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| 19 So that's how we got the two lines on the curve.
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| 20 The orange line and the yellow line.
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| 21 DR. KERR: When you talk about a percent, is that 22 a percent of hours or components?
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| 23 MR. ULLRICH: No. That's a percent of activities.
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| I 24 For instance, when we complete the integrated leak rate test 25 we will get one and a half percent on this curve. So you
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| ~ (.) l1 must' complete the activity. It.has nothing to do.with 2 hours.
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| 3' MR. McNEILL: However, there is an' implied 4 relationship between. effort and activities. 100 percent of
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| < 5L the activities. complete would equate to,100 percent.of the 6 predicted work' load that was scheduled back at the'beginning.
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| 7 of time.
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| DR. KERR: Thank you.
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| '9 MR. McNEILL: And hopefully, there is'a one-to-one 10 relationship between the two.
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| 11 MR. ULLRICH: We-are presently at -- this was a 12 May 1st' slide. We are now about 88 and a half. We are 13 getting about three percent per week now.
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| 14 The two major tests left of the integrated leak
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| 15 rate test which is scheduled for this weekend; the loss of-
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| '16 ' air' test which'is scheduled for next weekend. All the ECCS 17 systems are done. . Loss of power test is done. Diesels are 18 -finished. So all the big systems are done. In fact, most 19 of them are turned over to the: plant staff at this time.
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| 20 MR. CARROLL: Ted, could you describe the loss of 21 air test? What sort of a test is it?
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| 22 MR. ULLRICH: Yes.
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| 23 First of all, we' re- doing an overpressure test for 24 'both the air system as well as the air system that feeds the 25- containment. And that test, overpressure test is based on 1
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| ) 1 -having the first thing that would limit pressure fail. But 2 then go to the second.one.
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| 1 L 3 So I think the pressure on the overpressure test 1
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| 4 is 122 pounds. We have dual headers at Limerick where ;
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| l 5 there's an A and.a B header-and the major users are fed ~from l f6 both headers-through check valves.
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| 7- Now we have been,,for the last couple of months, 8 doing independent loss of air test on one header or the 9 other to verify that those check valves are in fact 10 operable. And we've had to do a lot of maintenance on those 11 check valves. That's -- we did the last one in the turbine 12 building last night which was successful.
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| 13 The test then does two things: it takes down one header at a time and verifies nothing happens. It then
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| [ } 14 15 takes down the other header and verifies nothing happens.
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| : 16. It then takes down both headers fast and also repeat it slow
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| -17 to verify that the safety related parts that are fed by this 18 non-safety related air system fail in'the appropriate 19 direction.
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| 20 The overpressure test verifies that nothing 21 changes state. The same thing is being done on the 22 instrument gas system for the containment.
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| 23 But let me just say, we took a long look at Reg i
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| 24 Guide 1.68, I think it's 3; and also NUREG-1275, Volume 2 to 25 make sure that we were doing the test that would meet those
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| )%)5..1 criteria.
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| 2 MR.' CARROLL: Would you care to repeat those tests 3 after'the plant goes into operation?
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| 4 MR. ULLRICH: I'll have to defer to the plant
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| ,5 manager. But.I think it's worthwhile during shutdowns 6 verifying.that the check' valves are in fact still working.
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| 7 Because there's a design feature that is unique I think to 8 .actually Peach Bottom and Limerick. Maybe it's a typical 9 design,.I don't know. But that criteria, unless you check 10 it it's not going to be there in a couple of years.
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| 11 MR. CARROLL: How about the test where both 12 headers are depressurized?
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| 13 MR. ULLRICH: Well, the biggest thing - you can't j } 14 do-it while the plant is one, because immediately the plant 15 will shut down; we know that. So you got to do it during an 16 outage. It affects primarily ventilation systems, take a 17 beating.
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| 18 I don't see any reason why you couldn't repeat it.
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| 19 MR. McNEILL: If I could interject in this.
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| 20 The test is designed to see that components fail 21- tuo the design safety condition. I don't think that you need-22 to repeat'the test for that reason too often.
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| 23 I do think that there are maintenance tests on 24 your air header that tests the condition of the check valves 25 and things of that nature that are worth doing. And I don't
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| 'l' .think that.they may be as demanding or as time consuming as.
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| : 2. 'doing.the complete header 11oss of air test.
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| 3 MR. CARROLL: Or as risky.
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| 4 MR. McNEILL: Right.- Or as risky.
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| -5 MR. ULLRICH: But the maintenance test.that you 6 ' described is.what we've been doing now. Really, with one- :j l 7 header at a time to verify check valves are still there and 8 work. That's really what we've been doing. Getting' ready 9 for the real. test.
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| 10 MR. CARROLL: Thank you.
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| 11 MR. ULLRICH: Preoperational test program is shown 12 -on -- the status.is shown here, there were 92 preoperational 13 tests required.
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| 14 I've got to look at the chart.
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| 15 There's about 88 completed as of today. Started 16 as of today. 79 are completed. Now once we complete the 17 test'we write up a summary report and submit it to the Test 18 Review Board which is shown here as TRB. And there's 70 of 19 those.
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| 20 Now, at Limerick we have a Test Review Board made 21 up of about five Philadelphia Electric Company senior 22: engineers and some 15 or so vendors who were chosen based on 23 their resumes and qualifications. They report directly to 24 the plant manager and they provide an independent technical 25 review of both the preoperational test and the
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| (,/ 1 preoperational test results.
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| l~ 2 And their charge is, make sure that these tests 3 adequately demonstrate that the system perform in accordance 4 with the FSAR requirements and the tech spec requirements.
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| 5 That program has been very useful. It's 6 independent of startup. And there have been occasions where 7 they said, we can't see what you did well enough, go do it 8 again. And we have repeated at least two preoperational 9 tests over the last six months, just to satisfy these folks.
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| 10 They have reviewed and approved 56, the test 11 result packages. Following their approval it goes to QA.
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| 12 They do somewhat of an administrative review and a 13 qualification review that says the people that ran the test i
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| fl 14 were qualified to run it and so forth. i
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| 15 And once QA approves it, it goes to the plant 16 manager for signature. And then to the NRC for review. And 17 there's 48 or so that have been turned over to the NRC.
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| 18 Once the preop test is completed we work off any 19 test exceptions or maintenance items or anything else and 20 put together a turnover package for the plant. There's 182 21 systems or subsystems that we've identified that we need to 22 turn over to the plant staff. 95 of those including all of 23 the ECCS systems have been submitted to the plant for their 24 approval. The plant has accepted 62 of those to date. I 25 think they've accepted core spray and recire. The others j l
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| 1 are in the shop forLreview. .
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| R '2 Part'of.this program, though, also verifies that.
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| -3 all:the tags,:all the permanent tags for that system'are in- i 4' fact installed. -That the check off lists have been worked g
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| L 5 in and are available. That the procedures are completed..
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| l' 6 And'any surveillance test that would relate.to that systems- q 7 are done and approved.
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| 8 So once we turn the system over to-the plant' 9 staff,' then we start surveillance testing. .We've identified.
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| .10 389 surveillance' tests to support fuel load of which 95 are-11 completed; and 708 surveillance test to support initial 12 criticality. You need them both to go critical. -That's an 13 additional 708. And of those 170 are complete. So we are into our surveillance testing program.
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| J 14 '
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| 15 Power ascension program. Management guidance in 16 .1986 and '87 when we started to develop our power ascension 17 . program is, do not suggest any power ascension program which
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| : 18. would require:any licensing initiatives. So that was the 19 guidance that we got from management. -
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| 20 We put together a program'between Philadelphia
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| .21 Electric Company and GE. Had it reviewed by the plant 22- staff, company management, Region 1, NRR,-and eventually 23 submitted that program to the NRC on June of 1988, 24 The scope is.similar to Hope Creek, River Bend, 25 and some of the others. We have included in our program
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| 261 1 both a single recirc pump trip and a double recirc pump trip 2~ which we thought was a good idea because you don't see.that 3 ve ry. ~ o ften, but it's going to happen to you some day. So it 4 was a good idea to do it while you.were waiting for.it.
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| 5 All the startup test procedures, to support that 6 power ascension program have been written and approved and 7 turned over to the NRC. And,I believe the.NRC has reviewed 8 about 22 of the 32 procedures available. So they're about
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| '9 two-thirds done.
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| 10 All the hardware and cabling to support data 11 accumulation, pipe motion, pipe vibration has been 12- installed. Lanuer pots are there, they haven't,been strung 13 out yet. But all that equipment is there, checked out and ready to go.
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| ( } 14 15 The schedule then is to load fuel in early June.
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| 16 Go through low power testing which would include' fuel load, 17 hydro and heat up to full temperature and pressure. About 18 August 1st we will be ready to exceed our five percent low 19 power license. Test conditions 1, 2 and 3. Take the 20 reactor from about five percent to 75 percent power with a 21 75 percent rod line as max. l f 22 The first synchronization of the generator would l 23 be about.a week and a half after we get our full power 24 license.
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| ( 25 In November we go to test conditions 4, 5, and 6.
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| -( 1 That's .where you would hit -- first achieve 100 percent 2 power and it would include the 100 hour warranty run. We.
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| 20 couldLeonceivably be commercial by the-end of the year.. 1 4 The test program would certainly make it unless 5 there's some' major equipment problems that would shut us
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| .6- down for an outage, we would probably make the end of the 7 year.
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| 8 We think that we've got a quality plant. Unit-1 9 had demonstrated its reliability.- We don't foresee any 10 major equipment concerns during this power ascension 11 program.
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| 12 Yes, sir.
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| 13 DR. SHEWMON: Let me ask a question that's not as near or dear to you heart, but what I missed in this
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| } 14
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| .15 condensed presentation is the pretty pictures that show how 16 well you have landscaped the site. But also how close the-17 nearest large population centers are.
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| 18 Could you comment on that or maybe Mr. McNeill.
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| 19 Because I don't think it's going to'come any place else in 20 the agenda. And compare it perhaps with Peach Bottom.
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| 21 MR. McNEILL: This unit is the second highest 22 population density plant in the country. There are three 23 million people within 25 mile radius. Pottstown is the 24 nearest town, it's about five miles away and it's in the 40 25 or 50,000 population range.
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| (). Heritage Reporting Corporation (202) 628-4888
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| 263' l- .The owner control'1ed area is shown by the. carved 2 area around the plant plus some of the adjacent tree areas
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| ~
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| 3 'there. And that's one reason that this plant has been given-4 such high attention with respect to PRA,'was the. fact that 5 it is a high population density' plant.
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| 6' DR. SHEWMON: This is a river in the lower left >
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| 7 corner?
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| 8 .MR. McNEILL: Yes. That's the Schuykl River in 9 the lower left hand corner.
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| 10 DR. SHEWMON: And beside it is a railroad.
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| 11 MR. McNEILL: Railroad track that is a major
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| '12 ' east / west travel for cargo heading toward Harrisburg.
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| 13 DR. SHENMON: That's your water supply in the background.
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| (])'14 15_ MR. McNEILL: Yes. That is in fact-the spray 16 pond. That's the ultimate heat sink in the background. We 17 have two' water sources for the plant. One is just off the 18 picture. It takes the. suction from the Schuyk1 River and 19 then we have an elaborate 30 some mile alternate water 20 supply from the Delaware River that is the principal water 21 supply for the plant.
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| 22 DR. SHEWMON: Is it a premium there? You seem to 23 be a little bit more cramped on that site than some I've 24 seen. :
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| 25 MR. McNEILL: It's a peninsula but I would tell
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| -( )' Heritage Reporting Corporation (202) 628-4888 l~
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| 264 .
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| f''s
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| (/ 1 you that that's probably one of the -- from the air at least l 2 there is more physical plant on that site than you will find 3 in most nuclear power facilities. It is an immense site.
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| 4 MR. ULLRICH: With respect to landscaping, though, 5 they are moving trailers offsite so fast that my people 6 can't sit down anymore.
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| 7 DR. SHEWMON: I'm not interested in the 8 landscaping.
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| 9 (Laughter) 10 DR. SHEWMON: All the cars in back, really, 11 because you've got more people on construction now -- !
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| 12 MR. ULLRICH: Yes.
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| 13 MR. McNEILL: And most of those are now gone.
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| (~)
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| \_/
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| 14 We're at a point where construction force is one-third of 1 15 what it was when that picture was taken. i l
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| 16 MR. ULLRICH: This picture is about "wo years old.
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| 17 See, the diesel building is not there yet. The diesel 18 building is just coming out of the ground.
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| 19 DR. SHEWMON: Thank you.
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| 20 MR. WYLIE: That's your switchyard on the left 21 hand, lower left hand corner.
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| 22 MR. McNEILL: That is one --
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| 23 MR. ULLRICH: The 220 switchyard.
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| ~4 MR. McNEILL: The 220 switchyard. l 25 MR. ULLRICH: The 500 kv is across the river on O)
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| (_ Heritage Reporting Corporation ,
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| (202) 628-4888 l
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| l
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| \ . .
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| , 4
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| e 265 1 the other side..
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| 2 ML McNEILL: Across the river. There's a 3- ' railroad bridge that you can see in the l'ower right hand 4 corner at the other end of-that and across the road there's
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| ~5 a 500 kv switchyard.
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| '6 This is a funny plant.. Unit-1 has got a 220,000 7 output voltage. Unit-2 has got a 500,000 output voltage.
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| 8 DR. REMICK: Ted, looking at both unit-1 and 9 unit-2 are the suppression pools vented? ;
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| 10 MR. ULLRICH: The suppression pools vented? j 11 DR. REMICK: Yes. Do you have a vent capability on 12 -the suppression pools? ,
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| 1
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| -13 MR. ULLRICH: Yes, we do.
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| 14 MR. McNEILL: There is a containment ' veinting 15 potential.
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| 16 MR. ULLRICH: But it can come from either the 17 suppression pool or the -- either way.
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| 18 MR. McNEILL: It's the six inch integrated leak 19 rate test vent line, is what it is. It is not a specific.
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| 20 containment design hardened vent of any kind.
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| 21 DR. REMICK: Oh, it is not. I see.
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| 22 MR. ULLRICH: We'll talk about that under PRA. l l
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| 23 MR. McNEILL: Under PRA we'll have a slight 24 discussion of that.
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| 25 DR. KERR: It is not a hardened?
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| 1:
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| [.
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| .266 1- MR. McNEILL: I don't think it's. hardened.in-the 2i sense.of the,iguote " hardened" that'is discussed in the 3 NRC's proposals for mark I. containments. It is obviously a
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| .4 pressure:containing' boundary up to'the design pressure of-5 the containment.
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| 6 DR. KERR: Okay.
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| 7 MR. MICHELSON: Where'is it vent.to?
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| 8 'MR. McNEILL: It vents at ground level,, external' 9 to'the reactor. building.
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| 10- MR. MICHELSON: Relative to air intake. To the 11- control room where is it venting?
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| 12 MR.'McNEILL: Somebody might be able to come.up I
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| 13 and show us on the plant.
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| This'is Mr. Al Marie.
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| } 14 '
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| 15 MR. MARIE: I'm supervisor of the PRA' branch.
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| 16- The six inch line vents to the diesel generator-17 building. corridor which then is -- there is procedures to 18~ open that door to the outside to open a path directly to~the d
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| '19 outside.
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| t 20 MR. McNEILL: How about the ventilation intake for
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| : 21. the control room.
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| 22 MR. MARIE: It's on the opposite side of the 23 reactor enclosure.
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| .24 MR. MICHELSON: Opposite side of the building?
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| 25 MR.-MARIE: Yes.
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| 'h Heritage Reporting Corporation (202) 628-4888 o
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| i 267 7%
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| ()
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| i 1 MR. McNEILL: Right.
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| 2 MR. MICHELSON: Thank you.
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| 3 DR. REMICK: One other question.
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| 4- MR. CARROLL: Why didn't you invest in a piece of 5 a six inch pipe and bring it up to the top of the building.
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| 6- MR. MICHELSON: You would think so.
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| 7 MR. McNEILL: Excuse me. l 1
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| 8 MR. CARROLL: I suggested you might want to invest 9 in a six inch piece of pipe and bring it up to the top of 10 the building. !
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| i 11 MR. McNEILL: After we finish our IP we may in I
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| 12 fact come to that conclusion.
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| 13 DR. REMICK: Ted, this might come later --
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| r's 14 MR. McNEILL: Wait, let me -- excuse me just one N-]
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| 15 minute.
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| 16 DR. REMICK: Yes.
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| 17 MR. McNEILL: I don't want to be too strong here, 18 but I don't like investing even relatively small amounts of ;
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| 19 money in something where a year later the regulator turns 20 around and says you've got to do something else.
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| 21 When the issue.is resolved we will move quickly to i
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| 22 implement those simplistic things that can be done. I've 23 been through too many things where I rip out after I install 24 because it doesn't quite meet the regulation.
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| 25 DR. REMICK: Maybe the others will cover it, Ted,
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| () Heritage Reporting Corporation (202) 628-4888
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| i i: "
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| 268 ]
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| (f 1 ~ but what EPGs do~you use in unit-1 and'what are planned for j
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| 2 . unit-2? Maybe that's not an appropriate question for you.
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| 3 MR. ULLRICH: I can answer that, but it will.be 4 covered later. It's EPG-3,.Rev.13. We have the information
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| '1 5 for EPG-4 here'and our operators are trained on EPG-3 now. U 6 They qualified on that and later this year we'll start-J
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| , 7 developing.our procedures for the fourth revision. '
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| 8 DR. REMICK: .Thank.you.
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| 9 MR. MICHELSON: That is an inerted containment?
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| 10 MR. ULLRICH: It is an inerted containment, yes..
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| 11 MR. MICHELSON: Are you using hydrogen water
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| '12 chemistry?
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| 13 MR. ULLRICH: Excuse.me?
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| 14 ' M1. MICHELSON: Are you using hydrogen water 15 chemistry?
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| 16 MR. ULLRICH: Not yet.
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| 'l 17 MR. MICHELSON: ,Not yet.
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| 18 MR. ULLRICH: Not yet. We will not use it on 19- unit-1 or unit-2 for the.next cycle. But it's in the plans.
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| l 20 MR. WYLIE: On your five transmission lines, one 21 unit feeds the 500 and'one 230. Is-there an auto 22 transformer on site tying those together?
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| 23 MR. ULLRICH: Yes. There are two tie-lines 24 between the substations.
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| 25 If there are no other questions I would like to
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| m_._____._________________ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . _
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| 269 I (O_) 1 introduce Mr. Graham Leitch, our Vice President of Limerick
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| , 2 sitet 3 DR. KERR: 1 hank you, Mr. Ullrich.
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| 4 MR. McNEILL: Mr. Wylie, I might also note that we !
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| 5 have a 69 kv line that we have, that is not permanently ;
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| i 6 connected to the site, but it has about -- all of the 7 procedures are in place for about a one hour time interval l
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| 8 to in fact connect that into the plant. !
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| 9 MR. WYLIE: Where does that come from?
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| 10 MR. McNEILL: That comes from our Kromby 11 Generating Station which is further down the Schuyk1 River
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| '12 about five miles.
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| 13 (Slides being shown.)
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| rm MR. LEITCH: Good afternoon.
