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| 'O L UNITED STATES NUCLEAR REGULATORY COMMISSION i
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| ............... e4====o==============="""*"""""""""""*""""""
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| ADVISORY COMMITTEE ON REACTOR SAFEGUABG.S In the Matter of: )
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| )
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| )
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| 350th ACRS Meeting )
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| Day Two .)
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| O ,
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| Pages: 247 through 465 Place: Bt hesda, Maryland Dato June 9, 1989
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| .......... ....a......./. w.o.c. L >.O....;..
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| * v j
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| HERITAGE REPORTING CORPORATION p# 0$EisiReperses 1220 L Seest, N.W., Same des -'
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| WeaMagton, D.C. 2000$
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| gg61gg.4 soo6 ' A4M T-174:< t ac m .-- ]
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| m- y. ,
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| 37 = -- y 4 ,
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| <. j .-
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| . ()- 1 PUBLIC. NOTICE BY THE:
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| 2 '
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| UUITED STATES NUCLEAR REGULATORY COMMISSION'S' .
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| 3
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| . ADVISOR 7.COMMTTTEE'ON REACTOR SAFEGUARDS' 4
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| 5 6
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| .x . , w <
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| 7 The contents of this stenographic transcript offthe- +
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| '8 proceedings of the United' States Nuclear l Regulatory #
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| 9 Commission's Advisory, Committee.on ReactoriSafeguards iACRS),
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| ~'
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| 10 as reported herein, is an uncorrected record of the discussions' 11 recorded at the meeting held on;the above datu.' '
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| 12 No member of the'ACRSLStaff~and no participartmat' 13' this meeting actiepts any responsibilityffor errora or 14 inaccuracies of statement or data contained :in this " transcript.
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| O 15 16 17 18 19 20 21 22 23 ;
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| d 25 1
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| y I
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| Earitage -Reporting I Corporation (202) 628-4888 L-f 1
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| a=___________ _ _ m - _ n .: t
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| 247 V UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE.ON REACTOR SAFEGUARDS In the Matter of: )
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| )
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| )
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| 330th ACRS Meeting )
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| Day Two )
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| Frfday, June 9, 1988 j heom P-110, Phillips Building 7920 Norfolk Avenue Bethesda, Maryland The meeting convenedi pursuant to notice, at 8:50
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| : a. m.
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| BEFORE: FORREST J. REM 7.CK-Chairman. ACRS Associate Vice-P6esident for Research
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| ,3 Profeesar of Nuclear Engineering (
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| t The Pennsylvania Star.e Univereity "
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| University Park, Pennsylvania i
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| ACRS MEMBERS PRESElg.:
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| sTII.LIfjM KERR Professox of Nucleer Engineering Director, Office of Energy Research University of Michigan Ann Arbor, Michigan CHARLES J. WYL1E Retired Chief Engineer E3ectrical Division Duke Power Company Charlotte, North Carolina 1
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| t PAUL G. SHEWMON l
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| Professof, Metallurgical Engineering Departme:nt Ohio State University Columbus e Ohio
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| ( h ritage Reportineg Corporation (202)' 628e4888 l
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| : 9. .
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| '248 ACR$ MEMBERS PRESENT (Continued):
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| CHESTER P. SIESS .
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| Prof 3&sor Emeritus of Civil Engineering'
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| ' University of Illino$s-Urbana, Illinois DAVID A. WAPC .
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| Research Manager on Special Assignment E.I. du Pont de Nemours & Company, I Savannch River L%boratory-Aiken, South Carolina-HAROLD W. LEWIS d '
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| i Professor of Physics .
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| Department of' Physics l Univer?!ty. of California Santa Barbara, California CARLYLE MICHELSON Retired Principal Nuclear Engineer Tennesaec Valley Authority l Knoxville, Tennessee, and 1
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| Retired Director, Office for Analysis and Evaluation of Operational Data i U.S. Nuclear Regulatory Commission Wa.shington, D.C.
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| t O- JAMES CARROLL l Retired Manager, Nuclear Operations support Pacific Gas & Electric Company I San Francisco, Californie !
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| IVAN CATTON Professor of Engineering j Department of Mechanical, Aerospsce'& Nuclear j Engineering School of Engineering and Applied Science University of Calif 0rnia.
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| Los Angeles,.. California I
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| DESIGNATED FEDERAL OFFICIAL: 1 RAYMOND FRALEY, Executive Director, ACRS- )
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| I 2
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| 6 i
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| Heritage Reportlng Corporation (202)~ O?.8-4888 l l
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| 249-
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| . :NRC STRFF PRESENTERS:
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| MARK WILLIAMS - (Chief, f Trends . and Patterns Branch, AEOD)
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| NEILL.THOMASSON (AEOD) -
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| STEVE STERN (Performance Indicator . Group) . .
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| SAM.PETTIJOHN (Performance Indicator. Gropp)
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| ARASMI LOIS (Office .of Research')
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| CARL JOHNSON (Office of Research)
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| MICHAEL POORE- (Oak ' Ridge Mat'l- Lab):
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| GARY 14AYS (Oak Ridge Nat'l Lab)-
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| CARL LOVELL (Idaho Nat' l.' Lab) d.LSO PRESENT:
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| ROBERT DENN$G PAUL BOEHNER!
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| i h 250 1 EERHEEDIEGA 2 8:30 a.m.
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| 3 -MR. REMICK:. Good morning ladies and'. gentlemen. The 4 meeting will now come to order.
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| 5 This is the second dry of the 350th 1secting of the-6 Advisory Committee on Redctor Safeguards. Pyring today's 7 meeting the co:nmittee will discuss acciderit policy -
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| 8 consideration in connection with the General Electric Company:
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| 9 Advanced Boiling Water Reactor; resolution of theLBWR core 10 power . stability issue; USY&-17 Systems Interaction; education 11 experience requirements for nuclear power plant' senior 12 operators and control room supervisors; discussion of Generic O 13 2 "e 1 ze, =1ectric t re-er sv ete ae11 8111*vi na 14 nomination of ACRS riemb9rs.
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| 15 Items for consideratica on Saturday are listed ou 16 the schedcle posGed ca the bulletin , board outside this meeting j 17 room. This meeting is being conducted in accordance with'the I i
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| 18 provialens of the Federal Advisory-Committee Acf: and the l 19 Government and. Sunshine Act. l l
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| 20 Mr. Raymond Fair.?.e*y is bhe designated federal 21 official for the initial pcetion of the meeting.
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| 22 We received no written statemy.itu or Mguests to !
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| l 23 make oral statements from raer(ers of the public regarding j 24 today's sessions, A transceipc of pp.rtion6 cf the me#tirig is
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| . 25 being kept. It is request 6d that each speaker s.Ise one of the; HERITAC2 REPORTIND' CORPORATION i (202) 528-4888 I i
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| 1 microphones, identify himself or herself, and speak with 2 sufficient clarity and volume so that ne or she can be readily 3 heard.
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| 4 As indicated, the first item on our agenda this 5 morning is a discussion of the General Electric Con:pany 6 Advanced Boiling Water Reautor. Mr. Carlyle Michelson is our 7 subsommittue chairman, so Carlyle, I tvrn the meeting over to 8 you.
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| 9 MR. MICHELSON: Thank you, Mr. ChairyAn.
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| 10 The subject this morning I believe is primarily an 11 informational type briefing on the part of the staff. This 12 was not a subject for a subcommittee detailed discussion. So
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| ()
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| -u i 13 aince I havo no other introductory remarks, I believe, who's '
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| 14 going to be the spokesman for the scaff? Introduce yourself.
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| 19 MR. MILLER: Thank you, Mr. Chairman. My name is 16 Charles Miller.
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| l') As you mentioned, we'rs here today to disques 18 certnin featuren of General L'lectric's ABWR ilesign that the 1 l
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| 19 staff believee will enhanca safety, and will satisfactorily ]
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| 1 20 address severe accider.t concerng upon completion gaf the 21 staff's review. l 1
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| 22 What i ranted to do this morning is gkve a short I i.
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| 23 piece of backgifound and then get into the specific topics we l 24 have on the viewgraph.
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| i l .
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| 2$ In 1988 s paper was presented to the commission l
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| '(_) 252 1 proposing an avenue for generic rulemaking for the 2 evolutionary plants, advanced light water reactor plants.
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| 3 Since that time, and upon further reflection and review, the l 4 staff has decided that rather than proceeding with rulemaking, 5 we wanted to proceed through dcuign specific resolution and to 6 handle the resolution of severe accidents for the evolutionary 7 plants through the design certification rulemaking procedures B that are outline in 10 CFF.52.
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| 9 Up on the board are some aspects of Part 52 that are 10 requirements of the rule to be addressed by anyone seeking 11 design certification. I'll call out three of them.
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| 12 Compliance with 10 CFR 34F. That's the TNJ concerns. Some
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| () 13 CP/ML rule. I'd remind you gentlemen that that's the rule 14 that applied to some future plants at one point, none of which 15 were ever completed.
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| 16 You also must reach resolution of generic issues and 17 unresolved safety issues proposed and have the staff accept 18 their resolutions for those on a design specific basis. Also 19 must provide probabilistic risk e.ssessment to support their 20 design.
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| 21 I wanted to say that General Electric has addressed 22 each of these in their submittal and has made commitments to 23 comply with these even prior to the rule being promulgated.
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| 24 These commitments were made by General Electric as part of the 25 licensing review basis that we established in 1987.
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| h 253 1 MR.'KERR:
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| Mr. Miller,.when you said that this 2 design would be certified or whatever the appropriate word is.
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| 3 by rulemaking, does that imply for example,. that the severe 4 accident requirements will be decided during the: rulemaking
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| -5 process rather than be required to conform'to, staff 6 requirements?
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| 7 HR. RUEENSTEIN: This is Les Rubenstein of.the 8 staff.
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| 9 I think we would codify the design in the 10 rulemaking. However f the staff'over the last three or four.
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| 11 years in conjunction with research and industry, and industry.
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| 12 themselves, have pretty well defined the phenomena associated
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| () 13 with severe accidents.
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| 14 During th9 course of the review of what-the staff 15 should do about severe accident requirements, we started the 16 review of the EWR design. It bact.me clear'that General 17 Electric had for the snost part. satirfied dealing with the 18 severe accident phenomena through their. design.
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| 19 Additionally, as Dr. Miller said, SECE 98 246 was 20 withdrawn, and at that time a decision was made'to deal with 21 tho severe accident issues no a plant specific basia,c It 22 turns out that General Electric is the first plant goir g 23 through the staff's review. I i
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| 24 What you see before you-today that.Dr. Miller is ;
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| 25 presenting are essentially the very preliminary conclusions of HERITAGE REPORTING CORPORATION (202) 628-4868 1
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| :O 2s4 1 1 the design that suggest most of the phenomena, if not allfthe 2 phenomena, have been addressed.
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| 3 Concomonant with this meeting or slightly after this 4 meeting in the presentation to the Commission on the 20th, the 5 staff will be presenting its views to the Commission, and if 6 they agree7 then what GE has offered and the staff will have 1
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| 7 reviewed over the course of the next year will be what goes 8 into the rulemaking. So.we invite your comments. The q l
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| 9 Commission is address 6ng these issues on and about the 20th, l 10 and they certainly would, be interested in any views you may 11 have.
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| 12 MR. KERk: I~ guess I didn't make my question. clear. ;
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| () 13 or else I didn't know what question to ask. I'had thought 1
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| 14 that the rulemaking process was itssif a dacision making .
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| 1 11 process and that one did not g6 into it with a pre-determined 1
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| 'l 16 an:Swor, but r.sther the ' rulemaking determined eventually ' what -
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| 17 requirements were g;dng to be. Am I mistaken?- .i 18 MR. RUBENSTEIN: Y&u're right, except that th's ll 19 Commission certainly after reviewing the staff's comments on ]
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| 20 the design and the degree which the design at General ~ Electric .
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| I 21 has proposad.to deal with the severe accident phenomena may t .
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| 22 ch3nge its mind and tell us to add or delete something in the l:
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| 23 design. Then certainly the rulemaking in and of11tself.would -j
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| . 1 24 be the final approval by the-Commission.
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| 25 MR. KERR: Then I think Mr. Miller said earlier- l
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| 255 l 1 thht, or perhaps you said, that you concluded that General i
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| 2 Elect.ric ha4 satisfactorily dealt with the severe accident j 3 issuo. That zust nean there is somewhers a set of criteria 4 which determines when, or which is used to determine when 5 sati faction bas osan achieved.
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| 6 MR. ROBENSTEIN: Thby have proposed design criteria, 7 and the Commission has a number of viewpoints on the 8 phenomena. For example, hydrogen controle as Dr. Miller said, 9 5034 F required hydrogen control. The sovere accident policy 10 which is now part of 10 CFR 52 dealt with the requirements of 11 the PRA. So under these broad guidelines and after a long and 12 involved examination of severe accident phenomena such as core
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| () 13 debris coolability and other things, in looking at the design 14 we found that this plant specific design to a large degree 15 satisfied these needs and the Commission didn't have to 16 explicitly state many of these requirements.
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| IT MR. KERR: My understanding of the way the severe 18 accident policy, the form in which I remember it dealt with 19 future plans Yas that it required that a PRA be performed. It 20 did not specify anything about the resulte one would get.
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| 21 MR. RUBENSTEIN: TDat's fair to say. However, the 22 E2RI utility requirements document and the st.aff's licensing 23 review basis which I believe you may have participated in a 24 couple of years ago, did set forth certain design guidelices ;
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| 25 in terms of core melt frequency of ten to the minus five; a HERI*tAGE REPO'tTING CORPORATION (202) 628-4988
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| . 3
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| . '256 1 conditional containment failure probability of .1; the.EPRI '!
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| ~ .l 2 safety goal; the prcbaoility of a large release being ten to 1 1
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| 3 the minus six for a 25 EEM half mile exposure. This anci other; 'j
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| .i 4 design guidelines are built into the process. So one has to 5 look at the staff's review o.S the EPRI Chapter 5 document and i 6 what General Electric has offered. Suilt-into this are things j
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| ')
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| 7 like 100 percent metal water reaction which we'll talk about 8 in some detail; 10 percent uniform hydrogen volume percent 9 concentrations; and other features which we want to discusa 10 with you today. ,
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| 11 MR. KERR: Okay, I'11 have a better picture then 12 after the day's discussion, Thank you. _
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| h 13 MR. MICHELSON: One clarification on the slide. You i 14 talk about including the resolution of the applicable TJSI's J5 and certain of the GSI's. 'Many, if not'most of these I 16 resolutions: that I've eeen of late at least, make no mention l
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| 1 17 of what you do with that rewolution on future plant. What is !
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| 'i 18
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| * your understanding and position about each of these so-called j
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| i 19 resolutions?
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| 20 MR. SCALLETTI: Dino Sealletti from.the NRC staff. l 21 All the USI's and GSI's will be resolved on ths AWR-on a l l
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| 22 design specific bacis. The last amendment, Amendment 6, that e
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| 23 was received, and the portion of the amendment that dealt with 24 the USI's and GSI's, the staff will come t6 a resolution on ,
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| 25 these issusa, will leview them by the January 1990 SER._
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| 9ERITAGE REPORTING CORPORATION (202) 628-4688 )
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| ( 257 1 MR. MICHELSON: That's irrespective ofIwhat the 2 resolution itself might have said to do for present: day 3 piknts? e 4 MR. SCALLETTI: That indeed could be the' fact, yes.
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| 5 NR MILLER: TheLresolution'for present~ day plants 6 may or may not be acceptable or applicable resolution for this 7, plant.
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| 8 MR. MICHELSON:. That'.s the point. You're going to 9 review them with a fresh view.
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| 10 MR. MILLER: Yes.
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| 11 MR.'MICHELSON: Thank you.
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| 12 MR. 14 ILLER: "I'd like to get into some~of the
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| () 13 specific topics now that we looked-at, the first of which is 14 station blackout.
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| 15 The design proposed by General Electric.the . staff 16 feels clearly goes beyond what's required in the station 17 blackout rule. Some of the specifics: They've offered three 18 independent electrical divisions'which include three 100 19 percent capacity diesel generators. In addition to that as a 20 diverse sourco, they've offered an alternate AC combustion 21 turbine generator. The design has a 10 hour blackout 22 survivability period, coping capability, and in addition to 23 that the design includes the capability for the AC iraependent 24 addition of water through diesel driven: fire pumps and/or if 25 an absolute necessity hookups to such things as a fire truck.
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| HERITAGE REPORTING COR? ORATION (202) 628-4888
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| _.4 0, 2se 1- MR. REMICK: Could you' expand on your-words '
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| 2 alternate AC combustion turbine? I'm not sure what you said. ]
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| .3 Is this an option for staff. consideration? What'do-you mean- l 4 by alternate AC combugition turbine?
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| 1 5 MR. MILLER: In addition to the three 100 percent 6 capacity diesel generators and the three independent trains, 7 they are also going to' include in the design'...-
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| 8 MR. REMICK: So they are going to include it.
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| 9 MR. MILLER: They are going to include.it. They've 10 committed to provide,~in addition to that, an AC independent i
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| 1 11 source'which in this case they want to be a combustion turbine 12 as a diverse source of AC power. That meets and goes beyond 13 the requirements of the rule..
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| 14 MR. MICHELSON: I think there are some restrictions j 15 on how good that design is from the safety grade viewpoint.
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| 16 Is that a full safety grade alternate? j 5
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| 17 MR. MILLER: No .t's not. {
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| 18 MR. MICHELSON: Coul'd you tell us briefly what the '
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| i 19 limitations are? !
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| 20 MR. MILLER: My understanding of the limitations... j 21 MR. SCALLETTI: It clearly is not a safety grade-l 1
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| 22 combustion turbine as far as we know. We don't have the l
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| ! l 23 details on it yet. It will be provided with the design. .l 24 Basically, that's it. l l
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| 25 MR. MICHELSON: Basically it's another single track j
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| 259 1 of power, butIdon'tknowthiedetailsofhowyoucan 2 electrically separate it from the others and so forth. Safety 3 grade would tell me, but non-safety grade does not.
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| 4 MR. SCALLETTI: It is not safety grade. It is an AC 5 combustion turbine and the details of how it will be tied into 6 the plant we don't have yet.
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| 7 km. RUBENSTEIN: We believe it's an off the shelf 8 gas turbine. It probably has on the order of a five minute 9 start capability. One of the nice features about it, as Dr.
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| 10 Miller said, it goes beyond the rule. The rule really said 11 have an alternate diesel and here is a completely diverse 12 power source.
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| () 13 MR. MICHELSON: Most of the interest comes from the 14 direction of the electrical separation of this non-safety 15 device from the rest of the devices, and particularly for 16 events that might take out one or more of the diesel 17 generators, or precipitate a power blackout.
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| 18 MR. MILLER: That's correct.
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| 1 19 These items taken together, we believe, will provide l 20 a significantly lower risk from station blackout than what we 21 have seen in current generation plans.
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| 22 MR. KERR: GE has done a PRA on this, I think. What 23 is the contribution to core melt frequency of station blackout '
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| 24 compared say to Grand Gulf?
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| 4 25 MR. SCALLETTI: We don't have that information as t
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| HERITAGE REPORTING CORPORATION (202) 628-4888 1
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| 260 1 yet with the addition of the AC combustion turbine. We have 2 Mr. Duncan here from General Electric. Perhaps he could 3 address this.
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| 4 MR. DUNCAN: I'm Jack Duncan from'GE. I.think, 5 although it's been awhile since I looked at the Grand Gulf 6 results, we calculated-I think probably' core damage on the low 7 ten to the minus six for Grand Gulf. Question. Anyway, 8 that's what we calculate for ABWR internal events..
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| 9 MR. KERR: I was thinking of the contribution;of' 10 station blackout to core melt frequency. How do the two 11 compare?
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| 12 MR. DUNCAN: I'm not quite sure I remember the Grand O 13 Gu1f resuits. The resu1ts are probab17 simizar.
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| ror interna 1 14 events it's like 60 to 70 percent station blackout 15 contribution on ABWR before the alternate AC supply and before 16 the AC independent water addition systems are considered. The 17 staff has the first results without the new features yet being 18 shown in the calculation.
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| 19 MR. KERR: I see a bullet that says it provides 20 significantly lower risk. But that's.just a qualitative 21 statement.
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| 22 MR. DUNCAN: I think it's on the order of a factor 23 of ten for either the AC independent water addition'or the gas 24 turbine, depending on which one you do first, which one you 25 put in the calculation first. Then of course the second one HERITAGE REPORTING CORPORATION (202) 628-4888
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| () 261 1 is worth less, having reduced that.
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| 2 MR. KERR: So if it were ten to the minus six for 3 Grand Gulf it would be ten to the minus seven for ABWR7 4 MR. DUNCAN: Right.
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| 5 MR. KERR: Thank you.
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| 6 MR. MILLER: The next topic I'd like to discuss is 7 the intersystem LOCA. The concern here is that we wanted to 8 be able to eliminate our concern about LOCA's outside 9 containment. Those LOCA's that could occur as a result of low 10 pressure, high pressure interfaces.
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| 11 Offered in the design here are ECCS inboard check 12 valves that are testable and have position indication. In
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| () 13 addition to some other features that have been included in the i
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| 14 design, the staff feels the ABWR low pressure systems are i
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| 15 adegaately protected from reactor coolant syctem pressure. We {
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| 16 feel the intersystem LOCA is resolved for the ABWR.
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| I 17 These details have to be confirmed. I should put I
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| '. 0 s
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| the caveat on all remarks that I say this morning, our 19 detailed review will confirm the remarks that I'm making this 20 morning. Not in all cases have we completed our detailed 21 review.
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| 22 MR. MICHELSON: There are no check valves on the 23 reactor water cleanup letdown side. You can't put a check 24 valve there, obviously. So you must have some other 25 considerations that are taking care of it.
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| o EERITAGE REPORTING CORPORATION (202) 628-4088
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| ( 262 l
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| 1 1 MR. MILLER: Yes.
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| 2 MR. MICHELSON: Are these considerations in design 3 assuming that you're unable to isolate the break for at least 4 a reasonable period of time like a minute or something? In 5 other wordo they count for the pressure buildup in the 6 building?
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| 7 MR. RUBENSTEIN: I don't recall. But let me answer 8 your first question and think about your second for-a second.
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| 9 All the piping designs, or piping that is less than 10 or equal to one-third reactor coolant pressure would require 11 approximately three malfunctions.
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| i 12 MR. MICHELSON: We're talking about full reactor 1
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| (
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| (_"j\ 13 pressure line. i 14 MR. RUBENSTEIN: Yes. They would require at least 15 three malfunctions before the low pressure side would be j 16 subjected to that pressure. For those which are greater than 3 i
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| 17 one-third reactor coolant system pressure, would require about i l
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| 18 two failures. I 19 MR. MICHELSON: I hear your numbers. I've heard l 20 them before. We know that valves may behave differently when 21 in line, which these are, because of the downstream effects of
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| {
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| 22 the first trying to close on the second and neither of them 23 end up closing. So I don't buy how many valves you've got.
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| 24 Rather I ask, if the valves don't close have you accounted for l
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| ,, 25 tne pressurability before you blow the building apart.
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| HERITAGE REPCRTING CORPORATION (202) 628-4888
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| V , 263 1 MR. RUBENSTEIN: Let me say, not leave it rest like 1 2 that. Charlie did say these are testable valves, j
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| 3 MR. MICHELSON: No, check valves are.- There are no 4 check valves there.
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| 5 MR. RUBENSTEIN: I don't recall specifically.
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| 6 MR. MICHELSON: You can't put a check valve in a led 7 bound line.
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| 8 MR. RUBENSTEIN: No. There ultimately is a place 9 where you come to ambient... ,
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| i 10 HR. MICHELSON: We'll pursue it later. Thank you..
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| {
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| 11 MR. MILLER: The next topic I'd like to discuss is l l
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| 12 ATWS.
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| ()
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| r 13 Offered in the design are both hydraulic and l 14 electrically controlled rod control drives. The ability for 15 recirc pump trip. SCRAM discharge volume has been eliminated i I
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| 16 in this design. The design provides for alternate rod 1 I
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| 17 injection. The design also provides for manual standby liquid j i
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| 18 control system. I should point out to the committee that the l 19 ATWS rule itself requires automatic SLC. General Electric has 20 agreed to do a reliability analysis on the manual SLC to try 21 to demonstrate to the staff that the manual SLC in this case 22 will fill the bill. I wanted to point out to the committee l 23 that reldsbility analysis will be reviewed by the staff before 1
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| l 24 any determination is made. Should an acceptable determination 1
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| 25 be made on the part of the staff, it would require an HERITAGE REPORTING CORPORATION (202) 628-4888
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| 1 exemption from the rule.
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| 2 MR. WARD: This reliability analysis is going tc-3 depend, the results of it, strongly on what is estimated about 4- the action of the operators.
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| 5 MR. MILLER: That's correct.
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| 6 MR. WARD: Is there some new information that's 7 being generated for this? I'm curious as.to how this analysiv ,
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| j 8 is going to be made, how it's going to be more believable,.
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| 9 let's say, for the ABWR than it has been for the BWRs.
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| 10 MR. NEWBERRY: Scott Newberry,.NRC staff.- You're 11 certainly correct about the dependence on the operator. -I 12 think GE has indicnted to us that they believe that analysis
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| () 13 would show that the operator would have significantly more 14 time to act for this design. I think that would be the 15 primary point in their analysis, but of' course they're going 16 to have to talk about procedures, indications in the control-17 room, the entire situation, and we're going to have to look'at 18 it very closely.
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| 19 MR. KERR: In calculating the contribution of ATWS 20 to core melt frequency, what is the number that GE calculates 21 for the unavailability of the combined shutdown systems?-
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| l 22 MR. SCALLETTI: _Can General Electric respond to l 1 l 23 that?
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| 24 'MR. DUNCAN: Our failure to SCRAM by either the 25 electrical or hydraulic is less than ten to the minus six in HERITAGE REPORTING CORPORATION 3 (202) 628-4888 J
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| _______--_A
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| i l
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| 265 ;
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| i 1 our calculations. We calculate a lot lower number than that, !
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| i 2 or would calculate a lot lower number than that, but just l i
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| 3 assume what we think is a pessimistic number of ten to the 4 minus six.
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| 5 MR. KERR: You really_believe that?
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| 6 MR. DUNCAN: Yes. We think it's lower than-that.
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| 7 MR. WARD: It's better than the tua t o the minus 8 fourteen numbers we used to get.
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| 9 MR. KERR: This is ten to the minus six per demand?
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| 10 MR. DUNCAN: Right.
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| 11 MR. KERR: Can that be demonstrated some way other 12 than by calculation?
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| () 13 MR. DUNCAN: Others may be able to answer better 14 than I. I'm not familiar with the details. I don't know how 15 to do it beyond the calculation, other than experience based.
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| 16 MR. KERR: You're apparently depending for the --
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| 17 frequency you get on a system whose reliability is 18 extraordinarily, assumed to be extraordinarily great, perhaps 19 greater than any other system in the plant.
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| 20 MR. DUNCAN: Well it's for good reason that we try 21 to make it so, of course, because the SCRAM is so important.
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| 22 MR. KERR: I know you try to make it so, but you 23 can't demonstrate that it is that.
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| 24 MR. DUNCAN: It's difficult to demonstrate
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| ,_ 25 probabilistic numbers when you do get that low, b
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| HFRITAGE REPORTING CORPORATION (202) 628-4888
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| [}. 266.
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| 1 MR. KERR:- It certainly is.
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| 2 MR. DUNCAN:' There is backup'with_SLC...
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| 3 MR. KERR: It would seem to me it would therefore'be 4 difficult to depend on numbers that are that low.for an 5 incident whose probability I hope is low,-but whose 6 consequences could be rather severe.
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| 7 MR. DUNCAN: We're assuming ten-to the minus six.
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| 8 Given that assumption, the contribution of ATWS to:our PRA 9 calculations is-on the order of two decades.less than our 10 total result, ao it's about one-one hundredth of the total 11 result.
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| 12 MR. KERR:- I'm not surprised..
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| () 13 MR. DUNCAN: Even if'one' disagreed by a' factor'of:
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| 14 ten squared, you would have not much effect on'the total 15 result.
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| 16 MR..KERR: Even ten squared is hard to demonstrate.
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| 17 I'm sorry, not ten squared. I was thinking' ten to the minus-18 four is hard to demonstrate.
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| 19 MR. DUNCAN: Ten squared I was talking about. If 20 one differed with our view on ATWS by a factor of< ten-squared, 21 you would still come to the conclusion that.there's-not much 22 effect on the core damage frequency.
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| 23 MR. KERR: But'even ten to the minus four'is rather; 24 -difficult to demonstrate,.if not-impossible.- I ca'n perhaps
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| > 25 understand the ancient designs that depended'on this system, F
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| O HERITAGE REPORTING CORPORATION (202) 628-4888
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| () 267 1 but new designs when it is perhaps possible to make the 2 consequences of ATWS much less by appropriate designs give'me 3 some concern.
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| 4 Mr. Lewis?
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| 5 MR. LEWIS: I just wanted to say something to this 6 general point of what you can demonstrate at low probability 7 because there's a little bit of confusion. Bill, you're 8 absolutely right, of course, at very very low frequency, low 9 probability, if an event as complicated as this one is there's 10 no way to demonstrate it, but there are cases which you can 11 demonstrate really unambiguously very low probabilities of the 12 form ten to the minus six, ten to the minus seven. That is
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| () 13 when the sequence goes through an identified bottleneck, an 14 intermediate state that it has to go through, and you can 15 demonstrate that the probability of the first sequence is say 16 ten to the minus three, which you can, and that the 17 probability of the second sequence, given the first one is ten 18 to the minus three, then you really have demonstrated ten to l 19 the minus oix.
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| 1 20 That's not the case here. But just to avoid the 21 impression that in principle never possible to demonstrate.
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| 22 For example, you can calculate the probability of a pe.ifect 23 came in baseball just by concatenating the probabilities that 24 all the batters get put out and it comes out just right.