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| x) 1415 My name is Graham Leitch, I am the Vice President 16 of Limerick Generating Station. I have been employed by 17 Philadelphia Electric for 33 years. All of that time in the 18 business of operating power plants.
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| 19 I have had the overall responsibility for the 20 operation at Limerick since 1975, having various titles and 21 with various spans of responsibility depending upon the 22 organizational structure.
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| 23 Five years ago when Limerick-1 was at this stage I 24 had the privilege to speak to you as plant superintendent.
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| 25 I am here today to tell you about our operating experiences
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| () IIeritage Reporting Corporation (202) 628-4888
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| h 270' 1 with Limerick Unit-1 and our readiness to operate unit-2..
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| 2- Since'the beginning of staffing for Limerick we 3 have emphasized values such as: quality; safety; and the 4 impo~rtance of people. But it has'only been within the past' 5 year that we as a nuclear group formalized statements of our 6 vision; our mission; and our values.
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| 7 As this slide indicates, our vision is to be a 8 leader in the nuclear power industry.
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| 9 And our mission is the safe, economical, reliabin 10 generation of electric power.
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| 11 The values to which we adhere are, first of all, 12' safety. And then in no particular order of priority, since 13 they-are all extremely important, quality, dynamic business j ~ 14 focus, team work, people, and integrity.
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| 15 We the management of the nuclear group;and of 16 Limerick station firmly believe in these values and consider 17 them not only in what we write and in what'we say,-but also 18 .in our day-to-day decision-making processes.
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| 19 We believe as we communicate these values to the
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| ~20 employees at Limerick, we~see these values reflected back in 21 a positive culture. We feel that such a culture has always 22 existed at Limerick, and the formalization of this statement 23 of values serves to reinforce that culture.
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| 24 MR. MICHELSON: What does a " dynamic business 25 focus" mean?
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| l' i-271-
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| 1 MR. LEITCH: Dynamic refers to the fact that we 2- believe that we are in a changing environment and we'have to 1
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| - J l
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| -3 be receptive to change. Changing in our thinking.-
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| 4 Business, of course, refers to doing work-in an 5 . economic way. We believe that we have a fine technological
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| '6 process here, but that the challenge for Limerick, indeed 7 perhaps the challenge in the nuclear power. industry in these
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| .8 next.few' years-is to make it a viable. economic process.
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| 9 And we think the challenge is to be receptive to 10 change and-to bring about change with no compromise to 11 safety or no compromise to quality. But to bring.about-12 change in such a' fashion that will make the process more 13 economical.
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| 14 A reflection of the culture at Limerick is our pJ 15 ability.to manage a number of variables at or better than 16 -imposed best quartile. .Among these variables are rad 17 control. Our volume of low-level rad waste and the square 18 feet of surface contamination at' Limerick are both better 19 than the INFO best quartile.
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| 20 Our radiation exposure of 53 man-rem in 1988 is 21 not only better than the INPO best quartile; it is the best 22 in the United States and one of the best in the world.
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| 23- We also point with pride to our industrial safety.
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| 24 record. Since commercial operation at Limerick there have 25 been only two lost time accidents. And in April we passed l
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| l 1
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| i 1
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| 272 j
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| : 1. two'million man hours without a. lost time accident.
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| 2 DR. REMICK: Mr. Leitch,.how does that compare
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| + '3 -with the goal you set for the'INPO performance indicator, 4 i
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| 4' that figure? )
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| 5 MR LEITCH: That makes-us better than the INPO-6 best' quartile in that regard.
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| 7 DR. REUICK: How about your.own. corporate goal 8 .that.you must have set at the time that INPO was setting?
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| 9 MR. LEITCH: A corporate goal?
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| '10 .DR. REMICK: :Yes.
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| 11 IGL LEITCH: We had a corporate'-- we surpassed 12- our corporate goal. In 1988 the corporate goal for Limerick 13 was four lost. time accidents. And we had one very'early in 1988. So what I'm saying is, we passed two million man
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| } 14 15 hours since'we had that one.
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| 16 In 1989, this year, we have made that corporate 17' goal even more aggressive and lowered it to two lost time 18' accidents for Limerick in 1989.
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| -19 DR. REMICK: Thank you.
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| 20 MR. LEITCH: We are also proud of our safety 21 system performance.. Because in 1988 there was no forced 22 unavailability of HPCI, RICI or RHR systems.
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| 23 We have also demonstrated our ability to operate 24 at or better than INPO's best quartile. An. example of this
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| '25 is our very low forced outage rate. It has been 19 months
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| u ____ __ _ _ _ _ _ _ _ _ - _ _ _ _ _ . .
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| q 273 p.
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| CJ' 1 since there was a forced outage at Limerick. And our forced
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| ]
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| 2 outage rate in the year 1988 was zero.
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| 1 3 As well as having a very low number of scrams l l
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| 4 during the power ascension program, we have had only four ]
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| 5 scrams in the almost four years of commercial operation.
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| 6 We attribute this to very low -- this very low 7 number of scrams to a conservative design combined with 8 conservative quality approach to operations.
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| 9 At Limerick the major downtime has been for 10 planned outages.
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| 11 MR. CARROLL: Out of curiosity, what has been your 12 cumulative forced outage rates since commercial?
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| 13 MR. LEITCH: I don't know that I have that data.
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| MR. CARROLL: I can look it up in the grey book I
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| ( } 14 15 guess.
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| 16 MR. LEITCH: In 1987, I cannot remember a forced 17 outage. In 1987 there were two forced outages of short 18 duration, two or three days a piece. One caused by a false 19 indication of moisture separator drain tank high level. One 20 caused by a scram on the rupture of electra-hydraulic 21 control fluid line.
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| 22 I would say that that represented a total of, 23 perhaps no more than 10 days forced outage. I can think of 24 no other forced outage in '87.
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| 25 In '86 there was a scram caused by an instrument
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| ~
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| . Dj
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| , i 274-i, ) 1- _ technical grounding a probe.- And that forced outage lasted 2 for perhaps two days.
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| 3 Later in 1986 there was a packing leak into 4 containment. And we~had some problems with the recirc pump 5- seal. So while we were off to repack that containment
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| : 6. valve, we-also replaced the recirc pump seal. I would think 7- that was of the order of a 10 day outage as I recall.
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| . I p 8 I don't-know. Jay, do you -- Jay Derring is the 9 . superintendent of operations. Do.you remember any'others, 10 Jay?
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| 11 MR. DERRING: I think you got them all.
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| 12 MR. LEITCH: Okay.
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| 13 MR. CARROLL: Impressive record.
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| 14 MR. LEITCH: Between these outages we have
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| : 15. achieved long periods of continuous powerLoperation. In 16 1986 there was 198-day run. 1987 through 1988 there was a 17 200 day run.. And the run which ended with the'second 18- refueling outage was a 268 day run.
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| 19 We continue to track our performance against all-L 20 published'INPO performance indicators as well as a. number of 21 other indicators. This performance information is reported-22 to me on a monthly basis, so that.I can be aware and take
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| -23 appropriate corrective actions, if I observe trends toward E
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| 24 degradation.
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| 25' An example of a performance indicator that
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| ()l Heritage Reporting Corporation (202) 628-4888 l
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| l ..
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| 3.,
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| l 275
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| ( )' J1 . required specific management attention was the cause of a.
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| 2 number of LERs,' licensee _ event reports. Although not an 3' INFO indicator,-it_was clear that 132 LERs in the first year 4 of operation was an unsatisfactory level.
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| 5 We applied special attention to this indicator.: '
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| 6 The root cause of each LER was determined and appropriate 7 corrective actions were taken to prevent recurrence.
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| 8 In most cases this consisted of special training; 9' procedure revision; or plant modifications. We continued.to
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| 'O work to further reduce the number of'LERs. But we feel that 11 the' number we are. presently experiencing is ind'cative1of i a 12 maturing plant.
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| 13 Unit-2 will be started with the benefit of this 14 experience. We do not expect to see a repeat of-these high 15 numbers experienced on unit-1.
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| 16 DR. KERR: You don't want to get that down too 17 low, the-NRC staff will think you're trying to avoid the. I 18 (Laughter)-
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| 19 MR. LEITCH: Well, we sure are trying to avoid 20 them.
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| 21 MR. McNEILL's I would like to get on a -- I forget
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| : 22. .what the exact terminology is -- but I'd love to get this 23: plant on one of those extended inspection cycles or reduced 1
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| 24' inspection cycles that some of the northern' midwest plants j 25 are on.
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| () Heritage Reporting (202) 628-4888 Corporation I
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| 276
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| (~ 1 ke) 1 MR. LEITCH: We have been well pleased with the 2 quality of operations at Limerick. It is important to us, 3 though, to consider how others view our performance. And it 4 is gratifying to notice in this tabulation of NRC's SALP 5 ratings that our performance has improved and continues to i
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| 6 be strong. The NRC has, in their presentation, already 7 addressed these ratings.
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| 8 MR. MICHELSON: Let me ask, what is your present 9 status and experience with the motor operated valve problem 10 such as -- you know, your 80 bullet in 8503 response and so 11 forth? l 1
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| 12 MR. LEITCH: We have a very aggressive program.
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| 13 In fact, 'we believe we're an industry leader in the field of
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| (~) 14 motor operated valves. We have -- early on we worked in the 15 development of the MOVATS process. On unit-1 we took every 16 motor operated valve and rebuilt it to the latest standards ,
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| l 17 and tested it using the MOVATS process. And in that time 18 frame of unit-1 we were a leader. We were one of the first 19 to be on that course.
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| 20 And unit-2, of course, we're doing the same thing 21 but it's more traditional now to be doing that type --
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| 22 MR. MICHELSON: I sense that perhaps you extended 23 your rework and examination beyond the requirements of 8503; 24 is that correct?
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| 25 MR. McNEILL: Yes, that's correct.
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| () Heritage Reporting Corporation (202) 628-4888
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| 277 1 MR. LEITCH: Bob Lees is,in the audience and I 2 1think he can perhaps give us some additional details in 3 that.
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| ~
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| 4 ~ Bob, could you amplify in that area a:little bit.'
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| 5 MR. LEES: Yes. I'm Bob Lees, I'm manager of'
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| : 6. electrical. engineering.-
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| 7 Yes, we did extend the program beyond the 8503 8 requirements into essentially all of the Q listed motor
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| ;9 operators. And essentially,'the similar program was also 10 extended to our Peach Bottom Station, and I think we talked 11 about that when we were down discussing Peach Bottom with
| |
| [" 12 you.
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| 13' So it's become more or less standard operating procedure to use the MOVATS program and to measure these
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| { } 14 15 parameters.
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| 16 MR. MICHELSON: Are you somewhat familiar with the 17 proposed generic letter to extend the requirement to all 18 valves?
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| 19 MR. LEES: Yes, but not in detail.
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| 20' IE. MICHELSON: I just wondered if you had 21 evaluated its impact.
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| 22 MR. KEMPER: Unit-2 all valves, motor operated 1
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| R23 valves is MOVATS. l 24 DR. KERR: Would you identify yourself.
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| 25 MR. KEMPER: John Kemper, Senior Vice President of
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| ( )- Heritage Reporting Corporation (202) 628-4888 1
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| 278
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| () 1 Nuclear Construction.
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| 2 MR. McNEILL: His name is John Kemper, he is i
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| 3 Senior Vice President of Nuclear Construction. And 4 indicates that all Limerick-2 valves have been MOVAT tested.
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| 5 I'm not sure that we have done the differential calculations 6 or let me say, differential pressure demonstrations that are 7 required by 8503. I think we've taken the calculational 8 methodology into account in determining the settings.
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| 9 MR. MICHELSON: At least you've done the initial 10 part.
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| 11 MR. McNEILL: That is correct.
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| 12 MR. MICHELSON: To all valves.
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| 13 MR. McNEILL: Yes, we have.
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| . (~g 14 MR. MICHELSON: Thank you.
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| V 15 MR. McNEILL: We intended to do that through both 16 plants over a period of time.
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| 17 MR. MICHELSON: Thank you.
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| 18 DR. KERR: Thank you.
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| 19 MR. LEITCH: There has been one significant 20 technical problem with Limerick No. 1, fuel cladding 21 failures which we experienced in the second cycle.
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| 22 The problem was crude induced localized corrosion 23 commonly referred to as CILC. Limerick is a high power l
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| 24 density reactor having condenser tubing. And having l
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| 25 filtered demineralizers rather than deep bed demineralizers 1
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| Heritage Reporting Corporation (202) 628-4888 l
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| l
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| 279 m in the condensate feedwater cycle.
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| (_) 1 2 For these reasons it is considered a CILC 3 susceptible plant.
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| 4 We experience fuel failures not only with the 5 initial core fuel, but in fuel that was installed during the 6 first refueling outage.
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| 7 Although the CILC mechanism is well known and 8 understood in the industry the phenomena was unusual at 9 Limerick because of the speed with which it progressed and 10 led to the cladding failures.
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| .l 11 The contributing factors to this accelerated 12 cladding failure were found to be the synergistic effect of 13 the reload one fuel cladding surface condition, which was em not as corrosion resistant as we had first thought.
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| N) 14 15 Secondly, the levels of copper in the feedwater 16 were somewhat in excess of recommended values.
| |
| 17 And thirdly, in the second cycle we experienced a 18 rupture in the electra-hydraulic control fluid line. I 19 referred to that earlier in causing one of the scrams. And 20 scme of this fluid spilled into sumps and found its way into 21 the reactor system.
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| 22 Because of the fuel cladding problem we have 23 instituted a number of corrective and preventive measures.
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| 24 A short term actions are to improve the reactor 25 water chemistry, including enhancing on-line chemistry
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| () IIeritage Reporting Corporation (202) 628-4888
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| L j 280 1- monitoring. Limit the copper concentration in the V .
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| ~
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| 2 feedwater, even if that requires operating at somewhat less 3 than full power. And improve responsiveness to chemical 4
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| ~1 transienta.
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| '5 Longer term actions include the-installation of
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| : 6. ' deep bed.demimeralizers which will be installed at the next 7 refueling outage on both units. And to support efforts to-8- improve the' manufacturing process to find the most corrosion 9 resistant cladding me.terial.
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| 10 DR. REMICK: Am I correct in remembering that the 11 deep bed demineralizers would be-in series with the present -
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| 12 filter demineralizers.
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| 13 MR. LEITCH: Yes, that's correct.
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| 14 DR. REMICK: In addition to --
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| 15 MR. LEITCH: That's correct. Yes, sir.
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| 16 These efforts supply equally to unit-1 and to 17 unit-2.
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| 18 MR. CARROLL: What are the bad actors from ak 19 cladding corrosion point of view in EH fluid?
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| 20 MR. LEITCH: We had high total organic -- well, we 21 had the introduction of total organic compounds into the 22 reactor water. And although the linkage between those 23 fluids and the CILC failure is-not well understood, it is 24 clearly a distinction which occurred at Limerick early on in 25 the second cycle right after this, you know, reload fuel had l
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| L L1! .been' installed. f if ; 2 And we b'elieve that it prevented the formation-or
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| , '3 in some:way disturbed the formation of an oxide film on the 4 zircalloy tubing.- That is-clearly a distinction'in this 5 second cycle of operation. To exactly link that as cause 6' and effect is not entir'ely we31 defined. But we do believe 7 there is some relationship there.
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| 8 Because there have been other plants that have 9 operated-at the copper levels that we have experienced.
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| 10 Yet,lwithout this very rapid progression of the CILC 11 failure.
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| 12 MR. CARROLL: Do the organic decomposition 13 products that you end up with in the reactor, are they 14 organic' sulfur compounds or --
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| -15 MR..LEITCH: I'm sorry,-I'do not know the answer.
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| 'e to:that. I know that they are not readily processed by the 17 demineralizers that we have. We believe that a carbon bed lf 18 would perhaps be more effective in the removal of these 19 organic compounds. But the exact nature of the compounds, 20 I'm sorry I cannot address that issue.
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| 21 MR. McNEILL: These are a phosphate ester, I 22 believe,.is at least one major constituent of this electra-23 hydraulic fluid. And'I think you would therefore see some 24 phosphate higher than normal in that water. But I don't 25 think we understand the full decomposition products.
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| 282 1- MR. MICHELSON: When you say, improve 2 l manufacturing processes, are you referring to the' fuel
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| 3 fabrication? 1 4 MR. LEITCH: Yes, sir, that's correct.
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| 5 MR. MICHELSON: Were some of the problems that.
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| 6 attributed in part to the -- some of the.former
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| : i. .
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| 7 manufacturing processes?
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| 8 MR. LEITCH: Yes.
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| 9 MR. MICHELSON: Could you give an example of what 10- is now going to be change?
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| 11 MR. LEITCH: Let me say that there's rtwil some 1:2 ongoing changes that may occur in the future and that's
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| {. 13 specifically what.I referred to here. But what we did-find out in this -- with this reload one fuel particularly, which
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| { } 14.
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| 15 was all heat treated and which we thought to be.the~very 16 best fuel that was available at that time.
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| 17 We found that there was a difference in the way 18 the material was tested versus the way it was manufactured.
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| 19 In other words, after the fuel cladding was manufactured a 20 test specimen was removed. And that test specimen was 21 etched'and then tested for its corrosion resistant ability.
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| 22 Whereas the run of the plant, the manufacturing 23 run uss not etched at that point. We believe that that
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| -24 etching masked.to a certain extent the fact that some of 25 this tubing that was being manufactured was not up to
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| ) 1 standard's.
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| 2 And in fact we went back and tested the archive 3 ' samples and found that it passed properly when using those 11 techniques. But then when not etched, when just tested on
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| : 5. an as-received basis it failed and would not have passed the 6 standards that the manufacturer --
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| 7 MR. MICHELSON: What puzzles me is why the problem 8 appeared recently. Apparently they must have changed then 9 the heat treatment process earlier.
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| 10 MR. McNEILL: They did.
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| 11 MR. LEITCH: There are a number --
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| 12 MR. MICHELSON: That's what in part, at least, 13 contributed --
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| 14 MR. McNEILL: The etching sequence was changed on
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| (~)g s
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| 15 the tube. fabrication. And that unbeknownst to them because
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| ' 16 . of-the testing process it affected the final surface 17 condition.
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| 18 MR. MICHELSON: Because I've often been puzzled on 19 why does this appear all of a sudden.
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| 20 MR. McNEILL: Right. They changed their 21' manufacturing process and without fully comprehending what.
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| 22 _the effect of that would be. And their testing processes 23 .did not highlight it.
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| 24 One other potential change that we might see is 25 the cool down rate of the heat treated; and therefore the
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| _1 phase - Alpha, Beta phase mix of the surface -- of the, l 1F material, cladding material, there appear to be differences l
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| 3' in manufacture,-among-the different manufacturers. And the 1 4 higher tolerant ones use a different cool down process than 5 the one that our fuel manufacturer employs.
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| 6 I should hasten to add, though, that there are 7' reactors operating with fuel that has been manufactured like 8 ours and they're operating quite satisfactorily.
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| 9 That's why I say I believe it to be the 10 synergistic effect of this manufacturing process which was 11 not as corrosion resistant as we had thought, the high~
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| 12 copper. And then the abnormal occurrence of the 13 introduction of admittedly but rather'small quantities of EHC fluid into the system.
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| } 14 15 MR. MICHELSON: I thought Browns Ferry, for 16 instance, had this same problem and theirs was to high 17 copper.
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| 18 MR. LEITCH: Yes. Theirs, as I understand it, 19 though, was non-heat treated fuel that failed. You see we 20 had -- this fuel was installed in'1987 at the first 21 refueling outage and we were really shocked to find problems i 22 with this fuel. It was all heat treated and we believe that 23 we would not have this problem.
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| 24 MR. MICHELSON: I assume that that was supposed to 25 have been an improvement.
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| 285
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| (_ 1 MR. LEITCH: It certainly was.
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| 2 MR. MICHELSON: A cost improvement or material 3 improvement. But improvements don't always works out it.
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| l 4 seems.
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| 5 MR. LEITCH: That's exactly right, sir.
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| 6 MR. McNEILL: That's correct.
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| 7 MR. CARROLL: What was the, quote, " failure rate 8 of the fuel" or what is it?
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| 9 MR. LEITCH: Failure rate?
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| 10 MR. McNEILL: We have been forced to replace one-11 third of the fuel in the core that we had not anticipated -
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| 12 replacing.
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| 13 MR. LEITCH: Our calculations indicated that there were 55 pins that failed at that. Now we have not examined
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| (~J)
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| % 14 ,
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| 15 100 percent of the fuel, so we cannot confirm that it was l 16 indeed 55 pins that failed.
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| I 17 MR. MICHELSON: Have you tried to rerod the fuel f
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| 18 or are you just shipping back the entire assembly or what?
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| 19 MR. LEITCH: I'm sorry, I didn't quite hear yot r ,
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| 20 question.
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| 21 MR. MICHELSON: Did you have to rerod the fuel in 22 the pool or how did you take care of the problem?
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| 23 MR. LEITCH: We did some of that. We replaced 24 basically two-thirds of the core with brand new fuel. That 25 is, one-third was already scheduled for replacement, i
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| ' (,) Heritage Reporting Corporation (202) 628-4888
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| 1 286 r
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| [ssb 1. obviously, and we unplanned, we replaced another third of' ,
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| l 2 the core. l 3 The remaining third then we did some .
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| 1
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| : 4. reconstitution or reroding. I think that.same term we're j 5 using interchangeably where we reconstituted bundles in the' ,
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| 6 fuel in the pool and made good bundles of high visual 7 standards.
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| 8 Then we also took some fuel that had been I 9 discharged at the first refueling outage and was in the 10- ' spent fuel pit and inspected that and reused that fuel.
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| 11 So we fully reassembled the core with either brand 12 new fuel or' fuel which has a very high visual standard
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| ' 13 ' effectively equal to that of brand .new fuel.
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| 14 MR. MICHELSON: It didn't affect every fuel rod
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| }
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| 15~ equally, then, apparently.
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| 16 MR. LEITCH: No, it did not.
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| 17 MR. MICHELSON: Also puzzling. ;
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| i 18 MR. LEITCH: There seemed to be a propensity for 19 it to be near the center of the bundle. And in those 20 bundles that were affected, the bundles were in the high 21 power density zone of the core. There are outliers though, 22 what I'm saying is not rigorously true in all cases, but !
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| c 23 there certainly was a propensity for it to be near the 24 center of the core. And in those bund 3es in the center of l:
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| 25 the bundles.
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| .V 1 What.I would like'to do.is discuss with you
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| ' ]
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| i 2 . sustaining performance trends which currently' exist. I
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| ']
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| '3- believe that one important factor ic communications. We
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| '4 have improved' inter group communications in a number of 5 ways. We have initiated a site newsletter which is 6 published twice weekly for distribution to all employees 7 quickly disseminating information down through the 8 organization.
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| 9 We have had and will continue to have all-hands I I
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| 10 meetings to discuss with off-site personnel issues of common 11 interest. j
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| -12 'We also have had meetings with supervisors to 13 discuss specific concerns that they may have and to share.
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| l q .14 information of interest to them.
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| V 15 In addition, we have embarked on a supervisory 16 training program designed to upgrade the supervisory skill's 17 of incumbents.
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| 18 In the future, supervisors will be selected based 19 on assessment of their individual skills rather than by 20 seniority and new supervisors will be trained in supervisory 21 skills prior to assuming their duties.
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| 22 We also' plan to provide additional training at all 23 levels in the organization in 1989 and 1990. This training 24 will be primarily focused on inter personal relationships.
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| 25 We have instituted annual face-to-face performance
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| ! 287 L (,f - l' What I would like to do is discuss with you l
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| 2 sustaining performance trends which currently exist. I 3 believe that one important factor is communications. We 4 have improved inter group communications in a number of 5 ways. . We have initiated a site newsletter which is 6 published twice weekly for distribution to all employees 7 quickly disseminating information down.through the 8 organization.
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| 9 We have had and will continue to have all-hands 10 meetings to discuss with off-site personnel issues of' common
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| -11 interest.
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| 12 We also have had meetings with. supervisors to' 13- discuss speciric. concerns that they may have and to. share 14 information of interest to them.
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| 15 In addition, we have embarked on'a supervisory 16- training program designed to upgrade the supervisory skills 17 of incumbents.
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| 18 In the future, supervisors will be selected based I
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| 19 on assessment of their individual skills rather than by 20 seniority and new supervisors will be trained in supervisory 21 skills prior to assuming their duties.
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| 22 We also plan to provide additional training at all 23 levels in the organization in 1989 and 1990. This training 24 will be primarily focused on inter-personal relationships.
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| 25 We have instituted annual face-to-face performance
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| ( 1 evaluations for all employees.
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| 2 One of the things that any organization must do is 3 to continue to evaluate the climate that exists within that 4 organization. To that end, we plan to do, as INPO has 5 suggested, a self-assessment of personnel practices that 6 support professionalism in the work place.
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| 7 It is our objective to have this self-assessment 8 accomplished during 1989.
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| 9 Our demonstrated good performance on Unit 1 points i 10 toward our readiness for two-unit operation.
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| 11 Unit 2 procedures have been written and approved i
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| 12 and are being used to conduct the surveillance test as Ted 13 has already discussed earlier.
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| g 14 At Limerick we have always had cix shift teams in
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| 15 place. And we have been planning for a two-unit operation 16 for years. We now have more than adequate numbers of senior 17 reactor operators, reactor operators, and non-licensed 18 operators available to fill all six shifts for two-unit i
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| 19 operations such as scheduled overtime will not be required 20 to fill these positions.
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| 21 In fact, operations have been performing the Unit 22 2 functions around the clock for the last nine months. Not 23 only do we have enough operatcrs to fill the shift 24 positions, but we also have enough excess people to provide 25 for a deliberate flow of operators to off-shift assignments. !
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| ]I 1 Some of this has already occurred. And indeed, 2 two of the. original shift superintendents have been~ moved 4 3 off shift to other.important operator-related functions.-
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| 4 We also have as temporary off-shift assignment a 5 shift supervisor and a reactor operator working in the 6 blocking and permit-writing area.
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| 7 Finally, as I muntioned at the outset, we believe 8 that as management, it is of the utmost importance that we L 9 continue to convey to all the people who work-at Limerick 10 our sense of values. 4 11 We believe that as we continue to live t nese 12 values the culture will continue to reflect them.
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| 13 In summary, we have learned a great deal-from the 14 operational experiences that we have had with Unit 1. We 15 believe the plant has operated safely and in a high quality 16 fashion. '
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| 17 We are now ready to accept the challenge of l
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| 18 operating the second unit.
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| 19 Subject to your questions, that concludes my 20 presentation.
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| 21 DR. REMICK: Mr. Leitch, during our tour, you 22 introduced us to several of your shift supervisors and we 23 had the benefit of discussion with them. And we also met 24 one of your young STAS, if I recall, who had been on shift j ,
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| 25 for five years already.
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| W L k L 290 ln: 1 From those discussions we learned that you have a
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| l 2 different philosophy at Limerick than you do at Peach Bottom
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| '3 on how you engineering expertise on shift. Since.the
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| '4 Committee last heard your Peach Bottom presentation, could 5 you tell'us the difference of the two philosophies at 6 Limerick and Peach Bottom?
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| 7 MR. LEITCH: 'Yes. And let me mention that we have 8 in the audience Joe Monaghan who is one of our shift 9 superintendents and I think Ed Evans is here who is one of 10 our shift technical advisors. And those fellows may want to 11 approach the microphone. I don't know if they would have
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| .12 some additional remarks on this topic.
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| 13 But let me say first of all that at Limerick we 14 have shift superintendents as the management representative 15 on shift. He is exactly analogous in my mind to the shift 16 manager at Peach Bottom. He has all the same !
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| 17 responsibilities as the Shift Manager at Peach Bottom. He E18 'is in every sense a part o:? the management team here at 19 Limerick and he is my representative, the Plant Manager's
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| : 20. representative, and is responsible for all ongoing 21 activities.
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| 22 MR. WARD: That's for both units?
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| 23 MR. LEITCH: For both units. One man for both 24 units. He is at the top of the organization. And the 25 difference is that the shift superintendents have basically
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| I 291 4
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| 1 come up through the ranks and have been carefully selected 2 at the beginning of the operation of Limerick. I selected 3 the people. And I feel that we have a very good group of 4 shift superintendents who are dedicated to the safe 5 operation of the plant and who understand the public q j
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| 6 responsibility and the public trust that they have.
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| .i 7 They do not have engineering degrees. As
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| \
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| 8 contrasted from the shift managers at Peach Bottom, who have 9 engineering degrees, but have somewhat less experience than 10 the people that are the shift superintendents at Lime 2ick. j 11 We have on shift as well shift technical advisors 12 who are engineers, who do have engineering degrees, who 13 rotate with the shift and are in every sense part of the 14 shift. They train with the shift. They rotate with the
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| 15 shift. And they are well accepted by the shift. And they
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| .16 provide engineering expertise on shift.
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| L 17 We think this gives us a good strong leadership 18 position and I don't think you need to be around Limerick 19 very long to really feel that the shift superintendents are l
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| 20 definitely in charge of what's going on in that plant.
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| 21 So that's our approach to the situation.
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| 22 DR. REMICK: Thank you.
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| 23 Are there other questions <4 Mr. Leitch? If not, 24- I would suggest we take a ten-minute creak. In fact, we'll 25 expand that to-twelve minutes, returning at five o' clock.
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| il 292 N_/ L1- (Whereupon, there was a sh'rt o recess.)
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| 2 DR. REMICK: Please proceed,.Mr. Helwig.-
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| 3 M R .'' H E L W I G : . Thank you. ;
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| 4 My name is David Helwig. As Mr. McNeill 5 introduced.me, from November '87.to March of this year I was 6 GeneralLManager and Nuclear Quality Assurance with 7 Philadelphia Electric. In this capacity, one of major 8 responsibilities was to define, organize and' implement a.
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| 9 thorough ^ coordinated program for assessment of Limerick Unit 10 2 :and our readiness to operate it.
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| 11 Our Unit 1 experience had demonstrated,.we 12 believe, the adequacy of our programs for construction 13 start-up and. operation, but we desired added assurance that everything would go smoothly on the aggressive-schedule that
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| ) 14 15 we had set for ourselves.
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| 16 After quite a bit of study and deliberation, we 17 ended up with a three-level process of assessment comprised I
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| 18 of, first, a readiness program assessment. .Next, an l 19 organizational readiness assessment, and a Readiness 20 Verification Program. l 21 I will talk about each of these in turn.
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| 22 As the first step of our assessment, which began 23 about the summer-of 1987, called our Readiness Program 24 Assessment, we inventories and examined all of the programs 25 in place for design, construction, start-up and initial Heritage Reporting Corporation (202) 628-4888 i
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| 293 1-- operation. We uvaluated the completeness of those programs, 2 their interrelationship-and.the assigned responsibilities 3 -forth$ inexecution.
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| 4 As a result-of this study, we concluded that the.
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| e
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| =5 programs in place were generally adequate, but that our j 6 readiness could be better assured._if we implemented two 7 additional programs. The Organizational Readiness:
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| 8 Assessment and the Readiness Verification Program.
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| . ~9 .The second step of our assessment process, the 10 Organizational. Readiness Assessment, was really our process 11 to formally identify and track those specific activities 12 required'to ensure the readiness of each of the functional 113- tareasl involved with operations and start up and support of 14 operations.
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| 15 .Through this process we catalogued, s heduled and.
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| 16 haveEcontinued to track the completion of somewhere over 250 17 specific activities for these functional areas. They've 18 primarily.been comprised of items in the categories of !
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| 19 staffing procedures, equipment and training.
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| 20 The third step of the program is a Readiness
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| : 21. Verification Program and encompasses all of these components .I 2
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| .2 that are highlighted in yellow.
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| 23 Up to this point the program aspects I've talked 24 about have been kind of planning in nature. They are 25 assessing ahead of time what it is we're doing. In 0 rie e-(202) 628-4888 verei-e cereer eie-
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| 294
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| .1 contrast, the Readiness Verification, the. third component of 2 this program, is specifically targeted to verify that these 3 activities are, in fact, completed effectively.
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| 4 In the development of this. program, we looked at a 5 great deal of information', a large number of sources, and 6 selected somewhere over 300 elements of the program for 7 verification. Sources we looked at in developing this 8 program encompassed various sources of information about 9 Limerick and particularly our Unit 1 operating experience, 10 our Peach Bottom experience and lessons learned, and the 11 experience of other plants, contemporary boiling water 12 reactors, in particular, in terms of NRC and utility self-13 inspection initiatives.
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| 14 Each of these elements was then reviewed in one of
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| (}
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| 15 three ways. It was either reviewed by programs within our 16 Nuclear Quality Assurance Organization. What we did here 17 was target the audits and reviews over this year-and-a-half, 18 two year period, target the audits and reviews of our 19 Quality Assurance Organization, our independent safety 20 engineering groups, and our Performance Assessment Division 21 to specifically focus on these aspects of the program.
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| 22 We used a number of outside consultants to conduct 23 reviews of the independent oversight organization. We 24 didn't feel it would be quite appropriate to do that 25 ournelves so we employed some outside consultants to do a (f Heritage Reporting Corporation (202) 628-4888
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| I 295 l (j) f 1 number of reviews of QA performance assessment and 2 independent safety engineering activities.
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| 3 In addition to this, we had a large program that 4 I'll discuss in detail called our Independent Design and 5 Construction Appraisal which was conducted for us by Stone 6 and Webster at my direction.
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| 7 That's comprised in three boxes here. As you see, 8 the Independent Design and Construction Appraisal, it was 3 9 one integrated process but it can be conceptually divided 10 into two major areas. An appraisal of our construction 11 activities and an appraisal of our design activities.
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| 12 We can't take credit for this being an entirely 13 original approach. We patterned it after a combination of i
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| )
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| 14 NRC initiatives in the IDI--Independent Design Inspection--
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| 15 and Construction Appraisal Team Inspection processes. And, 16 in fact, we employed a deep vertical slide review technique 17 for which we focused on the combination of systems that 18 comprise the containment heat removal mode.
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| 19 This combination of systems is predominantly our 20 RHR system and residual heat removal service water system, 21 but the review encompassed all of the major supporting 22 system, power, HVAC, and service water, et cetera. And the 23 program expanded its focus. If this was a heat vertical 24 slide review, it expanded its focus horizontally to bound 25 any problem or question areas that Stone and Webster f
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| \_/ 1 identified, and also to cover topics that were not well ,
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| l 2 represented by meaningful populations of attributes within I l
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| 3 the selected system, 4 We did go through what I would call a joint effort I 5 with the NRC staff in terms of both developing this program 6 and selecting the system for examination. And, of course, 1
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| 7 the NRC staff, as was mentioned earlier, was intimately )
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| 1 8 involved at four agreed-upon times during the program in 9- terms of reviewing the depth of the review and the conduct 10 of the program. f 11 A very large program, as I've indicated here on j 12 the bottom bullet, between Stone and Webster and Bechtel 13 Engineering alone, we expended greater than 100,000 man
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| /~ 14 hours at this effort. I have not attempted here to account i
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| 15 for the Philadelphia Electric effort in terms of the J6 commitment of my Nuclear Quality Assurance Organization to 17 support this program.
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| 18 And just as a measure of the number of things 19 examined and looked at, I can count up over 45,000 specific 20 checks and verifications of hardware attributes and design 21 features.
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| 22 I have here a summary of the results of the 23 construction appraisal. I had summarized them. While there 24 were a number of items that required engineering review and 25 some document changes, and in fact there were a few program
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| :1 enhancen ents recommended as a result of this - review.
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| 2- There were in fact no rework items required in i
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| 3 order to assure a safety function. The net result.being '
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| 4 that Stone and Webster was able to conclude rather 5- conclusively that as far as the-construction effort was i
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| 6 concerned, the construction quality had been extremely good 7 and the NRC staff, upon their overview-of that activity and 8 their independent inspection of the activities at the site, 9 concluded similarly.
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| 10 As far as the design appraisal is concerned, the 11 results are somewhat similar to those I just characterized 12 for the construction appraisal. There were a number of 13 calculation revisions and document changes required, or document corrections required.
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| { } ' 14 '
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| 15 And, again, there were a few programmatic 16- enhancements recommended.
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| 17 In this case, I indicate here conservatively that 18 there was one item found that required a design change.
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| 19 Actually that's I' d say under dispute and I'm not sure I'll 20 ever know the honest to goodness truth about that. It turns 21 out there was an IE Bulletin 88-15 about undervoltage relay 22 set points and designs. And that was being reviewed within 23 Philadelphia Electric and Bechtel at about the same time i 24 Stone and Webster focused their review on that activity.
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| 25 So who really found it first, it depends who you i
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| ) 1 ask and everyone wants to own it. Nevertheless, we did, as 1:
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| 2 a result of either or a combination of the IE Bulletin l
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| 3 review'and the IDCA, replace some undervoltage relays and 4 change some tap change of settings.
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| L 5 I indicate here that there were six open items at L l 6 the conclusion of Stone and Webster's' design review. These 7 are six items I characterize as the sort of issues that 8 architect engineers just kind of don't see eye to eye on.
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| 9 And I was pleased to note that the NRC staff was not at all 10 surprise that there were six issues that Stone and Webster 11 and Bechtel didn't see entirely the same way.
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| 12 As a matter of-fact, last week the NRC staff spent 13 the entire week'in San Francisco reviewing the conclusion of 14 this_ design appraisal effort and each of those six-items has 15 been resolved to the staff's satisfaction.
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| 16 The net result of this very extensive design 17 appraisal review, and I would have to characterize that 18 there were many more items of questions and evaluation in
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| : 19. order to satisfy Stone and Webster in the design appraisal 20 area than there were in the construction appraisal area.
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| 21 The bottom line is that any deficiencies found in 22 this regard were minor and in fact they had no effect on the 23 design adequacy. This has enabled Stone and Webster and we 24 believe the NRC staff to conclude that the engineering and 25 design of the project has been satisfactory based on the
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| '( f Heritage Reporting Corporation (202) 628-4888
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| i 299 1 . s ampling . . They have'a1high degree of-confidence that the-2' plant, as designed and constructed, meets the licensing
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| .3' commitments.and-is. technical adequate.