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| , 25 If you aim for a situation which you must go through HERITAGE REPORTING CORPORATION (202) 628-4888
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| . .- - g
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| ' g, Q 4
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| '. :268 1 an intermediate state, you can.begin.to get. demonstrable very.
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| 2 low probabilities. That's not'the. case here, as-far as-I-3 understand it.
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| 4 -MR. WARD: And I guess: sort of related,. that's'~what 5 bothers me a little bit talking about ATWS.just'in: terms of; 6 risk core melt. ATWS is a little bit different animal than an--
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| 7 accident'which would' lead.to core. melt just from the K power.
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| 8 It seems to me it's a little bit misleading to, talk'about it'.
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| 9 merely from the standpoint of the' contribution of core melt.
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| 10 It's more directly related to a large release, I think. . ,.
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| 11 MR. RUBENSTEIN: The staff agrees, and-IIdon't want 12 to be too optimistic about'it, but.when we get into".the.
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| O 13 disoussion on the vent, and we ta1k ahout some deerees of vent 14 and quote the ability of the plant to ride through an ATWS 15 which Dr. Kerr alluded to in terms of the consequences,.there:
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| 16 is some more robustness here that the staff is discussing with 17 General Electric. Particularly 'its ability to increase- the -
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| 18 size of their vent pipe to approximately 10 or 12.or.14. inches-19 and deal with perhaps a'three percent decay heat.
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| 20 We haven't.seen this, we've had preliminary 21 discussions with General Electric and they've been working on 22 this. As the ATWS story evolves, I would expect this.to be an-4
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| .1 23 important contribution to our consequence mitigation. l n
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| 24 -MR. MILLER: The next slide is'.some-of the' !
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| 25 containment features.
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| O -
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| HERITAGE REPORTING CORPORATION (202)' 628-4888
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| (,) 269 1 The ABWR design goal is to provide a conditional 2 containment of failure probability of ten to the minus one 3 over credible core damage sequences. In doing that, I
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| 4 containment failure is defined as an uncontrollable release.- !
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| 5 Also the definition includes the fact that the sequence starts 6 at the onset of core damage.
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| 1 7 Hydrogen control is obviously something that has 8 concerned all of us over periods of time. In regard to this 9 design, the ABWR is going to have an inerted containment.
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| 10 Also the capability for hydrogen recombiner. With the 11 combination of those two features the staff feels the hydrogen j i
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| 12 control features of the ABWR are adequate. J
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| () 13 MR. REMICK: You say the containment failure is 14 defined as an uncontrolled release. Is that a release of any )
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| I 15 magnitude? ]
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| 1 16 MR. MILLER: No, it would be a release that would 17 exceed the EPRI safety goal guidelines. Mr. Rubenstein I J J
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| 18 think mentioned those earlier. !
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| 19 MR. RUBENSTEIN: The system incorporates a rupture 20 disk which would be set at 80 psi in the vent. The definition 21 is coupled with the use of a vent system with valves in line 22 to close the vent, and we're getting ahead of ourselves, to 23 deal with the rupture disks which are in series and which the 24 valves are in series.
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| 25 So an uncontrolled release in the first instance O
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| i i
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| i 270 j i
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| 1 would be one where you had the rupture disk fail.- Well.what ]
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| ~
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| 2 we're in a position better is-to. preclude an uncontrolled
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| -3 release.- I would better describe it by the circumstances.- An. l 1
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| 4 uncontrolled release would be one~in which the rupture disk 5 failed and we could not use the valves to-close off the 6 release after pressure dropped.
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| 7 MR._MEMICK: What magnitude is considered an' 1
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| 8 uncontrolled release? You might have a penetration with a 9 small leak.- Is that an uncontrolled release?'- It is"an 10 uncontrolled release, but is that a failure in the terminology 11 here?
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| 12 MR. RUBENSTEIN: 'I think we have to separate,-we're. ,
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| ) 13 talking now in severe accident space, and we're talking after 14 a major accident. i 15 MR. REMICK: That I understand.
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| 16 MR. KERR: If I understand what Les is saying is I 17 that they're going to use a rupture disk so that if failure 18 occurs they'll know what it is and where it is. That's the- 1 1
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| 19 idea, isn't it?
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| 1 20 MR. RUBENSTEIN: Yes. )
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| 1 l 21 MR. MILLER: If we'get to the next slide...
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| 22 MR. REMICK: Before' leaving it I have another 23 question. You're saying anything below the size of the
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| . q l
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| 24 rupture disk in that vent...
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| l 25 MR. RUSENSTEIN: Has to meet tech spec.
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| (:) !
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| HERITAGE REPORTING CORPORATION ,
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| (202) 628-4888 j 1
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| .-- _________ _ -U
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| y; _
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| Tj 271.
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| 1 1
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| 1 NR. REMICK: It's'not an-uncontrolled release. 1 2 HR. RUEENSTEIN: Without'the major ~ accident you have i
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| 3 to meet all the tech spec leakage requirements. I want to 4 distinguish between within the designLbasis1and severe 5 accident, q
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| 6 MR. REMICK: But you're going.to have a rupture disk' 7 in some kind of a vent size, and you're saying if you have a 8 leak anywhere else that's not an uncontrolled releasei 'That's 9 not considered a failure according to this criteria. -JLn I 10 right? I'm trying to understand.
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| 11 MR. RUBENSTEIN: We've. moved away from a mechanistic 12 failure and we've moved away from having, well let me digress
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| () 13 for a second.
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| 14 General Electric originally proposed and said an i
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| 15 uncontrolled release was bne which violated the public safety 16 goal of ten to the minus six, 25 REM half mile. We felt thBt ;
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| 17 to be quite unsatisfactory. So we' asked them to adopt a 18 definition....
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| h l
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| 19 MR. WARD: Why did you think tha4 was l
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| 20 unsatisfactory?
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| 21 MR. RUBENSTEIN: In dealing with the point one 22 condition of containment failure probability, we felt that it 1
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| 1 23 would be better to have a more detailed mechanistic reloaee. I l
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| 24 One can't relate that physically as I'm being question?d ebout i
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| 25 to some event. That's sort of abstract and 6nly achievable '
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| ()
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| HERITAGE REPORTING CORPORATION I (202) 628-488B
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| %~~____2_m_ _ _ _ _ __ _ - . _ _ _ _ _ _ _
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| si. Il o.
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| 1
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| ['i 272
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| %J
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| ~
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| 1 through some calculation. So ve felt it would be better. to l 2 get some specific physical milestono'that we could deal with.
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| 3 and then use it a2 a basis for analysis.
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| 4 HR.'SIESS: What's epecific about the word-5 uncontrolled? Thet was voluma percent a day or. curies or.
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| 6 standard cubic feet per hour or sorAething, you eay 4t wan' 7 specific, but-I don't see what's specific about it.
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| 8 MR. RUBENSTEIN: It's that pressure which would 9 cauwe the rupture disk to fail. l 10 ?R. SIESS: Hou big"s the. rupture' disk?
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| 1 11 MR. EUBENSTEIN:
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| I said again, that they're working 12 on the detaile and we haven't got into.the very specifics, so j
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| {} 13 conceptually what we see la a mystem-where they're' going to 14 set it somewhere below the rupture strength. If.the ultimate ]
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| 1 15 rupture strength is about. 100 for this containment they're 1 1
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| 16 thinking in terms of about 80 psi.
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| 17 MR. SIESS: The rupture disk leads to a filter? ,
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| 18 MR. RUBENSTEIN: It goes through one. It-goes out' -i i
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| 19 to the stack. +!
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| 20 MR. SIEGS: What essurance do you- bev6 tliat it ' won't' 21 fnil somewhere else before the rupturc disk? i 22- MR. MILLER: The rupture disk is downstream of the ,
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| l 23 . suppress 6on pool. It would be filtered through the <
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| l L 12 4 suppression pool before going through.the vent-where the- i l- 25 rupture disk, the rupture disk...
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| ( '
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| HERITAGE REPORTING CORPORATION (202) 628-4863 j 1
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| -%B : ."' &
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| ..y se s 273
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| -)
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| 1 ' MR. -. SIESS : .As'long as it's in the suppression; pool
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| :]*
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| 2 itf s in contairunent.
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| 3 MR.-MILLER:. That''o correct. s. I{
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| 1 4 MR.:SIESS: We're-not worried about thet, are we? .
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| h 1
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| 5 MR.-MILLER: The' suppression p9ol itself provides l
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| (
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| 6 the filtering :uechanism, to answer the question...
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| 7 11R. SIESS: That's beside the point.. It doesn',t say- <
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| i 8 an uncontrolled release of what, it:just.says an uncontrolled ]
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| 9 release. ]1 10 MR. RUBENSTEIN: Let me'try specifically. The design creesure for the containment is approximately 45 psi.-
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| 11
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| ]
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| 1 12 You're saying'why is 80 psi' good.- t7e beldsvv.the. actual -]
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| -13 ultimate rupture strength,'what General Electric proposes ae' ji 14 the actual ultimate rupture strength ja the containment wculd i 1
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| 15 be about 100 psi.
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| J By containment you r.ean everyt"ning?
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| l 16 MR. SIESD: '
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| i
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| ?7 MR. RUBENSTEIN: Yes.
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| 18 MR. SIES$: all the penetration 3 subjected to high- >
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| i 19 te.mperature, all the dooz.s and seals, etcetera. All 2hs 20 valves closed.
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| 1 21 MR. RUBENSTEIN: I understand your quest &00 =I 22 can't address it right now in that way. -ise'll have.to pursue L 23 this with General Electric. As T said at ' the start, we're in I
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| l- 24 the verv early stages of seeing what the vent's design is.
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| 25 We'11 have to review how complate it protects us.
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| RERITAGE REPORTING CORPORATION (202) 628-4888 e - - . - - - _ _ _ _ -- _ _
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| {'.Y , ll i '
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| 0: =
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| 1 MR. CIESS: Ww can they design'a= vent of:eny, kind-1 1
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| 2 ' sit hout ,ha ring some quantitative mapure of h6w largs a' .
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| : l. 3 release t a y havs to vent? c l.
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| 4 m. RUBENSTF.INi e line, tha public They do as 9L gcid' 5L -safety goal,'the ten to the minus..sixc ' 25 RElis 6 MR. SIESS: It seems to n@'that was'$omething like o
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| -7 10 percent a day.
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| 8 MR. RUBENSTEIN: I don't recall.
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| .< 1 9 ~MR. SI53S; The public safety g?al talks abcut'a ,)
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| 10 large release.
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| 11 MR. RUBENS'IEIN: And the vent is designed ageinsi...
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| 12 MR. SIESS: This talks about an uncontrolled '
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| 13 release. Somewhere you must be'an uncontrolled largo. release e "1 14 is that right.? l 4
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| i 15 MR. RUBENSTEIN: That's what we're talking about. .;
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| 16 This is an event of a coro melt. I 17 MR. SIESS: But the ruptured disk is a controlled l 18 .ikrge release.- Right? )
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| ' I l? MR. MILLER: .It's a controlled large release to the 20 extent that the purpose of the rupture disk is to keep the 21 containment from losing its integrity due to over pressure. )
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| 22 MR. SIESS: You're saying the containment should be ;
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| 23 designed to maintain its integrii y up to 80 psi.
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| 24- :MR. RUBENSTEIN: No,.I think the design pressure for 25 the containment is 45 or 50 psi, but the ultimate rupture O HERITAGE REPORTING CORfeOR3LTION (202) 628-48e3 1 <
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| _]
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| ;27$
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| 1 atxength of the ocntainnent~in actassed at about 100. So we 2 belie're, Or they believe that with the rupture A5 3k set at j 3 about -approxinat ely 80 pai they will keep the pressure 4 integrity of the containment.
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| 3 141. SIESS: If the pressure does not exceed 80 they 6 will not have a release?
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| 7 MR. RUBEt1 STEIN: That's right, e MR. 31sSS: or eny kine.
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| 9 MR. RUBENSTE1N: I didn't say that: That remains, 10 I'm not poing to talk about electrical penetrations. Ms'11 11 have to look at that. But they will not have a release which 12 would exceed the public safety goal. I said we have not
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| (~\
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| (_/ 13 reviewed this in this kind of detail. We're deuling right now 14 in a conceptual sizing of a venting system and a rupture disk 15 and we recognize that we'll have to address other issues such 16 es emergency preparedness associated with this. We haven't 17 got into those kinds of detalis. But conceptually when they in do their PRA and they start to take credit for heat removal l 19 through the vent und other things, it gives a certain 20 robustness to the design and the staff will have to continue 21 reviewing it. I can't answer some of these detailed !
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| 22 questions.
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| 23 MR. SIESS: I don't s0e how they can be designing l 24 something that you're going to review when you don't know what ;
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| - 25 you' re going to review the design against. For some re.a:aon 1
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| t, 1 EERITAGE MEPORTING CORPORATION (202) 628-4088 j i
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| l l
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| i I -
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| i l
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| ?76 i
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| 1 I'm going around in circles, so lot somebedy elce talk. ]
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| I 2 MR. REMICK: I think the p0 int wefre trying to make, J 3 you say containment failure is defined ae an uncontrolled 1
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| 4 release, and we're saying release of what magnituue, You're 5 got to define the magnitude. That's the question basically i
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| 6 we' rc asking. You don't have to answer it now. We can take j l
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| 1 it vp separately, j 8 MR. ROBENSTEIN: I understand the question.
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| 9 MR. R$i4ICK: The other question I have on the sid.de 10 is it says hydrogen recombiner capability. Does that mean 11 zhere's no decision on whether there would be hydrogen 12 recombiners and the design will allow for that depending on 13 the outcome of the rulemaking? Is that what the bullet means?
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| ({ )
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| 24 MR. MILLERi It ifill have hydrogen recombiners.
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| 15 Whet?.or they're permanently installed or portable..
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| 16 MR. SIEMS: These will take care of the hydrogen 17 what, from electrolysis'.
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| 18 MR. MILLER: I believe it will. l l
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| 19 MR. SIESS: Is that the only source of hydrogen in a 20 severe accident? j l
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| 21 MR. MILIiER: Ralph Architzel... l l
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| 22 MR. GIEES? I'm sorry. Unlese you're using a 23 nicrophone, I dcn't hear that well. l 24 MR. MILLER: Ralph Aichitzel of the staff -- o::yge: 6 25 from the... I HERITAGE REPORTING CORPORATION ;
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| (202) 628-4888 i
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| () 277 1 MR. SIESSt Huh?
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| 2 HR. MILLER: It's not the hydrogen concern, but the 3 oxygen.
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| 4 MR. ARC 8ITLEL: That's correct. It's radialysis of 5 Lhe water e long term.
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| 6 MR. SIZSS: Sc these are the gams capacity 7 recombiners that we have now in some of tha PWR'c? Are you 8 talking about that same level of capacity?
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| 9 MR. ARCHITZEL; That',7 correct.
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| 10 MR. CARHDLL: On the inert bullet, is the first 24 11 hours after start-up, uningsted still going to be acceptable?
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| 12 MR. RU$ENSTEIN: 'Yes.
| |
| () 13 MR. CARROLL: Have you looked at the risk of thist 14 I've'always considered following a refueling cutage things.
| |
| I 15 aren't put together right or rorebody does some mai6tenance ao 16 a pipe hanger and jams up a pipe Nnd rips the nozzle off a i 17 l vessel. Even tLaugh you don't have e lot of fission products 10 it's a bad t1xne to have an accident. l 19 MR. RUBENSTSIN: I believe we have in plant systems, 20 but I can't recall the ,results. Y6ur comments are well taken.
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| 21 We've considered it.
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| 23 MR. MILLER: I think ve've already gat into the 23 beginning of the next slide and that was the vent design 24 'iteelf. I guess what I would add to the discussion that's 25 taken place so far is that our vent design not only contains a g,
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| (/ ,
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| HERITAGE REPOGTING CORPORATION (202) 628-4886
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| s}
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| O 22e 1 1
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| q 1 rupture disk but it ' also conbains isolation valve.s so that. the l 2 relense can t,o teEmierm.ed et such a time that the pressure has 3 d.repped to the extent that the containment ichegrity is no 1
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| 4 Longer threatenod. So it' allows the oporator v.o take' action, ;
| |
| l SL to Asolate and control the release. j i
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| 6 MR.-CARROLL.: What'a the rizing b7.se for the vent? M I T How big is it, for example, in percent decay heat?
| |
| 8 HR, MILLER: ' The -actual' dimensions ' of the . vent yet ,
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| 9 we haven't got the- details nn. General Telectrie is still4 4 I
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| 10 working on the d? tails. . .i i
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| 11 MR. RULENSTEIN: We think from preliminary i 12 dirscussiors, that it's ebout three percent capability.
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| O 13 "*- e anote'= ra t'= dieser ed a 1 vre eat 11 deiae 14 put in o:t plants like Pilgrim. I think that's-one percent, 15 isn't it?
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| i 16 MR. ARCHITZEL: We understand'it's, we believe, a 14 -l 17 16ch sized vent and equal -- three percent decay heat with ;
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| i
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| .18 combined c:ipacity of the existing decay heat low pressure l
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| l' 19 decay heat removal systems.
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| 20 MR. WARD: Did I understand that yo;2 belf.evo that 21 was going to be big enough to play some part in A2WS o
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| 22 :nitigation?
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| 23 MR MILLER: Yes we dc. .
| |
| 24 MR. MICHELSONs Wi71 the safe shutdown equipment 25 inside e containment be environmentally qualified then for 80 O HERITM;E REPORTANG d6APORATION -
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| (202) 628-4888 i
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| f%
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| l U" 279 l
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| (, 1 pounds preacure? If that's;whers the set point of the disk ~
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| 2 is? Not just a severe accident mitigation, the actual normal-3 safe shutdowa aquipment.
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| 4 MR. RUBENSTEIN: I don't know.
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| 5 MR.JMICHELSON: Ta build the coursos that if-6 something goes wrong and you're u.$ing normal' safe shutdown 7 equipment and you can't open the vent until 80 pounds you'll 8 hope that the normal safe ehutdown equipment operates until 9 you can.
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| 10 MR. RUBENSTEIN: Let me answer you with a general 11 statement. We got into this when research was looking at 12 certain oi the phenomena and what mitigation systems'should be
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| () 13- designed to. We left it sort of no, we would not require 14 safety grade for events which take place in severe accident 15 space. However, we did require and we put.in189013 our SECE 16 paper that wo had before and we may have discussed with you, a 17 general statement which I'll try from mencry goes like the 16 system should be designed to operate in the environment with a R 19 time life as long as necessary to fulfill its function.
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| l 2D MR. MICHELEON: Which system?
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| 21 MR. RUPENSTEIN: Any mitigation system in severs 22 accidents 23 MR. . MICdEL3ON: Lo Jafe chutdown'syetems th6.n would 24 be operable until they are no longer needed, is that what 1 1
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| 25 you're saying?
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| 'sTERITAGE REPCATING CORPORATION (202) 628-4bFS
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| 280 l
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| l 1 MR. RUBENSTEIN: I'm talking about severe accident 2 mitigation systems.
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| 3 MR. MICHELSON: I'm Laying I haven't got a severe 4 accident...
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| 5 MR. RUBENSTEIN: If you're talk 3ng about the 6 alternate shutdown panel and those kinds of...
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| 7 MR. MICHELSON: No, I'm talking about equipment 8 Inside a containment which I may still need to be able to 9 maneuver up until you reach the 80 pound point when your other 10 system...
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| 11 MR. RUBENSTEIN: I don't want to get pulled into 12 agreeing with you about 80 poundn...
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| 13 MR. MICIIELSON: Whatever.it is.
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| 14 MR. RUBENSTEIN: What I want to say.is those safety 15 systems which arc required to shut the plant down for design 16 basis events would have to have the appropriate equipment 17 qualification, and in those cases we use the classical 10 pres?.ure/ temperature containment codes.
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| 19 MR. MICHELSON: Yes, which is much lower than 80 j 20 pounds.
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| 21 MP. RUBENSTEIN: -- or some of the others. That's l
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| 22 r*ght. But for those systems in severe accident space, they 23 have to ha able to...
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| 1 24 MR. MICHELSON: We'll pursue thia later after you j 25 decide what the vent looks like. Thank you. i
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| /'T 4 l
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| UERITAGE REPORTING CORPORATION (202) 628-0B88
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| 10 m 1 MR. MILLER: I'd like to move now to.Gome discussion 2 on core debris coolability. The design ~of.the ABWR we-feelL 3 eliminates tb9' containment line or degradation problem that 4 has specifically been discussed I know in a lot of detail <on 5 Mark I's. We feel the design enhances the core 1. debris.
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| 6 coolebility and provides that there's no path and we eliminato:
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| ? the suppression pool fission product bypsEs.
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| 8 I think the bottom line is given the design at this S point we feel that we don't expset to'have containment failure 10 through melt through.
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| 11 HR. CATTON:- How does it do that?
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| 12 MP. MILLER:
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| 3 The suppression pool itaelf 10
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| () 13 circugferential}y uround the dry well. .It also has e the 14 design also now includes what they c431 fusible plugs betwnen 15 the suppression p4ol and the_ dry well. At a tepperaturer_when 16 some tempotature is reached inside, the fusible plugs then 17 will melt and weter will flow in and cover the' melt.
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| 18 MR. CLTTON: Yorf re employing a great deal of i 19 knowledge about the physical processes that I don't think we 20 nave.
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| 21 MR. RUBENSTEIN: Well, the design has a fair surface 22 area in the lower dry roll to accommodate and hopefully spreed (
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| 23 out the degree. We'll have to look at this in some' detail.- !
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| 24 MR. CATTCN: We're not suro it will spread out. i j
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| i 25 MR. RUBENSTEIN: We:also, the'dosign also will flood -
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| HERITAGE REPORTING CORPORATION (202) 628-4388 L _ __
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| l
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| ,/ ~) 2e?
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| L- }
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| i 1 the lower dry well... j 2 MR. CATTON: It b me a dem or something.
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| I 3 MR. RUBENSTEIN: The pathway is there. There's a !
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| 4 fair amount of research going on. I agree with you that the 5 concluulone are not absolutely unambiguous. However, the 6 tentative conclusions are such that if you provide an 7 appropriate geometry, you provide a surface crea, and these 8 are sort of EPRI type guidelines which is en tne order of .02-9 square meters per mcgawatt, and you d:an't have a crust which 10 is beyond 20 cent!.aeters. And I agree, there's uncertainty in 1
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| 11 agreement on this. You havs an excellent chance of cooling, i 1
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| 1 12 the debris and containing the heat. l
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| (')N q 13 MR. CATTON: I would believe you if you said you l 14 were going to try. You said that it was going to happen. I'd i 15 like to see some pict.ures and maybe a little descript: ion of 16 thie if I could.
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| 17 MR. RUBENSTEIN: Sure.
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| 18 MR- CATTOM: Maybe I'm already supposed to have it.
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| 19 I don't know. <
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| 20 MR. MICHELSON: One containment issue that you did 21 not allude to here is the question of whether or not the guard 22 pipes on th6 safety 1elease valves need to be guarded, which 23 they have been in the past but are not proposed to be here. I 24 think there are a 'few operating plants now that do not have
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| ; 25 guard plates. But the question is, of course, the l
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| HERITAGE REPQtTING CORPORATION (202) 628-4888 i
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| t _ _ _ . _ _ _ _ _ _ _
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| 1 283 1 incredibility of one of these failing during a severe accident 2 or being the severe accident in some way. Has the staff 3 looked at this and is comfortable with the absence of guard 4 pipes on the relief valve tail pipes?
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| 5 MR. ARCHITZEL: Th&tfs an open issue we're pursuing 6 with GE.
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| 7 MR. MICHELSON: Okay. I'm not saying I believe.it's 8 a problem, but I just want to find ont wherB the staff finally 9 arrived.
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| 10 MR. SHEWMON: Roughly at what temperature do you 11 expect...
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| 12 MR. RUBENSTEIN: They tell us they're looking about 13 700 degrees fahrenheit on the fusible plugs.
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| 14 I see GE has now changed their mind and they're new 15 thinking 500? Jack, would you care to address it? The last 16 time we spoke it was about 700.
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| 17 MR. DUNCAN: Maybe there's a mind change, I'm not 18 sure. I thought it was 500. i 19 MR. RUBENSTEIN: My notes show 700.
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| 20 MR. KERR: So it's somewhere between 500 and 7007 l
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| 21 MR. MILLER: I'd like to move now to source term 22 discussion.
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| 23 For this class of plant the licensing basis will 24 continue to be 10 CFR 100 citing criteria which is associated 25 with source term, that being the traditional TID 14844 source HERITAGE REPORTING CORPORATION (202) 628-4888
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| 284 j 1 term.
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| l 2 In doing that, GE is assuming credit for certain 1
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| 3 design foatures which are under discussion with the staff.
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| 4 The staff currsntly has some of those aspects under review and l 5 we have not .made any final determination on that yet.
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| 6 MR. KERR: You're citing this plant by assuming you 7 get fission products in large quantities into the containment 8 with no melt on the ccre?
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| 9 HR. MILLER: Yea, that's true.
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| I 10 HR. CATTON: That's interesting. How do you do it?
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| 11 MR. MILLER: I think going back to the traditional l
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| 12 TID source terms, and it was just the sseumptions used for ths l - 13 instantaneous release.
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| l 14 MR. CATTON: So it's non physical.
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| I
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| ! 15 MR. MILLER: It's a conservative.
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| l l 16 MR, KERR: This is called being shackled by 17 tradi. tion .
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| 18 ME. WARD: I think this was an ACRS proposal. It i i
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| 19 comes on an ACRS letter. (Laughter) 20 MR. MILLER: With regard to the GA safety goal t a 21 more realistic source term is being ente.ctained. Again, to 22 state that the safety goal is a probability of an off-site' 23 does of greater than 25 REM beyond a half mile limit.
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| )
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| 1 24 MR. REMICK: The 211de says half a mile from the j
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| _ 25 reactor. Is that what it metns, or from the reactor site?
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| HERITAGE REPORTING CORPORATION (
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| g 285 1 The controlled accean there. I'm just curious.
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| 2 MR. MILLER: I believe it is from the reactor.
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| 3 MR. WARD: When.y>u say safety goals...
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| 4 MR. RUBENSTEIN:L Public. safety _ goals as prcposed by' 5 EPRI and industry.
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| 6 MR. WARD:. That's not the NRC safety goals.
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| 7 MR. . RUBi::NSTEIN: No. We believe this 'is :nuch''more B stringaut than the safety goal health objectives by maybe'.w 1
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| 9 order of magnitude, although I wouldn't want to.get pinned l 10 down.
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| -11 MR. WARD: It would seem to me it Would be .1 good
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| ;- 12 idea to make that clee.r.
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| l l
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| O 13 MR. RueE STEIN: we sueu1d ca11:st the guh11c safety 14 goal. In the jargon it means the industrial design goal. .
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| [ 15 MR. MILLER: General. Electric ~is committed to.
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| 16 provide a level three internal / external events PRA. As we've l 17 discussed earlier, the PCA is being refined to take into 18 account sone of the features that have been added to the I 19 design since the initial PRA was pe:-formed.
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| I 20 The external events portion of the PRA is on its i )
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| l 21 Way. The staff has not yet received'that so we have not yet l 22 begun our review on the external-portions of it.
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| q 23 MR. KERR: Have you, reviewed the internal portion? i q
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| 24 MR. MILLER: 'l The internal portion is-currently under -i 25 review.
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| O-V HERITAGE REPORTING (X)RPORATION (202) 628-4888
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| () 286 1 In addition, GE is going to provide reliability and 2 maintenance criteria to ensuro that the as-built design 3 described by the certified design is maintained. That's going 4 to be a rigorous task and it's something we're very anxious to 5 pursue farther with them.
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| 6 The application of the design, we want to be able to 7 ensure that it includes the key assumption commitments of the B PRA so we end up with a design plant that really reflects the 9 assumptions that were assumed in the PRA and are maintained 10 through the life of the plant.
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| 11 MR. SHEWMON: Very often, on at least older plants, 12 the balance of plant varied enough so it's tough to make one
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| () 13 PRA serve for both of them. Is the commitment here on balance 14 of plant to be deceribed in what you review or what you're 15 talking about? Or do you sort of pick a typical one and do 16 their PRA...
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| )
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| 17 MR. MILLER: 10 CFR 52 requires for evolutionary 18 plants to be essentially completely designed before they can 19 move forward, full scope design before we can move forward ;
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| 20 towards design certification. I i
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| 21 MR. SHEWMON: That's the only thing that would be j 1
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| 22 sold? '
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| 23 MR. MILLER: That's correct. Once the design j 24 certification has been promulgated as a rule, for that to be 25 sold it's a complete design, ,
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| i~ l HERITAGE REPCRTING CORPORATION (202) 628-4888
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| - . . =
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| 287 1 MR. MICHELSON: .Now your term essentially complete 2 design only means that it's essentially complete, process 3 design so to speak. Not detailed building layouts, detailed 4 cable tray routings, all the other kinds of details, as I 5 understand it. Maybe your definition of complete ~is different 6 than mine.
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| 7 MR. RUBENSTEIN: No,'no. We've had a fair amount of B discussion with the committee on that, paid careful attention 9 to the letter. We followed your discussion on procurement 10 specs. That's what it means. The rule speaks to this very 11 specifically.
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| 12 MR. MICHELSON: When you come to doing a FRA.you
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| () 13 have to begin to understand where the powers, which cWble 14 trays contain which cables so if you postulate a fire and do a 15 fire PRA you know what the consequences are. Is that. level'of 16 detail going to be available to the PRA analyst?. t 17 MR. RUBENSTEIN: I'd like to throw a general. answer.
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| 18 to my good friend for research, Jerry Wilson, who will. talk 19 about what the rule contains specifically and the intent. Wo 20 haven't seen that kind of level of detail. Perhaps GE can 21 elaborate on that.
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| 22 MR WILSON: In Part 52 we stated that the detailed 23 information needs to be provided or essentially complete.
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| 24 It's that information necessary to prepare _ procurement specs.
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| 25 But we didn't actually require the submittal procurement and-O HERITAGE REPORTING CORPORATION (202) 628-4888
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| l 1
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| 288 1 construction and installation specifications.-
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| l 2 FR. MICHELSON: That I think I will understand, but 3 of course that's not what you need necessarily to do the -fire-4 PRA. You need a lot more information than that.
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| 5 MR. RUBENSTEIN: The second half, General Electric 6 may be able to give some light.
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| 7 MR. DUNCAN: 3 peaking generally, sometimes when 8 we're doing a PRA we find the design is not as-evolved as we'd' 9 like. When that happens we make an assumption with the l
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| 10 expectation'of how the design will come about,. and that will 0 1
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| 11 be one of the items I think a couple of charts back that:are 12 assumptions, and they essentially will become commitments.
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| l O 13 MR. MICHELSON: I would expect to find those i 14 explicitly stated in the PRA then when you have to make such 15 assumptions. -!
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| 16 MR. DUNCAN: That's right. ;
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| 17 MR. MICHELSON: I'll watch for them.
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| 18 MR. WARD: Could I ask a parallel' question to Dr. -(
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| 19 Shewmon's original about the maintenance criteria. General l 20 Electric is going to provide you say reliability maintenance ~ d 21 criteria. Will that be for the entire plant including the 22 balance of plant and the generator system and everything? Or 23 is that just for the balance of plant? l i'
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| 24 MR. MILLER: We haven't seen it=yet,"but.my 25 . anticipation is we're going to want it for the balance of i
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| HERITAGE REPORTING CORPORATION l (202) 628-4888 .)
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| 1
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| 5 tp 283 1 plant also since that's included in the scope.
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| 2 MR. RUBENSTEiN: This is an extremely difficult 3 subject. NUMARC has a subcommittee which has triad to address 4 how are we going to assure the reliability we said we had at 5 the review time throughout the life of the plant, General.
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| 6 Electric, because'of the urgency of their sch9dule, has 7 informed us that they're wrestling with it individually. . It's, 8 really tough, and us can't give yco that answer right now in .
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| 9 specifics. But it's a design requirement and a review 10 requirement that we've asked them to address.
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| 11 Any insight from the committee on how this could be 12 achieved would be certainly desir&ble. I':m sure they would 13 love it.
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| 14 MR. MILLER: I'd like to make a remark or two 15 concerning BWR thermal-hydraulic stability. ThisLyou will 16 remember- is an outcry of the LaSalle event..
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| 17 The ABWR has included in its design some factures 18 that basically will preclude this from heppening. They're 19 going to avoid plant operation in the region of least 20 stability. Selected control rod run-in initiat3d upon trip of 21 at least two reactor internal' pumps is included. There art 22 several other features that % can oursue if you're interested, 23 or can be pursued farther with the subcommittee.
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| 24 Basically we feel ths design eliminates the need for 25
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| .. operation action anci reduces the potentini for exceeding fuel E5EITAGE REPORTING CORTOFATION (202) 628-4888 4
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| O 290 1 damage limits.
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| 2 MR. KERR: Even in er.isting reactors it seems to me 3 that the only concern one has about severe accidents is in 4 case of an ATWS. Does this design preclude oscillatory 5 behavior in case of an ATWS7 6 MR. RUBENSTEIN: I think oscillatory behavior is an 7 inherent feature of the core design of a BWR.
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| 8 MR. KERR: I do too.
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| 9 MR. RUBENSTEIN: I think in terms of an ATWS, I can 10 only make a general statement. I believe it would be 11 mitigated with our ability to accommodate the decay heat 12 removal.
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| 13 MR. KERR: If the evidence we have seen from other 14 segments of the NRC staff is an indication of the staff's 15 present knowledge, I would say one would have difficulty 16 demonstrating that with a great deal of confidence.
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| 17 HR. RUBENSTEIN: 1 would agree. I've only recently 18 heard anecdotally that EPRI believes they have a code which 19 can deal with the instability issue. I, of course, over a 20 number of years had one at Oak Ridge and dealt with General 21 Electric on this, and it remains to b6 seen if the code can 22 predict these things. They say their code can now predict the 23 LaSalle event. I have no opinion on it.
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| 24 MR. WARD: That's on our agenda. In an hour we're 25 going to be hearing about that. From what we've heard HERITAGE REFORTING CORPORATION (202) 628-4888
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| l () 291 1 previously, I think the subcommittee might be a little bit at 2 odds with it.
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| 3 MR. RUBENSTEIN: That was their claim. I have no 4 first hand knowledge.
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| 5 MR. REMICK: Before leaving that, let's go to.the 6 SLC system and the case of ATWS. Let'r say hypothesize that 7 there was an ATWS and you tripped the recirc pumps'and 8 therefore you did get into an area of instability. Is the SLC' 9 system, if it was injected automatically fast enough to stop:
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| 10 the oscillation? Have people . looked at that? Or even if it 11 was manually injected. If you can't get rods in to stop the 12 oscillation...
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| (} 13 MR. RUBENSTEIN: I don't know if we looked at that 14 or not.
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| 15 MR. KERR: Do you mean fast enough to stop it or to 16 prevent it?
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| 17 MR. REMICK: To control it.
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| 18 MR. KERR: Because all you have to do is make.the H l
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| 19 reactor sub-critical and that takes care of it.
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| 20 MR. REMICK: Yeah, but in ATWS of course you can't 21 because with rods, so the question is...
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| 22 MR. KERR: But the SLC system if it works will make 23 the reactor sub-critical. -!
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| 24 MR. REMICK: But how soon? Is it possible that you 25 have enough oscillation before you get... l
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| (
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| .r.
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| (:) 292 1 MR. MICHELSON: If the' operator waited too long and 2 it started oscillating, now...
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| 3 MR. KERR: This is the reason I asked him will it 4 stop it or will it prevent it. I think the answer is 5 unquestionably yes,.it will stop it. The question is how g 6 soon.
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| 7 MR. MICHELSON: How soon does it stop it once....
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| 8 MR. KERR: Once the reactor becomes sub-critical.
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| 9 (Laughter) 10 MR. MICHELSON: That's a pretty slow system.
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| 1 11 MR. RUBENSTEIN: There are two ways you can get out d 1
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| 12 of the critical region. You can get out of there through1 flow
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| (} 13 and rods in, coming down the rod block line. You're up there.
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| 14 in that 70 percent region and I think you'd have to take both ]
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| 15 into account. .j 16 MR. REMICK: Chances are in ATWS you wouldn't'want l
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| 17 to restart the circ pumps, presumably.
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| .i 18 MR. RUBENSTEIN: That's right. I would prefer-you .!
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| 19 wait for the experts. !
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| 20 MR. REMICK: Okay. It just seems to me that would 21 enter into this discussion of automatic versus manual :
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| 22 injection of SLC.
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| : 23. MR. WARD: Particularly when you make the. statement j i
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| 24 that the design eliminates the need for operator action and i 25 reduces the potential for. exceeding. It seems to me with the
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| HERITAGE REPORTING CORPORATION '
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| (202) 628-4888
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| O 293 1 present state of' knowledge, of understanding of the 2 oscillations, it's not clear to me that' statement can be made.
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| 3 so positively. I guess'I'm repeating myself.
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| 4 MR. RUBENSTEIN: We were very careful.to say reduces 5 as opposed to precludes.
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| 6 MR. WARD: It says eliminate, yeah. Okay.
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| 7 MR. MILLER: I wanted to move'on to the conclusions 8 that we've made at this time. First of all,'GE and the. staff 9 are in general agreement with the approach to severe accident 10 concerns. The staff believes that its review will confirm the 11 effectiveness of these features in addressing severe accident-12 goals as defined in 10 CFR 52, and in the commission's policy 13 papers. And if the effectiveness is confirmed, severe 14 accident clorure will be achieved for the ABWR. The staff 15
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| ~
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| will inform the commission, and I should also say the 16 committee, in a timely manner if additional requirements are 17 found to be necessary during the course of our. review.
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| 18 That concludes my prepared remarks, Mr. Chairman.
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| 19 MR. REMICK: I have a question that's not related to 20 what we just discussed, but just to remind me. Has there.been.
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| 21 a schedule established yet by GE on design certification? Has 22 there been a specific...
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| 23 MR. MILLER: Yes sir, l
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| 24 MR. REMICK: Do you remember what it was?
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| 25 MR. MILLER: We are generally proceeding on a HERITAGE REPORTING CORPORATION (202) 628-4888
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| d
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| '294-
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| 'l schedule to anticipate on starting the' design certification 2 hearings a111ttle over a year from now. ~
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| The current schedule:
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| 3- allows for about 14 months for the hearing l process to take 4 . place.- The targeted goal is to. proceed towards design 5 certification in about October of 1991.
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| 6 MR.'MICHELSON: That schedule'is probably already 7 slipping.some, isn't it, since'we haven't^seen:the FCR on the 8 first module'yet.
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| 9 MR. SCALLETTI: The FCR on the first module has 10 slipped, as you're well aware. There is no; intention, 11 however, of slipping the...
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| 12 MR. MICHELSON: You're going.to play. catch-up on the-13 rest of them?
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| 14 MR. SCALLETTI: I'll play catch-up, yes.
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| 15 MR. SIESS: So all the components:that go into the 16 rulemaking you expect to be in place a year.from'now?
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| 17 MR. MILLER: ' Yes. sir. I 18 MR. RUBENSTEIN: For the ABWR plant specific. I 19 MR. MICHELSON: Does General Electric have a j 20 presentation at all? You were given until 10:30.
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| i 21 MR. MILLER: That's correct. I guess'at this point
| |
| ]
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| 22 we're willing to entertain any remarks or questions.~ j 23 l MR. MICHELSON: We're quite a bit ahead of. schedule, 24 but that's fine.
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| .g i
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| 25 MR. BUBENSTEIN: I guess in summary, we'would ask-HERITAGE REPORTING CORPORATIOtt (202) 628-4888
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| * 295 1
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| 1 you to consider any comments you may want to.make to the i
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| 2 commission. We're going'to present essentially the same d l
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| 3 information to them'on the 20th.
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| 4' MR. MICHELSON: I don't think we'd anticipated.
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| 5 writing any kind of letter on this at this time.
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| 6 MR. RUBENSTEIN: That's-your option.
| |
| 7 MR. KERR: Mr.fChairman, it's my understanding that >
| |
| 8 Mr. Rubenstein is retiring'from the NRC shortly, s.o this may 1 9 be the last time we see him. I for one would like to express 10 my appreciation for the. interactions I've had with him over '
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| i 11 the years, and tus wish him well. I 12 MR. REMICK: We all join.you in that.
| |
| O 13 MR. RUBENSTEIN: That's very kind of you, and I i
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| 14 thank you very much. l 15 MR. REMICK: You'll miss us certainly, won't you? j 16 (Laughter) 17 MR. RUBENSTEIN: I've learned a lot here.
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| 18 (Laughter) 3 19 MR. WARD: Are you going into the diplomatic service 20 now? !
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| l 21 MR. REMICK: Any other comments by the committee to '
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| 22 the staff or anything on this matter?
| |
| 23 (No response) 24 MR. REMICK: I suggest we take an early 15 minute 25 break and come back. One letter'we can start considering, HERITAGE REPORTING CORPORATION (202) 628-4888 I
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| _____m___--
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| | |
| 1 O- 296 I 1 because I think our next item-requires staff and owners. group, 2 so I think we have a letter on the joint responsibility of 3 ACRS and ACNW that should be ready. Are there any other' L 4 letters? Bill, is your letter ready?
| |
| 5 MR. KERR: It's ready for further consideration,.
| |
| 6 yes.
| |
| 7 MR. REMICK: All right. So let's return at_10:00' 8 a.m. and take up one or so of those letters until our next 9 scheduled discussion on the LaSalle station oscillations..
| |
| 10 (Whereupon, a brief recess was taken.)
| |
| 11 MR. REMICK: Shall we get back to the agenda? We'll 12 now hear about the LaSalle ' Station Unit 2. . .
| |
| 13 MR. WARD: Thank you, Mr. Chairman. I'll try to get 14 us back on schedule by not taking much time for an 15 introduction.
| |
| 16 Most of you are familiar with the fact that a little 17 over a year ago there was an event at LaSalle Unit 2 which 18 involved the core power operation. As understanding- of this I
| |
| 19 unfolded, I think from the. safety standpoint it became a -)
| |
| 20 little more interesting than perhaps the initial impression.-
| |
| i 21 We held a subcommittee meeting on May 23rd to hear 22 presentations from the owners group, BWR owners group'vhich ;
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| i 23 described their program for dealing with this sort of l 24 situation, and with what's-somewhat of a'new issue, and in 25 particular for dealing with the recommendations.the staff had HERITAGE REPORTING CORPORATION (202) 628-4888
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| 1 developed in a generic letter and' supplement to the generic i l
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| 2 letter. j i
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| 3 I think I'll just go now to the presentation. The .l 4 commission has asked that the ACRS, if it bas something to say i 1
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| 5 to comment on this in a letter. And I do propose, the 6 subcommittee thought'it would be appropriate for the committee .I 7 to write a letter. So we will anticipate doing that tomorrow 8 after you hear this presentation.
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| 9 Bill Kerr, do you have anything you'd like to say 10 before we go to the presenters?
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| 11 MR. KERR: No. j 12 MR. WARD: I think our first presentation then, and 13 we are back on schedule, is going to be Mr. Rausch, a 14 representative of BWR owners group, 15 MR. RAUSCH: Before I begin, just one clarification.
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| 16 We were here in December, and that was when the bulletin 17 supplement 1 issuance was imminent, and we had had a few '
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| 18 meetings with the NRC staff, so our presentation we gave to 19 the thermal-hydraulics and core performance subcommittee two ;
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| 20 weeks ago was an update from that point in time. Today I'll l 21 be doing the same, only much briefer, 22 We envision our purpose as primarily to update you 1
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| 1 23 on our activities associated with stability; give a status 24 report on the development of long term corroctive actions, 25 also called the long term solution; and just briefly discuss O HERITAGE REPORTING CORPORATION (202) 628-4888 I
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| () 298 1 some NRC-suggested activities, some topics that are.assodiated 2 with a wide range of stability issues. Also discussing a 3 letter from the NRC on March 22nd..
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| 4 The disclaimer on the~ bottom is just a standard-5 piece of protocol to recognize that the owners group has to 6 have conseneus for written opinions. This is not a written 7 opinion.
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| 8 Our agenda, we'll just briefly, a brief 9 introduction, results to date, spend most of our time on the 10 long term corrective action status and then a~1ittle bit on 11 the letter to the owners group which we'll also be talking 12 about ATWS-related issues.
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| () 13 This is a quick overview of what our major programs 14 have been up until now. There's another one going on now that 15 I'll talk about associated with long term actions.
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| 16 We had a program called Phase I which was to 17 investigate plant responses to regional instabilities. There 18 are three types of instability that we're interested in.
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| 19 There's a core-wide phenomena, also called end phase where the 20 entire reactor pretty much.goes up and down in phase.. The 21 flux would oscillate in phase throughout, radially, and act 22 with some normal axial time lag. Then there's a regional 23 instability where the easiest way to think of it is'while one 24 part of the reactor is going-up in power the other side is 25 going down in power. The reason for the. specification was i O -
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| HERITAGE REPORTING CORPORATION (202) 628-4888 '
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| l 299-1 because that type of instability can' decrease the sensitivity 1
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| 2 of some of your nuclear instrumentation. .Then ther?'s. legal'
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| '3 instabilities which are more or less postulated that would be.
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| 4 a pure thermal-hydrsulic instability of a single' channel.
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| 5 The objective of this program was t6 identify 6 appropriate remedial actions, and that's been done.
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| 7 We had another' study which was to.look at large-8 amplitude oscillations postulated that may happen-during an 9 ATWS and see what happens to the average power response.
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| 10 We haa a number of other activities asGociated with 11 reviewing the work we've done. We did an extensive peer 12 review. EPRI formally got involved vith the work to' lend
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| () 13 more technical support to the. topic 4 that were being addreseed 14 for the first time.
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| 15 We've been provided substantial guidance on the-16 interim actions through my stability committee to the 17 utilities in terms of what type of things to look out for, 18 what recommendations in terms of what procedures should look 19 like in complying with the bulletins.
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| 20 We've been gathering worldwide data to better I 21 understand what has happened in other. BWR's. outside this 22 country. Of course a major effort has been identifying viable 23 long term solutions.
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| 24 -In the handout, I won't go through them now, but I 25 have a brief summary of a chronology of things that have O HERITAGE RKPORTING CORPORATION (202) 628-4888
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| j 1 happened since back in November when we first Sound out tne ]
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| 2 results of-the Phase I study which showed that there were come j l 3 concerns in regional oscillations,-the margins weren't as good 4 as we thdoght. Essentially it's been a non-stop series ef _-
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| 5 meetings, several meetings per month. Working with the NRC, 'l 3 6 working among ourselires, getting funding, splittingfinto
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| -j 7 several subcommittees to work on a lot of iesues at 6nce, -
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| i 8 It's besn hectic, l 9 I have a short summary of what the Phase'I results <
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| l 10 were. I've already hinted at.a little bit'of it. The Phase I. l 11 study was an engineering scoping analysis.- It was not 12 intended to be a lice.nsing" grade analysis.
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| 13 To evaluate thermal margin, is this case MCPR- ) 4 14 associhted with regional oscillations.
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| 15 We used TRACC which.iB the General Electric tersion i j
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| 16 cf TRAQ. Dreve the power response based!on empirical model' d
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| 17 which was largely based on -- regional oscillation event. And 1 i
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| 18 let TRACG solve tbs thermal-hydraulics, and lookLat the :
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| l 19 associated margin dynamically. -
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| 20 We studied individual channels and the neutron l 21 monitoring system response.
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| 22 c Our ~onclusions were that there was a potential for i 23 a safety limit violation under some conditions. Somewhat j 24 unusual conditions. Nothing we've seen.- We've seen ne events 1
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| 25 like this. Also, on the good side, we noted that there was .!
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| : l. HERITAGE REPORTING CORPORATION (202) 628-4888 L I 1
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| 1 1 substantial' instrumentation ~ responses.'available before ar 2' safetyElimit would be. reached 4 These results were used to "
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| 3 support the interim corrective actions:that the. owners group- 4 i
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| 4 proposed and had taken . st ops to put 'in place ' prior to is'suance I 1
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| 5 of the bulletin. The bulletin more or less, reinforced all the 6- commitments the owners were hiready making on their'own,'and-7 added a few claz.ification requiremehtsf and another:
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| 8 requirement for n certain claiss of plants to manually 7 SCRAM.onf 9 two pump trips.
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| 10 MR. CATTON: What does potential for' safety limits 11 violation moan?
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| 12 MR. RAUSCH: It means that'under the.right~cora 13 conditions acci postulated regional oscillation-of a rather 14 large magnitude, and no operator response- to SCRAM the unit on l 15 a very high power density plant,-the result is it is possible-16 to, via the hydgoctynamics of ths situation, to roduce the 17 marcin in MCPR down to the safety limit temporarily. It would 16 be a temporary dry out and rewet phenomena. What we locked 19 at, we wouldn't expect fuel -- but it was'still a vi61ation of 20 the safety limit, unless, if you Were to postulate.them going 21 that large.
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| 22 MR. CATTON: So even with these very large 23 violations you would not have cladding perforation?
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| 24 MR. RAUSCH: I wouldn't call.it a large violation.
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| 25 Large oscillations. Rather lirge oscillations. There is no BERITAjE REPORTING CORPORATIOtt G02) 628-4888 b __ _____ - . _ _ _ ___ - _ - - - - - - - - - - - - - - --
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| , 7my
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| '302
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| . ,l l' definitive study of it, its don't nxpect it before the ' level j j
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| ~2- of magnitude we looked.ats Although there would be' sone- l
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| '3 level...
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| 4 ~ MR . CATTON:- Simply becaus6 you're not dried'out 5 long enough. 1 l
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| 6 MR. RAUSCH ' Thai' !!: right. 'So.there is'an extra 7 margin built in there.
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| 8 MR. SEEWMON: -- is a criteria'for' fuel. failure,; q 9 melting of the clad, cr What? ,
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| 10 MR. REUSCH: Th6 next 1 1svel us'll pr#bably hAve to il .look st soaething like that.
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| 12 MR. SHEWMOM:. You said these oscillations worn not.
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| 1 13 enough to ususe fuel' damage. .I- wonde N}Q whgt your basis; for
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| [
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| 14 that was.
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| 15 MR. RAUSCH: The oscillations we lookod'at,~there-16 was relatively miid clad rise, teppbrature rises. .' Mild 17 compared with several other transi&nts that also don't expect 28 anything.
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| 19 MR. CATTON: bo you de something diffarent with TRAC 20 to handle the oscillatory flow and he3titrensfer?- 6r do,you' 1,
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| 21 just assume what's in there is okay?
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| 22 MR. RAUSCH: I believe the mod.91s were developed to 23 he oble to hand?.e this kind of situation, Do nothing was 24 changed.
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| 25 MR. CATTON: So.you've made some major modifications HERITAGE REPORTING CORPORATION (202) 628-4S8B
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| 1 to track that?
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| 2 MR. RAUSCH: No. I said nothing was changed.
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| 3 MR.-CATTON: If nothing was changed, then you're not l
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| 4 sure of the heat transfar.
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| 5 MR..RAUSCH: TRACG. GE's version-of TRAC.
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| 6 ER. CATTON: 7 don't think it was modidied, though, 7 to handle oscillatory flows. It was modified to handle otheri l
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| 8 things. ,
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| J 9 MR.'RAUSCH2 This is rather low frequency, also.
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| 10 It's not, nothing extreme in terms of getting into sonic...
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| 11 1m. CATTON: Still froc what I understand it uses i 12 drift flux mede3ing, and I'm nct'sure that drift flux modeling 0j, J
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| 13 is any good when you have oscillatory f16w. I 14 MR. RAUSCH: We had some pretty interesting j t
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| 15 discussion in the subecmmittaa about the adequacy-of this l l
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| 16 analysis. We don't have as much time here to do that, but 1 j 17 wp21d like to point out that all this analysis did, was 18 intended to doe was look at the instrumentation response and i 19 see there we were. Did we have excellent response in i
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| .20 automatic protection before we believed we.were 2ven- '
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| 21 approaching the safety limit, and the answer was yes under 22 most donditions, but some conditions we didn't so we hav. to do '
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| 23 something. Th&t's where We are now. We r re having:to do 24 something. We aren't trying to defend our otudy other than-25 show there was a problem.
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| I [)
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| v HERITAGE REPORTING CORPORATION (202) 628-4688 '
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| 304 F
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| 1 MR. CATTON: Okay.
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| 2 MR. RAUSCH: Phase IA results, we're algo using.
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| 3 TRACG. It was again a scoping analysis to evaluate impact of 4 large amplitude oscillations on average roactor power.
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| 5 Essentially used LaEsile event 4onditions with a 6 somewhat generic BWR 5 base deck for the. hydraulics and the 7 vessel model. A"d sinall, on its own track. This was a repeat j 8 of what we sai An Decenber. Small magnitude oscillations 9 wegc predicted on its c'ni without any screw drivering or i 10 changing of any of ths input p&rameters under natural 11 circulation conditions. Then to facilitate getting large 12 ataplitude oscillations during the fairly high reactivity part
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| () 13 of the cycle was mid' cycle. All control rods were withdrawn 14 and the oscillation magnitude did go up.
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| 1 15 The study of the average core power showed a slight 16 increase, less than seven percent. The inlet flow and 17 subcooli$g were allowed to sustain this incisase by the way 18 the model was set up. Free water flow was allowed to change. 'l 19 Henk Pfefferlen of GE will be discussing this in a little more 20 depth in terms of ATWS, ATWS questiens the NRC has asked us.
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| 21 I just wanted to point evt during the ATWS events 22 today, that is not a valid assumption. The water flow would 23 be constrained, which does tend to constrain power.
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| 24 We reached oscillation magnitudea of approximately 25 100 percent with all control rods withdrawn, and a study
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| HERITAGE BEFORTING CORPOR7hTION (202) 628-4888
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| 305 1 reducing the level with those oscillations did not show an 2 increase in the magnitude of the oscillations. It's not a 3 number of sensitivities or anything, it's just a study mainly 4 to look at the power response.
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| 5 Your handouts, when you get them, will also have a 6 few pages diccussir.g what some of the subcommittees, we at one 7 time had four subcommittees and now we have approximately one 8 or two. We're still reorganizing because a lot of the initial 9 work has boen completed zn terms of like operating reviews and 10 gathering data. I'm not going to go through those.
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| 11 L little bit on the long term solution subcommittee, 12 the main thing I wanted to point is that's been our main 13 effort. The people we have involved and the urgency of the 14 issue from the owners group standpdint is to resolve the 13 operating significance of our findings, one phase one study, 16 and the questions associated with regional oscillations.
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| 17 Along that line we have been working on a wide range of 18 potential solutions consistent with what the stability 19 committee would like to .see in terms of addressing all 20 different plant types. Logical things like being something we 21 could livra with and still meet cur goals of resolving the 22 issues. '
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| 23 We've had detailed consultations with major ver, dors ,
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| 24 and consulting firms including ABB-ATOM and KWU and AdvancOd l l
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| 25 Nuclear Fuels. Obviously also GE. We've worked up work l HERITAGE PEJORTING CORPORATION (202) 628-4888
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| i 306 l
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| 1 secpes and estiinated resources to establish feasibility of ;
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| 2 p solution o'hions. I'll talk about that scheduln and what 3 we're doing in a little bit. f 4 We have estimates of what hardware coats and 5 development-costs associated with those. We d.iacussed some ol' L 6 this with the NRC April Cthe Again, nith the subcocaittee twoz L
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| g 7 wetisks ago. We hava a plan for defining final. solutions.and 8 it's in place right now.
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| 9 Just a quick status of where we are again, before I 10 go into the long term solutions. {
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| d 11 Interits corrective actions are in place at all 12 domestic BWR's. They're essociated both with the owners grpup O 13 and on their own in Bulletin 8807, Supplement 1. l 14 MR. CARROLL: What's happened overseas in this 15 regard? I 16 MR. RAUSCH: A varying number of things. I don't i
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| 17 think any regulatory authority has done anything major that '
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| 18 I'm aware of right now similar to the bulletin, although they ]
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| 19 may have. We've talked more with the vendors. I've talked to I 00 a few of the utilities and what they're planning. In Germany, i
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| 21 for example, they're looking along the same lines we are, i 22 types of fixes that could go in, t
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| 23 There's a difference in sev9ral countries in that ,
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| 24 they've-done a great deal of testing and= monitoring. There
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| ?.5 are relatively straight forward devices that could be put on U
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| HERITAGE REPORTING CORPORATION (202) 628-4888 ;
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| i 307 1 computero that could monitor the decay ratio of a reactor, 2 measure of performance and stability on-line. !
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| i 3 MR. CARROLL: These are things that they've done?.
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| ]
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| 4 MR. RAUSCH: They have them in place already. l 5 MR. CARROLL; Prior to the LaSalle' event, l
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| 6 MR. RAUSCH: They have a different-philosophy there. J
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| ~
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| l 7 in terms of just trying to map out where they might cee these. j 8 things and actually testing either at the end cycle'and i 9 sometimes periodically to see what they look like. .They've .
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| 10 allowed them to go on, including regional oscillations. l 11 The philosophy here was more in terms'that we hadn't' I 12 really expected them and we probably wouldn't, even-if we were
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| () 13 testing for them we probably wouldn't want them'to go to the 14 kind of magnitudes they've dan 9 in Europe. Therg's been no )
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| )
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| 15 problems with those. l l
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| 16 MR. WARD: I think you told us at the subsse.nittee 17 meeting that the Swedish design has someLcharacteristic to ;
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| 18 make it really apparently more stable. -j 19 MR. RAUSCH: .The Swedish reactors are inherently 20 more stable, but they.can be driven unstable-and they have 21 been. They are inherently more stable because they have a l 22 higher single phase pr4ssure drop. They have tighter ,
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| 23 orificing, coinpletely different lower internals. Internal 24 recirculation pumps. It's quite a bit different. But the two 25 phase versus one phase phenomena in the neutranic toedback,-
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| O HERITAGE REPORTING CORPORATION (202) 628-4888
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| t 308 1 the same thing applies, but different conditions for them to 2 have an instability.
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| 3 The corrective actions in place now are more 4 conservative than the base dccumerat that was being used prior 5 to the LaSalle event which was a General Electric service {
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| 6 information letter. -
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| l 7 We've had additional requirements, I mentioned the l 8 SCRAM on two pump trips. There has been greatly enhanced 9 training and operator awareness associnted with the ovent and il 10 the two bulletins, or the bulletin and the supplement. l 11 An instability event is very unlikely with the 12 recommendations in place. The probability of a thermal limits j 13 violation is even less likely. The areas being excluded via l 14 the interim corrective actions is larger than the region of l
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| 15 occurrences that we know of. l l
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| 16 Just a little word on the bottom, we probably 17 reduced the likelihood of a thermal limits violation
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| )
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| 18 associated with an instability, just our opinion, is probably. j 19 below the likelihood of that associated with other events.
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| 20 MR. CARROLL: Earlier you used safety limit 21 violation. Are these synonymous? i 22 MR. RAUSCH: Same thing.
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| 23 MR. CARROLL: Okay.
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| 24 MR. RAUSCH: As I mentioned a little bit about this, 25 our objectives are to close out stability as a plant HERITAGE REPORTING CORPORATION (202) 628-4888
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| l O '309 l
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| 1 operational issue. Simultaneourtly minimizing' impact on plant 2 operation and recognizing plant differences in providing-some 3 flexibility. We are going down a path of saying one vendor' 4 has one product, one type oi' way of doing this. .There-are 5 several ways of looking at-the issue.
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| 6 MR. SHEWMON: What different issues are'there in the-7 U.S. in BWR's? _
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| 8 MR. RAUSCH: There's advanced' nuclear fuels, ANF.
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| 9 MR. SHEWMCN: So the...
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| 10 MR. RAUSCH: And ABB-ATOM was trying tti get into the 11 market.