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| 41 In. conclusion, I am very confident that we have 5 employed a-thorough process for self-assessment of our 6 readiness'of construction, design and readiness to operate e, 7 Limerick Unit 2. I believe that this. process has provided 8 ' effective confirmation of our readiness. And I would like 9 to point'out that in my mind this very much exemplifies the' 10 sort of-meaningful self-assessment that we have set as a 11 -standard within-the company and is characterized in the 12 four-level process of self-assassment that Mr..McNeill 13 explained to you during the' Peach. Bottom presentations to
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| : 14- -the Committee.
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| 15 Any questions?
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| 16 DR. REMICK: Any questions of Mr. Helwig from the 17 Committee?
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| 18 (No. response. )
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| 19 If not, we thank you, Mr. Helwig.
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| 20 MR. HELWIG: Thank you.
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| 21 I'd like to introduce Alan Marie who will be our 22 next speaker.
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| 23 MR. MARIE: I'm Al Marie and I'm Supervisor of the 24 PRA Branch.
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| 25 I'm going to give an overview of our PRA program
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| - (k Heritage Reporting Corporation (202) 628-4888 F
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| 300 l) 1 focusing on the updat'es of our-Limerick PRA and how the.
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| 2 results have changed. And also the PRA applications that we
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| : 3. have' underway in support of engineering and operations.
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| 4- The Limerick PRA was initiated in 1980 at the 5 request of the _ NRC. This was originally a Level 3 internal
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| ~
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| 6 events analysis and expanded in 1983 to include external 7 events in our Severe Accident Risk Assessment Report. The 8 results of all these analyses-were described in detail to 9 the ACRS in 1983 and ' 84 prior to the Unit 1 full power 10 license.
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| 11' Since then, we have updated the Level 1 internal 12 events portion twice and I will describe these in subsequent 13 slides. We do. plan future updates which will be responsive to the individual plant evaluation and external events
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| (^)%
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| % '14 15 Generic Letters, including seismic and fire risk analyses.
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| 16 We also plan ongoing updates to quantify any 17 effects of future station modifications and procedure '
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| 18 changes.
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| 19 The first update incorporated the as-built design I
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| 20 changes for Limerick and this included the specific valving
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| [
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| 21' and piping arrangements for the standby liquid control 1
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| 22 system, the lowering of the MSIV closure set point from
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| -23 Level 2 to Level 1, and implementation of a TMI action item 24 that affected ADS logic.
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| o 25 This update also incorporated the plant-specific l
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| 301 A.
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| ls/ emergency operating procedures which are based on EPG'Rev 3.
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| 1.
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| :2- This included all the EOPs with the exception of the'ATWS 3 venting procedures which were incorporated in the subsequent 4 update.
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| 5 Previously the.PRA was based on generic'EPG Rev 0.
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| 6 The second update completed the incorporation of _j 7 the procedures that reflected two-unit operation by modeling 8 the two-unit demands on the shared systems by namely RHR 9 service water and emergency service water.
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| 10 We updated the initiating event frequencies per 11 the EPRI/NRC database. We provided more complete modeling 12 of common cause failures. And this was applied to all 13 systems per NUREG/CR-4780.
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| ] ) 14 We added a reactor protection system fault tree.
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| 15 -This was previously handled through engineering judgment.
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| 16 We accomplished full linking of our fault trees to account 17 for any commonalities across events. And this addressed a 18 Brookhaven National Lab comment on the original PRA.
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| 19 We investigated several special initiators 20 separately and this included internal flooding, loss of 21 instrument air, and reactor water level reference legbreak.
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| 22 Juni finally we installed the PRA model on a self-23 contained PC-based work station which provided greater 24 efficiency in use and responsiveness to request.
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| 25 MR. MICHELSON: Can you tell me roughly what f ) Heritage Reporting Corporation (202) 628-4888 l
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| 302
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| (/ 1 vintage fire risk PRA you did? In other words when did you 2 do it, with what knowledge and at what level?
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| 3 MR. MARIE: The fire-risk analysis was done in 4 1982/83 time frame.
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| 5 MR. MICHELSON: Has it been repeated since or 6 upgraded since?
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| 7 MR. MARIE: We have not updated that analysis.
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| 8 But we do plan to do it as-part of the update for the IPEEE.
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| 9 MR. MICHELSON: Thank you.
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| 10 MR. MARIE: This chart illustrates the integrated 11 effect of these changes on the results. As you can see by ,
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| 12 the smaller circle, the' core damage frequency decreased to 13 about one half of that in the original PRA.
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| The same initiators are present but the percent of
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| { } 14 15 ' contributions have changed somewhat.
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| 16 Most noticeable is the ATWS category which has 17 increased. And the absolute increase here is about 50 18 percent in terms of ATWS contribution to the core damage 19 frequency.
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| 20 This is primarily due to incorporation of the 21 EPRI/NRC database for initiator frequencies. When we 22 compare these frequencies to our first two cycles at 23 Limerick, we find that this database is high and we will 24 review this further for a future analyses. We expect that 25 if we use site-specific data, the analysis would decline
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| L i i
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| 303 even further.
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| [J) 1
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| l 2 MR. WARD: Back in '86 you incorporated the plant j i
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| 3 procedures, the ATWS--
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| 4 MR. MARIE: I'm sorry. I can't hear the question.
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| 5 MR. WARD: You have incorporated the ATWS 6 procedure in your EPGs or in your emergency operating 7 procedures.
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| 8 MR. MARIE: That's correct.
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| 9 MR. WARD: If you hadn't done that the 10 contribution from ATWS would be even higher? I'm trying to ,
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| 11 find out how much difference has that made in calculations 12 of risk from ATWS?
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| 13 MR. MARIE: Okay. We have not quantified each of g- 14 the pieces of the update.
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| '%)s 15 MR. WARD: Have you quantified that one?
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| 16 DR. KERR: Well, Dave, you see the total risk is 17 about half and originally ATWS was 8 percent and now it's 24 18 percent. So it would have been about--let's see--
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| 19 MR. WARD: No. But two things have happened, 20 Bill. One he said they've used a different database for 21 frequency of--they used the EPRI database. The other thing 22 is in that time span they've incorporated the improved ATWS 23 emergency procedures.
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| 24 DR. KERR: Yeah.
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| 25 MR. WARD: I'm trying to find out how those two
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| (~) Heritage Reporting Corporation (202) 628-4888
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| 19
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| i-) :1 things have contributed.
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| 2 DR. KERR: Contributed to ATWS you mean? Or 3 contributed to the total--
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| 4 MR. WARD: To the risk that ATWS--
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| 5 MR. MARIE: In terms of. trend, the initiator 6 frequencies were upward, of course. And the incorporation 7 of the EOPs were downward. The overall effect was about a 8 50 percent increase in the ATWS contribution.
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| 9 MR. WARD: Okay. I was just trying to get a feel.
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| : 10. I agree.
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| 11 MR. McNEILL: We don't have any quantification of 12 what it would have been if we would have just implemented 13 the EPGs--
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| TN 14 DR. KERR: If you just look at those numbers up
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| '. L]
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| 15 there, it looks to me like ATWS is still contributing about 16 the same amount to core melt.
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| 17 MR. McNEILL: It's a half again more.
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| 18 MR. WARD: And he's already said that.
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| 19 MR. McNEILL: Yes.
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| 20 MR. WARD: But two things are different and I'm 21 trying to find out--okay. You don't know, so just go ahead.
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| 22 MR. MARIE: I'd like to also mention that a subset
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| '23 of the loss of off-site power category is station blackout 24 which represents about 20 percent of the core damage 25 frequency.
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| ! Heritage Reporting Corporation (202) 628-4888
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| p4 -
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| 305 I 'l -The second area that I'm going to discuss is 2 ~ implementation of PRA applications to improve performance.
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| ~
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| 3 LAt' Limerick administrative guidelines have been developed 4 that incorporate PRA into the work process. . These are in
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| '5 _the' areas of prioritization of maintenance activities and 6 planning system outages in a manner that minimizes risk.
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| 7 Our guidance is based on system importance as 8- indicated ,by the' PRA model, and this guidance is in addition 9 to other requirements such as tech specs or equipment 10 qualification.
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| 11 Examples of this guidance include giving 12 scheduling priorities to systems of higher importance when a 13 backlog of corrective maintenance exists, Minimizing out-of-service time for preventive
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| , vN-s] 14 15- maintenance by pre-planning and assuring that all 16 prerequisites are in place prior to removing equipment from 17 service. And this includes parts, procedures and or.rmits.
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| 18 System outages are both planned and tracked using 19 a method that relates to the outage time of the system to 20 effect on core damage frequency. This allows these system 21' outages to be compared to targets and there is provision to 22 either shorten or defer the planned outages in order to 23 achieve goals.
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| 24 In addition, only one system at a time is planned 25 for outage in order to prevent synergistic effects on risk.
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| (/ 1 PRA has also been used in the design and 2 modification process. The original PRA provided several 3 insights which influenced the final design. And these are 4 also described to the ACRS prior to Unit 1 full power 5 license. The systems affected were the standby liquid 6 control, the MSIV and ADS air supply systems, and fire 7 propagation barriers and reactor enclosure.
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| 8 Since then, we have implemented the integrated 9 management process for modifications. And this is our 10 version of the integrated living schedule process which is a 11 cost benefit evaluation method used to rank and prioritize 12 modifications. Of risk impact based on a PRA is one 13 component of this evaluation. And this looks at the potential modifications impact on both initiator frequency
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| ( } 14 15 as well as system reliability.
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| 16 Other factors in the evaluation include dose, dose 17 reduction, regulatory requirements, station availability and 18 personal safety.
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| 19 Several potential modifications have been reviewed 20 with PRA. One example was potential bypass of diesel-21 generator protected trips following the loss of off-site
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| )
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| 22 power event. The concern here was that false trip signals 23 would reduce the diesel reliability.
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| I 24 Our analysis concluded that these trips should not J l
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| 25 be bypassed because these trips reduced the likelihood of l
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| () 1 damaging the diesel if the signals are real plus there is 2 sufficient time following the loss of off-site power event 3 to override any false trip signals if they occur and restore 4 the diesel to service. In fact, our analysis indicated that 5 this component of the long-term diesel reliability is about I 6 100 times greater with the protective trips in place than if 7 they were bypassed.
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| 8 A PRA proyzam plan which has been developed and )
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| 9 approved by the nuclear group includes additional 10 applications that are just now getting underway. In the 11 area of reliability-centered maintenance, we are working 12 with our central maintenance organization to develop a scope 13 of study and a pilot program.
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| 14 A task force has been established and a PRA Branch O 15 is represented. The PRA models will provido an excellent 16 basis for the development of these RCM models.
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| 17 In area of operator training, we have provided PRA ;
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| 18 insights to the training organization and these have been j 19 incorporated into the training program.
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| 20 MR. MICHELSON: Let me interrupt just a moment on 21 your diesel protective trips. I gather you've decided to go 22 back and leave them in.
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| 23 MR. MARIE: Yes.
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| 24 MR. MICHELSON: And are these all safety-grade 25 trips to begin with that you are leaving in now? There was i
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| () 1 a time when a number of these trips were not safety grade 2 but they were bypassed on a ECCS signal so people didn't 3 worry about it.
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| 4 MR. MARIE: Yes. These are bypassed on a LOCA 5 signal.
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| 6 MR. MICHELSON: Oh, they are still bypassed on the 7 ECCS.
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| 8 MR. MARIE: Yes.
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| 9 MR. MICHELSON: They are just not bypassed on 10 other starts. Okay.
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| 11 This still can give me a little trouble. It 12 depends upon what the event is, if it's a seismic event, for 13 instance. But you haven't yet got a LOCA signal, but you've 14 got a loss of off-site power. Will you bypass these trips 15 for that case? It's more than an ECCS signal. Because 16 that's not ECCS.
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| 17 MR. McNEILL: The ECCS would over--
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| 18 MR. MICHELSON: No, this is not an ECCS signal.
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| 19 MR. McNEILL: Okay.
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| 20 MR. MICHELSON: You've just lost off-site power.
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| 21 You now have--can you bypass that? If it's a seismic event 22 that's induced it and if these trips fail because they are 23 non-seismic, you may damage all the engines for other 24 reasons.
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| 25 MR. McNEILL: I believe that these are seismic--or
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| O) 1 seismic design--they are Q-listed equipment.
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| 2 MR. MICHELSON: All right. So these are not non-3 seismic--
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| 4 MR. McNEILL: Right. .These are not. I'm fairly 5 confident they are not non-seismic.
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| 6 MR. MICHELSON: Thank you.
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| 7 MR. CATTON: Does your operator training include 8 the venting process?
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| 9 MR. MARIE: Yes. We have procedures for training 10 and the operators are trained in that procedure.
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| 11 MR. CATTON: I heard no mention of what happens 12 following vessel failure. Is that part of your PRA?
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| 13 MR. MARIE: Yes. The original analysis was a Level 3 analysis. We have maintained, and I described it in
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| } 14 15 the updates here, the portion that we have maintained since 16 1983. And that is the core damage frequency part of it.
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| 17 The Level 1 portion.
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| 18 We will be updating the back end of the analysis 19 as part of the IPE and we are now developing our plans for 20 that.
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| 21 MR. CATTON: Is your pedestal filled with 22 concrete?
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| 23 MR. MARIE: No. There is suppression pool.
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| 24 Beneath the diaphragm slab.
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| 25 MR. CATTON: Just out of curiosity, what do you do
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| ()~ 1 with all that molten stuff falling in the water in this 2 suppression pool?
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| 3 MR. MARIE: Quench it.
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| 4 MR. CATTON: So you are using the 1983 vintage 5 Henry position of what goes on?
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| 6 MR. MARIE: Yes. And that has been the analysis 7 performed to date. As we go through the revision of the 8 back end analyses, we will review that as well as other 9 available information and models.
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| 10 MR. MICHELSON: Now, early on in a core melt, if 11 you come through the vessel, you lose the suppression pool 12 capability if you postulate that you've eaten through the 13 floor. You bypass the suppression pool capability, is that fg 14 correct? Or is that part of your model?
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| U 15 MR. MARIE: Yes.
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| 16 MR. MICHELSON: So your pressure rises very 17 rapidly because you can no longer suppress the pressure?
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| 18 MR. MARIE: Yes. As a matter of fact, our 19 containment of entry which we will be developing for our 20 back end analysis will include that as a possibility and we 21 will have to assign a probability to that.
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| 22 MR. MICHELSON: Do you have guard pipes on the 23 tailpipes of the relief valves going into the suppression 24 pool?
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| 25 MR. MARIE: Sorry?
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| _() 'l MR. MICHELSON: Do you have guard pipes on the 2- tailpipes of the' relief valves?
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| 3' MR. MARIE: No, we don't.
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| 4 MR. MICHELSON: You do not. Thank you.
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| 5 MR. MARIE: I was discussing operator training.
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| 6 These insights have been provided to.the training 7 organization and incorporated into their training program.
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| 8 These insights include the important initiators such as 9 transients and loss of off-site power. As well as the 10 important systems, such as.the emergency service water and 11 high pressure injection. And this is an activity that we 12 expect to grow in the future.
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| 13 We also believe that PRA can help make emergency exercise scenarios more realistic. These sceneriosz are (qJ. 14 15 presently being developed by an in-house team and the PRA 16 Branch is represented on this team also.
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| 17 As illustrated by these examples, we use a team 18 approach to applications with the PRA Branch functioning as 19 a resource group that facilities the implementation of PRA 20 practices throughout the nuclear organization.
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| 21 MR. MICHELSON: In the case of your RHR system 22 where you draw suction from the suppression pool, do you 23 postulate a break between the first isolation valve and the 24- pool itself? Or how do you prevent the draining of the pool 25 if you do postulate a break?
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| . (3 1 MR. WYLIE: Let me ask a question. How long did
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| \_f 2 you say the section--
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| 3 MR. MICHELSON: Well, he hasn't answered the whole 4 question yet.
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| 5 Do you not postulate a break?
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| 6 MR. MARIE: Let me ask Mr. Philibaum--
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| 7 MR. MICHELSON: The question is do you postulate a 8 break between the suppression pool and the first isolation 9 valve on systems like RHR?
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| 10 MR. PHILIBAUM: And the answer is when we looked 11 at the internal flooding initiating event, that is one of 12 the possibilities that we did consider although we gave it a 13 low probability. We have included that as one of the potential losses of--
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| } 14 15 MR. MICHELSON: And find the water by what?
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| 16 MR. PHILIBAUM: By the physical place where it 17 drains from the--
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| 18 MR. MICHELSON: Well, you get it from something 19 because it's doing to drain in the equilibrium with the pool 20 depending on the piping. And so you are talking about 21 fifteen or twenty feet of water.
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| 22 MR. PHILIBAUM: But those rooms are designed water 23 tight and have water tight enclosures.
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| 24 MR. MICHELSON: Okay. Thank you.
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| 25 DR. REMICK: You indicated you are using the PRA
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| 313 0)
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| ( 1 insights and the training of reactor operators. Are you 2 doing it in the tech staff and managers program also?
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| 3 MR. MARIE: I'd like to ask Mr. Doerring to 4 address that.
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| 5 MR. DOERRING: Yes, we are doing it in the tech 6 staff training program. There is a PRA module for that.
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| 7 DR. KERR: Would you state your name please, sir?
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| 8 MR. DOERRING: I'm sorry. I'm Jay Doerring, 9 Superintendent of Operations, Limerick Station.
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| 10 DR. KERR: Thank you.
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| 11 MR. McNEILL: We have trained several hundred 12 people in PRA utilization across the tech staff spectrum of 13 people.
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| MR. MARIE: In conclusion, I'd like to summarize
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| ( } 14 15 that at Philadelphia Electric a PRA program is underway.
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| 16 The PRA studies cn Limerick have consistently shown the 17 risks to be very low. And this is a result of the excellent l
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| 18 design and procedures at Limerick.
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| 19 And finally the value of PRA is being recognized 20 as is evidenced in the growing areas of application which I 21 have described.
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| 22 Are there additional questions?
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| l 23 MR. WYLIE: In your loss of off-site power, did l
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| l 24 you consider your 6900 KV line participation in that?
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| 25 MR. MARIE: Mr. Philibaum?
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| ( lj MR. PHILIBAUM: The answer to that is at this 2 ~ point ~no, we did not take credit for recovery of off-site
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| .3 power through that 69 KV line because up to now it doesn't 4 have the capability of being recovered within the length of 5 time that would be beneficial: to consider.
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| 6 DR. KERR: Remind the Recorder of your name 7 .please, sir.
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| l 8 MR. PHILIBAUM: Jerry Philibaum.
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| 9 DR. KERR: Now, you said that came from one of p 10 your other generator stations. Is that a hydro plant or--
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| l l ~11 MR. MARIE: No, it's not. It comes.out of the-1 12 switch yard there so that.if you did not lose the entire 13 system, you would have some increased probability that it 14 would be available.
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| 15 Also at the other end of the line is some gas 16 turbine generators.
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| 17 MR. WYLIE: How long did it take to get that 18 power from that line into the plant?