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| 12 MR. SHEWMON: To some extent the design...
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| 13 MR. RAUSCH: Certainly. The reason it's associated 14 with that is the reload design characteristics provida-encygh 1 i 15 of a change that stability modeling in the past was done in !
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| 16 recycle. It was looked at as recycle. That's true today.
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| 17 Although I think in terms of solving the problem, tb ; hardwsre 18 and its inter-relationship with all the plant systems, General l 19 Electric's involvement.is obviously essential. We've 20 recognized that.
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| 21 Depending on your interest, this is where I planned 3
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| 22 to spend most of my time. j 23 This slide contains a brief summary of what all. '
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| 24 types of solutions we're pursuing right now. The easiest way <
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| 25 to think of them is first of all, that they all have automatic HERITAGE REPORTING CORPORATION (202) 628-4888
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| 310 1 ' protection associated with tlem. That'was one of the central 2 issues I think we've discussed with the NRC. We've come to an- :l 3 agreement that that's really: appropriate. Keeping in' mind'
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| 'i 4 that there is~a varying degree of automatic, protection already.
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| 5 in the plants.today, and that some degree'of'.thst-as is may be 6 found to be sufficient, although that would take significant-'
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| 7 analysis.
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| 8 Mith that-in mind, the basic philosophies are 9 prevention or mitigation. You can still prevent an 10 instability via sophisticated calculation, and modifying I 11 allowable power flow mat space. I'll illustrate that a.little' 1
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| 12 bit if you' d like.
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| 12 Or you can mitigate based on a; couple.of different' ,
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| 14 instrumentation responses. The average range monitor response 15 which again has a d$1uted response-to a. regional instability 16 because while one-half-the core is going up the other half is
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| ]
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| 17 going down in flux. A lot higher level fluxes,.there is 18 nowhere near perfect cancellation because instabilities ~'are i i
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| 19 non-linear versus time. Fluk versus time tends to go.up more, 20 a spike function. Whereas the trough still approximates a l 21 sine. -l 22 There could be mitigation based on LPRM response. ;
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| 23 That'a probably the most elegant solution we're'looking at ,
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| 24 -right now.- It-has extremely high likelihood of success no ,
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| 7 25 matter wh6t you possibly, in the liinit. What this_would do is O HERITAGE RKPORTING CORPORATION (202) 628-4888 I' __ _ __ __i
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| 311 1 have a large number of LPRM's, local power range monitors, 2 connected to a trip system with enough logic to look for an 3 instability at various numbers, places in the reactor, and 4 trip the reactor perhaps on two coincident cycles of an 5 oscillation. You could easily protect any type of oscillation 6 in this mode.
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| 7 MR. WARD: How many changes are there?
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| 8 MR. RAUSCH: It varies widely with plant size. In 9 the LaSalle case it's 43 times 4, so 172. Forty-three 10 strings, four axial heights, -- quantitiee, 164. Some' smaller 11 plants I believe as low as 23 strings.
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| 12 MR. WARD: It is the flexibility and instrumentation 13 for almost any logic?
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| 14 MR. RAUSCH; We've identified an clmost infinite 15 number of ways of doing it. Associated with the LPRM solution 16 we have two types of approaches we're looking at. Yes, there 17 is flexibility. We think something on the order of 40 18 protectors disbursed throughout the reactor would be more than 19 sufficient. There are studies geing on now to show what type 20 of response they would get.under a limiting oscillation.
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| 21 One of the solutions uses an intelligent device, a 22 NUMAC type device. It's the GE name for it. It doesn't have ,
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| {
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| 23 to be a GE device. It's basically a micro-processor 1E 24 approved device that could look in parallel to the LPRM's 25 without really, monitor it without really changing its ,
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| 4 HERITAGE REPORTING CORPORATION (202) 628-4888
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| 312 l
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| 1 functions.
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| 2 The other LPRM aclution we're considering would be 1
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| 3 to taodify the existing amplifier cards and put in a less f
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| I
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| ' {
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| 4 sophisticated trip system. That's cheaper in hardware. That ]
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| 5 may be more expensive in terms of loss of flexibility and l 6 potential for inadvertent SCRAMS.
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| 7 1'11 go into these exclusionaries a little bit in a l 8 minute. But if you use an average range power monitor l 9 detector, we realize that would take analysis to establish, 10 siniilar to Phase I analysis, to establish what level of I
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| 11 response is sufficient to prevent concerns about violating 12 thermal limits, the MCPR safety limit.
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| 13 What's particularly intriguing about that is for 14 some plant classes, the lower power density plant classes and 15 those who a_ ready have flow by SCRAM protection, that is SCRAM 16 line when the ARPMs comes down to a low level versus power.
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| 17 There are some things we could consider such as improving the IS sensitivity, that is like looking at an oscillation detector 19 where instead of looking at just the flat magnitude of the 20 average power range, look for its peak to peak range itself l 21 which we think would also be a viable solution. The problems 22 associated with it are analytical. It's harci to hone in en 23 what is the limiting three dimensional oscillation, regional j 24 oscillation. It's very difficult.
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| 2S The other plant class that probably is easilv HERITAGE REPORTING CORPORATION (202) 62G-4888 ,
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| i O 313 j
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| 1 sufficient is the BWR II's, this' type of response. Their 2 average power range detectors are not disbursed throughout the 3 reactor. They're in a quadrant system already. So it's hard l
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| 4 to imagine any significant degree of cancellation of'that type 5 of system.
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| 6 The exclusion options, let me just show you1a little !
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| power flow map. I chose this map because it's power versus 8 flow. It's nicely illustrative. These are known stability 9 events on GE reactor types. This is the area.being excluded 10 in the bulletin right now, and this is the area where only 11 controlled entry under certain conditions is allowed via the l 12 bulletin.
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| 13 What we've been talking about doing is something 14 basically, just envision, one example would be this outline 15 here, this parallelogram. If you were to put hardware-in that 4 16 were to SCRAM automatically whenever you entered that region 17 and then you backed.that up with sufficient analysis to show 18 tnat under reasonably extreme or limiting conditions i 19 throughout the cycle decay ratios would not be expected along 20 with uncertainties, allowing an instability outside of this 21 region. That's a rather simple hardware fix compared to the i
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| 22 LPRM solution.
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| 23 Analytically it's not that difficult. We think the- l 24 models are available today. Frequency demand type codes.to 25 calculate those decay ratios.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| (~
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| ( 314 1 The problem with it is you loso a lot of operating 2 flexibility and inadvertently it's not that difficult to find 3 yourself down here during rapid power reductions. So you 4 could be, that's a major detriment.
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| 5 But we wanted to see what this looked like. Maybe C the shape of this region could be something like this. Maybe 7 it's for lower power to some plants it's a very small region l
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| 1 8 of concern. Those studies are also underway now.
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| 9 MR. SHEWMON: You say it's a region of concern. I 10 realize if you go into oscillation it sort of gives you a 11 black eye because it suggests you don't know how to operate 12 the plant. But in terius of risk to the public or to the
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| () 13 plant, what does it do? What's the basis of concern?
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| 14 MR. RAUSCH: It's a matter of opinion at this point.,
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| 15 It's not highly analytically answered.
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| 16 MR. SHEWMON: Was it practically answered?
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| 17 MR. RAUSCH: No, no. There's no indication of any 10 type of damage under any scenario.
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| 19 MR. SHEWMON: Some people stress that more than 20 analysis.
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| 21 MR. RAUSCH: The problem is more of if you postulate 22 the operator not responding for whatever reason and he has the 23 type of oscillation that is the most masked that you could 24 possibly, it's a matter of degree,-how high of a magnitude can 25 you let it get before you do have a concern. On paper the HERITAGE REPORTING CORPORATION (202) 628-4888
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| 315 1 plant can't risk violation of the safety limit if he had 2 reason to believe it wouldn't damage his fuel. That's still a 3 major outage or delay in start up. By technical 4 specifications you need regulatory approval, NRC approval, to 5 start up.
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| 6 MR. WARD: Maybe it would help to define what the 7 safety limit is in this case.
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| B MR. RAUSCH: The safety limit we're using is the 9 MCPR, the minimum critical power ratio, which is the hydraulic 10 performance. Margins on bad boiling or departure from nuclear 11 boiling.
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| 12 HR. WARD: That's related to departure from local,
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| ('- 13 departure from nuclear boiling.
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| 14 MR. CATTON: Local dryout on the rod.
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| 15 MR. RAUSCH: We have considered it. My previous 16 slide at the bottom of the page, and I wasn't going to talk 17 about it, but one of the things that's been kicked around over 18 and over again is perhaps analytically and experimentally we 19 could show that very high level oscillations would not damage 20 anything and create a new figure of merit. While that's 21 fraught with enormous uncertainty and expense, the need to 22 work very heavily with the NRC and their research people and 23 all the time associated with that. It's just not practical,
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| ! 24 and we can't frankly say what the answer would be.
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| c 25 MR. CARROLL: I think what Paul is really getting at
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| <J HERITAGE REPORTING CORPORATION (202) 628-4888
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| -----_J
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| th U 316 1 is take this to the extreme. What bad thing could happen 2 physically? Forget about violating safety and tech specs.
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| 3 MR. RAUSCH: That's being addressed, I think staff 4 research can address that a little bit. Some of the questions 5 that have been postulated to us under the ATWS regime. We 6 feel that's the only place it's appropriate to address such 7 issues, just assuming that you can't respond. The operator 8 can't kill the oscillations so there's no system there to stop 9 it. Then the answer is we don't really know right now, other 10 than that it's going to take awfully large magnitude before it 11 is a major concern.
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| 12 MR. SHEWMON: I'm sure you'll' keep that in mind some
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| .O L/ 13 place when you start doing automatic --
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| 14 MR. RAUSCH: Certainly. There will be, like I said, 15 a cafeteria style selection when you see our schedule. We're 16 shooting for as early as fall, which options people line up j i
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| 17 behind to develop the final specifications and final limits (
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| 18 associated with the option. I suspect plants will be fairly !
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| 19 intelligent in choosing the right mix of up front costs versus 20 downstream costs. Although everybody has their own 21 philosophy.
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| 22 The rest of the prevention solutions are really just 23 permutations on this that would allow controlled entry into a 24 small part of the :,egion to give them some operating 25 flexibility for startups and perhaps pump transfers, if they HERITAGE REPORTING CORPORATION (202) 628-4888
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| 1 i 317 1 vere to have a good analytical basis f6r it and the stability 2 monitor to show that &t the time they're in the control 3 situation they have adequate margin.
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| 4 That's it ir a nutshell where we're heading in l 3 solutions. I h&ve e schedule. I can amplify that a little C bit better now, versus what I could say two weeks ago.
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| ? Tha slide doesn't look a lot different, but we've 8 had a significant amount of accomplishments in the last, since 9 the subcommittee.
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| 10 This $s just a little timeline of what we call our 11 lor.9 term solution, our schedule. This is similar to what we 12 prSaented to the NRC on April 6th. We worked on bid specs.
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| 13 We ended up single sourcing it with General Electric because 14 of all the problems associated with the complexity of the 15 issue.
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| 16 We worked out work scopes. A major step here was 17 getting funding. I believe we were in here May 23rd with the 1S subcommittee. We had a half million dollars authorized on May 19 24th at the executive meeting in Chicago associated with the 20 feasibility work I'm talking about now. The work essentially 21 started before that. We called a day after.
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| 22 Last week a subgroup of the stability committee, 23 including myself, was in San Jose working out final details of 24 what we had asked to be done versus what someone who is a 25 little bit smarter in a lot of the details would recommend we O
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| (:)
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| * 1 do, and that's GE, and we had a very good meeting, and work 2 has started in three separate tasks associated with the 3 solutions I've described.
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| 4 We looked at various decision milestones along the 5 way. Optimistically, September timeframe, not optimistically, 6 we will be updating the NRC in September, what's happened.
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| 7 But optimistically, we will have enough results by then and 8
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| confidence in them that we'll be able to make recommendations 9 to all the owr.ers in terms of for their particular plant types 10 which ones look viable, which solutions look viable, what 11 generic costs associated with the owners group, and what plant 12 type costs they should consider in terms of deciding what
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| {) 13 solutions to go behind in the future.
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| 14 That concludes the discussions I had on long term 15 solution work. We have a few other, we have a little section 16 entitled formal comments on NRC suggested activities 17 associated with their March letter. I'll go through a few of 18 those.
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| 19 Slightly out of order, the first two. Let me put up 20 two issues and I'll explain what our philosophy on it is 21 quickly. The first iesue is associated with understanding of 22 symmetric and asymmetric oscillation modes. In other words, 23 what do we need to know about all the different types of l
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| 24 instabilities that may be possible spatially. Regional l
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| 25 oscillation, theoretically, could come under various forms in O HERITAGE REPORTING CORPORATION (202) 628-4888
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| 319
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| ~1. terms of where the peaks and valleys are geographically 2 located in the' reactor.
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| 3 Then what is the maximum amplitude of oscillations I 4 and possible variations in shape.- This will be time shape, 5 the neutron flux. Our answers for both those'two is the same.
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| }
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| 1 6 I think I just skipped a page.in here, but.I'll come'back to 7 it.
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| 8 Basically we're taking into account all the 9 experiences we know of, and our long term solutions will be 10 predicated on the basis.of our ability to prevent and' detect 11 oscillations of different shapes and periods and take action 12 as appropriate. In other words, whether it's prevention or
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| '13 detection and response, the solution,-in terms of-operating 14 concerns it won't matter, these kinds'of issues. In terms of 15 ATWS concerns, it's a different story. We're working on that 16 separately. We'd like to draw a very distinct line betwsen 17 severe accidents, concerns, and normal plant operation 18 concerns.
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| 19 Last, this is a relevant question towards every day.
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| 20 operation. What is the impact of instability on operator 21 response to an ATWS? That is a severe accident issue, however 22 we've already started investigating that. We felt there was 23 less known about, we felt less certain about what's likely to l \
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| ! 24 happen in the plant in this-area than we do in terms of the potential for severe core damage or anything else associated.
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| 25
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| ( j HERITAGE REPORTING CORPORATION (202) 628-4888
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| j O 32o l
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| . i 1 with an ATWS event.. l 2 So through the owners group and really'another 3 organization, INSAT, the same people, EPRI has begun l l
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| 4 investigations'in this area. I do have a short,'if you're -)
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| l 5 interested, a short presentation,.just two pages, on what 1 1
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| 6 their plans are. I don't have that many handouts. 3 I
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| 7 (Pause) 8 MR. RAUSCH: This is_a brief INSAT summary of what 9 they're doing in this aroa. The work is ongoing ~right now. _j i
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| 10 The question they're answering is will the operator be able to i 11 follow the intent of the emergency operating procedures during 12 an ATWS. That is fith oscillations going on, will there be .
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| 13 some indications that might fool him? Instruments, etcetera, 14 will they look normal to him? Beginning at time zero with 15 oscillations in existence they'11'look at large limit cycle l 16 and diverging oscillations using RETRAN. In this case it's 17 not necessarily that important to know the full detail, three 18 dimensional, of the reactor. We're looking at how the 19 system's responding.
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| 20 We'll extend these type operations and the various 21 ATWS scenarios such as MSIV closures, safety relief valve 22 actuations. Simuiste operator reactions including termination 23 of feedwater flow, lowering the' water level, reinjection, and 24- evaluate the operator's ability to follow-the emergency 3
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| 25 operating procedures. They've had to set up special mini- l HERITAGE REPORTING CORPORATION (202) 628-4888
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| q
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| 'i 321' I
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| 1 models tacked no to RETRAN to look at exactly wnat would a ,
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| t 2 water level sensor do with the pressure. perturbations .;
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| 3 . associated with it. I do have-to say that'everything we've i
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| 4 seen so far, the pressure fluctuations'are rather mild and j J
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| 5 significantly damped as soon as you get away~from the' reactor ;
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| 6 core itself. So we aren't. anticipating anything major in that' I i
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| 7 area. )
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| 8 The date, I have to clarify. I checked.with EPRI 9 yesterday. They're saying it looks more like September _for j 1
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| 10 completion. We'll work.out some way of informing the NRC of.
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| 11 those results, j 1
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| 12 That's all I have associated with owners group 13 activities. Hank Pfefferlen, GE, will give you a brief 14 discussion of some of our response to'some of the'ATWS i 15 questions.we've received. We've worked on it: a little bit 16 since subcommittee. There's also another question remaining' l 17 about code qualifications in this area.
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| 18 MR. WARD: Thank you, Mr. Raush.
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| 19 l Any questicno? l 20 (No response) 21 MR. PFEFFERLEN: My n&me is Hank Pfefferlen. I'm 22 manager of BWR licensing issues for GE. .I'm also the owners 23 group program manager on the stability issue.
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| ; 24 What I'd like to do today is to address the NRC i l l 25 question on heat dumped to the suppression pool during'an l
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| HERITAGE REPORTING CORPORATION (202) 628-4888 4
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| q 1
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| ,)
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| j 322 j
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| ([) ]
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| 1 ATWS. The question really'is based on:the postulated increase 1
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| 2 in average power in the presence'of. oscillations and what' 3 effect that increase in power'can have on the heat load on the 4 suppression pool given that ATWS, one of the limits:in the. ;
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| a 5 ATWS was the suppression pool temperature.. If the average; !
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| 6 power increased then that average power would increase,,and j 7 that was a concern. Theory would predict that such-an j
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| 8 increase would happen and so there was some work done to .
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| 4 9 explore this. j i
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| 10 The Phase IA effort that Tom discussed earlier.did )
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| 11 show a slight increase in this average power. The analysis 12 was done with the plant in what we call level of' control, and
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| (} 13 that's an important point. This allows the system to l
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| 14 accommodate the power increase and provide water so the plant 15 could operate at a higher level of power. l 16 Even under those conditions we found that the 17 increase was of short duration and self terminating. In other i
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| 18 words, the non-linearities in the system tended to overcome 19' this power increase and limit the magnitude of that increase.
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| 20 The other mooe of operation from an ATWS point of 21 view, this is where we would be, is with a plant.in flow 22 control. In other words, with systems that provide fixed flow-23 to the reactor. In the flow control we have to have 24 feedwater. In ATWS, the feedwater is turned off and we're 25 operating with the ECCS equipment which is fixed flow. Under O HERITAGE REPORTING CORPORATION (202) 628-4888
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| 323 1 those conditions the natural circulation, if there is an 2 increase in the average power, this forces a reduction in i
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| 3 level. You have more steam leaving the vessel than water j 1
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| 4 entering, and the level will reduce which will reduce the core 5 flow and bring the power back down. )
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| 6 So under those conditions we believe that the power l I
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| 7 out will be dominated or controlled by the amount of water in. I 1
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| 8 And in that sense the ATWG assessment that has already been f 9 done is still valid.
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| 10 In the Phase IA study we've also done some ]
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| I 11 sensitivities to look at the consequence of the oscillations. I 12 In other words we allowed the oscillations to grow to reach a m
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| 13 new steady state point. We went back in and looked at the {
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| J 14 power for the given boundary conditions, if the plant were not )
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| I 15 oscillating, and found that the average power during the l 16 oscillation and the average power that would be predicted for 17 a non-oscillatory state were the same, which basically 18 confirms our view that the system effects have to be 19 satisfied. The inter-relationship between the neutronics and 20 the boundary conditions have to be satisfied.
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| 21 What we're seeing in the oscillations is the 22 tendency towards increasing power that can be overcome by 23 system effects. So we again conclude that the analysis, the l
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| 24 ATWS analysis is valid.
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| 25 One other sensitivity that was performed was to look
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| HERITAGE REPORTING CORPORATION (202) 628-4880
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| r 324 1 at the offect of reducing the water level, realizing that.in-2 the ATWS case we started on the power flow map that. Tom had up.
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| 3- here fight at the corner of the 100 percent, rod linc, and 4 natural circulation. The question was,what would happen if we-5 reduced the level as the ATWS emergency procedure guidelines 6 direct. . We found that.indeed the power leve1' decreased 7 slightly, but for all intents.and purposes remained the same. i 8 We believe that's consistent with some work that has been.done1 9 at Oak Ridge. So there is, at least for'the case we studied, 10 a tendency to increase oscillation magnitude with reducing 11 level, although again Oak Ridge I think indicated that under 12 certain power shapes you may see an increase.-
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| 13 Taken collectively, we believe that from the' point 14 of view of heat dumped to the suppression pool that the ATWS 15 analysis has not been invalidated because.of the. stability u i
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| 16 concern.
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| f I
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| 17 MR. CATTON: This ATWS analysis is one TRAC run,.
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| 18 right? I 19 MR. PFEFFERLEN: I'm sorry?
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| 20 MR. CATTON: You did this with TRAC?
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| 21 MR. PFEFFERLEN: The ATWS analysis was'done prior'to ,
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| 22 TRAC. The assessments that were performed with a number of 23 codes where we followed the whole event down. So this is 24 historical analysis.
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| 25 MR. MARD: That was ATWS analysis without HERITAGE REPORTING CORPORATION (202) 628-4888
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| 325 1 oscillation.
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| ~
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| 2 MR. PFEFFERLEN:
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| As a matter of fact, it. turns out-3 that we did predict oscillations for certain of the ATWS 4 analysis. This was with a code that.we didn'.t have asLmuch
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| : j. 5 confidence in as-we do with. TRAC. But' oscillations were-l l 6 observed under certain conditions. Then mitigated'as the ATWS~
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| 7 proceeded.
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| 8 MR. WARD: What leads you.to'particular confidence 9 in TRAC?
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| 10 MR. PFEFFERLEN: There'as been an awful' lot of' 11 separate effects tests and system tests that-indicate that 12 TRAC does a better job of hydraulics.than the REDY code, 13 although REDY was not doing.that bad. REDY'is the code.that-14 was used for the ATWS analysis. It was not'doing a bad job ,
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| ,)
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| 15 but it just had never been qualified for instabilities. The- ')
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| 16 testing basis was not as extensive as that-for TRAC. We have 17 more confidence in TRAC, and there.was some discussion.at the 18 last meeting about TRAC's ability. It is our view'that TRAC 19 is doing a better job and we are in fact qualifying, and I 20 have a chart coming up where I'11 talk about what we're.doing !
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| 21 to qualify TRAC for this type of application.
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| 22 MR. CATTON: Since the subcommittee meeting I talked 23 with Sorroca at GE. Apparently there have been significant 24 changes to various parts of TRAC.
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| 25 MR. WARD: In the GE version.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| . 326 1 MR. CATTON: The'GE version has gotten away from 2 some of the problems that the regular TRAC has by changing 3- some of its internais. I'm supposed to receive a report from 4 Sorroca describing these. things, but it sounds okay. Maybe ,
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| 5 NRC ought to look into what you guys did.
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| 6 MR. PFEFFERLEN: We're in the process'of qualifying 7 to try to bring this all together. ,
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| l 8 That's basically the Phase'IA work. I.would like l 9 to,. based on some of the discussion we had at the subcommittee i
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| 10 meeting, step back and talk about ATWS in a'little more J l
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| 11 general terms. I'd like to' start out with a prospective.
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| 12 That is that the, first of'all we believe'the ATWS event 1 13 probability is very low to begin with. Then we have to 14 recognize that not all ATWS events result in operation where 15 instabilities are possible. I say.that because you have an I
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| 16 ATWS even if you get some rods in. The design basis of ATWS l 17 is all rods are stuck out, but the probability was really l 18 based on a number of combinations of potential failures to 19 SCRAM groups of rods or certain individual rods. It would be 20 of concern in an ATWS Cense. But a partial' SCRAM would move 21 you down on the rod line and get you away from the unstable 22 region. So partial SCRAMS would reduce the potential-for l 23 instabilities. ;
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| 24 Clearly boron injection will do the same thing. So 25 not all ATWS' will get you in that region. And secondly, not HERITAGE REPORTING CORPORATION (202) 628-4888 c -______ _
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| 1 i
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| 327 1
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| 1 all recirc pump trips, not all plants will be unstable down at- '] -
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| 2 that corner of the map so that even if you had a complete _,
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| l 3 ATWS, not all plants would be unstable. 1 4 So we' conclude from this that the probability of a-t S combination of ATWS and instability is lower, and I-believe I 6 much lower, than the probability of ATWS alone. -
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| j 7 MR. CATTON: Have you mapped these things out, your l 8 calculation?
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| 9 MR.'PFEFFERLEN:. The location of the instabilities?-
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| 10 MR. CATTON: The-various conditions that allow you. ,
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| 11 to avoid the instability. . 4 12 MR. PFEFFERLEN: What we have is the powerLflow map- q 13 that Tom put up with the dots on that .show where all'the
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| [
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| 14 observed instabilities were.
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| 15 MR.' CATTON: You're talking _about'ATWS here and 16 arguing that not all recirculation pump trips lead to '
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| 17 instability. Have you looked at the range of recirc pump 18 trips and said gee, this one doesn't oscillate are a result of l 19 calculation, or is this...
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| 20 MR. PFEFFERLEN: That's...
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| 21 MR. CATTON: Or are you just postulating?
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| 22 MR. PFEFFERLEN: No, no. I think.it's more than 23 that. We have operated plants at the corner of, this is the 24 natural circulation line and the rate of rod line on a power 25 flow map, the power flow map that Tom put up showed the O HERITAGE REPORTING CORPORATION (202) 628-4888
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| .s} 228 1 regions of ins ~tability and the dats' points being up here.
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| 2 Theery would support.that, that there is some kind of line 3 that defines the unstable region versus the stable region. .
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| 4 In thlkory,Lif you're operating at';100 percent rod 5 line and you came down that rod-by slow &f. reducing. flow, you 6 would end'up at this corner of the map. Realistically,Ewhat 7 really happens is.when you trip the recirc pump because of the 8 change in heat versus, heat transfer versus flow, that you get 9 & response that looks something like this where the power 10 falls below the equilibrium state . knd then slowly comes back 11 a as the' temperatures come b~ck in'the line'and approaches that 12 corner again for a given rod position. This does take tige.
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| 13 Furthermore, even trheh you - get back up here, in.some 14 cases the plant region or threshoid or stability is off that-15 power flow map. So the second point here.is saying even if I-16 get here, I may not be unstable. If I insert some rod, I'd 17 end up down here at some other rod line, or put in boron which-18 would again move me away from th&t region.
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| 19 I think that you do need an ATWS that fails to. move i
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| 20 very many rods and you have to neglect boron. Now'there's q y
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| 21 time, and this is why I drew this curve because it takes time 22 to get the boron in, but it also takes time for the 23 oscillations to begin. I believe in the LaSalle case they 24 didn't start for five minutes, and that was attributable to l
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| . 25 the fact that the plant is coming down and then slowly coming HERI'tAGE REPORTING CORPORATION (202) 628-4888
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| 329-1 back to an equilibrium state. So it-does take time.
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| 2 MR. cal' TON: But this does.. sound like judgment.
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| 3 MR. PFEFFERLEN: It's not absolutely. . You can' argue -
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| 4 that the boundary.in.some plant is way'down here'and things 5 would be different. It's difficult to pinpoint.the precise-6 location based on.what we've done to date. But the' 7 probability is the point I'm trying.t6 make here. 'It's not:
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| 8 very likely. All the evidence we've had of stability 11s very 9 close to that rate of power point. We have.not eeen.a plant 10 oscillate much below tne 100' percent red line. We have some 11 points above that.
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| 12 .To date, the data and the analysis support the fact-() 13 that you've got to get pretty close'to thatLcorner of the map 14 before you'll see an oscillation.
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| 15 MR. WARD: That's an easy to understand explanation, 16 but how well can you predict those stability / instability 17 boundaries? You sketch them in there and I just wonder how 18 well...
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| : 19. MR. PFEFFERLEN: We believe we can predict 20 reasonably well. The problem is not so much in the prediction-21 if we know "what the operating conditions are, but the fact l'
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| 22 that the unstable ctate is very dependent on power shapes, on' 23 a lot of factors that go into the analysis. That's what has 24 happened in the past with doing analysis, that we find the 25 plant is actually operated in a little different' condition l
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| (:) -
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| HERITAGE REPORTING CORPORATION (202). 628-4888'
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| O 330 lj 4
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| . ]
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| 1 than the basis for the analysis ' which made it . lea ^A stab;l.e. d 1
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| 2 That's why I think it's important. to leok at the operating
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| {
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| 3 data. Where have wo seen these stabilities. That does-more j i i l 4 or less reflect on how plants are operatedLand where<you'would
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| ~l 5 expect to see that condition.
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| 6 So I think it takes a combination of. analysis and l i
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| 7 operating experience to try and . quantify that, .and that is 8 part of the feasibility study that Tom dis:::ussed earlier to
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| ~
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| 9 define this. exclusion region. That's exactly'what we're 10 trying to do, to quantify-just where the boundaries to that j
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| 'f 11 region should be based on analysis and operating experience.
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| 12 MR. EAUSCH: Let'me make two quick points, Hank.
| |
| r 13 One is that the reason we think an exclusion region solution- l 14 is quite viable, at least in terms of licensing, is that we're 1
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| 15 looking at the high flow end. There is ah' extreme sensitivity j j 16 of decay ratios to raising core flow. So we would take
| |
| .]
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| 17 advant&ge of the fact that the more stable you go, the more j 18 confidence you have in your methods-and the knowledge that you {
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| 19 just can't go unstable at some point. i J
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| l 20 That's a distinct difference. All the points you're 1
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| 21 raising are still correct, but in terms of trying to define 1 22 higher flow space where it won't go unstable is a lot easier, l 23 we believe, than.trying to define right in the middle of where 24 it is possible to go unstable, what-all the things are that.
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| 25 make it more or less stable. !
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| HERITAGE REPORTING CORPORATION (202) 628-4088 l
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| 1 Onh othe:c (piick point. Me.do know'from all the c2 events in Europe and the teeting that's been done,Lthat's done-i 3 . routinely in Europe, that going,from unstable'to significantly 4 stable is-a matter of a few notches no:a fes cnntrol rods, !
| |
| 5 It's very very . little control it takes ~ to' inake n ~ big 1
| |
| 6 difference. That lends & Int of credence 'to Hanks'. beliefs j 7 that have. been stated. regarding. a small nufaber of red -
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| 8 $nsertion of an ATWS-is all it, takes.
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| .]
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| '9 .
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| o 10 l 11 12 0 13 i 14 1
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| HERITAGE REFORTQQ CORPOftATIOW (7.02) @@-4.88 8 >
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| 332 1 MR. WARD: I am confused. This is interesting, 1
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| 2 but we are taking -- Larry Phillips, how much time are you 3 going to need?
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| 4 MR. PHIkLIPS: 7 figure about 20 minutes.
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| i 3 MR. WARD: That is about what we have left. l I
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| 6 MR. PFEFFERLEN: Let me just very quickly put this 7 up. This is the power floor map with the data peints i
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| 8 showing. This is the rated rod line. This is above the 9 rated od line. And you can see that this is the corner of 10 the map that I was talking about and these are the observed 11 dn. stability occurrences. So we don't get them way down into 12 the m.sp. With a little bit of cont.rol we believe you ars l n
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| # 13 out of that region of potential instability.
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| 14 MR. CATTON; But I gather that you have data, you I 15 have codoe, you can confirm the codes. So if you war.ted to 16 epend the money on computations, you could create those 17 boundaries to whatever level you needed. !
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| 10 MR. FFEFFERLEN: And that is exactly what is !
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| 10 happening on the feasibility stuMy that Tom des;;ribed. We s 20 are doing just that.
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| 21 MR. CATTON: So ner.t time you won't have to say we 22 believe, you can cay we calculate.
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| 22 MRt PEEFFERhEN: Yes. Again, very quickly, this is ;
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| 24 the scenario that we went through, and the point, the only 25 point I want to make here is that we talked about the one, n.
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| ',)' HERITAGB R.EPORTIGG CORPORATION (202) 628-4888 i
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| 333 1 It begins to enter the cars three minutes and if you 311ow 2 time for the temperature P.o relax before the oscillations 3 start, there is a high likelihood that boron will begin to d mitigcto, ii.aybe prevent the oscillation before'you even get 5 started.
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| 5 Further, the emergency procedurcs acknowledge the 7 potential for instability and tell the operator to proceed 8 w!.th nis steps irrespective of that.
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| 9 MR. MICHELSON: That is the automatic boren 10 injection, isn't it, for this condition?
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| 11 MR. PFEFFERLENE I'f6 sorr??
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| 12 MR. MICHELSCN: You say that boron starts flowing 13 at three minutes. Is that automatic?
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| 14 ffR. PFEFFERLEN: No, no. The assumptions in the 15 ATWS analysis, the operator starts it in two minutes and it 16 takes a minute, it actually takes a minute to get " rom the 17 tank to the vessel and begin mixing in the vessel.
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| 18 MRc MICHELSON: You're sure the operator will 19 start injecting in two minutes?
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| 20 MR. PFEFFERLEN: That is the basis fo.T the 21 assumption. That was the basis for the ATWS rele. In fact, 22 the operator in the EPG3 is told to load a 16 vel which --
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| 73 this analysis bounds the lowering of the heat load because 24 you have actually lower power.
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| 25 MR. MICHELSON: The boron --
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| HERITAGE REPORTING COEh? ORATION (202) 628= 4888
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| ) 334 s-1 MR. PFEFFERLEN: There is some question as to 2 would he start in two minutes.
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| 3 Mk. MICHELSON: it is not a thing you do lightly.
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| 4 MR. PFEFFERLEN: No , I agree.
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| 5 MR. MIChELSON: And every reason to believe people 6 will wait as long as possible to decide. And.vou are saying 7 tnat this can 59 done in two minutes. q 8 MR. PFEFFERL5N: If he delays too long with 9 injecting boron, he is in'troubla for other reasons also.
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| 10 MR. MICHELSON: I am'just wondering if the 11 decision will be made in a timaly tachion, i
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| 12 MR. CATTON: I think wh9n ho neea hs hasn't got I
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| () 13 any control rods going in when he should be is probably 14 going to inject boron.
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| 15 MR. PFEFFERLEN: I sure would. 1 l
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| 16 RE. CATTON: Unless he j:24t freezes.
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| 17 MR. PFEFFERLE'N; Let me jttst focus now on what 18 the iduues are as we see thum. I l
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| 19 The entries from containment heat load,- i 20 containment integrity, things that we talked about, the 21 average power. Oscillation amplitude. This le something 22 that came up at the subcommittee meeting. What is the
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| ! 23 impact of thece oscillations on the core. And I think it 24 was asked in the context of what kind of protection do you 25 need.
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| HERITAGE REPORTIME CORPORATION I (202; 628-4888 i
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| ___ we
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| 335' 1 And it is our belief ('and I am going'to.show.youl L q
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| l 2 the basis for that in a minute,.that we will not.see-
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| :3 extraordinarily-large-or. unacceptably large oscillations,- +
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| 4 given the large ' of this combination of events based on-5 operating experienne and because of the inheront1 features 6 within the BWR.
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| 7 The third issue is the operator response,'the 8 thinge we were-just talking about, and the work thatlEPRI is 9 doing.
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| 10 So there are three issues. And let me'now just Al take a minuts to talk about the oscillation' amplitude.
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| 12 I don't offer this as the final solution, but as' I 13 an indi6ation of the basis of my commenta;1ast tima that-we'-
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| 14 believe this is not going to be a prbblein.
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| 15 There are a number of inherent and. passive-16 features that will limit oscillation magnitude.in the BWR.
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| 17 These are the fuel channel flow characteristics. We don't j
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| 18 bring coclant from the side, but it has to flor through the l l '40 channel. There is direct coolant heating, negative void 1
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| l 20 feedback and negative doppler feedback. All of these things !
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| l l 21 act together to limit'the magnitude. l 22 Given that situation, we looked at the. field data ,
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| j 23 and the magnitude of the oscil2.ations we have seen in the 24 -fi91d. And they are all well below the~1imit that we have 25 indicated here that we have seen in the Phnso 1A.
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| ( ,
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| HERITAGE REPORTING CORPORATION (202) 623-4888.
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| m: :
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| 1 bO 336 l
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| 3 l
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| 1 So actual operating experience, we have not seen, l l
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| 2 large oscillations, we have not seen any fuel failures-as a 1 3 result of oscillations, which indicates that we haven't.seen.
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| 4 it in the field. ;
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| 5 The Phase 1A' analysis, we saw a 200 percent peak 6 taa peak with all rods out. This was for a core, the very.
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| i 7 reactive 18-month cycle, very high peaking, conditions that 8 would tend to make this oscillation very bad.
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| ]
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| 'i 9 Now, whether it is absolutely bounding I cannot; )
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| 10 say that right now.
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| 11 MR. CATTON: Would the Oak Ridge analysis have j
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| .i 12 said about that case?
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| ]
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| (} 13 MR. PFEFFERLEN: I don't know'about Oak Ridge. In-14 Brookhaven we probably would get results that go a lot-jl 15 higher. But from some of the results that I have seen, they 16 have used very high voids, void reactivity feedbacks that we. <
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| 17 don't have in the BWR.
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| i 18 MR. CATTON: Convergence is needed, j 19 MR. PFEFFERLEN: You're right. You know,-you are 20 absolutely right. We have to come together on this. But 21 this is one step in what leads GE to conclude that. it is 22 difficult to get very large oscillations, even though 23 theoretically it may be possible, you know, if you do the.
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| [ 24 analysic; when you look at the-inherent feedbacks that have 2:1 to take place and if yots proper 3y size them in your
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| (:)
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| l HERITAGE REPORTING CORPO!".ATION (202) 628-4888
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| >1
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| -1; i
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| .)
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| C:)
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| )
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| 1 analysis.
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| 2 MR. WARD: What you,are saying is that you don't-3 .think, for example,-the Brookhaven. analysis with this> code 4 they have is properly -- that_is exactly.what it is' supposed 5 to be doing is taking account of all these. feedback 1
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| 6 mechanisms -- but apparently it is not doing it properly. ;
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| 7 MR. PFEFFERLEN: I'm not sure:about all. 'I know -
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| B in some of the analysis, they've used voids that are much i
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| ~
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| 9 larger that exist. Now, I am sure there are other analyses, i
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| 10 and I am not sure which ones have led to the largsr l l
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| 11 oscillations. 1 12 We'need to'do our work and they need to bring that ]
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| 1 13 together to get to a better understanding. 1 14 MR. KERR: It seems to me it is not surpris!ng 15 that at this point that GE is convinced that these 16 oscillations are unlikely to be very large, and that there 1
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| -l 17 is still some uncertainty. )
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| -l 18 Why don't we leave it at that?' I
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| .i 19 MR. PFEFFERLEN: Let me just say one other thing.
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| 20 We don't think they will be very large, and we did one other !
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| 21 thing. We did a study sometime ago where we took a plant 22 and turned off all the water, depressurized it'and then l
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| l 23 flooded it with cold water.
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| 24 It-is our engineering judgment <that that greatly i
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| 25 bounds whatever we could get out of an instability. We had HERITAGE REPORTING CORPORATION (202) 628-4888
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| 1 j
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| ('- - 338 1 old pressure core sprays and low pressure coolant injection j 2 feeding into a. core.that was shut down.on' voids with m1 water' 3 level down at about'the two thirds core heights level, and
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| . i 4 . it all went into the core and we got fairly algnificant''
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| i 5 power responses, but none of them viola'c ed the ATWS criteria 6 which says' maintain coolable. geometry. 'Wefeertainly went-by l 7 the thermal limits, the safety limit. But we didn't get to' 8- the point where you would expect'the. fuel to just start j i
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| 9 losing coolable geometry. And that is the ATWS criteria.
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| 10 Now, again, this is, as I say, this is the basis 1
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| 11 for our stating that we believe this is not a problem,. not- 1 i
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| 12 an absolute conclusion, you know, but we need to look at it. l 0* -
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| 13 -i' But this is the sort of thing that chows that.it is very.
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| 14 difficult.to get high mognatude' oscillations because in the 15 case of an instability,.the direct coolant-heating, which 16 tends to put void back into the coolant very.quickly and-17 turn the peak around before you get very large. And it is 18 even more effective than doppler. Doppler I think was.
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| 19 effective in this particular case because of the subcooling. I 20 MR. KERR: 'You sesm to be ignoring the fact that 21 in order to get this instability.one has to have a phase 22 shift between the power and the void formation.
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| 23 So what in a steady state situation.would be a 24 negative coefficient is ont of phase and it becomes a f 25 positive. coefficient in effect. The coefficient does not
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| (
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| HERITAGE R!u'ORTING CORPORATION (202) 628-4888
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| 339 1 become positive, but you get a decrease in voids at the 2 point at which it will increase power, because of the phase 3 shift between power and voids. So the fact that you have a 4 large one that would be in steady state negative void 5 coefficient is not necessarily favorable. It may make 6 things worse.
| |
| 7 MR. PFEFFERLEN: My point is, in this analysis we 8 took credit for the feedback and as the voids travel through 9 the core, and if you have a large power pulse, you do get 10 direct h9ating which tends to introduce void, which is a 11 non-linearity in the system. And that is what we are 12 maintaining will prevent the oscillations from getting 13 excessively 1hrge.
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| 14 MR. KERR: I think that is a misunderstanding of 15 the mechanism.
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| 16 MR. PFEFFERLEN: A large negative void coefficient 17 can hurt you in the amplitudes.
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| 18 ZE. RAUSCH: Lat me clarify _that. We are not 19 talking about an increase in voiding because of this. We 20 are just saying for a given power condition, when you drop 21 the power down low enough, the direct heating effect is a 22 vastly stabilizing effect. That is all we are saying. I 23 think that is the way we've discussad it.
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| 24 MR. KERR: What do you mean by the direct heating?
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| 25 MR. REMICK: Direct heating of the water.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| ,~\
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| (_/ 340 1 MR. PFEFFERLEN Gamma neutron heating of the ;
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| 2 water introduces voics.
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| 3 MR. RAUSCH: Immediately. There is no phase lag 4 associated with that.
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| 5 So it is a power drop.
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| 6 MR. KERR: This would be the case if your power l
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| 7 were extremely low, I suppose, in which case you probably I 8 wouldn't have any oscillation, anyway. J 9 MR. PFEFFERLEN: No, no, no. For a high peak, as 10 the peak goes up you do get the direct heating which 11 introduces the voide in terms to peak around. That is what 12 happened in this case and that is what we are looking at as r~s !
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| k-) 13 a mitigating feature in the BWR that you do have this, you j I
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| 14 don't have to wait for the heat to get out of the fuel into 15 the coolant but you get direct heating, which is a very 1 16 rapid feedback.
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| 17 MR. KERR: How do you get this direct heating?
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| 18 MR. PFEFFERLEN: The neutron and gamma.
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| 19 MR. CARROLL: We are getting into a lot of 20 speculation here.
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| 21 MR. KERR: The neutron heating is only the energy 22 carried by the neutrons which is a very small fraction of 23 the total fission energy. Most of the fission energy comes 24 out as kinetic energy of the fission products.
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| 25 MR. PFEFFERLEN: That's correct.
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| (
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| ~~ ' ' '
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| .o ,
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| , q
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| =l
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| <341
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| ~
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| 2 1 MR. WARD: A lotfof that-shows-up[directly'in.theI )
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| l
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| .2' coolant.- -
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| 1 v
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| .' j 3 MR. KERR:. No, no.
| |
| i 4 MR.' WARD: Gamma heating. SureLit;does. i l
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| 5 MR , KERR: Eamma heatingEdoes. But'thdt,'isEvery. . ' j a
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| 6 small.
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| 7 MR. PFEFFERLEN: 2 to 4' percent is:the.-numbers ~I-1 8' recall. ll 9 MR. KERR: Yes.-
| |
| 1 10- MR. RAUSCH: But :if 'you . are talking . aboutIneutron .;
| |
| I 11 flux spikes of 300 percent, that is'not-an. insignificant'- _;
| |
| 12 amount of void creation. :
| |
| 1 13l MR. KERR: It's an^insignificantJamount of-the 14 t'ot al .
| |
| 15 MR. RAUSCH: Yes, but it-is a stabilizing offect. . a 16 It is in phase.
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| 17 MR. PFEFFERLEN: As I indicated, this is'not the 18 final answer, but this is the basis-foe-our conclusion that 19 in an instability.you have a saturated system and.it'doesn't t
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| 20 take much to introduce voids and the analysis we have done '
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| 21 today supports that and we agree that this-is~not'the. bottom 22 line.
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| 23 MR. CATTON: I think you need to.do some more i
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| 24 calculations. ,
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| 25 MR. PFEFFERLEN: We agree.
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| -O HERITAGE REPORTING. CORPORATION (202) 628-4888
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| .l l
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| + ]
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| >I 342 1 1 MR.' MICHELSON: What:do the pressure oscillations-l 3
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| 2 lock'like during this time? -Reactor vessel. pressure j l
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| 3 oscillation?- Clearly you are increasing power and you are: )
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| :1 4 . relieving.through the relief valves. There must be a .j i
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| 5 commensurate' increase in pressure.' What kind of pressure 6 are we talking about, in oscillatory pressure?T 7 MR. PFEFFERLEN: There_is veryElittle pressure.
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| ~
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| i 8 The core Delta P stays about the same..in theseLthings. So ,
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| 9 what we are seeing is really a density wave propagation, fit 10 is not a pressure --
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| 11 MR. MICHELSON: That wasn't my question. My. !
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| 12 question is what is the total pressura during this' event'and !
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| 13 how does it change as the power oscillates 7. ,
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| l 14
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| ~
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| MR. KERR: Carl, unless you get some significant 15 change in average power, you probably don't see very much ,
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| 16 pressure oscillation.
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| 17 MR. MICHELSON: There is relative to. average-1 18 power. Is that right? l 19 MR. KERR: Unless you get'a very large 20 oscillation, you probably don't get a significant increase :
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| q 21 in average power. There is some speculation about what 22 happens if the oscillation is very large and I don't think 23 the codes probably treat that very well. ,
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| l 24 MR. MICHELSON: So any pressurc fluctuations would !
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| 25 be damped out if there isn't much change in the average O
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| HERITAGE REPORTING CORPORK. TION (202) 628-4888 n._.___. _ _ _ _ . . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _____ _
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| i l
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| 'v ' ;3431 1 power,.anyway.
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| 2 MR . PFEFFERLEN: On my.last chartLI was just7 going-3- to make:the point, I think.we've alreadyLdiscussed'itH that 4 we are in the_ process of cp2alifying the TRAC in our, 1 5 frequency domain codes to the. stability that that' is 6 availsble;, and that is aimed at the latter part of this-year.
| |
| 7 being complete nod putting _us in'a much better position to.
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| i
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| '8 come and talk to you about the' capabilities,cour analytical a q
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| 9 capabilities. . i
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| ~
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| 11 0 Right now it is our judgment based on.theEwork; )))
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| 11- that has been done that the codes are doing'a good job and' 12 we need to qualify it and document that fact. '
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| 13 MR. WARD: Do you have access, I guess you do'have 14 access, for example, to the~Brookhaven code.- Is there any 15 reason why you prefer not?
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| 16 MR. PFEFFERLEN: RAMONA7 1 17 MR. PARD: They have this other code. )
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| i 18 MR. PFEFFERLEN: The B&L? l 19 MR. MARD: HIFA, or something like that.
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| 20 . MR . PFEFFERLEN: The point analyzer.
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| 21 MR. WARD: It takes a machine, I guess, i 22 MR. PFEFFERLEN: I guess I could suffice it to say 23 that we believe TRAC surpasses the other codes that are out L 24 there and that is our view, with the work'that has been put l
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| L 25 into it, and so we are concentrating on that, not to say HERITAGE REPORTING CORPORATION (202) 628-4888
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| 1 I
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| () 344 1 that there isn't something to be learned by an exchange.
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| I' 2 But we believe we have a tool that can do the job and that 3 is, we are focusing our efforts on that. And I believe 4 Idaho has their version of TRAC and there is some work that 5 is planned in the NRC with their TRAC. So I think we will 6 get a lot of different data points here to help quantify and 7 qualify.
| |
| 8 MR. CATTON: Can you afford to make a sufficient 9 number of runs with TRAC? I don't think you can. That's I 10 why you need to look to the analyzer, maybe to supplement 11 what you do with TRAC. I 12 MR. PFEFFERLEN: I agree with that. Certainly.
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| /,
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| (_) 13 MR. CATTON: If you don't do that, you are never 14 going to be able to map out that region.
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| 15 MR. PFEFFERLEN: But let me say that the mapping 16 of the region is done with the frequency domain code, not 17 TRAC. And that is much quicker to run. So what we use TRAC 18 for is to bench mark the performance.
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| 19 HR. CATTON: If you are going to be absolutely 20 sure that you stay out of that region, then your stability 21 code is probably all right. But I heard you say that you 22 may drop down into those regions. If that's the case, you 23 need to use the code that can do the finite amplitude.
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| 24 That's going to cost money.
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| 25 MR. PFEFFERLEN: I agree. And the owner's group (v)
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| 345
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| )
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| 1 is well aware of what it costs. But let me again say that, 2 and I think Tom made the point in his presentation, that if 3 we put automatic protection into the plan such that 4 oscillations of a certain magnitude will cause an automatic 5 action be taken to mitigate it, then we may not have to do 6 too much analysis to look at how big can they get, except in 7 the ATWS case.
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| 8 MR. CATTON: I'm thinking more in terms of the 9 ATWS case.
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| 10 MR. PFEFFERLEN: Okay. In the ATHS case, here we 11 need to - you're right. There may need to be some work 12 done, and it may require a combination of RAMONA, TRAC and '
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| {} 13 the analyzer.
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| 14 MR. MICHELSON: Can you clear up for me the 15 confusion on my part?
| |
| 16 The TRAC is a thermal-hydraulic code. How have 17 you coupled the neutronics into it?
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| 18 MR. PFEFFERLEN: It's a coupled, neutronics-19 thermal hydraulics, 3D.
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| 20 MR. MICHELSON: For some reason I have a vague 21 recollection that neutronics in some of these thermal-22 hydraulic codes it not too good.
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| 23 MR. WARD: It is a little better in TRAC than in 24 RELAP.
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| 25 MR. MICHELSON: Yes, that is very poor. But TRAC O HERITAGE REPORTING CORPORATION (202) 628-4888
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| . l l
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| _______ _ A
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| Oss - 346
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| 'y.
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| 1 is thou:ght to be sufficiently good to power such things as. l 2 these power oscillations in. conjunction with thermal-
| |
| -3 hydraulic effects?. 'l '
| |
| .4 HR. PFEFFERLEN: I'm not sure. But I did talk to 5 Shere1kar, and he said that they have done a-lot of things )
| |
| 1 6 to TRAC. In particular, this business of the j
| |
| :I
| |
| : 7. multidimensional neutronics. .Apparently, they have improved. Ej 8 that part of it quite a bit. 'j 9 NR. MICHELSON: I've talked to. thermal' hydraulics.
| |
| 10 experts who say yes, that the thermal hydraulics in the code I 11 is pretty good but I never talked to anybody who understands '
| |
| 12 both the neutronics and the thermal hydraulics that says ;
| |
| 13 yes, this coupled together is also' good.
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| 14 MR. PFEFFERLEN: I_ don't think it is the. coupling 15 that is a problem. If you can solve the'neutronics, you 16 have the heat load and that is all you need to put into the 17 hydraulics. And that's all you need to put into the 18 hydraulics.
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| 19 MR. MICHELSON: Well --
| |
| 20 (Simultaneous voices) 21 MR. PFEFFERLEN: He didn't' send it right away like 22 he said he would. So I don't have it yet. But he did say 23 that he would send it.
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| 24 MR. MARD: Okay.- Mr. Chairman,'we are out of 25 time, but I would like to request that we go on until 12:30.
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| O .
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| HERITAGE REPORTING CORPORATION.
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| (202) 628-4888
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| | |
| 3e
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| .O-I 1 MR. MICHELSON: .All right.
| |
| 2 ' MR . PHILLIPS: 'I am going to very briefly. review i
| |
| -3 the NRC BWR stability program in response to thelLaSalle l 4 power oscillation event and the' status thereof. After'our- 1 5 . initial' studies,~we issued Bulletin 8807 to the licensees j
| |
| .6 telling them'in effect do not depend-upon decay ratio 7 calculations to say.that your reactor is stable. Everybody-8 should implement the operating procedures previously l l
| |
| 9 defined, and review your operator training and awareness of i 10- the oscillation events.
| |
| 11 At the same time, we requested RES to assist.us in 12 seeking the answers to some safety questions that'we had ,{
| |
| O 13 a **= a -atow
| |
| * er vio= 11
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| * a at o= a " 1 e too*
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| 14 on an extensive re-review of foreign experience.and found .l 15 several surprises with respect to non-GE reactors. We were 16 well aware of all of the events that occurred in GE 17 reactors, but many more oscillation events had occurred in l
| |
| 18 Swedish and German reactors and particularly.the-out of. 1 19 phase oscillations.
| |
| I 20 We were also surprised to learn of the hardware 21 protection that many of them had-employed to protect against 22 entering isolation regions, many of the thin'gs that.the BWR 23 owners group are now considering as their long term 24 solution.
| |
| 25 MR. CARROLL: The non-GE foreign experience is O HERITAGE REPORTING CORPORATION ~
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| (202) 628-4888
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| 28 348 I mostly inadvertent getting into oscillations or getting.into 2 oscillations as a result of testing to define where 3 oscillations occur?
| |
| 4 MR. PHILLIPS: Both. I would say to a larger 5 extent that it is the testing, that the testing did reveal 6 that within operating regions where they could normally be 7 that they would be unstable.
| |
| 1 8 We also asked the BWR owners group to do work and 9 initially their Phase 1 study revealed that they could under 10 certain conditions violate safety limits. And therefore we 11 had to supplement our bulletin and put on more strict 12 interim operating restrictions to reduce the probability of l 13 that happening. And as we were told, there is an ongoing l i
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| 14 BWR OG program seeking a longer range solution.
| |
| 15 The Phase 1 GE study has been discussed where they 16 ran one TRAC calculation with very large -- they simulated 17 the LaSalle event right up to 200 percent oscillations.
| |
| 18 Their integrator there indicated that the thermal power j 19 increased by about four percent in fifty seconds. We do not 20 know how much of that was due to system effects. The 21 evaluation is incomplete. The report is due this month.
| |
| l l
| |
| 22 And there is the ongoing study by EPRI that they told you l 23 about.
| |
| 1 24 These are the objectives of the research program
| |
| , 25 that we have undertaken. And we have initiated some HERITAGE REPORTING CORPORATION (202) 628-4888
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| 10 349 1 stability analyses aimed at accomplishing the: objectives.
| |
| l 2 RES fortned ' a. technical. program group to . review and .
| |
| 3 coordinate-the-stability:research,. and that group has.been-4 functioning very well.
| |
| 5 Among the analyses that we are doing or theicodes 6 .- that we are using, there is'RAMONA 3B where initial work was-7 done and' simulated the oscillations thatiwere obtained at 8 LaSalle, the same periodi et' cetera.. And as.it moved''
| |
| 9 through oscillations, we could not get extremely large.
| |
| 10 oscillations because we found the thermal-hydraulic model t'o. .
| |
| 11 be inadequate when we got to around 300 percent on the power.
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| ~
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| 12 oscil1ations. And that is currently-being modified.on'a 0 13 1eneer groeram te inseau the eherma1 hverau u c mode 1 which:
| |
| 14 would hopefu11y allow us to" carry on advanced. studies. ,
| |
| 15 This code is in a' sense equivalent to: the. GE ' TRAC 'j l
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| 16 except that it is. faster running and'probab1y not as.
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| 17 sophisticated in come areas or at least in detail, that in 18 the reason that it is faster running, but we think that"it-1 19 does a very good job. It is still a long running code.
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| 20 We are also doing initial work or more near term work with.
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| 21 Track BF-1 which has a well-proven thermal hydraulic model ;
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| .)
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| 22 but only 1D neutronics.
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| 1 23 MR. CATTON: Did you check to see if these same.
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| '24 changes have been made to TRAC as have been made to the GE 25 version? l O i HERITAGE REPORTING CORPORATION (202) 628-4888 I
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| q 350 1 MR. PHILLIPS:. Well,'we know they have not. GE l
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| 2 took TRAC and incorporated the 3D physics model..
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| 3 MR. CATTON: Well, I am not referring'to the i 4 .neutronics but the hydraulics side. GE made corrections to' 5 some of the difficulties of TRAC. This problem of the. heat 6 transfer and the weight fraction being. compensation.
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| 7 MR. PHILLIPS:' Yes.
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| 8 MR. CATTON:. They fixed it. If they have not' 9 fixed it with the TRAC version, you should look with a 10 little bit of skepticism at the results.
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| 11 MR. PHILLIPS: Right. I cannot answer your 12 question.
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| 1 1 13 MR. CATTON: You have to look into it.
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| 14 MR. PHILLIPS: Right. We have a frequency domain-15 code at Oak Ridge which although it is a1very simple: running.
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| 16 code has practically unlbmited capability depending on the 17 skill of the operator, and we have a.very skilled one there.
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| 18 And some of the things that we found out.with that code so 1
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| 19 far is that the average power increases with oscillation 20 magnitude, and I will show you a curve on that.
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| l 21 MR. WARD: You say that you found this out with 22 this code, and GE says that that is still under contention, l]
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| j l
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| 23 There is a substantial difference of opinion here, j 24 MR. PHILLIPS: >Well, I'do not know that there is, 25 because we are talking about one and a half percent per )
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| i HERITAGE REPORTING CORPORATION (202) 628-4888. 4 i
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| 351 x
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| 1 hundred-percent on the. oscillation.- And I think that GE-2 TRAC calculation shows that too.- They1 initially said that 3 there was not' power = rise purely due to the oscillations, 4- that most of it was systems effects,'but I believe thatithey 5 changed their position on that,. and Hank nods._ So I'do not-6 believe that there is-any. great discrepancy in what we are l
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| 7 predicting here except that this goes'much further.
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| l 8 And what you see is, and this is very pertinent to 1
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| 9 the ATWS question, what you sec'is that if you have got 11 0 oscillation amplitudes up to about 500 percent that you 11 would reach around 13 percent power increase due to the 12 oscillations. This is above and beyond any systems effects..
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| 13 You then get bifurcations in the oscillations where they 14 themselves become unstable and that levels off according to j 15 the calculations such that if you get up to around 2500 or !
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| 'i 16 3000 percent peak oscillation amplitude,_which we predict
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| 17 that you can get and we believe it except it is very extreme 18 conditions, and we do not believe that that is going to .!
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| 19 happen in any reactor of current vintage.
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| 20 MR. CATTON: Is this. linear. analysis or ,
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| l 21 non-linear analysis? '
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| 22 MR. PHILLIPS: This is non-linear. i 23 MR. CATTON: Non-linear. Jl 24 NR. PHILLIPS: We also found, as Hank pointed out, 25 some discrepancy with the initial GE results on the decay i HERITAGE REPORTING CORPORATION (202) 678-4888
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| 1 ratios changing when lowering the water level during the j 2 ATWS. If you look at this as decreasing the power by l j
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| t 3 decreasing water level, we found it to be very axial shaped l
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| 4 dependent. That is the behavior on the decay ratios. These f 5 are decay ratios. Of course if they are going up, it means I 6 that they are becoming more unstable. If they are going 7 down, it is the opposite. And this optimal column 8 represents the severe double hump power shape which was 9 found to be the optimum for increasing the decay ratio as 10 you lower water level.
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| 11 MR. WARD: That is the definition of optimum.
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| 12 MR. PHILLIPS: That is the definition of optimum.
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| () 13 MR. CARROLL: You could have chose a better word.
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| 14 MR. PHILLIPG: Yes. And we are doing some bench 15 marking on Oscarshem 3 which had very large' asymmetric 16 oscillations with that code. The Brookhaven analysis on the 17 plant analyzer has shown very similar results. And those 18 neutron flux oscillations that you see on an expanded scale 19 were shown to go up to about 2500 or 2800 percent, something 20 in that range. And you see the power increase below. !