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| 19 MR. McNEILL: About one hour.
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| 20 MR. WYLIE: But that was too long to help you out?
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| 21 MR. PHILIBAUM: Well, no. There may have been 22 modification during this recent outage. Before that it 23 would have been quite a number of hours and now it's going 24 to be, with further procedural changes, it's going to 25 reduced down to an hour. And then at that time it would be
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| ) 1 a reasonable thing to try-to take credit for. Up to this 2' point in time it's too long.
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| 3 MR. WYLIE: And that would be part of your 4 training?
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| 5 MR. PHILIBAUM: That's correct, for the operations 6' people to make those changes.
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| '7 MR. SHEWMON: Since to a simple metallurgist 8 electricity travels at the speed of light, could you tell me 9 -just what's happening during this four hours or one hour 10 that you assumed that it takes for the electricity to get 11 from here to there?
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| 12 MR. PHILIBAUM: What's happening with the reactor 13 ' vessel?
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| 14 MR. SHEWMON: No. You are apparently assuming 15 some sequence that started this that now has to be fixed,~
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| ~
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| 16 and I'm curious as to what that is.
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| 17 MR. McNEILL: We have to hook up some cables to 18 bring this 69KV and hook it up to the rest of the plant.
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| 19 DR. KERR: I want you to tell this simple 20 metallurgist that electricity in a transmission line doesn't 21 travel with the speed of light.
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| 22 (Laughter.)
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| 23 MR. SHEWMON: There's additional cable--
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| 24 MR. McNEILL: Right. This is not normally 25 connected to the switch yard and the modifications that we
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| ()' Heritage Reporting Corporation (202) 628-4888 L_________-______-__-__________--____-_____-_______-_. _ _ _ _ _ .
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| 316 L () 1 have made have been designed to allow us within a reasonable 2- period of time to hook it up so it's available in the plant.
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| 3 This happened to have been a construction power 4 supply to the site which we have decided to retain because 5 loss of-off-site power is a relatively high risk in the PRA 6 and, you know, the alternatives to that are on-site gas 7 turbines or things of that nature. And we already have this 8 line and so we took advantage of it and we tried to modify i 9 it such that we can get it into use within a reasonable 10 period of time.
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| 11 MR. SHEWMON: Fine, thank you.
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| 12 MR. MICHELSON: How did you get your valve 13 reliability numbers? Did you develop those from experience within the plant or were you using other peoples?
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| { } 14 15 MR. MARIE: Mr. Philibaum will address that 16 question.
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| 17 MR. PHILIBAUM: At this point in time we've 18 looked--Jerry Philibaum--at this point in time we've used 19 extensively the generic numbers. Ne were looking at 20 building upon a plant-specific database but with about two 21 and a half reactor years of operation, reactor years at 22 Limerick, we're not to the point of being able to really use 23 a lot of plant-specific information yet.
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| 24 MR. MICHELSON: Thank you.
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| 25 MR. CATTON: What do you use as the basis for
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| 317 h ~1 venting?
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| 2 MR .~ MARIE: Mr. Doerring.
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| 3 MR. DOERRING: We specifically follow the EPG Rev-4 3 guidance for venting. The parameter which limits us is L 5 the instrument gas pressure to the ADS valves. If your 6 pressure gets I think above 75 pounds, you would not be able
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| ~7 to open ADS valves and that's when you would begin venting 8 the containment per the EPG implementing procedures which we 9 have. I'm Jay Doerring.
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| 10 Below 75--the criteria.for venting is pressure, is 11 containment pressure. Okay. And there are several 12 parameters used in your Appendix C calculations from the 13 Emergency Procedure Guidelines. The actual parameter that 14 causes us to vent would be the limitations of instrument gas -
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| 15 in lifting JUNS valves. We don't take the pressure up to 16 challenge the containment ultimate pressure. The limitation 17 that we have to go on is this ability to continue to vent 18 the vessel.
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| 19 MR. MICHELSON: Question.
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| 20 DR. KERR: Would you speak into the microphone 21 please, Mr. Michelson?
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| 22 MR. MICHELSON: Okay. I got the answer.
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| 23 MR. CATTON: Don't go away yet. If venting is to 24 help you with a core melt, I don't quite understand how it's
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| : 25. going to do that. Could maybe you help me?
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| 318. j
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| ) -! 1: MR. DOERRING: The purpose of the venting in the
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| : 12. EPGs is to maintain the integrity of your containment so
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| '3, that you breach.the. containment in a controlled fashion.
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| ~4 rather than a catastrophic fashion. That's one of the 5 bases. That's the--
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| 6 MR. CATTON: I understand that.
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| 7 MR. DOERRING: Yes, sir.
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| 8 MR. McNEILL: ' Boiling water reactor containment
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| .9 venting is for containment--maintaining the containment.
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| 10 You would depressurize the reactor system through the 11 automatic depressurization system to prevent core melt. So 12 you can get'your low pressure injection in.
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| 13 MR. CATTON: So this all takes place before core melt?
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| { } 14 15 MR. McNEILL: That is correct. If the systems 16 -operate normally--let me say, you have to get'into severe 17 accident almost before you get enough pressure. Your 18 supposition is that you have gone beyond design basis and 19 you are into severe accident, and that is generating the 20 high pressure in the containment because normally the 21 pressure in a containment under a LOCA won't exceed 30 some 22 pounds I would expect. Somewhere in that range.
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| 23 MR. CATTON: I understand that part of it. And I l 24 understand why in a Mark I you might do it. But in the Mark 25 2 it seems to me that if you have a core melt you are going
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| i 319 l' to lose the benefit of the suppression pool for' scrubbing.
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| 2 MR. DOERRING: Well, the venting procedures are
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| '3 structured to first vent via pads from the suppression pool.
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| 4 that gets the scrubbing action from the-suppression pool.
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| 5 MR. McNEILL: You would vent scrub gasses.
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| 6' MR. CATTON: The gasses won't necessarily go 7 through the suppression pool like they will in the other
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| '8 systems, will they?
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| 9 MR. McNEILL: Sure they will.
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| 10 MR. CATTON: If the stuff falls--well, you are 11 going to lose those big headers that stick up through the 12 floor.
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| : 13. MR. MARIE: You are speaking of post-vessel l 14 failure. .The biggest advantage of venting from a PRA 15 perspective in reducing risk has been to-really reduce the 16 frequency of loss of decay heat, removal type sequences.
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| 17 The TW type sequences.
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| 18 MR. CATTON: That different. I understand that.
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| 19 MR. MARIE: Okay.
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| 20 DR. KERR: Please continue.
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| 21 MR. MICHELSON: I'm bothered now by the previous 22 answer. Apparently you are thinking of this venting at 75 23 pounds of pressure. Is that correct?
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| 24 MR. MARIE: Yes, sir. 75 pounds-- ;
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| 25 MR. MICHELSON: I'm a little skeptical I guess Heritage Reporting Corporation (202) 628-4888 ;
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| 320 (f 1 Ebout'that 6 inch line that dumps into the corridor of the 2 diesel' building with 75 pounds of gas behind it and have you 3 really looked at that? You aren't going to blow doors off, 4' that sort of thing?
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| 5 MR. DOERRING: The procedure for doing that does 6 open the doors.
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| 7- MR. MICHELSON: No, no. But there'sEdoors to the 8 other parts of the building. There's no way to get from the 9 rest of the building into that--
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| 10 DR. KERR: Mr. Michelson, since this is part of 11 the BWR EPGs, we probably ought to review those, don't you 12 think?
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| 13 MR. MICHELSON: We'd have to look at the-plant 14 specific one, yes. I thought he could'give'me assurance 15 that he's really thought this through for 75-pound air, and 16 I guess he has. I'm a little--
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| 17 MR. McNEILL: Let'me say that-we vent, although 18 not a full flow, we vent the containment through this line 19 from the integrated leak break test pressures which are in 20 the 30 pound range.
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| 21 MR. MICHELSON: But you intend this to be a wide 22 open line for this vent that's going to do it during the 23 accident, is that correct?
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| 24 MR. McNEILL: I believe it would be a--I'm not 25 sure it needed to be wide open. It would be controlled at a
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| 321 A
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| 's )
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| _ 1 rate to cause depressurization. l 2 MR. MICHELSON: Okay. You put an appropriate 3 throttle valve in.
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| 4 MR. McNEILL: Yes. We would be able to throttle 5 the valve that was there. !
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| 6 MR. MICHELSON: Is it air operated?
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| l 7 MR. McNEILL: No , there's at least three motor- '
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| 8 operated valves in the pad.
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| 9 DR. KERR: Any further questions on this?
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| 10 (No response. ) ;
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| 11 DR. KERR: Please continue.
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| 12 MR. MARIE: Our next speaker will be Dave Honan.
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| 13 MR. HONAN: My name is David Honan, Branch Head of LGS-2 Licensing.
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| ./ } 14 15 The purpose of my presentation today is to update 16 you on the status of ongoing licensing activities for 17 Limerick 2, and a good place to begin would be with the 18 activities of this Committee.
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| 19 Dr. Kerr mentioned earlier that the ACRS has 20 reported twice on Limerick. In October of ' 83 an interim 21 report which, while deferring to report on Unit 2, endorsed 22 operation of Unit 1 at 5 percent power.
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| 23 And the second, in November of ' 84, which again 24 deferred on Unit 2, endorsed full power operation at Unit 1, 25 and included three recommendations for future action.
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| 322 1- And I'11 take this opportunity to review the-2' status of those recommendations.
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| 3 3' These are the subjects of those recommendations 4 and the rationale for each is slightly different. Due to 5- the limited attention given the subject'of severe accident 6 ' mitigation' features, Dr. Okrent recommended that further 7 consideration be given at a later date. Because of 8 Limerick's demography, special attention to systems 9 interaction was recommended by the Committee.
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| 10 And finally due to large uncertainties associated 11 with the determination of seismic risk, the ACRS recommended 12 that the NRC and the industry work to better quantify those-13 risks.
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| NRC staff efforts to date have focused primarily
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| { } .14 15 on generic resolutions for these issues and for each of 16 these I'll now describe the current Limerick status.
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| 17 As Al Marie indicated, our original PRA showed a 18 very low risk =due to severe accidents and our 1988 update 19 showed even lower risks. Identified no design 20 vulnerabilities and showed some value in procedural 21 upgrades.
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| 22 Again, as Al mentioned in passing, Limerick does 23 -incorporate some features analogous to those suggested for 24 Mark l's. Specifically six-inch hard pipe containment vent 25 is installed together with the usual larger duct-type vents.
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| 323 r 5-(_) 1 As Jay Doerring indicated, the operators are trained in the 2 use of those vents.
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| 3 We have at Limerick the ability inject water into 4 the vessel independent of AC power using our diesel water 5 pumps via reactor water clean up which gives us an 6 additional decay heat removal pathway.
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| 7 MR. MICHELSON: Is that a hard pipe derangement?
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| 8 MR. HONAN: Yes, it is.
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| 9 MR. MICHELSON: How do you isolate it from reactor 10 water clean up?
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| 11 MR. HONAN Let me see if I can--Jerry, can you h 12 help us with that one?
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| 13 MR. PHILIBAUM: Let me make that correction.
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| 14 Jerry Philibaum. What has to happen is the operators have 15 to take a hose, fire hose, and run it from the fire header 16 over to the reactor water--
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| 17 MR. MICHELSON: It's not hard pipe?
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| 18 MR. PHILIBAUM: No, not all the way.
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| 19 MR. MICHELSON: Thank you.
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| 20 MR. HONAN: And, again, as Al mentioned and Jay 21 Doerring expanded on a bit, we are in the process of {
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| 22 upgrading our procedures to Rev 4 of the EPGs. Specifically 23 adding new provisions for secondary containment control, j 24 radioactivity release control, and primary containment 25 flooding.
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| 324 r%
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| (_) 1 MR. CATTON: And the radioactivity release '
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| 2 control, what is it?
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| l 3 MR. HONAN: My understanding of that issue, and I ;
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| 4 don't want to characterize myself as an expert, focuses on 5 controlling the rate at which radioactivity which has made j l
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| 6 its way into the secondary containment is released and
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| 7 thereby reducing the risk to the public by controlling that 8 to the maximum extent possible. i 9 Jay, can you expand on that?
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| 10 MR. CATTON: I understood your answer.
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| I' 11 MR. HONAN: The first of these two issues have 12 already been incorporated into the station procedures and 13 the third is in work.
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| ("S 14 The 1988 PRA update did model containment venting
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| 15 as I think Al mentioned, but didn't model the additional ;
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| t 16 sources of injection or EPG Rev 4. These features will be 17 modeled as part of the PRA update plan in support of the 18 individual plant evaluation program.
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| 19 MR. CATTON: Doesn't that vent become a short 20 circuit to outside once you've had a core melt?
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| 21 MR. HONAN: I'm not sure I understand your 22 question.
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| 23 MR. DOERRING: Yes, it would. This is Jay 24 Doerring. As a matter of fact, the reason for that portion 25 of the procedures is to take into account the effects that l
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| 325
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| ! (_ rw) ' 1 venting or any other actions contained within the vessel and 2 :the containment guidelines would have on the release. So 3 it's.there in order to accommodate those J other actions which j l 4 are taken to protect the ability to make up and protect'the 5' containment.
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| 6 MR. CATTON: So do you close.it down if you have a.
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| 7 core melt?
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| 8- MR. DOERRING: It does not address core melt.
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| 9 MR. CATTON: I can't. hear you.
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| 10 MR. DOERRING: It does not address core melt 11 specifically.
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| 12 MR. CATTON: I thought EPG Rev 4 did, but--
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| 13 MR. DOERRING: No , it does not.
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| 14 MR. McNEILL: That's under review right now in'the
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| -15 development of'the Severe Accident Management Plan, which is 16 an NRC staff initiative, in which NUMARC has formed a 17 working group and they are working to define severe accident 18 management measures'and programs, which would be implemented 19 I think within the next couple of years at the various y 20 stations.
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| 21 MR. MICHELSON: Did I misunderstand, or is the 22 venting a local manual operation? I heard something.about 23 hand wheels. I 24 MR. DOERRING: There are manual steps, 25 prerequisite steps to the venting.
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| 326 '
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| t' 1 MR. MICHELSON: And that's local along the pipe?'
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| 2 MR. DOERRING: Yes, sir.
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| 3 MR. MICHELSON: Well,.if.you ever get very high.
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| '4 activity you may not be able to do those steps.
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| 5- MR. DOERRING: If youlgot high activities in the 6 particular areas.
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| 7 MR. MICHELSON: Yes. Thank you.
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| 8 MR. HONAN: The subject of systems interaction was 9 addressed at the 1983 Subcommittee meeting on Limerick'and-10 at that time we described how the processes and programs 11 that.were in place at the time combined with insights we 12 gained form our PRA activities, operating plant feedback 13 programs and various special studies yielded a plant as free of adverse systems interactions as we could make it.
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| ) 14 15 Since then we've focused our efforts the 16 continuing improvement of those processes and programs 17 through the application of feedback and lessons learned.
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| 18 Some of the tools that we've developed to help us.
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| 19 do that are a design process improvement program, an 20 enhanced operating experience program, improved non-21 conformance corrective action deportability processes, and 22 the strengthened self-assessment capabilities you've heard a 23 great deal about already.
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| 24 The goal of all these efforts, relative to systems 25 interaction, is to capture events or problems, evaluate them I
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| 327 r's
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| (_) 1 for root cause, and feed the results to cognizant line 2 organizations for long and short-term corrective actions.
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| 3 MR. MICHELSON: To what extent do you look at 4 other people's experience in the process of deciding whether 5 you have a potential. systems interactions problem? !
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| 6 MR. HONAN: That's the essence of operating 7 experience assessment program.
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| : 8. MR. MICHELSON: So you are saying you are looking 9 at your own operating experience?
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| 10 MR. HONAN: The scope of the operating experience 11 assessment program includes industry.
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| i 12 MR. MICHELSON: And how do you do that? How do 13 you get that experience? l
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| 14 MR. HONAN: We capture those--
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| 15 MR. MICHELSON: Reading all the LERs, for .
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| 16 instance, how are you capturing it?
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| 17 MR. HONAN: We capture those principally through 18 our participation in INFO's SER and SOER programs.
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| 19 MR. MICHELSON: Yes. But you know that's a pretty 20 high level stuff when it comes to a lot of this system 21 interaction problem, but I'll leave it pass as a comment.
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| 22 MR. HONAN: George Hunter, would you like to 23 expand on the scope of that program?
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| 24 MR. HUNTER: I'm George Hunter, Director of 25 Licensing. And part of the activity under my cognizance is
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| .f x, 1 the operating experience assessment initiation. We receive 2 the information from the NRC, from INPO. We do receive 3 other reports but not all LERs from all the industry.
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| 4 We send them directly to the technical 5 superintendents at both stations. Technical superintendents 6 at both Limerick and Peach Bottom then initiate a technical 7 review of that information as it terms its applicability.
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| 8 MR. MICHELSON: How many of the LERs from other 9 than your own plants do you look at?
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| 10 MR. HUNTER: We look at those that are captured by 11 INPO in the SERs. We do not look at specific LERs from 12 other utilities. ,
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| 13 MR. MICHELSON: They don't even send you the LER 14 when they capture it in an SER.
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| 15 MR. HUNTER: That's correct.
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| 16 MR. MICHELSON: Okay. Thank you.
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| 17 MR. HONAN: At the bottom though, our objective is 18 to keep Limerick as free from adverse systems interaction as 19 the information available to us allows.
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| 20 As part of our ongoing effort to constantly 21 improve these programs, that is our goal.
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| 22 Again, as Al Marie mentioned, our original PRA
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| 23 showed that the risk due to severe seismic events could be 24 significant if higher estimates of seismic hazard are 25 assumed.
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| 329 (G_) 1 Since we originally performed those calculations 2 in the '82/83 time frame, PECO has worked as part of the 3 Seismicity Owners Group formed to assess the impact of the 4 1886 Charleston earthquake on seismic safety of nuclear 5 plants in the region. That effort is nearing completion and 6 their preliminary results indicate that a general increase 7 in seismic hazard doesn't result when the Charleston 8 earthquake is considered.
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| 9 Their Limerick-specific results show essentially 10 no change in seismic hazard for Limerick. And of the fifty-11 seven sites examined as part of that effort, Limerick shows 12 up in the middle of the pack.
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| 13 I'm not knowledgeable enough on the subject to definitively state that this effort has reduced
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| {J} 14 15 uncertainties. I think it's better characterized 16 uncertainties. It does support I think the conclusion that 17 Limerick is not an outlier relative to seismic risk.
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| 18 I should mention that PECO is also a member of the 19 NUMARC Severe Accident Working Group working with the NRC to 20 define acceptable methodologies for quantifying seismic risk 21 and the results of the NRC/NUMARC efforts which include the 22 results of the Seismicity Owners Group work will go to 23 support the individual plant evaluation, external events 24 evaluations, to come.
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| 25 Looking at our list of to go licensing activities,
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| , 330 b 1. 'our principal _ ongoing activity is NRC staff' review of' 2 changes to the application since Unit 1 was licensed.