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| 21 So as far as the completion of the program, as I 22 said, the GE reports are due in June. The recommendations i
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| 23 for long term solutions is expected in September through the 24 end of the year. And implementation of the long range 25 solutions on individual plants will be scheduled in HERITAGE REPORTING CORPORATION (202) 628-4888
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| 1 es i k-) 353 1 individually depending on the outages and the scheduled 2 shutdowns. :
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| l 3 As far as future plans and schedule, the staff l 4 needs to review the reports from the owners group, and 5 continued interaction with our consultants and the review 1
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| 6 group, interaction with the BWR OG on this power increase 7 significance. We have a number of tech spec changes 8 associated with procedural changes that have to be reviewed.
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| 9 We have to review the long term solution when it comes in.
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| 10 We have to review the individual utility long term solution 11 selections. And we are scheduled to give what is currently 12 advertised as the final report to the Commissioners in 13 February 1990.
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| 14 MR. WARD: Are there any other questions for 15 Larry?
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| 16 (No response.)
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| 17 MR. WARD: Thank you very much.
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| 18 MR. PHILLIPS: Thank you.
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| 19 MR. WARD: We want to thank everyone for their 20 presentations. It has been very informative. !
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| 21 MR. REMICK: All right. Thank you very much. I 22 suggest that we take our lunch break returning at 1:30. And 23 I wonder if the ACRS staff might attempt to alert the NRC i 24 staff of our first agenda item this afternoon, alert that we
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| ,,, 25 are running about fifteen minutes late. We will come back k-)
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| 1 t
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| d 354' o . j 1 'at it'30.,
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| 2 (Whereupon,.at 12:30 p.m., the hearing was-3 recessed, to reconvene at-.1:30 p.m. , __ this same day. )
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| -j 355 1 A E I E B N'2 Q H zE E E E l .Q H
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| -2 ' (1: 30 lp.m. ) :
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| Li 3' DR. REMICK: 'Let's reconvene'the meeting.
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| i 4 And the first topic:on our agenda.this afternoon. ;]
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| 5 is USI A-17, Systems Interaction. David' Ward:is the :s 6 subcommittee chairman. j 7 David, we turn to'you. j i
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| 8 MR. WARD: Thank you,-Mr. Chairman. .l 1
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| 9 I want to apologize to the. Staff for being 15' l 10 minutes behind schedule andLI hope it hasn't inconvenienced: !!
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| Il you too greatly.
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| 12 MR. BAER: That was a. benefit, we took the shuttle l I
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| {} 13 down. '
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| 14 MR. MARD: USI A-17. The ACRS identifi6d a 15 concern about the general subject of systems interaction.
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| 16 back a number of years ago, 1974 I believe, as a matter of 17 fact. At least the concern became regularized as.an 18 unresolved safety issue A-17 back in 1974.
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| 19 And since then the comniittee has had a number of 20 meetings with the Staff to. discuss the issue. The most 21 recent one was in August of last year.
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| 22 In August of last year and also a couple years 23 before that we issued letters. Those are you in your book 24 behind tab 10. In the last letter we reviewed the proposed 25 resolution of the issue and we made some comments. But we O' HERITAGE REPORTING CORPORATION (202) 628-4888
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| -1 indicated that.we' wanted to review.the. final' resolution l
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| ,1 2 'after it had'gone.outifor public commentiand.the-public ;
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| 3' comments'had been received:and evaluated. !)
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| a Well,.the Staff now proposes't'o.' issue'the' final'
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| '5 -resolution without'the benefit of obtaining public comments, 6 So I don't'know'if.we're; going to. hear /very much new as far.
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| 7 ss the resolution proposal today. :I don't think so.. I-think we may hear.why.the. Staff-has decided not1to' issue.l it
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| 8 j 9 for public comment, q 1
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| 10 But I have a.particular.requestjto the' committee-L 11 ~ members here. I have not been. deeply-involved in this'issueJ -
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| 12 and my subcommittee. sort of'has inherited this.- 'And so'I'm )
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| :l O 13- soi=9 to
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| * v =7 ===* 1ooxt=9 to ** oth :co==ite
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| * r-1 14 for your opinions and guidance on exactly what, if'anything, )
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| 15 we want to advise the Commissions with, with regard to the.
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| .I 16 proposed resolution of this issue. i I'm alerting you. Even. ]
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| 17- Dr. Siess isn't hare yet I see. -
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| 19 With that confident start, I-will:ask thw Staff:to- i 19 bergin their presentation. !
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| 20 MR. BAER: I-!was going to make a brief .4 i
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| 21 introduction and then Dale Thatcher will'present the major !
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| 22 portion -- make the major portion of the presentation.. '. i 23 I was just going to go back over the recent; l 1 24 history of this issue and very briefly try-and. describe 'l L 25 where we are and how we got there. '!
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| O HERITAGE REPORTING CORPORATION s
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| \ /' 357-1 As Dr. Ward stated, we met with the ACRS last-on 2' this issue in August of 1988 and at that tinte the only- ,
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| l 3 specific licensee. action that we were proposing was the. deal. 4 4 with internal flooding, what I call water intrusion and 5- : flooding from internal plant sources.
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| 6 There was some other' aspects of this issue that1we 7 were going to' issue.in terms of NUREGs and.a generic letter j 0 for information to licensees, but there was only one f 9 specific action that was requested, as I mentioned.
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| i 10 Prior to meeting with ACRS, just prior to that,: we 11 had met with CRGR and they agreed with the proposed )
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| l 12 resolution, but they had asked us to make a specific backfit 13 finding on the water intrusion aspects of this issue.
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| 14 So in September we sent that finding to CRGR, a 15 written finding, and CRGR agreed with the Staff proposal.
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| i 16 And about the time we think we were getting reasonably close 17 for putting this out for public comment the generic letter ]
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| 18 on IPE went out in November of 1988'and that had words in 19 there that explicitly required licensees to treat flooding 20 from internal plant sources as part of the IPE for internal 21 vulnerabilities. In other words, not to defer that to the 22 external vulnerabilities.
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| l 23 For several months we, I guess, debated internally 24 the pros'and cons of proceeding with A-17 as originally 25 planned or to take the guidance that we were going to issue Q
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| . HERITAGE REPORTING CORPORATION (202) 628-4888
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| 358 f')
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| m 1 to licencees as part of A-17 and somehow wrap that into IPE.
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| 2 And as of March the NRC management agreed with the 3 approach of issuing this guidance as part of the 4 supplemental guidance that's going out on IPE and not to 5 have A-11 as a separate licensee action..
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| 6 We met with CRGR a couple of weeks ago and they
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| : 7. agreed with that approach, also. !
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| 8 Now Dale, as I-indicated before will be making the l 9 major part of the presentation. And to refresh everybody's 10 memory he is going to give an overall summary, an overview 11 of tne whole A-17 program.
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| 12 However, I want to emphasize that this doesn't l l
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| f'' 13 really contain any new or different technical information j
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| , 's-) i l 14 that we haven't discussed with the committee previously.
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| I' 15 The only real change that we're proposing is the 16 one of the approach, namely, to wrap this into an IPE rather 17 than have it stand as a separate issue.
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| l 18 MR. MICHELSON: Have the guidance documents been 19 provided for the IPE?
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| 20 MR. BAER: We have published the technical 21 findings, NUREG-1174, has just been published. And one of 22 the appendices --
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| 23 MR. MICHELSON: That's the one we received this 24 morning.
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| ! 25 MR. BAER: Yes. I think it was just --
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| I 1 101. MICHELSON: So we haven't rsaally had time to 2 ese what guidance is being provided.
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| 3 MR. BAER: Well, the appendices I believe was in ]
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| 1 4 there previously. You have seen this in draft. Am I !
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| 5 cor. rect, just a few editorial changes. l 1
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| 6 MR. THATCHER: I believe the package that we sent I 7 down to you had an appendix and it's basically the same.
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| 8 Probably cleaned up somewhat because of the publishing 9 process.
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| l 10 MR. MICHELSON: I don't recall it, but --
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| 11 MR. THATCHER: At one time it was part of tne j 12 generic letter of the A-17 package, i
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| l f(s) 13 MR. MICHELSON: Yes.
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| l l 14 MRe THATCHER: That's right.
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| 15 MR. MICHELSON: I've seen that one, yea.
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| 16 MR. BAER: And we have been working closely with l
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| 17 the IPE people and they're about to put out --
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| 18 MR. MICHELSON: I just want a clarification. Now, j 19 NUREG-1174 is the document.that the IPE people -- it's the 20 instruction on how to do systems interaction under flooding j 21 conditions; is that what it is?
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| 22 MR. BAER: They have -- we were just discussing i 23 this with them yesterday. They are putting out an 1
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| 24 additional guidance document. This is highlighted right in 25 the front section, this 1174. And then it's mentioned l HERITAGE REPORTING CORPORATION (202) 628-4888
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| ., .1 1 briefly in the . text End .it's included in ths Lefarences. ,
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| .1 2 See yes.
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| q 3 M P.. - M T C G L S O N : . .I's.this the'only guidance'the , 1 4 agency will give then, is thic document?
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| I S MR, BAER: Yes. .
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| 6 MR.. MICHELSON: 'Is it?
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| 7 ' Mit. BAER: On that issue, I believe.
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| 8 MR. THATCHER: Well, there's - a number of. documents . ;i 9 in the IPE guidance document.
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| 10 MR. MICHELSON: Yes, I Eppreciate that. ,
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| 1 11 Relative to what you do and how do you do systems ]
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| j 12 interaction studies for IPE,.is.this th6 controlling 13 document, 14 Mit. BAER: In terms of the flooding.watar 15 intrusion. l 16 ' MR . MICHELSON: Yes, only fro:t that viewpoint, 17 yes. l l
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| 18 MR. BAER: There are other information that we 19 plan to send out to licensees.
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| 20 MR. MICHELSON: There will be others later on how1 21 you do the fire part and so forth as it has to do:with ,
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| 22 systems interaction?
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| 23 MR. BAER: Well, that was going to be part of that i 24 MSRP program.
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| 25 MR. MICHELSON: So there will be no guidance to O .
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| .1 IPE.- That's not a part of IPE 46 cll'.theni /
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| 2 'MR.' BAER: . No. Nict sa currently.
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| 3 MR. MICHELSON: 'Okay.
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| '4. HR. BLEK; Th6re's'O.ome additional'guidanco'in-5 . forms of a gener4e letter.thst will go-out-te' licensees..on 61 information that will help An their revicw of operating
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| 'i ev6nts as associated with system intterection.
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| weil, again, I wanted to_ emphasize.thatithis.is- -
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| 9 the significant change that we're proposing a9 one of.the-10 . approach.
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| 11 And with thet much of'. an introduction why don't' I . H
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| 'l 12 turn it over to Dale, if thara are.no further questiens. .
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| 13 ML MICHtLSON: Maybe before we get to the'detaild 14 fou cecn help !ne with a little larger question.
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| l 15 We have been looking at several a solutions''lately i 16 of generic issues. And ciao of the resolut; ions 1that we'sc' j l
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| 17 looking at le - your USI A-17 Osner:1c 'lettu, which . I achume ;
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| i 18 goes out.
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| l 19 And in there on page 2 and 3 - page 2 it ta2.hs ,
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| t 20 about generic issue 128 the electric powar reliability. l l
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| 21 Unless I'm not reading this. correctly it seems' to say that [
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| 22 the system interaction issue is associated with 1&C power 23 supply failures has been subsumed into generic issue 128; is l 24 that correct?
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| 25 MR. LAER: Yes, that's basically our intenta HERITAGE REPORTING CORPORATION (202) -628-4888 i
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| 1 MR. MICEELSON:- I asked Charlie, since I did not N have'tho time to go into<12b and he handled it-in
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| : 3. .aubcommitte6 I. asked him how that all came'out.and he was
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| !. 4 . un& ware that this was really your plan' because it didn'.t 5 .ssam to come out.in the resolution.of 128.
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| 6 MR. THETCR'Rr E Can I address -- I have soms slides 9 that talk sp5cifically --
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| 8 MR. HICHELSON: Will you. talk.about this later?-
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| 9 MR. TIfATCHER) Well, actua2,1y it's in the 128 i l 10 discussion. We ought to do it on.this-discussion, l' think.
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| l 11 MR. MICHELSON: Why wasn't it;in the 128 12 subcommittee discussion?
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| 13 HR. THATCHER: Well, we did talk absut the 14 relationship of 12 9 to 'UGI A -24 in' some detail.
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| 15 MR. MICHELSON: Yss, but ve r re talking A-17.
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| 16 MR. TiiATCZIER: -And also, USI A-17 and A-47, but -l 17 nct in very much detail. I think 1 p61nted out in that.
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| 18 subcommittee meeting that MUREG/CR-4470~which was anJoutput 19 of USI A-17 was utilized as one of the reference documents 20 in GI-128.
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| 21 MR. MICHELSON: From yOur statement I can already 22 see and I think the committee can 'see,.these things are all.
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| 23 crisscrossing and pointing to each other and I'm trying to 24 ' fit <M i he ultimmt.e home where the work vill be done. And I 25 want to make sure you are going to do the system interaction l
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| 1 1 work- as it has to do with instrumentation and . control'in: 128:
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| 2 ~ work, which has'already'been installed. -I will.go there to 3 find how you did it. '!
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| 4 MR. WYLIE: .Woll, let me ask'a question,.then'. j 5 128, you know, addressed taree specific generic 6 . issues.and we will get into that a little' bit'later. .You ;
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| i 7 don't claim that that's all.there'is to systems interaction, l
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| 8 do you, in the. electrical instrumentation and control area' 1
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| 9 In$ petrer ares?
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| 10 MR. Biln: I "hink what We said -- '
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| I 11 MR: THATCHER: We don't claim that's all there is i
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| 12 to systems interaction. I guess we need a clear definition-33 of what someone means wheh they sey the systems interaction 14 issue and the instrumentation and control power systsm.
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| 15 ICR, WYLIE: You know, in A-17 you mention things
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| ~
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| 16 like electro-magnotic interferences and all other kinde of 17 things. None of that'C addrbssed in these three resolut3ons 18 you have brought forward. i 19 MR. TEATCHER: Well, I think BMP was addressed in 20 a separate document.
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| 21 MR. WYLIE: Well, there's things other than EMP.
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| 22 NR. THATCHER: Well, again, I don' t know if we can 23 bring each one up.
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| 24 MR. WYLIE: Flooding effects on elsctric l-25 squipment, fire effects from electrical equipment, short l (+") HFTC[TAGE REPORTING COF2OPATION (202) 628-4888 r
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| - - _ _ _ _ _ - _ _ _ _ - - _ _ _ _ . - _ _ _ _ _ _ - _ = _ _ _ - - - _ _ _ _ _ _ . . _ . _ . _ . . - - . _ _ _ - - _ _ - - - .
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| .. d 1 circuit effects on electrical equipment ar;d instrumentation 2' ' control. I'mean, those'are systems-inter &culon.-
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| .J 3 MR. BAER: Well, I thibk on systems interaction.we 1 I
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| 4 recognize there were a Act of activities ongoing. For 1
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| 5 example, there'e a wholis question of. seismic interaction.. -
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| 6 -MR. WYLIE: .Yes.
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| 7 MR. B2ER: And a piece of that is. going:.to be. )
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| 8- handled by A-46 and the remainder we have'this multiple 9 system response program which we'11 be down discussiug',:I l 10 hope, next month with yo2. Thef re apprised to' pick up some' 11 of these residual issues. We identify -- '
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| 12 MR. MICRELSON: If you would look at your generic f i
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| O 13 1etter ea 9 ee 2 merhe veu c n ee11 me wh = we'>e s sine.
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| J. 4 MR. BAER: I have to get to that.
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| 15 hT. . MICliELSON: I'm only. reading.what you wrote. I 16 It starts on page 2 and concludes.on 6arly'part of.page.3.
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| 17 Maybe while you're serzrching for it I'll read the 18 statement to the other members in case they don't have it.
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| 19 MR. BAER: I think I re'nember what it says.
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| 20 MR. MICHELSON: It's attached to Dean Houston's 21- memo. We got it in a tab somewhere? It starts at the 22 bottom of the page and concludes ~at the top of the next.
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| 23 page.
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| 24 The concern 7.have is that-the first sentence says
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| .25 that: "The work of USI A-17 reemphecie the potential O H5RITAGE REPORTING CORPORATION (202) R28-4888
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| 1 interactions, and in particular instrumentation and control 2 I&C power supply failure."
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| 3 And the in the next page it goes on to say, the' 4 last sentence of this section in the middle of page.3: "To 5 better deal with.all of the' activities'on electric power was 6 decided to handle all these issuos'in one integrated 7 program. This became generic issue 128."
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| 8 To me that says that 2 can go to 128 resolution.
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| 9 and read how I&C power supply failures systems interaction 10 problems are handled. That's, I think, a reasonably, 11 logical interpretation of your words.
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| 12 MR. BAER: Yes, I would agree -- that.is not, I 13 guess, how we ultimately handled it.
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| .14 MR. MICHELSON: It's not what you did. And I'm 15 just, you know, I'm a little concerned that I read all these 16 good things and start searching for them and we don't find 17 them. And I'm wondering if they're being done or.will be 18 done.
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| 19 MR. BAER: On A-17 we ended up, after years of 20 searching for some magic method of finding only a couple of 21 specific actions that we wanted licensees to do. Part of it 22 was seismic interactions that largely is being handled by 23 A-46.
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| -24 The'other one is water intrusion and flooding for 25 internal plant sources.
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| m . .
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| - m 7:
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| .. ;s.-
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| d h >. t 366-
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| 'l' 'Now,.ths other areas we're.trying to.give..as 2 attachment'to the generic letter and in:moreJdetall'in'our 3- NUREGS, And I think in the -- I don't know if it's in 1174-
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| '4 ~ or whether it's in the Reg Analysis-that'w'e-hope'to publish-5: -- but has a lot of operatin7r experience'. including
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| ~
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| n, 6 electrical system' operating experience,.to t~yqand r highlight 7- that;for the111censees.
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| 8 Am I correct i.nwaying,Ne:.weren't able to: come up
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| ? with some systematic why that licensees ought-to look at -
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| 10 this;other-than to look.Gt' operating experience and' assure
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| : 11. that they're reflected in their plant.
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| 12 MR.-THATCHER: Well, that's in addition'to-A
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| (_) 13- improving certain. aspects of the electric power system which 14 we're going to get into in GI J128, 15 MR. MICHELSON: But I'think it's kind of 16 misleading, re_ ally, to=put11n a generic'letterifor the 17 public that you are handling this issue ~as part of 12b 18 unless, indeed, you are doing it.
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| 19 And if you are'doing'it I should be able to go to=
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| 20 the' documentation on 128 and read how you handled the issue 21 How you ress19ed it. Maybe you resolved it by saying,-I 22 don't know what to do or.maybe you said, it's e no, never..
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| i 23 mind.
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| 24 But I should be ablw to go tn:128 and fiddcout.
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| 25 MR. BAER: I agree, this is not reall'J worded very.
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| HERITAGE REPORTING CONDORA7 ION (202) 628-4888
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| o 357 g .
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| 1, precisely.
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| 2 MR. MICHELSON; So we're off to a bad' start at 3 best.
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| 4 MR. BAER: -With that much of an introduction I 5- guess I'll turn it over to Dale.
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| 6 ($lides being shown.)
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| 7 MR. THATCHER: I don't know how much of this i
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| 8 background we want to go through in detail.
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| 9 I would just say, as the casual observer probably 10 alreacy realized from this brief discussion so far, that the 11 issue is very difficult to define to start with.
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| 12 So what we did in A-17 is, we provided a set of 13 definitions that we used in our program. Based on those 14 definitions we performed a number of tasks and I will talk-15 on the next slide about the definitions and subsequent to 16 that about the tasks.
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| 17 Based on those tasks we formulated a number of l
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| 18 technical findings, that's about the fifth slide. Based on i 19 those findings we considered a number of alternatives for l 20 resolution. We also considered related ongoing activities.-
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| l 21 You will see some of that appearing in the resolution. i 22 Over the years, as Bob somewhat described, we L 23 developed a number of proposed resolutions anywhere from l
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| l 24 'taking no action at all to requiring walk-downs for 25 flooding. One tim we were going to take some action on O HEAITAGE REPORTING CORPORATION (202) 628-4888
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| I]
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| 'v 368 1 seismic, but based on A-46 actions we decided not to.
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| 2 As was_ described, we presented a proposed 3 resolution to ACRS in August of ' 88. And subsequent to 4 that, we developed a final resolution.
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| 5 As far as the definition goes this is rather 6 abbreviated but I think it gets the idea across that we are {
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| j 7 dealing with single failures that lead to a common cause l l
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| 8 type of event in that they propagate between systems through 9 hidden or unanticipated coupling. That's generally what we i 10 call a systems interaction. j 11 And then we try to focus in on a subset, adverse 12 systems interaction. And we used the -- tried to find the
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| (~
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| l)
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| ~/ 13 adverse aspect in terms of those bullets about undesirable l 14 results.
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| 15 And there are things like failure of portions of a 16 safety system or failure of a safety system that is caused 17 by a nonaafety system. Initiating of an event could be 18 something like a LOCA main steam line break or something 19 like that. And common cause failure of a safety system a
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| 20 simultaneously or failure of critical operator information.
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| 21 DR. LEWIS: Dale, I have always known that I 22 didn't know what the words " systems interaction" meant, but 23 you have just reinforced the feeling.
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| 24 ,
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| I wonder whether I'm really completely confused, I
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| ,_ 25 guess I know the answer to that. I've always thought a HERITAGE REPORTING CORPORATION (202) 628-4888
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| 369 O
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| 1 ' systems interaction had nothing to do with a common cause 2- failure. That a common cause failure was an event, whether 3 external or internal, that caused:the failure of two systems
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| '4 . independently, systems that are supposed-to.be independent.
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| 5 And that a systems interaction was,something
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| ~6 either spontaneous or external, it.doesn't matter, which
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| : 7. causes.a failure of one' system. And that the failure of' 8 that one system is what,causes.the failure of,the second 9 system. Not.that they have a. common cause, but that one-10 causes the other failure. And that seems to me to be an 11 important distinction, if it is right, and yet you have 12 treated them as if they were the same.-
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| 13 MR. THATCHER: Absolutely not; we.do not treat O 14 them as the same thing. I use the Webster's two English 1
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| 15 words " common" and "cause," and it.may have gotten crossed 16 with what your definition of common cause is.
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| 17 I think I can put the slide back up that I have 13 used since the original issuance of the task action plan j i
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| 19 that states adverse systems interaction is just one subset j 20 of common cause. There's all those common causes through i
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| 21 the common maintenance problems on two systems or something 22 like that. i 1
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| 23 DR. LEWIS: We're talking past each other because !
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| i l 24 I'm saying it's antithetical to common cause, not one !
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| \
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| 25 example of common cause. )
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| i HERITAGE REPORTING CORPORATION (202) 628-4888
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| -i i
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| .)
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| (%
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| : k. 270 I J
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| J 1 So am I wrong? f 1
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| 2 MP. . THATCHER: It ma'f be just an opinion of what i
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| 3 the call. '
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| 4 We often use the term " common mode failure," too. y i
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| 5 DR. LEWIS: Yes. i
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| -l 6 MR. THATCHER: To describe'the things that I 7 believe you describe as common cause. And I believe IEEE 8 still uses that term. {
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| 9 DR. LEWIS: I'm not trying to distinguish between k; 4
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| 10 common cause and ccamon mode here, I know the difference.
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| 1 11 But between common cause/ common mode and systems 12 interaction. !
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| (~h k l \/ 13 MR. THATCHER: Common cause/comiaon mode is one j 1
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| 14 set. Common et se/ adverse systems' interaction is another i i
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| 15 subset. ]
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| l 16 DR. LEWIS: That's absolutely different from what i,
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| 17 I have always understood to be a systems interaction. I i
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| 18 MR. THATCHER: Well, you know, I-don't like to l i
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| l 19 argue definitions and I don't know what to do about that !
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| l l 20 other than the fact that we presented that story at least 21 five years ago.
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| 22 DR. LEWIS: Oka . I'm suitable chastised for not 23 having said this five years ago, but I'm still trying to 24 understand. Because it's just not a matter of being pichy
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| - 25 about definitions, it's a matter of what you look at.
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| HERITAGE REPORTING CORPORATION i (202) 628-4888 l :
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| i
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| () '371 1 Because in the case of systems interaction, since you l 2 started out saying quite correctly that people have trouble 3 defining it, you have gone off on a track of defining it by 4 picking examples that you felt you could deal'with and 5 that's reasonable. I have no problem with that.
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| 6 But the questio.u is whether those examplos are 7 cht en to be samples of what 1* wou3d have calied common 8 cause failures or whether they are to be samples of systems 9 interactions as I have understood them, you're telling me 10 that I'm simply wrong. There is nothing wrong with that, 11 you can do that. But I want to know what my understanding 12 is, whether that makes any contact with what is going on 13 around here.
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| 14 MR. EAER: Well, could you repeat again what your 15 understanding was, Dr. Lewis?
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| 16 DR. LEWIS: Sure, no problem 17 My understanding was that there is an absolute and 18 flat difference between common causo -- and let me not just, 19 you know, say slash common mode -- between a common cause 20 failure and a systems interaction in that a common cause 21 failure is a situation in which something, whether it's 22 internal or external it doesn't matter, affects two systens 23 which had been regarded previ6usly as independent End causes 24 them both to fail, 25 The external events, we all know very well, an HERITAGE REPORTING CORPORATION (202) 620-4888
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| i
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| .. j 1
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| 372' 1 earthquake can make.two-things are separate fail; that's a: g
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| -1 2 common cause failure. j
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| ~3 A systems' interaction is when something. internal-4 or external, it doesn't matter,.it'can beispontaneous, 5 causes a single system to failure. And then the failure-of j i
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| 6 that single system in turn causes-the failure of another l
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| ;I 7 system. It's not that they have the same cause,.but'that.
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| 8 the failure of.one is the. prerequisite to the failure of the-1 9 other. That's really an entirely different concept. i
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| '10 I could be talking about something that isn't what
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| -11 you had in mind and that's what I'm trying to find out. ~j 12 MR. BAER: Well,'in terms of control system,.we
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| () 13 certainly 1 coked at that in terms of control systems and 14 protection systems under USI A-47 where we tried to look at-15 failures of, quote "nonsafety control systems" and see if ;
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| 16 they could propagate into multiple failures of protection i
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| 17 systems. .,
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| 18 DR. LEWIS: Sure. l l
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| 19 MR. BAER: And we were unable to find any, either 20 through experience or any -- identify any specific j 21 vulnerabilities in that regard, i 22 DR. LEWIS: Would you call those systems 23 interactions you were looking for or common cause failures 24 or don't you make the distinction 7 l
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| l 25 MR. BAER:
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| I guess I personally didn't make the O HERITAGE REPORTING CORPORATION (202) 628-4888 l
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| av i
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| () 373 1 distinction except that, as Dale was saying, we clearly 2 under systems interactions try to exclude certain common 3 cause failures. We didn't look at maintenance, for example.
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| 4 We didn't look at design -- multiple design errors.
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| 5 DR. LEWIS: So you're, in effect, agreeing with 6 Dale -- I'm just trying to understand -- with what Dale 7 said, tahich is that you think of systems interaction as kind 8 of a subset of common cause failures.
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| 9 MR. BAER: Oh, yes, very definitely.
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| 10 MR. THATCHER: I don't think we're that far apart 11 on our --
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| 12 DR. LEWIS: I think we're very far apart.
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| () 13 MR. THATCHER: No, I don't think we are. If you 14 look at this '-- I mean --
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| 15 DR. LEWIS: I get a vote on this, too, you know.
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| 16 MR. TRATCh3R: I know. I don't like to argue 17 definitions, but I guess I'm try.'r; to argue that we're -- I 18 think I understand what you're saying. It's just that I 19 maybe don't classify things that way.
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| 20 But as for what we looked at in this program was 21 propagation of a failure f rom one system to another and it 22 doesn't have to -- I agree, it doesn't have to be from the 23 same cause like simultaneous failures of redundant cafety 24 systems due to an earthquake. That's over on the other 25 common cause. '
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| O HERI'TAGE REPORTING CORPORATION (202) 628-4888
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| ll) 374 1 DR. LEWIS: Due to what?
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| 2 MR. BAER: Why don't you point to the ones that we 3 did look at.
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| i 4 MR, WARD: It's common cause in series instead of 5 in parallel.
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| 6 MR. MICHELSON: I don't know if its series or 7 parallel.
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| l 8 DR. LEWIS: He has other common cause here.
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| 9 MR. BAER: Dale, why don't you slide it over so 10 you can look at the part that's under " adverse systems 11 interaction" and why don't you discuss that for a moment.
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| 12 MR. THATCHER: We try to call things - you know, lll 13 there's significant events that we're worried about, let's 14 say. And some of those things could be due to multiple 15 independent failure.
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| 16 MR. MICHELSON: Is this in your handout?
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| 17 MR. THATCHER: No. No, it's not. I really didn't 18 want to go back to the original slide.
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| 19 But anyway, we weren't looking at multiple 20 independent failures. Okay. Now there is something that 21 some people call common cause, common mode, dependent 22 failures. There's a whole lot of terminology that gets 23 mixed up in here.
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| 24 So what we did was, we called it common cause 25 failure events for lack of anything else. And unde that we O
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| , 7 V
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| l 375:
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| l ~ said'there was'this subset. adverse' systems interaction,'
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| 2- subset of common cause.
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| Okay. I. understand what'you're doing.-
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| ~
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| 3' DR. LEWIS:
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| ~
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| 4 'But'I really believe you are out'of. sync with normal; 1 1
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| 5 terminology on these things.1 That's fine,.you._can'do'what a
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| 6 you like.
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| 7 But we're not quibbling. 'We're'really talking 8 .about categories of events and which'ones are included.'