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| .i 3 Those changes are comprised principally of Unit 1
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| 4 modifications which have been incorporated into the Unit 2-5 based design. Unit 2-unique information which was earlier i 6 unavailable. Our response to generic correspondence, 7 bulletins, Generic Letters, and what have you. And the 8 development of technical specifications.
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| 9 As Dick Clark earlier mentioned, a number of these 10 issues are under review with the staff, but at this point' 11 none are in dispute.
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| i 12 We are also working closer with Region I personnel 13 day to day to assist in closure of their open items.
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| 14 We plan to certify readiness ~to load fuel late 15 this month. We anticipate low power licensing around the 16- 9th of June. And if all goes well, we'll be looking for a 17 full power license late in July.
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| 18 In conclusion, we see no impediment to licensing 19 other than work punch-list items, and look forward to a 20 successful licensing.
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| 21 And if you have no further questions I'll turn the 22 podium back to Corbin McNeill for his conclusion.
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| 23 DR. KERR: Any further questions?
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| 24 (No response.)
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| 25 DR. KERR: Thank you, sir.
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| 331 (b 1 MR. McNEILL: Before I do conclude, I think there 2 would be'two appropriate comments. First-is on the issue of 3 venting.
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| 4- Even though--venting is a debatable topic which 5 has received a lot of debate and really the issue that I 6 think is' unresolved is the political issue of venting.
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| 7 There is a lot of discussion that even if the EPGs would 8 allow you to vent, whether at that time there would be 9 enough political support to vent the containment.
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| 10 So that issue in my mind is really not just a 11 technical issue. It's one of. policy and politics.
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| 12 MR. CATTON: Part of it's a technical issue. If 13 you have vessel failure and you've got that six-inch line open, you have a hold to outside. So you have to seigh
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| .( y 14 15 that, the benefits of having it there versus what will 16 happen to you if you. lose the vessel.
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| 17 DR. KERR: I'm with Mr. McNeill. I don't believe 18 anybody will ever decide to vent. Because in order to vent 19 and do any good, you have to vent before the thing has 20 happened that will rupture your containment. So you've got i 21 to have a pretty good predictor.
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| 22 DR. LEWIS: Well, you know, if the pressure inside l
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| l 23 the vessel--just gradually opens--
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| 24 MR. McNEILL: You are running up against the 1
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| 25 failure pressure on your containment. You may want to vent.
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| \_/ 1 DR. KERR: But you also at the same time you are 2 working to get back electric power or water, either of which 3 will get you out of trouble.
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| 4 DR. LEWIS: I make the same argument.
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| 5 MR. CATTON: I would just stick the end of that 6 pipe in a sandbox.
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| 7 MR. McNEILL: The second item that I would like to 8 comment on is the fact that although we do not review every 9 LER, there are two events that occur which do provide for 1 10 think LER review.
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| 11 The first is through the INPO communications 12 system everyday we get a synopsis of events at operating 13 units that are reported to the NRC as part of the. reporting
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| /~ 14 mechanism. So although we do not get the details and do not V) 15 necessarily analyze those, unusual events are highlighted in 16 relatively near term.
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| 17 Secondly, the AEOD Branch does in fact, and I can 18 tell you by the volume of their correspondence lately, has 19 been doing more review of events in the field and publishing 20 them in some manner to the industry to provide information 21 that might be appropriate where there is common mode failure 22 or interaction issues involved.
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| 23 And I personally think that the quality of that 24 has increased as we have moved from the construction phase 25 of this industry to the operating phase.
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| l 333 :i 1 MR. MICHELSON: Do you review all the AEOD 2 reports?
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| 3 MR. McNEILL: I look at the AEOD quarterly or 4 semi-annual summary. I forget which it is. But when they-5 do put out a specific bulletin or Generic Letter or 6 something, they generally are for'the purpose of informing 7' the industry of some event that has that kind of implication 8 to it. You know, the molten circuit breakers issues and 9 things. I feel that they are in that category of. event 10 review. .. i 11 I would like to conclude today by indicat 9 .g that 12 we do have a dedicated organization focused on and capable 13 of supporting the operation of Unit 2 at Limerick.
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| 14 'Jhe quality of our design, construction and 15 testing has been proven through the. testing program, through )
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| 16 reviews, the IDCA and the IDA. Through the quality 17 assurance reviews that have been conducted internally within 18 the company. And by the NRC inspection process.- And have 1 19 been found to be extremely good.
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| 20 Our Unit 1 experiences have been incorporated into 21 the design and the procedures for Unit 2 and we expect that 22 they will have an immediate payback in the early operation 23 of the plant. l 24 Ltd finally we have a well-trained, well-25 qualified, and dedicated staff who are prepared in all O aerie ee aegereine corror eie-(202) 628-4888 i
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| l' respects to operate Unit 2. And I believe that we as an 2 organization are dedicated to the quality and safety 3 necessary to protect the general public in the operation of 4 that plant.
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| 5 Thank you very much.
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| 6 MR..WYLIE: Mr. McNeill, do you have a projected 7 cost for the completion of the plant?
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| 8 MR. McNEILL: Yes. We do. It's~$3 billion for 9 the Unit 2 plant and it's around $600 million for the Unit 2 10 portion of the common plant-for a total cost of about $3.6 11 billion.
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| 12 MR. WYLIE: $3.6.
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| 13 MR. McNEILL: That is $200 to $300 million below 14 the estimate at the time that construction was resumed and 15 the cost cap that was imposed by our. Public Utility 16 Commission.
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| 17 MR. WYLIE: Do you have an estimate as to how much 18 that delay cost you?
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| 19 MR. McNEILL: I do not.
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| 20 John, do you know what the delay cost us in terms 21 of cost?'
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| 22 MR. WYLIE: Well, it would basically be what you 23 had it projected originally to cost I suppose versus what ,
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| 24 it's going to cost you?
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| 25 MR. McNEILL: It would certainly--we are running l
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| () 1 'right now--I can give you some estimate of it.
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| 2 What was the construction delay, John?
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| 3 VOICE: Two years.
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| 4 MR. McNEILL: Two years of AFUDC at the end of the 5 project would rcughly be another $600 to $700 million.
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| 6 MR. WYLIE: Thank you.
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| 7 DR. REMICK: Mr. McNeill, back in the early days 8 of Limerick I remember there was some kind of a flap on 9 assuring back-up water supply. Remind me of how that was 10 resolved for the Limerick site?
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| 11 MR. McNEILL: Well, it's not reso1* red 100 percent 12 yet. As I indicated earlier, there are two make-up water 13 supplies for Limerick Generating Station. The first is from 14 the Schuylkill River and the second is from the Delaware 15 River. The water from the Delaware River is processed 16 through a series of projects, the first being a pumping 17 station and transmission line which is owned and operated by 18 a public agency under Bucks County in Pennsylvania. It then 19 goes into a reservoir which is owned by Philadelphia 20 Electric and the water is then pumped to a creek, runs 21 twenty miles or so down a creek, and is picked up by a 22 second pumping station that then pumps it another ten miles 23 or so to the plant.
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| 24 That whole project will be complete later this 25 summer. And there remain three elements of risk in that
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| () Heritage Reporting (202) 628-4888 Corporation
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| 336 rr
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| (_) 1 project. The first is that we have not completed 2 condemnation of the riparian rights to run water down the 3 creek. We expect that that will be completed by the end of 4 June.
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| 5 The second one is that we have been issued a 6 permit to put water in the creek. However, that's under 7 appeal in the courts because of erosion considerations.
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| 8 The legal case is under review by an Environmental 9 Quality Board, Administrative Law Judge, who will complete 10 the hearings at the end of May and we're hoping for an 11 expedited resolution by the first of Auguet. If it does not 12 occur, we have an option that we will run. There is a 13 certain flow in the stream below which there is no 14 contention of erosion and we would run below that flow rate, 15 which is--well, I don't want to get into details.
| |
| 16 The third item is that for the first time in the 17 history of this country an inner basin water transfer is 18 subject to a National Pollution Discharge Environmental 19 Permit. Our permit has three very difficult restrictions in 20 it. The first is water temperature in that the stream that 21 we are discharging to is a trout stocking stream and from 22 February to the end of July we cannot exceed 74 degrees 23 water temperature on our discharge. And during the months 24 of June and July the water temperature in the Delaware River 25 exceeds 74 degrees.
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| () Heritage Reporting Corporation (202) 628-4888
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| i l
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| 4 i
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| ) 1' The second item is that we cannot have any l 2 detectable inercury or cadmium.
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| 3 And the third one is that we must limit the fecal 4 coliform on the discharge during the swimming season which 5 runs from May through September to 200--whatever the 200 6 parts per billion or something. Fecal coliform. And the 7 rest of the years 2000.
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| 8 We have just submitted a compliance plan. In 9- fact, on Tuesday of this week, submitted a compliance plan 10 which indicates that we will put in a cooling system to cool 11 the water in the summer months so that we would stay below 12 74 degrees. This is 6,000 tons of air conditioning.
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| 13 We will also put in a purification system to meet the fecal coliform limit. And we have proven that
| |
| { } 14 15 statistically we will not have any mercury or cadmium limits 16 above the nondetectable level.
| |
| 17 So that we right now are hopeful of putting that' 18 system into service on August the 1st which would meet our 19 needs for power production at about the schedule that was 20 shown earlier in the power test program.
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| 21 DR. REMICK: Are there any risk-significant 22 aspects of those limitations or is it--
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| 23 MR. McNEILL: The one ri'tk that we really think we 24 have is the zoning to locate the cooling water process 25 system for cooling the water.
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| () Heritage Reporting Corporation (202) 628-4888
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| 1 L
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| l 338
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| () 1 DR. REMICK: My point was if those limitations, 2 let's say, are at the most adverse, are there safety 3 implications from operating the plant, or are they capacity-4 factor related?
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| 5 MR. McNEILL: They are capacity-factor related.
| |
| 6 To give you some feel for that, in 1990 without this 7 supplemental cooling system--yeah, this year without the 8 supplemental--no. For an average year of water flow in the 9 Schuylkill River, which would be our principal source at 10 that point, we would have about an 81 percent capacity 11 factor with both units in operation. We would have to back 12 them down during the high temperature season.
| |
| 13 So that's the rish we run. We are somewhat
| |
| (~g 14 confident that this issue is time driven and that we will QJ 15 resolve it with time, but it's been through the courts for 16 five years and it's probably going to be there for a few 17 more years.
| |
| 18 DR. REMICK: Thank you.
| |
| 19 Dr. Shewmon, did you have a question?
| |
| 20 DR. SHEWMON: No.
| |
| 21 DR. KERR: I see no more questions. I turn things 22 back to you, Mr. Chairman.
| |
| 23 DR. REMICK: All right. Thank you.
| |
| 24 Mr. Marvin Lewis had asked to address the 25 Committee. Is Mr. Marvin Lewis in the audience? He's not.
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| f%
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| () Heritage Reporting Corporation (202) 628-4888
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| 1 l
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| 339 l
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| A
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| 's j 1 Are there any concluding comments the staff wishes 2 to make? J i
| |
| 3 (No response.)
| |
| 1 4 DR. REMICK: If not, we thank the staff and !
| |
| 5 Philadelphia Electric personnel for their presentations.
| |
| 6 And gentlemen, we were scheduled for a report of 7 your Planning and Procedures Committee. I'm certainly not 8 tired, but some of you might be, so I suggest that the 9 Handout No. 9 is a report. You read it and we'll pick it up 10 sometime later.
| |
| 11 Yes, Bill.
| |
| 12 DR. KERR: Could you give me some idea of the kind 13 of letter that I should draft? I need to know specifically 14 whether we look favorably on this--
| |
| 15 DR. REMICK: I personally look favorably on the, 16 letter. How do others feel?
| |
| 17 MR. CARROLL: I see no reason why we shouldn't 18 look favorably on the letter.
| |
| 19 DR. REMICK: Anybody wish to the contrary?
| |
| 20 All right. Is that enough direction?
| |
| 21 DR. KERR: That's enough direction.
| |
| 22 DR. REMICK: All right. With that, we'll close 23 the record and adjourn the meeting.
| |
| 24 (Whereupon, the meeting was adjourned at 6:05 25 p.m.)
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| () Heritage Reporting Corporation (202) 628-4888
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| 9
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| () 1 CERTIFICATE 2
| |
| 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter 5 of:
| |
| 6 , Name: 349th ACRS meeting 7
| |
| 8 Docket Number:
| |
| 9 Place: Bethesda, Md.
| |
| 10 Date: 5-4-89 .,
| |
| 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 1 14 thereafter reduced to typewriting by me or under the O 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings.
| |
| 18 /s/ fn Nh l IRWIN L. C0FFE[pfRRY l 19 (Signature typed) : 7 20 official Reporter l
| |
| 21 Heritage Reporting Corporation 22 23 24 25 l
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| O .rie ,o ei ,
| |
| (202) 628-4888 corpor tio-l 1
| |
| l
| |
| | |
| t 1 CERTIFICATE 2
| |
| 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter 5 of: 349th ACRS MEETING 6 , Name:
| |
| 7 8 Docket Number:
| |
| 9 Place: BETHESDA, MARYIAND 10 Date: May 4, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 14 thereafter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing -
| |
| 17 proceedings. ,.
| |
| 18 /s/ h5 19 (Signature typed) : JOAN POSE 20 Official Reporter 21 Heritage Reporting Corporation 22 1
| |
| 23 24 25 O Heritage Reporting Corporation (202) 628-4888
| |
| : n. O y i
| |
| INTERIM STANDARD FOR OCCUPATIONAL EXPOSURE OF THE SKIN T0 RADIATION FROM SMALL RADI0 ACTIVE PARTICLES (HOT PARTICLES)
| |
| -PRESENTATION BEFORE THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MAY 4, 1989 O BY FRANK J. CONGEL, DIRECTOR DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS OFFICE OF NUCLEAR REACTOR REGULATION j
| |
| I O
| |
| - __- - seudn .
| |
| | |
| INTERIM STANDARD IN GENERIC LETTER I
| |
| IS AN INTERIM. STANDARD FOR EXERCISE OF ENFORCEMENT DISCRETION !
| |
| i APPLIES TO OCCUPATIONAL EXPOSURE OF SKIN FROM HOT PARTICLE OF ANY SIZE OR ACTIVITY ON BODY OR CLOTHING APPLIES TO SINGLE EXPOSURE OF INDIVIDUAL IN A CALENDAR CUARTER
| |
| * 2 NRC WILL ENFORCE LIMIT OF 50 RAD AVERAGED OVER 1 cM AT A DEPTH OF 7 MG/CM NO NOTICE OF VIOLATION FOR SINGLE EXPOSURE BELOW 50 RAD g* POSSIBLE NOTICE OF VIOLATION FOR MORE THAN ONE EXPOSURE PER CUARTER ABOVE CURRENT PART 20 LIMITS POSSIBLE NOTICE OF VIOLATION FOR FAILURE TO MEET OTHER REQUIREMENTS (E.G., FAILURES TO SURVEY)
| |
| DOES NOT CHANGE REQUIREMENTS FOR RECORDS, NOTIFICATIONS, AND REPORTS I
| |
| 0
| |
| | |
| h INTERIM STANDARD:
| |
| REPEATED AND MULTIPLE HOT PARTICLE EXPOSURES.
| |
| NO NOTICE OF VIOLATION IF HOT PARTICLE EXPOSURES OF AN. INDIVIDUAL ARE:
| |
| LESS THAN 50 RAD EACH, AND
| |
| ~
| |
| NO MORE ThAN ONE EXPOSURE PER CALENDAR QUARTER ABOVE PART 20 LIMITS POSSIBLE NOTICE OF VIOLATION IF AN INDIVIDUAL RECEIVES,-IN A CALENDAR QUARTER:
| |
| MORE.THAN ONE EXPOSURE ABOVE PART 20 LIMITS L O 3 ASIS NOT RISK BASED INDUSTRY EXPERIENCE TO DATE STAFF NEED TO CONSIDER CIRCUMSTANCES OF UNUSUAL CASES INDUSTRY EXPERIENCE TO DATE SINCE'1985, NO INDIVIDUAL HAS RECEIVED MORE THAN ONE HOT PARTICLE EXPOSURE ABOVE PART 20 LIMITS O
| |
| - -_ m__ --___--__-_mm-___m_-.___.___--_____m. .._____---_-___m_m ___u___-_-. - _ ___.__.____-__ _ ._ _m__._________.___m__ .__._____ ____
| |
| | |
| LO c0MeARiSON Or iNTERin f STANDARD AND PART 20.
| |
| QUARTERLY LIMIT'(REM) RATIO 0F LIMITS PART 20 INT, STD, (INT, STD,/PART 20)
| |
| SKIN OF WHOLE BODY 7,5 50 6,7 SKIN OF HANDS AND FOREARMS, FEET, AND ANKLES 18.75' 50 2,7-WHOLE BODY-(1,000 MG/cM2 DEPTH) 3.0 N.A. N.A, O
| |
| O
| |
| | |
| l g' BASIS FOR CHANGE 1
| |
| I WHY?
| |
| 3 CURRENT LIMITS INAPPROPRIATE POSSIBLE SAVINGS IN WHOLE-BODY DCSE HOW?
| |
| RULEMAKING PROVIDES OPPORTUNITY FOR PUBLIC COMMENT TAKES 2 YEARS OR MORE BETTER TECHNICAL DATA BASE NEEDED
| |
| ~
| |
| INTERIM STANDARD FOR ENFORCEMENT DISCP.ETION USE UNTIL RULEMAKING COMPLETED CONSERVATIVE - RECOGNIZES LIMITATION OF CURRENT TECHNI-({}
| |
| CAL DATA BASE i
| |
| )
| |
| o l
| |
| L____________ J
| |
| | |
| 1 l
| |
| LO:
| |
| NCRP DRAFT RECOMMENDATIONS l!
| |
| ON LIMITS OF EXPOSURE TO HOT PARTICLES ON THE SKIN (NCRP DRAFT REPORT-NO, 101, JUNE 1988) i RECOMMENDED LIMIT OF 75 MICR0 CURIE-HOURS APPLIES TO PARTICLE ON (IN CONTACT WITH) THE SKIN PARTICLE LESS THAN 1-MM DIAMETER RECOMMENDED LIMIT'DOES NOT If4CLUDE A SAFETY FACTOR OR ESTI-flATE OF UNCERTAINTY O
| |
| O
| |
| | |
| l O INTERIM STANDARD FOR HOT PARTICLE EXPOSURES WHY NOT IMPLEMENT NCRP DRAFT RECOMMENDATIONS IN INTERIM STANDARD?
| |
| FINAL NCRP REPORT NOT AVAILABLE YET - COULD DIFFER SIGNIFI-CANTLY FROM DRAFT UNRESOLVED DIFFERENCE BETWEEN FORBES-MIKilAIL AND HOPEWELL ET AL, CONCERNING THRESHOLD FOR ULCERATION - Il0PEWELL TilRESH-OLD AE00T 1/5 FORBES-MIKHAIL (NCRP SC-80-1) THRESHOLD i
| |
| NARROW APPLICABILITY PARTICLE IN CONTACT WITH SKIN NOT PARTICLE ON HAIR OR CLOTHING NEED FOR PUBLIC COMMENTS NCRP LIMIT COULD ALLOW VISIBLE NON-STOCHASTIC EFFECTS O - tIniT exeResSED AS EniSS10n, NOT DOSE j SAFETY FACTOR NOT INCLUDED ICRP RECOMMENDATIONS PENDING ONG0ING RESEARCil l
| |
| O
| |
| | |
| b i i
| |
| ($) COMPLETED ENFORCEMENT ACTIONS ,
| |
| HOT PARTICLES ON SKIN OR CLOTHING )
| |
| i
| |
| : EXPOSURE GREATER THAN NCRP 75 MICRO-PART 20 CURIE HOURS 50 RAD (NA*) NO ;
| |
| 6/85- LMCGUIRE YES 1-1/86 SUMMER YES YES. YES 5/87 YANKEE R0WE YES N0 NO 1
| |
| 8/87 NORTH ANNA YES NO N0 5/88' WATERFORD YES NO N0 i N0 l
| |
| .5/88 WATERFORD YES 11 0 11/88 ARKANSAS YES (NA*) YES ;
| |
| ( ) *NA - NOT APPLICABLE, PARTICLE ON SHIRT-i
| |
| | |
| l
| |
| (_~)
| |
| CRGR REVIEW 0F DRAFT GENERIC LETTER 1
| |
| CRGR APPROVED 50-RAD INTERIM STANDARD SUBJECT TO THE FOLLOWING:
| |
| DO NOT CHANGE INCIDENT REPORTING, ETC.
| |
| CLARIFY l REPEATED OR MULTIPLE EXPOSURES THAT STAFF IS NOT ADVOCATING REDUCED PERSONNEL MONITORING THAT INTENT IS TO CHANGE INAPPROPRIATE REQUIREMENT IMPLEMENT RULEMAKING PROMPTLY NRC STAFF ACCEPTED CRGR RECOMMENDATIONS O
| |
| O 1
| |
| | |
| A d '
| |
| NUMARC-SURVEY OF 25 POWER PLAllT SITES f ESTIMATED INCREASE ~IN MAN-REM DOSE THAT CAN BE ACCREDITED TO INCREASED SURVEY REQUIREMENTS
| |
| ' TOTAL ' NUMBER MAN-REM OF SITES (N0 RESPONSE) 7 0 3 1 '3 1-2 1 2 1 3 2 5 1 15,6 1 20 1 24 1 26 1 10-50 1 50/0VTAGE + 5/M0 1 O
| |
| | |
| H.
| |
| l g CONCLUSIONS l
| |
| CURRENT UNRESOLVED DIFFERENCES IN SCIENTIFIC DATA LED THE NRC STAFF TO USE AN INTERIM STANDARD OF 50-RAD THE 50-RAD INTERIM STANDARD IS CONSERVATIVE THE'50-RAD STANDARD WILL EFFECTIVELY INCREASE SKIN DOSE LIMITS BY A FACTOR OF 3 OR 7 RETROSPECTIVE APPLICATION OF THE 50-RAD STANDARD WOULD HAVE ELIMINATED 5 OF 7 VIOLATIONS.
| |
| RETROSPECTIVE APPLICATION OF THE NCRP 75 MICR0 CURIE-HOUR STANDARD WOULD HAVE ELIMINATED 4 0F THE SAME 7-VIOLATIONS ,
| |
| THE 50-RAD INTERIN STANDARD SHOULD BE IMPLEMENTED AS S00N AS Q POSSIBLE 4
| |
| a
| |
| | |
| O CHRONOLOGY DECEMBER 4, 1987 NUMARC LETTER TO DR.
| |
| MURLEY EXPRESSING THE !
| |
| NEED FOR AN INTERIM STANDARD DECEMBER 22, 1988 LETTER FROM DR. MURLEY AGREEING BUT WAIT FOR l NCRP RECOMMENDATIONS O
| |
| FEBRUARY 10, 1988 NUMARC LETTER TO DR.
| |
| MURLEY TRANSMITTING EEI l SURVEY RESULTS MARCH 10, 1988 MET WITH STAFF TO l DISCUSS IMPACT ON INDUSTRY
| |
| )
| |
| MAY 6, 1988 NUMARC COMMENTS SENT TO NCRP/SENT A COPY TO NRC ON MAY 9, 1988 O
| |
| inw?L 1
| |
| | |
| .4 j l
| |
| O I
| |
| CHRONOLOGY (CON'T.)
| |
| l AusuST 1, 1988 NUMARC SENT ADDITIONAL INFORMATION TO NRC I AucuST 24, 1988 MET WITH STAFF TO l DISCUSS IMPLEMENTATION OF NCRP'S RECOMMENDATIONS I
| |
| 20, 1989 MADE PRESENTATION TO c) APRIL ACRS SUBCOMMITTEE i
| |
| APRIL 28, 1989 NUMARC LETTER TO JAMES l CARROLL TRANSMITTING CORRESPONDENCE AND l NUMARC POSITION
| |
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| O PROBLEMS WITH C03 TROL ROOM !
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| l EMERGEXCY VEXTILATIOX SYSTEMS
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| * DESIGNED TO PROVIDE PROTECTION AGAINST AIRBORNE CONTAMINATION O*
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| COMPLICATED DESIGNS TO PROVIDE VARYING AMOUNTS OF MAKEUP AIR
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| * RELIANCE ON ACTUATION OF DAMPERS TO CHANGE OPERATIONAL MODE
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| OBSERVATIONS
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| * SINGLE AIR INLET DAMPER
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| * CONTROL OF NORMAL VENTILATION
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| * AIRLINE CHECK VALVES O* DAMPERS ON SAME POWER SUPPLY
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| * NO BACKDRAFT DAMPERS
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| * SINGLE POWER TRANSFER SWITCH
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| * MISPOSITIONED DAMPERS
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| * MANY PWRs PIGGYBACK HPSI 0FF LOW HEAD PUMPS DURING RECIRC
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| * 2 LERS INITIALLY INDICATED PROB-LEMS WITH NPSH IN THIS MODE l
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| * DEFICIENCIES MULTIPLE PUMPS RUNNING 0FF DISCHARGE OF ONE PUMP AS BUILT CROSS CONNECT PIPING HAS HIGHER RESISTANCE INTERVENING PARTlALLY CLOSED THROTTLE VALVES l O l
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| I NUREG-1150 O " Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants" Presented to ACRS May 3,1989 O Office of Nuclear Regulatory Research
| |
| | |
| O Topics for Discussion
| |
| * Status of NUREG-1150 and Peer Review a Status of Supporting Documentation
| |
| * Uses of NUREG-1150 0
| |
| * Differences in Methods .
| |
| * Differences in Results
| |
| * Summary O 2
| |
| | |
| O Present Status
| |
| * Report assembled and delivered to Commission
| |
| * Final QA review on May 8-9
| |
| * Plan to send to printers in May, issue in June
| |
| * To be published as second draf t for peer review
| |
| * Same wide distribution as February 1987 draf t O
| |
| * Peer review organization proceding smoothly first technical meeting week of July 10
| |
| * ANS special committee to be briefed in May O 3
| |
| | |
| O Present Status (continued) !
| |
| * NUREG-1150 has performed external events analysis. I on 2 plants: Surry and Peach Bottom.
| |
| * Seismic analysis includes consideration of low probability, high intensity earthquakes which
| |
| -could have significant consequences in surrounding population.
| |
| * Pending further review, seismic analysis in NUREG-1150 will be limited to core damage frequency and containment performance.
| |
| Q
| |
| * To aid review of work, contractor documents will include sensitivity studies on seismic risk.
| |
| i
| |
| * Final version of NUREG-1150 should include results of l seismic risk analyses. !
| |
| 4
| |
| | |
| Y T
| |
| I 0 L T D
| |
| , 5 I B S E S1 E E D1 E A N O D D T B G HN E E A O G N I
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| R US O E T E H l I R P P F S D S S T E R S 0 O H MR C C O WN O 5 H ND T T FO E R
| |
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| |
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| T D
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| Y P
| |
| A NU OB T R E
| |
| 1 N D M A T D E I
| |
| E AS N L E
| |
| S S SR I T I DE NM V US E NSE E Z E A E
| |
| R QN M T E UT I I MR S EO M A C CS FI C SD MP R U O OI D F UR O K DI S O Q R F O N AA O E S AU C E P sY - E TD C V T I R NL T D N AC T U AN E O OC A RN UQ R R OET C DA E N G O P U E C E E P T E N I
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| R F S V M N E T
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| |
| H F I
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| A EN CI I S s E M I C H RA L
| |
| L N S E
| |
| I L R E P D L D A E K M C C SS O O I T E STN OI E S D U E R P T R T O RC I
| |
| O A E UE F S N T T E O I C E SS N VI I
| |
| R NEI D P C G MW E T NY O E A E PA M,BE N MR L T EL R T P TC A E I
| |
| A R I CA S R X XC N L SD R O E E M NN W 0 E E EA B DL A C H I
| |
| C V M OA E 5 C TF A A OU P E T E E O C S I
| |
| V 1 N F O AO ET HO E H U R P S C 1 U E HS RR TC RP T F E T E E EO E Y S F DH I D S E V S U
| |
| WI L H P ME R S E R O VG I V O A O A TE OHO OO F S
| |
| T OSI RN O
| |
| R D
| |
| H S
| |
| I TT S R I DTF D N PI P -
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| E - -
| |
| M E
| |
| L E
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| O
| |
| | |
| 1
| |
| .O l i
| |
| i STATUS OF NUREG 1150 PEER REVIEW ;
| |
| 1 l
| |
| COMMITTEE MEMBERSHIP i
| |
| H. J. C. KOUTS, BNL, CH AIRM AN .
| |
| 1 G. APOSTOLAKIS, UCLA i
| |
| A. H. BIRKHOFER, GRS, FRG O LARS HOEGBERG, SKI Wm. K ASTENBERG, UCLA LEO LeSAGE, ANL !
| |
| 1 N. RASMUSSEN, MIT JOHN TAYLOR, EPRI HARRY TEAGUE, UKAEA l
| |
| O l
| |
| 6
| |
| | |
| I 4--
| |
| O STATUS OF NUREG 1150 PEER REVIEW TENTATIVE SCHEDULE OF ACTIONS REQUEST TO GSA FOR AUTHORIZATION TO FORM COMMITTEE APRIL 14 1
| |
| -l GSA AUTHORIZATION RECElVED MAY 1 COMMISSION PAPER ON FORMAL APPOINTMENTS etc MAY5 O
| |
| COMMISSION APPROVAL OF PKG MAY 12 ADVANCE NOTIFICATION OF CONG COMMITTEES (TENTATIVE) MAY 15 PUBLICATION OF NOTICE IN FEDERAL REGISTER MAY 18 FORMAL FILING OF CHARTER WITH GSA JUNE 1 O
| |
| FIRST COMMITTEE MTG JULY 10 7
| |
| | |
| f i
| |
| \
| |
| l O
| |
| Reports Supporting NUREG-1150 N UREG-1150 Summary and Perspectives m
| |
| m Accident Accident Frequency Progression Other Analysis and Risk Analyses NUREG/CR-4660 NUREG/CR-4 661 Supporting
| |
| - Reports 3
| |
| O - Vo l.1: Methods Vo l.1 Methods -
| |
| - Vol.2: Expert - Vo l.'2: Expert External Ever's Judgments Judgments -
| |
| - Vol.3: Surry - Vol.3: Surry Source Term
| |
| , Analyses
| |
| - Vo l. 4 : Peach Bottom - Vol.4: Peach Bottom
| |
| ~ Accident Management
| |
| - Vo l. 5 : Sequoyah - Vol.6 Sequoyah Analyses
| |
| - Vol.6: Grand Gulf - Vol.6: Grand Gulf - QA Studies
| |
| - Vol.7: Zlon - Vol.7: Zion ._ code Descriptions O
| |
| | |
| O DIFFERENCES IN METHODS
| |
| . IMPROVED EXPERT ELICITATION PROCESS:
| |
| MORE REPRESENTATIVE PANELS; NORMATIVE i TRAINING FOR EXPERTS; BETTER EXPERT ELICITATION DOCUMENTATION.
| |
| . IMPROVED QUALITY AND QUANTITY OF PHENOMENOLOGICAL RESEARCH.
| |
| . EXTERNAL EVENTS ADDED FOR TWO PLANTS.
| |
| . DIFFERENT EVACUATION AND WARNING TIME ASSUMPTIONS USING DATA FROM EMERGENCY O PLANS.
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| i External Events Analysis !
| |
| * Analysis of seismic and fire initiated events using NUREG/CR-4840 methods
| |
| * Seismic analysis uses both LLNL and EPRI hazard curves O
| |
| * Bounding analysis performed for other external initiators
| |
| ~
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| E.U.S SEISMIC HAZARD CHARACTERl2 AT ION LOWER MAGNITUDE OF INTEGRATION IS 5.0 PERCENTILES = 15. , 50. AND 85.
| |
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| |
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| |
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| )1 .
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| Figure 2.11.1 Comparison of the BEHC and AMHC aggregated over all S and G-Experts for the Peach Bottom site.
| |
| O is
| |
| | |
| O Offsite Protective Action Assumptions
| |
| * Emeraency Resoonse
| |
| * Evacuation of 99.5% of population in 10 mile EPZ (delay and speed derived from licensee studies)
| |
| * Relocation of population with projected doses of 50/25 rem within 12/24 hours of plume passage
| |
| * Lona Term Countermeasures
| |
| * Decontamination, temporary interdiction, or condemnation of property and foods to avoid doses of:
| |
| * 4 rems in 5 years of continued living 5 rems from consumption of milk and standing crops in first year 0.5 rems from consumption of crops in subsequent years i
| |
| 19
| |
| | |
| O i
| |
| 1 :
| |
| Differences in Results l
| |
| * Core Damage Frequencies
| |
| * Containment Performance 1
| |
| O a Risk
| |
| * Comparisons with Safety Goals O
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| .a I
| |
| Early fatality /ry -
| |
| 1.0E- 03 3 1.0E- 04 g J
| |
| r 1.0E- 0 5 g as
| |
| ~
| |
| 2 -
| |
| 87' 87 1.0E-06 g -
| |
| E_
| |
| 1.0E- 07 _
| |
| 87 ,,
| |
| 1.OE-08 g 1.0E- 09 ;
| |
| E
| |
| : RSS PWR SURRY SEQUOYAH - ZION 1.0E- 10
| |
| . Comparison of early fatality risks -
| |
| PWR plants (internal initiators) b n .
| |
| w _ -- - __ _____ - _ -__ _________- -_ _ - _ ____ _- _____-___- -___- _ _--_ __ ___ - _ _ - _______ _ ___ - __]
| |
| | |
| : l r.
| |
| i
| |
| ('.
| |
| l-L.
| |
| Early fatality /ry 1.0E- 03 3 1.0E-04 5 I I i 1 1.0E- 05 s -
| |
| E . '
| |
| 3 .1 1.0 E- 06 g I 89 l i
| |
| 1.0E- 07 ;
| |
| ;3 5 89 1.0E- 08 ; .7 .
| |
| g 87 1.0E-09 ; PEACH GRAND ~
| |
| RSS BWR 5 BOTTOM GULF 1.0E- 10 Comparison'of early fatality risks -
| |
| BWR plants (internal initiators) l l
| |
| 2r
| |
| | |
| O i
| |
| Latent cancer fatality /ry 1.0E+00 -
| |
| 1.0 E- 01 g 89 87
| |
| ~
| |
| 1.0E- 02 3 i
| |
| i -
| |
| O :
| |
| 87 1.0E- 03 3 3 87
| |
| - 89
| |
| - RSS PWR SURRY SEQUOYAH ZION 1.0E- 04 i
| |
| Comparison of latent cancer fatality risks -
| |
| PWR plants (internal initiators)
| |
| O Z (,
| |
| | |
| l 4
| |
| n .
| |
| - %f F
| |
| Latent cancer fatality /ry 1.0E+00 -
| |
| ~
| |
| 87 1.0E-01 :
| |
| : er
| |
| ~
| |
| ~
| |
| 89 1.0E- 02 :
| |
| ~
| |
| l 89
| |
| - O- l
| |
| ~
| |
| , J l l 1.0E - 03 -
| |
| .p
| |
| :- PEACH GRAND RSS BWR BOTTOM GULF L 1.0E- 04 l
| |
| l l
| |
| Comparison of latent cancer fatality risks -
| |
| < BWR plants (internal initiators) I O ;
| |
| 17 t _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ - - - _ _ _ _ - - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _
| |
| | |
| l
| |
| )
| |
| . (j l
| |
| h ,
| |
| i i
| |
| Individual early f atality/ry 1.0E- 06
| |
| : 8afety Goal
| |
| ~
| |
| 87 87 87
| |
| : t. 1.0E- 07 g ,, 87
| |
| ! :. 87 89
| |
| ~
| |
| 89 1.0E- 08 s 1.0E- 09 .
| |
| : 5. 89 89 1.0E :
| |
| - SURRY BOTTOM " GULF '
| |
| 1.0E- 11 Comparison of individual early fatality risk -
| |
| all plants (internal initiators)
| |
| ..O 23 ,
| |
| . 1
| |
| | |
| -q fj i; -
| |
| t.jk : g, '!
| |
| M .j
| |
| : 3. .
| |
| . -l
| |
| ,G \
| |
| l1 Individual early fat'ality/ry 1.0E-06
| |
| < -Safety Goal
| |
| ' t ..
| |
| 1.0E - 07 g-
| |
| ' '- 1.0 E - 0 8 ;
| |
| 1.0 E- 09 s na g _
| |
| 1.O E - 10 g -
| |
| t +
| |
| ' 1.0E - 11 SURRY PEACH BOTTOM FIRE FIRE l
| |
| Comparison of individual early fatality risks - i Surry and Peach Bottom (fire initiators) g O- :
| |
| 1
| |
| | |
| . L, >
| |
| Individuallatent cancer fatality /ry 1.0E -0 5 g
| |
| : SURRY PEACH SEQU OYAH GRAND - ZION Safety Goat 1.0E-06 g
| |
| ~
| |
| a7 1.0E-07 s
| |
| : se s7-
| |
| : e7 e7
| |
| ~
| |
| 87 se 1,0E -08 g 89 1.0E-09 g 1.0E- 10 Comparison of individual latent cancer fatality risk -
| |
| all plants (internal initiators)
| |
| O
| |
| _=_ _ _ _ _ _ _ _ _ . - _ _ - .
| |
| .o
| |
| | |
| , 1 s
| |
| A.);;
| |
| 7..
| |
| 1 l.
| |
| Individuallatent cancer fatality /ry 1.0E- 0 5 3
| |
| -< -Safety Goal 1.0 E- 06 g 1.0 E- 07 g 1.0E- 08 s O
| |
| 1.0E- 09 s -
| |
| h'
| |
| ~
| |
| i 1.0 E- 10 i SURRY PEACH BOTTOM !
| |
| FIRE FIRE 4
| |
| Comparison of individual latent cancer fatality risks - l Surry and Peach Bottom (fire initiators)
| |
| O l.f
| |
| | |
| p, .
| |
| * 3, t
| |
| ;;< :. /w.j .
| |
| . - \Q .