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| 9- MR.. THATCHER:- When you. say " normal terminology, "
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| 10 I think we-may be. But'I think.the. term." adverse systems 11' interaction" and " systems interact. ion" is a'little'out of
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| ~
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| l 12 the. norm, too. Because all I see in PRA type work' is' l
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| O 13 dependent failure and common cause failure.
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| i I
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| '14 You don't see a whole lot of systems interaction.. '
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| 15 DR. CATTON: That's because-they don't know how to 1
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| 16 handle it. _
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| 17 DR. LEWIS: That's exactly right;Lthat's why this- )
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| l 18 subject came up.
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| 19 MR. THATCHER: Well, I would argue-that systems 20 interaction involves a lot of dependent failures. l 21 DR. LEWIS: 'Well, I think'that, you'know,'to the 4 22 extent that this whole program'is supposed to be. responsive' 23 to -- I'm going to say this very'strongly -- it's supposed l
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| l 24 -to-be responsive to a concern that ACRS, I think in the 1
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| l~
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| 25 person of Dave Okren if my memory serves me right, brought BERITAGE REPORTING CORPORATION (202) 628-4888 ,
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| i l
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| 7
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| '376 !
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| : 1. up many years ago it is not' responsive to the specific
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| ~
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| 2 concern that he had and-that'was involved at the beginning.
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| 3 This is a different subject. You can treat it 4 very well and it may be important to safety, but it's a 5
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| different subject..
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| 6 MR. THATCHER: .Well, I took'it upon myself to try 7 to find out what the ACRS' concern with systems interaction 8 was. And I. read a lot of letters back on Indian Point 3.
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| 9 Am'I in the right world here. I mean,. Indian Point 3, and I 10 believe Diablo Canyon. And I saw a lot of examples. . Some' 11 of which I agree fit this definition.
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| 12 I also read an ACRS NUREG--- does ACRS write NUREG 13 -- NUREG-0572.
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| O 14 DR. KERR: No. We're not guilty of that crime.
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| 15 MR. MICHELSON: That'was our LER study, is that 16 the one.
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| 17 MR. THATCHER: It could be an LER study.
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| 18 DR. KERR: Okay.
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| 19 MR. THATCHER: But I disagree with the calling of
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| {
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| 20 some of those events systems interaction events, because 21 some of those events were clearly a maint'enance person 22 miscalibrated four redundant channels. To me, that's not a l 23 systems interaction.
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| 24 The fact that those four channels --
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| l 25 DR. LEWIS: If anybody said it was they.were
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| {
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| j HERITAGE REPORTING CORPORATION )
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| (202) 628-4888 i
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| L. _-_
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| }
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| - =- -
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| .. a 1 m.
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| . ,1 i
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| J377 g
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| i
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| . g J'
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| 1 : misusing the. terr. I don't:know, did we say,that?.
| |
| l 2 MR. THATCHER:. Well,.could'somebody get~ hold of; .j i
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| 3 NUREG -- ,
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| I 4' DR.. LEWIS:~ No. 'I don't want'to fight. .
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| yj i
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| 5 DR. lKERR: 'You're quite'right,Jthat1was-written byJ
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| .j 6 Dade'Hoeller and passed-on by the rest of the committee. R a-7 DR. LEWIS: 'Okay.: There are lots of, people who .')
| |
| .1 8 don't1 understand what a systems. interaction is.
| |
| '9 DR. lKERR: There'could be.--
| |
| 10 -MR. THATCHER: I guess, you know, there is'some 'q 11 disagreement on terminology. What we'try to do is, when we L]
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| q 12 got a hold of -- when we got into_the. program was to try to; j 13 get a handle on what is the problem. You can't work'a 14 problem without knowing.what it is. . .
| |
| 15 DR. LEWIS: That's correct. And that's been the 16 problem with systems interaction from'the beginning.
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| 17 But I do think your dead wrong by dismissing this l 1
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| 18 as reminder of disagreements about terminology. This is a 19 conceptual issue. ;
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| 1 20 MR. THATCHER: I,didn't say it.was minor!by any- _j s
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| 21 stretch. I said, we diesgree and unfortunately, it's majer
| |
| : 22. disagreements, I guess. !
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| 23 DR. LEWIS: There has been a real problem from'th9 24 very'beginning in knowing wha't people meant by systems l 25 interaction. You are quite right, that at the beginning it j HERITAGE REPORTING CORPORATION -
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| (202) 628-4888
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| ___-_-_____i~
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| 370 1 was done by example because anybody can conjure up examples 2 of' systems. interaction.
| |
| 3 I think Jesse when he was with us always had 4 batteries falling off -- their battery supports breaking in 5 an earthquake and falling on control systems or on operators
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| '6 or something like that, and that was a systems-interaction.
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| 7 We can all make examples. But they are-sequential' 8 ' examples. And that's the distinction between a common cause 9 failure --
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| 10 DR. KERR:- Let me suggest that if you look'at this 11 chart, whether you worry.about whether these are parts of' 12' common cause failure events is when you get'down to the L 13 operational level that his definition of adverse systems ;
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| i i
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| 14 interaction are not very much from what I think a systems 15 interaction or what you think a systems interaction --
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| 16 DR. LEWIS: No, I think your --
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| 17 DR. KERR: I think the operational consequences 1
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| 18 are miner. But the conceptual consequenc9s could be. .!
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| 19 serious.
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| 20 DR. LEWIS: No, no, I agree with you, Bill. In 21 fact, that's why this argument hasn't occurred because.
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| 22 It's because when they have come in with specific issues 23 which they have tried to deal with our. complaints have 24 usually been that that's much too narrow-a conception of.
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| . 25 what we meant, but gee, you had to do what you can do.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| l' I f
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| =
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| 379' 1 Nobody has any problem with'that.
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| 2 And it's only now wh9nLthey're trying to tie it' 3: into'a final resolution and say what.they're talking about' 4 that this-issue is now coming up.
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| 5 I'm going to-drop'it, but ~ I think: there:is a 6 conceptual problem here.
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| 7 MR. MARD: Could'you get us copies of that slide, 8 because I think we're probably' going to be arguing about it..
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| 9 MR. MICHELSON:
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| It's in~the earlier ~ report.
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| 10 MR,,. WARD: .Yes,'I know it is.
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| I've seen'it-11 before, but let's get it --
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| 12 MR. THATCHER: I'put this together in many 13~ different forms, I was f,ust hoping that was the latest one.
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| 14 I guess it is. Or the best one I mean.
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| 15 MR. MICHELSON: It may be different.than any other 16 report.
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| 17 MR. THATCHER: No, I think if you compare it to 18 the task action plan.
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| 19 MR. MICHELSON: That's the same one.
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| 20 MR. THATCHER: Oh, boy, that was pro 6uced in 21 NUREG --
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| 22 MR. MICHELSON: Yes, that's the long way back. ;
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| 23 MR. THATCHER: What's the NUREG that we produced
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| '24 task action plan, NUREG-0649?
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| 25 DR. KERR; I don't think you should feel bad if dERITAGE REPORTING CORPORATION (202) 628-4888
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| (_) 380 1 you have observed some confusion on this issue, because some 2 of the confusion has existed within the committee for years.
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| 3 MR. WARD: I think Dale has been a witness to 4 that. Longer than he hopes to like.
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| 5 DR. LEWIS: But the dise.greement that has been 6 within the committee has not been about the concept of what 7 is -- nobody has been able to define it in such a way that 8 inyone could do a:.:jthing about it. And that's been real.
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| 9 And that's certainly been true since the beginning.
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| 10 DR. KERR: There have been varieties of confusion.
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| 11 DR. LEWIS: Well, perhaps we're innovative in !
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| 12 inventing new forms of confusion.
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| [)
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| s- 13 MR. THATCHER: I guess I'll just go through some 14 of it. If you remember, some of the tasks we did was we 15 searched operating experience. We thought if we had a set 16 of definitions that we could give to a technical type person 17 that maybe through operating experience we could learn 18 something.
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| 19 It's not that we could find everything that's ever
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| )
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| 20 happened, that wasn't the intent. But it was just the idea I j
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| 21 of learning something; and then from that try to establish 22 some trends and patterns. We did learn some things. ;
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| 1 23 I'll go on. We also reviewed some, quote, j 1
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| 24 " systems interaction" studies that were done. Diablo Canyon gs 25 did a lot in the seismic area. Indian Point did failure k-)
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| HERITAGE REPORTING CORPORATION -l i
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| I' )
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| I () 381 1 modes and effects analysis, kind of work. And they also 2 submitted a 25 volume report on their systems interaction 3 study. And Midland had started on one which looked to us 4' like it had real promise of incorporating a lot of different 5 ' aspects, a lot of different methodologies and so forth. But 6 unfortunately, it was cancelled and we only got to look at 7 part of it.
| |
| 8 We reviewed work on methodologies. As Bob had 9 said, there was sometimes at some points in the program we 10 were searching for a, quote, " method, cure-all" whatever you 11 want to call it that if it was applied to a plant it would 12 uncover all these systems interaction and point them out to 13 someone so that they could take action.
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| 14 We looked at PRA, probabilistic risk assessment.
| |
| 15 We did -- we actually had a lab perform kind of a methods 16 comparison at Indian Point-3. One lab used what they called 17 the digraph matrix method; and another one used an FMEA 18 fault tree methodology. Unfortunately, I don't think the 19 results were really comparable because one lab found what 20 they thought was a systems interaction and another lab found 21 a different one. And when each was informed of the other 22 one they all said something to the effect that that wasn't a 23 systems interaction or something else. So it was very hard 24 to compare the results other than to say they found 25
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| (')
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| %/
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| different things.
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| 3
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| ! [
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| i L ',
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| 382 l
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| .( l 3
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| 1 DR.;KERR: Are you aware of the Siess theory on I l
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| 2 syetems interaction? .!
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| j MR. THATCHER:
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| l 3 I don't'know'if I am.
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| l 4 DR. KERR:- It says that the systems-interaction 2
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| H 5' issue will ncver be resolved,lbut that'one should-constantly l 6 be on the lookout for the. possibility of systems ,i 7 interactions in_ plants and where they're disadvantageous l
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| 8 cace you.try to do something about them.
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| 9 So we.might decide that this is one issue that~
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| 10 chould never be resolved.
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| 12 MR. WARD: Whether we decide or not, that's going 12 to be the case.
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| .i 13 DR. LEWIS: This-is the diogenes theory of-14 honesty.
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| 15 MR. THATCHER: I think there is some of that 16 flavor in our resolution.
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| 17 NR. BAER: I think the resolution is very close to 18 that.
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| I 19 MR. THATCHER: We tried to reflect it in our --
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| :{
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| 20 well, I'll get to some of that. j 21 As I said, we reviewed past and ongoing I 22 activities. One of the problems with the Indian Point-23 comparison, in my opinion was, it was started without a i
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| 24 -working definition of what a systems interaction was. And 25 as a result people found different things. I i
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| O- HERITAGE REPORTING CORPORATION (202) 628-4888 l mm_____.___._____ _ _ . _ _ _ _
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| * l 1 MR. BAER: I think you ought to point out that in 2 their judgment they only found things that had core melt 3 probabilities down in the ten to the minus six range.
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| 4 MR. THATCHER: I think, yes. I think everything 5 that was reported was in that range.
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| 6 MR. BAER: After much expenditure of funds.
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| 7 MR. THATCHER: Yes.
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| 8 I have ACRS here and I think that was just to 9 reflect my literature search of all the things that ACRS had 10 said on the subject and studies that had been done for ACRS 11 and so forth.
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| 12 We also, a number of years ago had the laboratory, 13 this was before I was involved, but the laboratory state-of-(])
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| 14 the-art reviews, we had three national labs look at the 15 state-of-the-art in terms of systems interaction. And I 16 think it may be interesting to note just one aspect. I 17 believe -- my memory gets a little fuzzy here -- but I think 18 it was Sandia who basically used FRA techniques to do a 19 systems interaction study as part of those state-of-the-art 20 reviews.
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| 21 We also took note of a lot of industry 22 initiatives. Maybe not necessarily in the name of systems 23 interaction, but certainly some of the activities that were 24 undertaken could be, in retrospect, said that they were 25 searching for systems interaction.
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| i 1 DR. LEWIS: I think that next time around -- I 1
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| 2 know many people mispronounce FMEA and call it FEMA, but j 3 probably you ought to spell it out. I 4 MR. THATCHER: I do have it spelled. You know, 5 this is an old slide that I'used before. Someone got me on i i
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| 6 that before. So I haven't gotten around to correcting it. j j
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| 7 Some of the findings, I guess we just tried to 8 make some general findings on the ASIS themselves. And then
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| )
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| d 9 also, on this whole subject of search methods. j I
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| 10 As you can see and as one might guess, adverse )
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| I 11 systems interaction are very plant-specific in nature. )
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| i 12 In addition to that, the overall effect on any
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| ~S 13 particular plant. In other words, the results of what an i (G
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| 14 adverse systems interaction causes is also very plant-1 15 specific. We do, though, think we observed some pattern, so i
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| 16 to speak. And those are the kinds of things that we tried I 17 to pursue somewhat with the aspect of flooding reviews. And 18 also, some of the operating experience, dissemination of l 19 infc rmation.
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| 20 We also concluded that a large number _of adverse 21 systems interactions that had occurred or were precursors to 22 occurrences had been dealt with. They maybe were not called 23 systems interaction, but they had been dealt with in one way 24 or another.
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| l 25 As far as the search methods, basically we l
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| 1 concluded that there is many methods available. Some are 2 better for one type of ASI. As you may recall, we 3 classified systems interaction into spacial, functional, and 4 human intervention. I can't remember all the terms, but-5 ones-involving the human.
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| 6 But really, the method, some are better for 7 functional and some are better for spacial. Maybe an 8 example of a walk-down you can find spacial problems. A 9 walk-down is not going to tell you a lot-about functional 10 interactions. You have to get some drawings, diagrams and 11 that to follow some of those down. Different aspects like 12 that.
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| () 13 We thought to do an overall plant search you-14 needed a combination of methods. And as I mentioned, we.
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| 15 thought Midland was really undertaking something on that 16 order.
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| I 17 But such a comprehensive search is very costly. !
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| 18 And really, we found that based on studies that even when a
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| 19 they're done there is no guarantee that all systems 20 interaction have been found.
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| l I
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| 21 In fact, I think I've seen at least two LERs on l 22 Indian Point-3 since they studied it, since our lab studied 23 it. Since our two labs studied it, that I would classify it 24 systems interaction type problems. l 25 l However, even tnough they came in and they were i HERITAGE REPORTING CORPORATION (202) 628-4888 ;
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| s, .
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| 386 1 corrected, I-still'think they were on,a very low probability- .
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| 2 end of the spectrum.
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| 3 DR. KERR: Well --
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| 4 MR. WARD: The event.-- excuse me, Bill.
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| 5 DR. KERR: That characteristic is certainly not- .
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| 6 peculiar to adverse systems interaction. I mean,.one can [
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| l 7 say the same thing about PRAs, there is no guarantee in a- q 8 PRA that all sequences that produce' risk will have been-9 found.
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| 10 MR. THATCHER: .Yes. Unfortunately, I think'.that's 11 true, too.
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| 12 I use PRA in the context here of saying that,a PRA L - 13 can find adverse systems interaction. It depends a-lot on 14 the modeling.
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| 15 MR. WARD: Only certain classes.
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| 16 DR. KERR: By that yo): mean that in the course of 17 performing a PRA one looks carefully at a plant and'in the 18 process finds systems interaction; I can understand.it.
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| 19 MR. THATCHER: Yes.
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| 20 The mode 3ing going -- the things you put into your 21 fault trees you can readily determine that there 14 a DC 22 dependence of the starting of the diesel generators. I 23 mean, they should already know that, but things like that.
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| 24 MR. WARD: PRA seems to me to find them only I
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| l 25 because you are sitting down and working hard at it, first
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| '387' 1 of all. 'Or if;you really identify?it and put-it'in1the PRA. j i
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| 2 DR. KERR: That's>right. f
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| .a 3 MR. WARD: 'You'have toLrecognize it to put:in the j
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| '4 PRA. ' Going through the exercise might help'you do that. l 5 MR. THATCHER: Some of it going through the'. l l
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| 6 exercise. Al'o, s some of the dependencies come'out?inLsome- J 7 of the. codes that they use to,.you--know, to solve their cut
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| 8 sets and fault trees..
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| 9 MR. WARD: An earlyLmodel. . '
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| ~l 10- NR. THkTCHER: Yes . - j i
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| 11 MR..MICHELSON: You must first be' smart enough to. '!
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| 12 know what to put-in the model that.might heve a. systems; j 13 interaction affect. .For instance,-the room tempsraturr ..
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| 14 related to a heating and ventilating systems'and a solid- l 15 ' state cabinet in the room. Models' don't normally put't. hat-16 environmental coupling between those two systems in=unless- 1 17 you purposely -- you can do.it, there are techniques'for-
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| ]
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| '18 doing it. But most PRAs don't seem tondo:that< kind of ;
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| 19 coupling.
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| 20 So you won't find those-kinds of interactions. I.
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| 21 don't know how they would come out if you didn't put them in- )
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| l 22 the model first.
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| l 23 MR. BAER: We're not trying to say, in any way, j 24 that doing a PRA assures you don't have systems interaction.
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| , 25 Xt's a way of finding some and eliminating some.-
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| O' - HERITAGE REPORTING COFSORATION (202) 628-4888 4
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| ,i, 388 1- NR. MICHELSON: I' guess'what I'm.trying to say is 2 ' that, just because past studies didn't necessarily find any ,1 3 . is no: great comfort because past studies did not'even.model' 4 - in the kinds of problems that would have come back out
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| .5 . tbrough them- during:the PRA and identified as the real' 6 problem.
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| 7 If you don't put them into the'model,.you don't 8 get them out of the model. o-9 MR..BAER: Oh, yes,.we recognize -- I think that's 10 a serious limitations of PRAs in general.
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| 11 MR. MICHELSON:. Most of the past -studies just 12 didn't do that in the level of details.' It's.a very 13 - laborious detailed' job-if you're going to try to do this by 14 PRA, but it can be done.
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| 15 DR. LEWIS: I don't think.this is necessa.rily a 16 probism with PRAs in general.
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| 17 MR..MiCHELSON: No.
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| 18 DR. LEWIS: I think it's a problem with PRAs in 19
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| epecific. And it's a difficult one. It's one in the 20 practice of PRAing, it's not intrinsic.
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| J 21 MR. MICHELSON: It's not in the methodology. 't 22 DR. LEWIS: That's right.
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| 23 MR. MICHELSON: It's in the modeling of your e
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| L 24 problem to put into PRA.
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| l
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| . 25 DR. LEWIS: I agree completely. It's in the o
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| 389 ,
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| 'O 1 a 1 practices,-not a general criticism.
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| 2 MR ~. THATCHER: Well, we basically concluded that'.
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| 3 if there is a most cost-effective approach it;would be to 4 focus a search, but basically, that led us.down the line'at j
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| 'l 1
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| 5 looking potentially.at seismic, which aslI said, we left '
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| 6 basically to A-46 and also the flooding; upact. l
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| .l 7 Through all' of this stuff we thought we saw/ a ')
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| B common thread that there were.ailot cf water problems /in 9 plants. There seemed to be a lot of n ter problems!in i 10 plants.
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| i 11 MR. MICHELSON: I guess'the Staff saw the' problem, i
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| 12 but refused to address it then, becauce I recall very j vividly the A-46 example that I kept . giving :you of. c' systuns' 13 l
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| 14 interaction problem that they refused to kddress in A-46, 15 namely, that when the water. tank fell over they were willing' Ji i
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| 16 to address the physical impact on other equipment, but wMe ' l 17 unable -- were unwilling to consider the. water coming out of 18 the tank running across the floor and hitting the inverter.
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| 19 That kind they just refused to include-in A-46.
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| lJ 20 DR. KERR: That's because they-only. considered 21 empty tanks.
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| 22 MR. MICHELSON: That might be.
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| i 23 I mean, I do not believe A-46 has considered. : .
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| i 24 ' systems; interaction simply because.that-example was ;
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| 25 presented repeatedly and they said, no, we're not going to O
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| 1 include that in A-46. '
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| l 2 MR. THATCHER: Well, I think what we decided to do 3 based on that, and I have to hold my final answer until I 4 look at the MSRP program, but I think what we concluded was 5 that, yes, A-17 was going to look at some flooding. And, 6 yes, A-46 was going to look at some seismic systems 7 interaction such as the tank falling down.
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| B But this aspect - possibly this additional aspect 9 of the tank falling down and, in addition, where does the 10 water go? We thought we would try to look at it potentially 11 as a separate issue under MSR.
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| 12 MR. MICHELSON:
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| ~
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| Yes. Now, I don't mind that as
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| #w i Y) m 13 being the answer all right. But don't tell me then that 14 A-46 is taking care of systems interaction problems becauso l
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| 15 it's only taking care of a limited possible set. It's not 16 taking care of your definition of syst9ms interaction 17 MR. THATCHER: I think we should probably preface 18 everything we say when we say -- I Lean, if you do a focus 19 search you're obviously only looking at a limited set of 20 systeme interaction. If you're off doing an A-46 --
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| i 21 MR. MICHELSON: But it is not looking at the j l
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| 22 systems interactions that result from seistaic events; it's l
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| l 23 only looking at physical impact effo0ts of seismic events.
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| l 24 That's what A-46 ended up doing. And not look at water i
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| 25 effects at all. l l
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| %s l HERITAGE REPORTING CORPORATION (202) 628-4888 I
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| C/ 391 i 1 MR. THATCHER: In my definition the physical 2 impact is a systems interaction.
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| 3 DR. KERR: He didn't mean it.was not. HO was i
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| 4 saying that that?s'an incomplete set. !
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| 5 MR. 5' HATCHER: Oh, a 1:Lmited set, right?
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| 6 MR. MICKELCON: Yes.
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| 7 MR. THhTCHER: I agree that it's a limited set. I 8 think anything we have in this program is a limited set.
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| i 9 MR. NICHELSON: I just want to make sure we ;
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| l 10 understand each other.
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| I 11 MR. THATCRER: We didn't -- well, I con see we -- l l
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| i 12 as you will see or you have seen, nowhere do we say i 13 everybody go out and do something and find all systems 14 interaction. Sverything we've done is one of them.
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| 15 MR. MICHELSON: That was ridiculous to limit, you 16 know, to define it so narrowly that you wouldn't even l 17 account for the fluid coming out of the tank. That was, you 18 know, that was a little more than I could even take. <
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| 19 DR. LEWIS: And what Carl is saying is really not 20 a quibble. Of course, nobody says anybody includes
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| .21 everything.
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| 1 l 22 He is saying that . fairly major things were being 23 left out.
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| I 24 MR. THATCHER: Well, I guess we'did acknowledge c 2$ that subsequent to those discusalons that 7.-46, which I'm k.
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| HERITAGIK REPORTING CORPORATION (202) 628-4888 L . ~~__ -
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| l , :;r i L .!
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| L 5 I
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| -( f 392'
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| 'l. not responsible for, but I.mean, A-46 appe,5ently''did--leave j 3
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| 2- that out. .
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| l 3- MR. MICHELSON- Yes.
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| 1 4 MR. THATCHER: Land:we agree that potentially we j i
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| 5 might have to look'at that.: :And that's why, I believe,~;you ,
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| i 6 will.see it in -- .
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| 7 MR. MICHELSON:- See, we askedLthe. industry to go i i
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| 8 out and do all:these walk-downs but don't consider fluids; )
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| 9 being released, just consider physical' impact.;
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| 10 And now, some day we're going to go backland tell 11 them, now, do it all over again and include the. water. ,
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| I 12 DR. KERR: Well, now'if theso'tanksfare well j 13 designed they probably won't leak..
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| ,- 1 14 MR. MICHELSON: No, no, they're not'that well' 15 designed. They were shown to. topple. And the. problem was 16 that thay said, okay,. as 3ong as it didn't impact other. y 1
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| 17 equipment you're okay. You know, equipment required.for l <
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| 18 aafe shutdown.
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| 19 But they didn't account for the fluid content of 20 the tank.
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| 21 MR. BhER; Well, Carl, in: fairness to.A-46 the i
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| 22 major. goal of A-46 was try to upgrade the seismic .i 23 que.lification of equipment on the older: plants.
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| (- 34 MR. MICHELSON: Yes. They were looking for the j l
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| i 25 tanke that they had to anchor down. But if the tank fall
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| HERITAGE REFORTING CORPORATION I (202) 628-4888
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| 5 '( ,
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| -393 1- and it.didn't1 physically impact, you were okay, even though 2 the-water'asy have run'across the floor and hit: thel e 3 ' invertor.'
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| 4 MR.'BAER:, But'you''have identifiedLit-and'we are:
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| 5- -treating an MSR program a number'of multiple sources =of,-
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| E :sater from seismic events. 'I mean,~probablyfa more likely;
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| -7' one is. multiple actions _orEinadvertent actascion.of fire / ~
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| 8 protection systems, which-gives you.the similar potential' 9 consequences.
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| 10 And we are certainly_trying to look'at multiple, 11 sourcea of. water from a seismic event.
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| 12 MR. MICHELSON: I:just couldn't' resist the D
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| d 13 opportunity, that's all.
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| 14 HR. THATCHER:' General -- I-don't need;to. state: )
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| 15 those. I think we've all basically discussed'those general; 16 findings.
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| 17 DR. KERR: Mr. Chairman, I want to_ remind you that 18 there is a fairly important event scheduled at 2:45 this l 19 afternoon. ,
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| i 20 MR. MICHELSON: During our break.
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| 21 350th anniversary.
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| l l
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| 22 HR. THATCHER: Just briefly, the A-17 proposed 23 resolution to ACRS in August of ' 88 was basically no new-24 requirements. But the generic letter to all licensees.did ,
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| 25 'have one last attachment that requested certification of HERITAGE REPORTING' CORPORATION' (202). 628-4888
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| q 394 1 flooding evaluations. ~l 2 'It was' basically,-at that' time,'to be-done under 3 existing requirements. . We'also proposed to provide lessons 4 learned about . adverse systems : interaction i'or: PRA. .
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| 5l . Acknowledge relationship of USI 46. ' Provide power supply. )
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| 6 information to GI-128, which'I will. talk about, but wa-1 7- belisve we'did. j
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| -)
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| 8 And then also, develop these other concerns that 9' came out of A-46,-and also, potentially out of A-47, A-17 10 for possible separate treatment; and we' called that the !
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| l 11 Multiple System Responses Program'. I 12 We discussed it briefly at some'cf those mestings.
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| 13 'And as was stated before, the August.'88 ietter-by the' .!
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| 14 committee basically recommend that the resolution be' issued' 15 for public comthont.
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| t 16 The one modification as was also' discussed, we are l 1
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| 17 now proposing that that one item that was in the generic 18 letter before be handled by the IPE. Basically, the'IPE i 19 already included in the letter that was issued in 1988, 20 November 1988 included internal flooding. We proposed to 21 provide our insights to the IPE program. And 'as weits 22 mentioned the NUREG guidance document in IPE which I think-23 is 1335 will reference NUREG-1174 on the water intrusion 24 aspect.
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| 25 Therefore, the final resolution as we' propose is HERITAGE REPORTING CORPORATION (202) 628-4688
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| l t
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| Y~%
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| V 395 1 l
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| 1 1 to-still issue a generic letter with the first'two i l
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| 2 attachments that we had before, eliminating the third. The:
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| 3 .first two attachments being the basis for the' resolution.and- 1 4 summary of information for'use in operating experience-5- reviews, somewhat.like an information' notice. In other 1
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| 6 words, a generic letter for information only. H l
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| 7 Coneider the flooding of water intrusion in IPE.
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| 8 Again,. still no new requirements._ No public comments to'be 9 solicited, but rather issue the Commission paper, the 10 Federal Register Notice knd'the two NUREGs, one of which has 11 already been published mostly because of the reference to-12 the IPE,-we wanted to get that information:out-'as soon as 13 .possible. And then inform the congressional committees of 14 the resolution.
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| 15 And that's all I have.
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| 16 MR. WARD: What was your argument for public 17 comments?
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| 18 MR. THATCHER: . Basically, it's my understanding 19 that with the placing of the one last action item into the 20 IPE that there was no longer a need for public comment.
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| 21 We are basically taking no action on A-17.
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| 22 MR. MICHELSON: Yes. There's nothing --
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| 23 MR. THATCHER: Similar to --
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| 24 MR. WARD: Well,"some members of the public might 25 object to that again.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| .I 396 1 MR. MICHELSON: That's right.
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| 2 MR. THATCHER: It was also done, to my knowledge, 3 USI 45 was handled the same.way.
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| 4 MR. BAER: One of the problems or one of;the 5 considerations that-we had was --fone of the optiens, I-6 guess I would say, that we considered was continue on A-17 !
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| l 7 as we originally planned and clearly include in the generic l 8 letter an option for licensees to treat the water intrusion 9 in the IPE program. ;
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| 10 But the timing was such.that it wasn't a real I
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| 11 option at that point. If you went that-route and the !
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| 12 licensees -- and published for public comment, then it
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| (} 13 wouldn't have a final resolution for approximately a year.
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| 14 And the licensees would not know for sure whether that was-15 going to be included in the. final resolution. And by that 16 time they would have had to make.their commitments on IPE>
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| 17 So that was one of the thoughts _that originally 18 the plan was, well, proceed with A-17 and give this option.
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| 19 But it was pointed out to us rather strongly that that 20 wasn't a viable option when you went that route.
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| 21 And as Dolo said, A-45 I guess is e precedent, 22 that if you put it in the Federal Register and if the public 23 objects, if there is some comments, certainly, they would L 24 have to be addressed at that time.
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| 25 MR. WARD: Is that it, Dale?
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| i O HERITAGE REPORTING CORPORATION (202) 628-4888
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| -397 1 10-l' MR. THATCHER:- Yes.
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| 2' HR.JWARD: Dale, do you think it would be useful 3 to have a comment' from the ACRS?
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| 4 -MR. B7.ER: Yes. '
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| 5 MR. THATCHER: . Could.I.say, no.
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| 6 MR. MARD: That's kind of how I feel about.it.