| |
| 1
| |
| (-
| |
| Probability of a large release 1.0E-04 =
| |
| 87 E
| |
| 1.0E-0 5 3 89 87
| |
| - Tentative og i
| |
| Goal 87 87 1.0E - 06 <
| |
| 5 89 1.0E -07 g 89 1.0E - 08 s" O !
| |
| ~
| |
| 89 1.0E-09 ; ,
| |
| 1.0E- 10 m 5 PEACH SURRY BOTTOM SEQUOYAH GULF ZION 1.0E - 11 l
| |
| Comparison with tentative safety performance guideline O
| |
| | |
| w-_ _ _ _ .
| |
| 's
| |
| , r~y' I /
| |
| s Probability of a large release (Fire) 1.0E-05 g
| |
| : Large Release - Release that has l
| |
| ~
| |
| a potential for causing an of fsite .I early f atality l l
| |
| 1.0E - 06 e< Tentative coal 1.0 E - 0 7 s
| |
| =
| |
| ?m -
| |
| 1) 1.0 E- 08 -
| |
| 1.0E - 09 s
| |
| =
| |
| ~
| |
| ~ + +
| |
| 1.0 E - 10 Surry Peach Bottom Comparison with tentative safety performance guideline i
| |
| O d
| |
| n
| |
| | |
| i L
| |
| f.O l
| |
| i l \
| |
| )
| |
| i Summary '
| |
| l 1
| |
| l
| |
| * Af ter final QA, report will be ready to issue as second draf t for peer review (June).
| |
| * Peer review to begin in July.
| |
| * Interim use of report per Commission guidance.
| |
| O + eian to compiete peer review. moeify report as needed and reissue as final report by end of CY 1990.
| |
| i O
| |
| o 3+
| |
| | |
| f NRR STAFF PRESENTATION TG THE O
| |
| ACRS 1
| |
| l l
| |
| | |
| ==SUBJECT:==
| |
| LIMERICK GENERATING STATION, UNIT 2 OPERATING LICENSE DATE: May 4, 1989 PRESENTER: Dick Clark O~
| |
| PRESENTER'S TITLE / BRANCH /DIV: Limerick Project Manager l
| |
| Project Directorate I-2 NRR PRESENTER'S NRC TEL. NO.: 492-3041 SUBCOMMITTEE: GE Reactor Plants i
| |
| O
| |
| | |
| U LIMERICK UNITS 1 AND 2 OPERATING LICENSE REVIEW JllNE 19, 1974 UNIT 2 CONSTRUCTION PERMIT MARCH 17, 1981 OL APPLICATION TENDERED JULY 1981 OL APPLICATION FOR UNITS 1 & 2 DOCKETED JUNE 1983 DRAFT ENVIRONMENTAL STATEMENT, PART I (NUREG-0974)
| |
| AllGUST 1983 SAFETY EVALUATION REPORT (NUREG-0991)
| |
| FOR UNITS 1 8 2 OCTOBER 1983 DES, PART II, FOR UNITS 1 a 2 OCTOBER 1983 ACRS MEETINGS ON LOW POWER LICENSE DECEMBER 7, 1983 LICENSING BOARD HEARINGS BEGIN
| |
| (]) DECEMBER 1983 CONSTRUCTION ON UNIT 2 STOPPED OCTOBER 1984 ACRS SUBCOMMITTEE MEETINGS OCTOBER 26, 1984 LOW POWER LICENSE FOR UNIT 1 NOVEMBER 6, 1984 ACRS REPORT ON UNIT 1 AUGUST 8, 1985 FULL POWER LICENSE FOR UNIT 1 FEBRUARY 1986 CONSTRUCTION ON UNIT 2 RESUMED JANUARY 11, 1989 UNIT 1 COMPLETES SECOND CYCLE OF OPERATION I
| |
| l
| |
| (--
| |
| | |
| l L. ~
| |
| ]
| |
| -Q. '
| |
| LIMERICK UNIT 2 READINESS ASSESSMENT PROGRAM l'
| |
| u l
| |
| APPLICANT PERFORMING COMPREHENSIVE READINESS VERIFICATION PROGRAM APPLICANT HAS CONDUCTED EXTENSIVE IDCA WITH INDEPENDENT CONTRACTOR NRC HAS CONDUCTED TEAM INSPECTION OF THE DESIGN AND CONSTRUCTION ASSESSMENTS THOROUGH DESIGN DOCUMENTATION AND VERIFICATION PROGRAM FSAR ACCURATELY REFLECTS AS-BUILT PLANT. AS-BUILT PLANT O CONSTRUCTED IN ACCO'RDANCE WITH DESIGN.-
| |
| O
| |
| | |
| [-
| |
| 14
| |
| \
| |
| O' READINESS ASSESSMENT PROGRAM (CONTINUED)
| |
| I CONSTRUCTION ACTIVITIES HAVE BEEN WELL CONTROLLED.
| |
| EXPERIENCED PEC0 AND BECHTEL MANAGEMENT PROVIDED ACTIVE OVERSIGHT.
| |
| THE PRE 0PERATIONAL TEST PROGRAM HAS BEEN WELL PLANNED AND EXECUTED. TEST PERSONNEL HAVE RIG 0ROUSLY ADHERED TO APPLICABLE TEST INSTRUCTIONS. OVERVIEW BY QUALITY ASSURANCE AND TEST REVIEW BOARD PERSONNEL HAS BEEN THOROUGH, THE PLANT OPERATIONS STAFF HAS BEEN FULLY INTEGRATED INTO THE IMPLEMENTATION OF THE TEST PROGRAM.
| |
| OPERATIONAL READINESS PROGRAM HAS SUCCESSFULLY INTEGRATED CONSTRUCTION, TESTING, QUALITY ASSURANCE, OPERATION AND CRAFTSMEN TRAINING, SAFETY AND ENGINEERING SUPPORT.
| |
| BASED ON PAST PERFORMANCE, HIGH CONFIDENCE THAT PLANT IS READY FOR SAFE OPERATION.
| |
| O
| |
| | |
| O LIMERICK UNITS 1 AND 2 CONDUCT OF OPERATIONS EXCEPTIONAL SITE MANAGEMENT AND SUPERVISION PROVIDE LEADERSHIP TO SUPPORT CONTINUED STRONG PERFORMANCE, GOOD MORALE AND STR0i4G SAFETY PERSPECTIVE.
| |
| STRONG ORIENTATION TOWARD SAFE PLANT OPERATION BY OPERATORS EXCELLENT LICENSED OPERATOR ATTITUDES.
| |
| GOOD WORK ON DRUG ALLEGATIONS AND FITNESS FOR DUTY.
| |
| MANDATORY ROUTINE DRUG TESTING PROGRAM GOOD ABILITY TO PROACTIVELY IDENTIFY / PREDICT PROBLEMS, CRITICALLY SELF-EVALUATE PERFORMANCE AND TAKE EFFECTIVE lll CORRECTIVE ACTIONS.
| |
| STRONG QA/0C ORGANIZATION AND PROGRAMS PERFORMANCE INDICATORS FOR UNIT 1 ABOVE AVERAGE. LOW SCRAM RATE. LOW FAILURE RATE FOR SAFETY SYSTEMS.
| |
| PERFORMANCE OF SITE ORGANIZATION HAS DEMONSTRATED THAT THEY ARE CAPABLE AND QUALIFIED TO SAFELY OPERATE UNIT 2.
| |
| UNIT 1 SALP RATINGS AMONG BEST IN COUNTRY ACTIONS BEING TAKEN TO PREVENT FUTURE FUEL FAILURES AND TO MINIMIZE GROWTH 0F INDICATIONS II: RECIRCULATION INLET N0ZZLE.
| |
| O
| |
| _4_
| |
| | |
| O tiMeRiCx UNITS 1 AND 2 MANAGEMENT i
| |
| MAJOR CORPORATE AND SITE REORGANIZATIONS HAVE NOT DISRUPTED
| |
| , OPERATING STAFF WHICH HAS BEEN THE KEY TO PAST SAFE PERFORMANCE OF UNIT 1 RE0 ORGANIZATION OF NRB FROM A COMPLIANCE FOCUSED REVIEW TO AN EXAMINATION OF PROCESSES, EQUIPMENT AND PLANT PERFORMANCE STRENGTHENED AND INCREASED SCOPE OF ISEG PROGRAM l
| |
| CONSOLIDATION OF ALL PREVIOUSLY FRAGMENTED QA AND OC FUNCTIONS INTO A SINGLE QUALITY ORGANIZATION 1
| |
| l l
| |
| L O
| |
| L_ _ _ _ _ _. _ _ _ _
| |
| l
| |
| | |
| 'O tiMeRiCx UNIT 2 OPEN' ITEMS-PLANT SPECIFIC POWER ASCENSION TEST PROGRAM PUMP AND VALVE (IST) PROGRAM FINAL TECHNICAL SPECIFICATIONS FINAL INSPECTION OF IDCA PROGRAM ANTI-TRUST REVIEW EXEMPTION FROM DECOMMISSIONING PLAN EQUIPMENT QUALIFICATION PROGRAM O
| |
| * CONTROL SYSTEM COMMON FAILURE ANALYSIS l l
| |
| EXTENSION OF TIME FOR OPERATING WITHOUT INERTED CONTAINMENT TURBINE SYSTEM MAINTENANCE PROGRAM l
| |
| EXTENSION OF TIME FOR OPERABILITY OF SPDS AND ERFDS :
| |
| i O
| |
| . - _ _ _ _ _ _ _ _ _ _ _ _ _ . __ ________-_________-_____________________A
| |
| | |
| . j 4
| |
| , O tInERiCK UNIT 2 OPEN ITEMS - GENERIC ISSUES BULLETIN 88-05 NONCONFORMING PIPING MATERIAL L
| |
| BULLETIN 88-10 NONCONFORMING MOLDED CASE CIRCUIT BREAKERS
| |
| ~
| |
| O O-
| |
| | |
| i 4
| |
| .O LIMERICK UNIT 2 E 4FF CONCLUSION SUBJECT TO THE SATISFACTORY RESOLUTION OF PENDING ISSUES, THE STAFF CONCLUDES THAT LIMERICK, UNIT 2 CAN BE OPERATED SAFELY BY PECO AND WITHOUT ANY UNDUE RISK TO THE HEALTH AND. SAFETY OF THE PUBLIC.
| |
| O i
| |
| l l
| |
| 1 O
| |
| L_______-______ _ _ _ - _ _ _ _ _ . . _ - . _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ -
| |
| | |
| j
| |
| ()
| |
| NRC REGION I STAFF PRESENTATION TO THE ACRS
| |
| | |
| ==SUBJECT:==
| |
| LIMERICK GENERATING STATION, UNIT 2 DATE: MAY 4, 1989 PRESENTER: J. LINVILLE PRESENTER'S TITLE / BRANCH / DIVISION:
| |
| O CHIEF, PROJECTS SECTION 2A DIVISION OF REACTOR PROJECTS REGION I e
| |
| 1 o
| |
| u
| |
| | |
| F y: ~, - ,
| |
| 3o;
| |
| -TOPIC OUTLINE CHRONOLOGY CONSTRUCTION INSPECTION PROGRAM PRE 0PERAT10NAL TESTING PROGRAM
| |
| .SALP
| |
| ' FACILITY READINESS FOR. POWER OPERATION
| |
| | |
| ==SUMMARY==
| |
| | |
| CONCLUSION
| |
| .O l
| |
| : f. .
| |
| l n
| |
| .g.IQ?'
| |
| ~
| |
| CHRONOLOGY 1
| |
| i l ,
| |
| ! CONSTRUCTION PERMIT ISSUED:. JUNE 19, 1974-
| |
| ~
| |
| CONSTRUCTION SUSPENDED (UNIT 2)-(30% COMPLETE): DECEMBER 1983 OPERATING. LICENSE (UNITL1): OCTOBER 26, 1984 FULL POWER LICENSE-(UNIT 1): AUGUST 8, 1985 CONSTRUCTION RESUMED (UNIT.2): FEBRUARY 1986 O .
| |
| CONSTRUCTION COMPLETION (UNIT 2): MAY 1989 O
| |
| _ - - _ - - __ - -- - u
| |
| | |
| l; l '' ,
| |
| '.- (
| |
| CONSTRUCTION INSPECTION PROGRAM INSPECTION EFFORT COMPARABLE TO OTHER PLANTS TEAM INSPECTIONS SINCE RESUMPTION OF CONSTRUCTION REGIONAL CONSTRUCTION TEAM INSPECTION INDEPENDENT NDE VERIFICATION INDEPENDENT DESIGN AND CONSTRUCTION ASSESSMENT OVERSIGHT NO ESCALATED ENFORCEMENT AND NUMBER OF VIOLATIONS COMPARABLE TO OTHER PLANTS REPORTING 0F CONSTRUCTION DEFICIENCIES IMPROVED SINCE RESUMPTION OF CONSTRUCTION AND CONSISTENT WITH OTHER FACILITIES FEW ALLEGATIONS AND NONE WITH MAJOR SAFETY SIGNIFICANCE O
| |
| --_ - - - - - - -- - -- - 1
| |
| | |
| D' PRE 0PERATIONAL TEST PROGRAM 1
| |
| INCORPORATED LESSONS LEA'RNED DURING UNIT 1 START-UP INCORPORATED START-UP EXPERIENCE FROM OTHER UTILITIES PREOP TESTING AND.NRC REVIEW IDENTIFIED N0 MAJOR ISSUES O
| |
| O
| |
| | |
| 1- 0 SALP 1986 SALP (1/11/86 - 6/31/87) 7 AREAS RATED CATEGORY 1 2 AREAS RATED CATEGORY 2 ENGINEERING CONTROL 0F DESIGN INTERFACES BETWEEN THE ARCHITECT ENGINEER AND BOTH EXTERNAL AND INTERNAL ORGANIZATIONS INDICATED SOME WEAKNESSES.
| |
| 0THERWISE GOOD CONTROLS OVER CONSTRUCTION ACTIVITIES.
| |
| 1987 SALP (8/1/87 -12/31/88)
| |
| ALL 4 AREAS CATEGORY 1 DURING THIS SALP PERIOD.
| |
| - ENGINEERING CONTROLS CORRECTED, ALL AREAS GENERALLY CONTROLLED VERY WELL.
| |
| O
| |
| | |
| 6 O
| |
| FACILITY READINESS FOR POWER OPERATION FACILITY STAFFING AND ORGANIZATION NUCLEAR DEDICATED ORGANIZATION SITE MANAGEMENT WITH EXTENSIVE NUCLEAR OPERATING BWR EXPERIENCE AT UNIT 1 SINCE 1984 SIX SHIFTS FULLY STAFFED FOR TWO UNIT OPERATION.
| |
| COMON PROGRAMS EMERGENCY PREPAREDNESS O
| |
| RADIATION PROTECTION AND RADWASTE SECURITY PROOF AND REVIEW TECHNICAL SPECIFICATION VERY SIMILAR TO UNIT 1 ISSUED AND REVIEWED REGION 1 APPLICATIONS OF PROBABILISTIC RISK ASSESSMENT START-UP PROCEDURES 76% COMPLETED O
| |
| | |
| w---. . . - - - - - - . - . , - - - - . . -
| |
| 4 O
| |
| | |
| ==SUMMARY==
| |
| | |
| LICENSEE i
| |
| NO MAJOR CONSTRUCTION DEFICIENCIES PRE 0PERATIONAL TESTS AND RESULTS. REVIEW FOR FUEL LOAD.
| |
| IN PROGRESS MANY YEARS OF NUCLEAR /BWR EXPERIENCE REGION I ACTIVITIES O -
| |
| AUGMENTED INSPECTION COVERAGE DURING FUEL LOADING AND STARTUP TESTING OPERATIONAL ASSESSMENT TEAM INSPECTION AFTER FUEL LOAD ,
| |
| j l _
| |
| O
| |
| _- _ -- - -- - - 1
| |
| | |
| I
| |
| .O ^
| |
| CONCLUSION OVERALL, REGION I HAS FOUND THE CONSTRUCTION PROGRAM AT LIMERICK TO BE~ EFFECTIVE. OUR REVIEW PROVIDES CONFIDENCE THAT PECO HAS BUILT A QUALITY NUCLEAR PLANT.
| |
| IN ADDITION, OUR REVIEW 0F THE PRE 0PERATIONAL TEST PROGRAM 1
| |
| AND THE LICENSEE'S BWR OPERATING EXPERIENCE WITH LIMERICK UNIT I INDICATE THAT PECO IS CAPABLE OF SAFE OPERATION OF THE' FACILITY, O
| |
| l L___-_.___--__--___--
| |
| | |
| ! l ;i l lljjlll)
| |
| O f d
| |
| v-x L
| |
| N O
| |
| S S
| |
| ,C N E O YSI 9 R L T BMR 8 E AT O C N
| |
| C I
| |
| T D
| |
| ESELE DIC 9 1
| |
| O R TRTLL ,
| |
| C A NCNIE 4 P EAEW Y S S N R T E R
| |
| EEO RKI Y AM T O S H P PIN U MU D
| |
| N I
| |
| O O
| |
| N"
| |
| | |
| S E
| |
| ER T CU C NS A AO P DP M IX I UE S G D N N N R YI S A S E RK S N S E C OS N O N N G N T O I O O N O T AE I T I I A C N LL T A T T H E
| |
| - UC A D A A C N M GI R N D T O E ET E E N N C T I C RR D M E E I C T R A I M M M T A A O S MP S O M E A P T F N I N C O L M M N N O RT O E C P M I E E I EO C R E M A M T TH R I R A E Y A N L P G R L R D IR A R C Y O A P O N
| |
| - O C C R R R L M T E F I N N T P A I A M N S L M
| |
| - H U U O
| |
| - C D G C E N E E T - - I - - - R R O O O O
| |
| | |
| D L
| |
| O H
| |
| S S N E S E O R A R I H E E U T T R G S A A N O E A M P R E L E R M X D D C G S A
| |
| O E I E S L
| |
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| |
| I D TA RR R
| |
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| |
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| T C L N S A B A R C O E P0 T O R I C R 0 A . T <
| |
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| |
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| |
| T ,
| |
| M I A T1 P M P E P C I S . E1 A S O G N N S M RD U 8 T N T H O V Ao E A I . O A O C I I T HR D 1 S R H E T E D T A I P Z 0 O0 R F 0 T M I M0 I0 O L 6 U S M5 D0 L E -
| |
| S ,
| |
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| |
| A C u o S E 17 R2 C R F C A C I R T E U I V O R
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| _ I S - - C - - -
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| R C 2 U I M O T C S R A 0 K P 1 S (
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| S I R N D E S S O T A N I E E E O T T M R I P I A A T M N I T A U I D A E D S F H G N S N M T R E A I M A M O L M E N 1 T O V O F C I R D S O E T D O A D '
| |
| E F R N Y R A S O P V A E0 P A P R R E B) S0 S R C S R O0 E E N N E E D ,
| |
| R H O S T 1 R T C O E D1 O O D M L C I A O - D D I H D A LD S0 L R O E0 O HM R5 H R S M H ,
| |
| S O E T7 E F R1 R H1 H T( - T -
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| O N N O O I I T T A A R R G E I C M L .
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