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| 7 MR. BAER: Well, are we allowed to take silence.
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| 8 MR. WARD: 'But I mean, really, do you feel the-9 need for something from the ACRS at this time?
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| 10 MR. BAER: I guess only if you feel strongly 11 against it,_that I' guess. You.know, if there is a strong.
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| 12 negative feeling, yes, I would want to know about it'before
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| () 13 we take the action and not afterwards.
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| 14 DR. KERR: .In-line with our feeling that the issue 15 should never be resolved, it seems to me that what has been 16 proposed is a good way of implementing that.
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| 17 (Laughter) 18 DR. LEWIS: There's nothing in principle wrong in 19 looking for the monster. The only problem arises if you 20 claim to have found it.
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| 21 MR. CARROLL: Same with cold fusion.
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| 22 DR. LEWIS: Same with cold fusions, but only if 23 you're a chemist.
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| 24 MR. MARD: Any other comments on this?
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| 25 (No response)
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| O BERITAGE REPORTING CORPORATION (202) 628-4888
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| .G < M 398-1 MR. WARD: 'Okay. Well, thank you very much,' Dale'.-
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| 2 Mr. Chairman,.that's~the end.
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| 3 .DR. REMICK:--All right. Thank-you.
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| 1; I
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| 4 Remember,' gentlemen, we have a little bit of-l 5- celebration on this. cur 350th meeting.
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| l l 6 Mr. Wylie, do we have, I guess,' Staff coming:for.
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| l 7 tho' next issue;. is that right?:
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| 8 ' MR . WYLIE: They're here.
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| '9 DR. REMICK: They're here. -
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| 10 Let's take 17; minutes for our celebration and
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| .l 1
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| 11 return 10 minutes to the hour. '
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| 12 (Whezzeupon, a recess'was taken.)-
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| - 13 14 15
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| .16 17 ;
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| 20 21 ,
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| 25 O HERITAGE REPORTING CORPORATION !
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| (202) 628-4888' !
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| i l
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| h 399 1 MR. REMICK: Go ahead.
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| 2 MR. WYLIE: The background for this portion of our 3 meeting is at Tab 7.2, and it concerns the staff's proposed 4 resolution of Generic Issue 128, electri al power 5 reliability. Generic Issue'129 is a combination of three 6 electrical power system issues which were combined in 1986 7 and given a high priority ranking. The three generic issues 8 which were combined to form 128 were Generic Iseue 48, 9 limited conditions of operation for Class 1E vital 10 instrumentation buses, and this deals with a safety concern 11 that some operating nuclear power plants do not have 12 administrative controls of technical specifications 13 governing operational restrictions for their Class 1E 14 128 volt AC vital instrumentation buses, and there could be 15 some other voltage I am sure. :
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| 16 And Generic Issue 149 concerning the interlocks 17 and limited condition of operation for Class 1E tie breakers i
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| 18 which involves a concern that independent redundant Class 1E '
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| l 19 AC or DC buses can be interconnected through tie breakers j l
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| 20 which may be left closed by mistake, and when left closed l 1
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| 21 the tie breakers can compromise the independence of the 22 redundant safety related buses, and in some case may prevent 23 loading of diesel generators.
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| 24 Generic Issue A-30 concerns the~ adequacy of safety 25 related DC power supplies and it deals with a concern that HERITAGE REPORTING CORPORATION (202) 628-4888 l
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| ~
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| 400:
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| : 1. some plants may not have adequate provisions such,as; 2 monitoring, maintaining,-and. tests to' assure thtat the'DC.
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| : 3. power supplies.are-available and capkble'of performing.their-4- safety functions when required.
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| ^
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| 5 The'. staff's proposed resolution' to GenericfIesue
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| '6. ?128 is to issue two-generic letters containing information>
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| 7 requests under.10 CFR 50'.54 (f) and informed the licensees .of..
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| B the problems-and concerns, and requested information'for'the-9 , staff to-assess that adequate measures have been or will.be.
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| '10 taken to resolve the concerns.
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| 11' The AC-DC power systems reliability subcommittee 12 met on Wednesday of this week and reviewed the proposed-13 resolution.with the staff. The subcommittee members in' 14 attendance at that meeting were Bill.Kerr, Jay Carroll and 1
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| 15 myself, and consultent Peter Davis, j
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| ;\
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| 16 Generally the. subcommittee felt that the issuance l i
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| 17 of the generic letters' and the 50.54 (f) request! would serve.
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| 18 to improve the situations which had been. identified by the 19 generic issues. However it was expressed that this' approach i
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| 20 is a continuation of the fragmented approach to the ,.
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| l 21 resolution of safety issues rather than'an integrated I 22 approach. And it'was expressed that an integrated approach' 23 such as folding the issues into the IPE process would result ]
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| 24 in a more efficientsand effective process. .Also concern was !
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| 25 expressed that reliability analysis has not been used to l HERITAGE REPORTING CORPORATION '
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| (202) 628-4888
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| O 4o1 1 measure what improvement has been achieved by the resolution 2 of these issues.
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| 3 With that. I will ask the members who were present 4 whether they have any additional comments to make before we 5- proceed.
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| 6 MR. KERR: I have none.
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| 7 MR. WYLIE: Hearing none, we will call on the 8 staff then to present the condensed version of what we heard 9 Wednesday regarding the resolution of these issues.
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| 10 MR. BAER: I would just like to make a couple of 11 introductory remarks. We have considered the comments from 12 the subcommittee particularly aimed at how this may be O 13 rectorea or oo=1a de e oeorea i=to es- ^=a -e ere soiae to 14 be proposing to give licensees an option to do at least 15 portions of this work in the IPE if they so chose, as part 16 of the IPE program. They will make the presentation and 17 will get to that toward the end. But we do want to reflect 18 the committee's comments.
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| 19 We have talked to the management within research 20 and the IPE people, and they are agreeable. We would have 21 to bounce this off CRGR again, but I would not anticipate a 22 problem giving this option.
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| 23 MR. WYLIE: Would it be helpful if the committee 24 commented supporting that?
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| 25 MR. BAER: Yes, I think that it probably would.
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| O HERITAGE REPORTING CORPORATION (202) 628-4888
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| _g
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| > > 1 'Y lO J
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| 1; With that much of a:little introduction,_ I am-going toLaskl 2, Dale to.go ahead and'make the. presentation.
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| .3 MR.. THATCHER: 'I did not' introduce myself before.
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| 4 :
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| I am' Dale Thatcher ofcthe Office of Research.- ILam task-
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| :i 5 manager on GI-128. LI reallyLdo not'have to;give much'
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| ,4
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| - 16 background-I guess lonsthis slide' exception'for maybe ai 7= ' couple of points. :These issues;were integrated for ainumber; i i
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| 8 of' reasons, and one_of.the. reasons:haszto'do'with.the' 9 . interrelationships among the-issues. Now-I will_ point out:
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| 1 10 that there is a slide'on-the back of the package that you -j
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| -i
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| ~
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| 11 have that'you'might want.to refer to, and that is this N
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| .j 12 slide. j 13 (Slides shown.)
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| ~
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| 14- MR. THATCHER: It is just trying'to.show where all-15 of these issues impinge on the electrical power system.- If I i 16 you look over_to the right-hand sideJof.this slide, you will q i
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| 17 see that I added the potential for tie breakers. Tn ' is l q
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| 18' the idea that this is one typical' general slide showing an 1 19 electrical power-system, and it is clearly only one- -1 ll 20 division.- .There.should be at.least one other and many - l, 21 plants have two or three more of them. The issue of GI-49 22 has to do with interlocks and LCLs for: tie breakers. So !
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| I 23 that is trying to represent some tie breakers.- !
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| 24 Now Issue 830 if you look atiabout the middle:of 25 .the slide, there is the 125 volt DC bus with the battery HERITAGE REPORTING CORPORATION (202) 628-4888
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| O 403 1 charger connected to it, and there is the DC battery source.
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| 2 So you can see that a DC power bus potentially could have 3 tie breakers to other DC power buses for example.
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| 4 MR. CARROLL: Where do I look to find the AC 5 battery?
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| 6 MR. THATCHER: The AC battery, that is the 7 invertor, right?
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| 8 MR. CARROLL: It bothers me when people talk about 9 DC batteries, I do not know why.
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| 10 MR. THATCHER: Oh, okay. I see your point, yes.
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| 11 They do not call it a DC battery. The battery rack, the 12 battery rack and the invertor which converts the DC supply 13 to the 120 volts AC for necessary vital instrumentation. So 14 as you can se), and you might want to keep referring to 15 that, as you can see there is an interrelationship among the 16 vital AC buses. the DC supplies, and the tie breakers. And 17 also that the DC buses feed one of the main sources to the 18 vital instrument buses.
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| 19 In addition a reason to integrate it we thought 20 was relationships to all three of these issues to a number 21 of other issues, and specifically these three USIs that I 22 have on here, USI A-44, A-17, and A-47. Specifically with 23 regard to A-44, I just wanied to point out that typical, I 24 do not know if it is typical, but many plants will have to 25 do a coping analysis which in many cases will rely on s' cored EdRITAGE REPORTING CORPORATION (202) 628-4888
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| i j
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| . '. i 404' l' .DC power,.i.e.'a battery. So that' brings in.the'A 4 2 . aspects..to the USI A-44..'Also they.may rely,on certain j
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| 'l 3- critical AC' loads which.then'will require things like 4 invertor which brings'in the'GI-48' concern.'
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| 5 .In' add! tion'there'is potential that for a coping' y 6 study for station-blackout that someone may decide that he.
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| .]
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| 7 needs to tie certain divisional loads together,..maybe even j 8 loads between units. -And the way to do'that would probably.
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| -l 9 be done through some kind of tie breakers. And so thatL d 10 brings in the aspect that we are worried out in~GI-49. ,
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| i I
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| 11 I will'just' point out that in the las't bulletin l 12 the capacity aspect of the batteries is not=part of 13- GI-128 for purposes.o'f station blackout.- Infa' coping-study ,
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| 14 for station blackout, it.'is understood that the' utilities j l
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| 15 must demonstrate that they do indeed have.enough. battery .j 16
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| ~
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| capacity to last through the station blackout-sequence.' .
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| i 17 Very briefly, I lumped USI-17 and'A-47 together, ]
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| l fl 18 but just to point out'that al' number of'significant' events, 19 system interaction type events,.have involved' loss of. vital-l 20 AC or loss of DC power.- Also certain control system failure 1
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| 21 scenarios have also involved those kinds of failures or have ;
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| 22 been due to losses of those power supplies.
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| 23 Any improvements in the DC, vital AC, or a l 24 ' divisional cross tie can help reduce both.the frequency and 25 the impact of certain power losses. In a sense, .if you'take O ~
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| HERITAGE REPORTING CORPORATION (202) 628-4888 i i
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| () 405 l
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| 1 for example divisional cross ties and you try to ensure that 2 certain supposed independent divisional electrical power 3 cupplies are indeed not tied together, then a loss of one 4 would not propagate to another one. So that is an example 5 of where the 49 issue comes in. Similarly improvements in 6 reliability of the DC power sources, obviously you get fewer 7 plant transients, and challenges, and so forth, and 8 similarly on the vital AC side.
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| 9 Those slides were just to try to give the idea why 10 we decided to work these issues together. There was another 11 reason why we put them all together. We thought at one 12 point that we could issue one action to be taken by
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| () 13 utilities on all three of them, in other words one generic 14 letter. But as it turned out, that really was not too easy 15 to do, because of the different nature of the subjects, and 16 I will discuss that a little. And that is why now I am 17 going to talk about GI-48 and 49 together, and later talk 18 about GI A-30.
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| 19 This is just some basic background information, 20 some of it which I have covered and some of which you can 21 see on that diagram slide that we talked about. The vital 22 instrument buses do supply or are intended to supply 23 continuous AC power to certain very critical devices and 4
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| 24 loads such as the control systems, certain instrumentation, 25 and safety system logics.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| () 406 1 Typical p3 ants as k said include more than one 2 division and one bus to meet these requirements, and also in i 3 order to meet the single failure requirement. The power 4 sources to the vital AC bus typically include, as you can 5 see on the diagram, typically include some device to change 6 the DC to AC which is usually an invertor, and also 7 sometimes there is a backup or just another source of power 8 that they can switch between coming from some specially 9 regulated transformers. It has to be special transformers 10 because of the nature of the loads on there.
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| 11 As I also pointed out, electrical buses both AC 12 and DC may include interconnections, that is tie breakers, 13 for special operating conditions. I just wanted to point 14 out that cross tie capability may exist between redundant 15 divisions, redundant safety related buses, or between 16 multiple units at one sito. These cross ties can provide 17 very important flexibility. But in addition depending on 18 how they are used, they can compromise the independence as I 19 stated before, the independence of the various electrical 20 divisions.
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| 21 Therefore basically the summary of the safety 22 concern was what the problems with losses of these power 23 supplies can lead to such as I said transients through the l
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| 24 control system, loss of operator information, loss of 25 redundancy and safety systems. And the safety issue that HERITAGE REPORTING CORPORATION (202) 628-4888 I
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| \ _-
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| l
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| -)
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| r~s 407 i N-] l I was raised was that some plants may not have restrictions on ;
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| 2 continued operation, that is basically continued operation i
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| 3 and power with vital AC buses'or other sources, sources such l 4 as an invertor unavailable. l J
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| 5 Without some. adequate controls on the vital buses I J
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| 6 or on the' tie breakere, plants could be operating in
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| {
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| 7 situations where divisional redundancy and independence is 8 lost, and then they may be very rulnerable to certain loss !
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| l 9 of off-site power events or random failures of power '
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| 10 supplies.
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| l 11 MR. MICHELSON: I think that I have understood 12 that you were going to include certain system interaction I
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| {' 13 effects here, is that correct?
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| 14 MR. THATCHER: The system interaction effects come 15 in via the importance, really on this slide,_the.importance i
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| 16 of the transients, loss of operation information and so 17 forth. Those are the kinds of system interactions that can i
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| 18 occur. 1 29 MR. MICHELSON: Did you include studying system 20 interactions that may lead to spurious closing of the tie 21 breakers for instance out of phase or whatever, is that the 22 kind of thing that you looked at, or did you look at a more-23 limited set?
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| 24 MR. THATCHER: The aspect of the tie breakers, 25 there is a potential that someone could inadvertently close HERITAGE REPORTING CORPORATION (202) 628-4888
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| 'i .,
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| 408 I- .
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| 1 it.
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| 2 MR. MICHELSON: Or.'some thing could inadvertently-
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| .3 .close'it. It may be~a person or it might be_a system x
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| 4~ electrical effect, a' local failure or whatever.
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| 5- MR. THATCHER: There is that potential.
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| 6 MR. MICHELSON: Did you look at that sortlof thing 7- at all'under this 128 program?
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| 8 MR. THATCHER: 'We did'look at'the interlocks 9 associated with tie breakers and'that gets into the 10 interlocks both in the closing circuit and in the opening 11 circuit. There are certain aspects that you want to prevent 12
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| ~
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| against. I think that the example that you are bringing.out
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| {} 13 if you have two diesels operating on two independent systems 14 and then you close the tie breaker that they probably are 15' not going to be in parallel and you are going to have some 16 major problems.
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| 17 MR. MICHELSON: Something is going to happen.
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| 18 MR. THATCHER: So that is an interlocked and'a 1
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| 19 closed circuit. In addition s lot of plants provide
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| )
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| 20 interlocks for lack of a better term or contacts.
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| l 21 MR. MICHELSON: Now these are always safety grade {
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| 4 22 breakers, but are there safety grade controls for those 23 breakers as well?
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| 24 MR. THATCHER: Yes.
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| 25 MR. MICHELSON: Any actions at all, all actuations O HERITAGE REPORTING CORPORATION (202) 628-4888
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| /') .
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| () _
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| 409 4 1
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| 1 come from safety grade decision circuitry?
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| l 2 MR. THATCHER: Yes, that is my understanding, one 3 hundred percent. j l
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| 4 MR. MICHELSON: But they can still close on one 5 decision of course and that has 1;o be. And that can be 1
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| 6 generated by a local fire, flood or whatever.
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| 7 MR. THATCHER: I guess at this point I should make 8 the point which I think that I might have eliminated because 9 I had taken some of my slides out. We looked at the 10 interlock aspect for the possibility of providing more j 11 interlocks. We also looked at the possibility of declaring .)
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| I 12 that nobody should be allowed to use tie breakers at all.
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| (~'
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| (-) 13 In other words, they are there and they do compromise it.
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| /
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| l I
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| 14 MR. MICHELSON: Generally they are locked, are.
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| 15 they not, physically locked such as even with the electrical l 16 actuation that they could not be closed, are they that well "
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| 17 tied down?
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| 18 MR. THATCHER: In some plants to my knowledge they l 19 are. In fact in some plants you have to physically get a 20 breaker and put it in.
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| 21 MR. MICHELSON: Rack it in.
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| 22 MR. THATCHER: Rack it in.
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| 23 MR. MICHELSON: But that varies from plant to i 24 plant I gather.
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| 25 MR. THATCHER: The administrative controls over HERITAGE REPORTING CORPORATION (202) 628-4888
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| (/ 410 1 the breaker varies from plant to plant.
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| 2 MR. MICHELSON: A lot of the problem would go away 3 of course if you looked out literally so that you could not 4 in any way short of physical action get them activated.
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| 5 ' MR . THATCHER: Well, I guess that I want to go 6 back and say that we decided not to come up with an edict 7 that everybody eliminate your tie breakers, do not have 8 them, get them out of there or whatever. But on the other 9 hand, we look at the competing risk and acknowledge that 10 there is a lot of flexibility that can be gained. And we 11 did recognize that documents like some of the PRAs that have 12 been done that it can be an advantage in certain scenarios em
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| -) 13 to be able to interconnect cartain equipment under certain 14 situations.
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| 15 So we did acknowledge that and we decided that 16 that alternative for resolution was not the best way to go.
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| 17 What we decided on for the tie breakers was --
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| 18 MR. MICHELSON: Just before you get to that, how 19 do you prevent a tie breaker from becoming the focal point 20 of an inadvertent closure through fire or whatever, you 21 short the thing out and it stays closed -- do you have two 22 tie breakers always in series or you just have one, do you 23 not?
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| 24 MR. THATCHER: Not necessarily. l 4
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| gs 25 MR. MICHELSON: We know from a little bit of fire
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| <)
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| HERITAGE REPORTING CORPORATION (202) 628-4888 l 1
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| 4
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| /~N -
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| (,). 411 1 experience that' breaker cubicles on fire can cause physical 2 faulting on both sides of the tie buses. And it looks like 3 if you have a fire inLthe compartment that.it could-4' inactivateLboth diesel panels for~ instance, distribution-5 panels, unless there is anotherJbreaker at~the panel tied in-6 to clear this. Certainly there.is just~not a tie breaker 7 hard bussed to.the emergency bus, is it?
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| 8 MR. WYLIE: Well, I do not know.
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| 9- MR. MICHELSON: They do not show any here, but.I 10 thought t' hat there would be one at the bus itself, you know, 11 the board.
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| 12 What happens when you get a fire for whatever
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| () 13 reason-in the area?
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| 14 MR. WYLIE: The breaker.
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| 15 MR. MICHELSON: Yes, but even with.the breaker 16 racked out, these cubicle fires, would you run the chance 17 that with a fire on the bus that you short the buses?
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| 18 MR. WYLIE: Well, that is always true. 1 19 MR. MICHELSON: Right. But here you are tying two .
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| 20 different buses at a common point within a short physical l 21 distance of.each other like a foot. -i 22 MR. WYLIE: You are talking about just the bus. I 23 l MR. MICHELSON: The two buses are coming together 24 at the tie breaker within about a foot of each other more or 1
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| 25 less in the breaker compartment.
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| HERITAGE REPORTING CORPORATION (202) 628-4888 1
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| il i
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| 412
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| \
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| 11- MR. WYLIE: 'Of'' course, most of these that it makes 2 no difference'as to cable. l 3 MR. MICHELSON:' I just.did not. realize. I; ssw: the - ,
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| 4 drawing. I-do not recall that.other people'necessarilyndid-5' that. . I thought that.there was always aLbreaker right at i 6 the diesel bus'and a then a breaker.at:the other.end.. In-7 .other.words, you always'had two breakers.to perform;the tie !
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| 8 function.
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| 9 MR. WYLIE: I think that'is.true.
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| 10 MR. MICHELSON: Maybe this drawing is not good.
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| 11 MR. WYLIE: The one at the other end.
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| 12 MR. THATCHER: Yes, oftentimes. This is one that
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| {} 13 this drawing shows. This is only one division. There is 14 another division,. imagine another set.
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| 15 MR. MICHELSON: That is why I asked the question, 16 are there:two tie breakers, and you-said one I thought.
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| 17 MR. THATCHER: Some plants have two and some I 18 think have one.
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| 19 MR MICHELSON: I would not think that i one would ]
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| 1 20 ever be acceptable, j I
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| 21 MR. WYLIE: The site here only had one.
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| {
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| l 22 MR. THATCHER: I think so. I would have to go- ]
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| 1 23 back and look. I am.not sure. I 24 MR. MICHELSON: .Normally you have to have two to l
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| 25 take care of the breaker compartment. .Those can also be'
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| ]
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| t: 't HERITAGE REPORTING CORPORATION i (202) 628-4888 ;
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| 1
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| I ex !
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| (_) 413 1 physically explosive under certain conditions. Clearly the 2 answer is two in most cases. ,
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| 3 MR. WYLIN: I do not know in all cases.. That is l 4 in the later plants but not the earlier plants. ,
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| 5 MR. MICHELSON: I see.
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| 1 6 MR. THATCHER: I should clarify, as was pointed l 1
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| 7 out in the subcommittee, this slide'should read to help !
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| 8 prevent operation in situations. Tnere is no way through 9 administrative controls, procedures and whatever that you 10 can absolutely ensure that things will happen. So we are j 11 trying to take action that will help prevent operation in 12 situations which could degrade the independence of the j
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| ( -
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| (,)/ 13 safety related electrical equipment.
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| 14 Basically our resolution and I will show you a 15 slight modification was to verify that the tech specs !
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| 16 include appropriate provisions and to verify that the plant 17 procedures include the necessary corresponding controls. We 1
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| 18 also allowed the possibility that plants because of their i l
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| 19 very specific plant aspects that they may be able to give us 20 a basis for not needing such provisions, and we have allowed 21 for them providing such a justification.
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| 22 Now that is what the package that was sent down to i
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| 23 the ACRS had as the resolution in the generic letter. We 24 made one modification to that, well maybe you would consider
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| -, 25 it two. But the generic letter no longer requires technical HERITAGE REPORTING CORPORATION (202) 628-4888
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| _ _ __m
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| .. 414 l
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| 1 specification additions. Rather it-requires that plants j
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| - I 2 certify to the NRC that they have procedures or that they- ./
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| 3: have established a basis that they do'not need'such j
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| 4 procedures for the kinds of things that we are talking:
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| '5- 'about, keeping tie breakers open, keeping invertor available j 6 'and so forth.
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| 1 7 We use'the standard tech specs as a' basic guide, )
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| ~
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| 8 -but we are only asking for certification. It.is; expected-9 that future technical specification improvements should: j i
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| 10 include these aspects. As you may be aware, there.'is a 11 separate technical specification improvement program. - And j
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| 12 to my knowledge, these aspects are not something that is ]
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| O 13 beine provosed to be taken out of the tech svecs. have j
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| 14 checked with the tech spec improvement program, and indeed 15 these aspects that are talking about as far as controls on l 16 operation of tie breakers and vital' instrument buses are
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| _l 17 still in the technical specifications. So that is' basically: 1 18 the GI-48 and 49 resolution.
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| 19 A1. far as GI-30.goes, just a little bit of ;
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| 20 background. Again the DC sources are very important. They 21 are fed to the vital AC. They also provide. General Electric 22 breaker control and also there are some DC control systems.
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| '23 Just like the AC buses, typical plants include more than one 24 safety related DC source to meet the single failure 25 requirements.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| ]
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| 415-l j
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| 1 As I said, there's batteries, battery chargesfaro 2 shown on that other diagram.
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| Although the safety related DC 1
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| 3 power' systems'are-designed to be highly' reliable, and we. ]
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| : .I 4 believe they are,>there-have been some failures.
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| 5 We think that'there are' failures of concern. .
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| 5 6 There have been some. problems. They have to do:with i 7 failures due'to common maintenance practices on be.tteriec 8 and so forth. The inability'to detect battery problems. d 9 MR. MICHELSON: Now, this issue deals with the DC' 10 power supply not just the batteries, of course.
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| Il MR. THATCHER:' There's some aspects of the charge.
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| {
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| 12 MR. MICHELSON: I assume it deals then with the n
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| U 13 invertor. <
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| 14 MR. THATCHER: Well,-the invertor is more in issue ,
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| I
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| : 15. 48. .i i
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| 16 MR. MICHELSON: Well, one or the other. I thought 17 the' invertor was a part of the DC power supplies since they-18 use it for -- well, your drawing shows it a part of the DC j 19 power supply. l l
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| 20 That's not the important point.' The important l
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| 'l 21 point is, are you -- in the 128 then are you looking at the !
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| 22 systems interaction issues dealing with the solid state j 23 invertor, because those are generally, although not alwaya-24 solid state devices.
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| 25 MR. THATCHER: We aren't looking at detailed HERITAGE REPORTING CORPORATION (202) 628-4888 i ll 1
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| 1 I
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| le')
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| yj 416 )
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| l <
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| 1 studies to be performed for systems interaction when an 2 invertor -- for example, when an invertor fails.
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| 3 MR. MICHELSON: Or for when an invertor gete wat l 4 or when an invertor is overheated or whatever.
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| i 5 MR. THATCHER: Wsll, when an invertor gets wet.'
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| MR. MICHELSON:
| |
| 6 Has that kind of work been done or 7 is it going to be done or what? Secause it would be part of 8 the IPE. You got to give some of the IPE people some of' 9 this kind of information or they must have access to such J l
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| 10 information in doing a systems interaction study on an 11 invertor.
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| i 12 MR. THATCHER: What we did was, the systems f
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| 'T)
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| ( 13 interaction events that occurred involving invertor were all 14 produced in a report, NUREG/CR-4470. 1 15 MR. MICHELSON: It listed a bunch of events.
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| 16 MR. THATCHER: Right. l 17 MR. MICHELSON: That's right.
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| 18 MR. THATCHER: And we didn't go into whether they ]
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| 19 were caused by water, electrical transients, or whatever.
| |
| 20 What we did was, we decided that the way to handle it was to 21 make sure that the power supply was available in the 22 configuration that the plant was analyzed in. And the best 23 way to do that is to put administrative controls on the 24 certain electrical aspects such as tie-breakers, uuch as s 25 invertor, such as vital buses.
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| U HERITAGE REPORTING CORPORATION (202) 628-4888
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| i ,
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| i i
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| ~
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| j H 417 1 ct .
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| : 1. That's 4hylI said'it wasEmore in the 48.49 aspect 2 'than itLis on the 8.30. And also, you really havsn't - -- )
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| l
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| ~3. we've seen some DC failure caus'e problems. ,
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| j l 4 MR. : MICHELSON:' 'You've seen some-invertor problems ,
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| L- due.te gatting wet in the LERs.
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| i 6 MR. THATCHER:. There'have been'some..
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| 7 MR. MICHELSON: Yes) indeed. M 8- MR.1 THATCHER: Yes.
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| 9 MR;~MICHELSON: And what puzzles me a little bit 10 is, you know, if I were.an IPE person having to do an IPE 11 now on my plant, what do'I do with the invertor in terms of 12 where do I-get soms guidance on what kindfof things to; worry I 13 about or think about other than~a fete exe.mples which you, 14 indeed, have published. But that's only examples -- a small 15 set of=n11 the kinds of things that could possibly happen.
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| 16 MR. TEATCHEA:- Well,-i think there's --
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| 17 MR. MICHELSON: So how do I get some guidance on 18 deciding whether my plant is safe frem the viewpoint of
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| ) 19 certain events that might involve one or more invertor.
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| 20 In some-cases I-know they can easily-involve more 21 than one invertor and not necessarily in the same train. h 1
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| 22 MR. THATCHER: Well, I guess I don't know of any \
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| 1 23 cases where it involves more.
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| l {'
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| 24- MR. MICHELSON: You better walk around the plants 25 and look to see where these power supplies -- often times 1 0 -
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| ll 1 they park the invertor out-.in openfarcas as. opposed to near '
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| 2 ~ the back rooms.
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| , . .l 3 - MR.' THATCHER: I haven't been to;every plant 1and,- j 4' you know, , you- stated- that you saw'sonse; '. I : just haven' t seen ,
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| 1 b any.
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| 6 But anyway, the point I think is that'the:failuxe.s' 1
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| -7 do occur and we think the most important-thing is to. attack 8 it to make sure that the plant.is operated in the. assumed..
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| 9- analyzed condition.
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| 10 MR. MICHELSON: And if you do'that I have to 11 determine --
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| 12 MR. THATCHER: So as far as the IPE'and guidance:
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| 13 available to them,.I thinkLthere is excellent - -well, Mr.
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| 14 Wylie probably can give more than I can -- but excellent--
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| 15 IEEE standards on'both the invertor,Lbattery charges, for 16 example.
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| 17 MR. MICHELSON: Now, let's narrow it --
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| 18 MR. THATCHER: And there's also INPO documents.
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| 19 MR , MICHELSON: My questions are only_related to 20 systems interaction and not into the quality of the design 21 process and so forth. l h
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| 22 MR. THATCHER: Mell, I think those all have j 23 systems interaction.
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| 24 MR. MICHELSON: I would like to go and read about :
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| l' 25 standards written on how to do systems interaction studies.
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| HERITAGE REPORTING CORPORATION .;
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| j l' ' MR . THATCHER: Well, I didn't say that. 1 2 MR. MICHEL8ON: Well, that's what"we're'. talking 3 about. IPE'is a' study., It's an examination. And the' '
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| l
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| '4 specific question here is: how do I. examine my invertor now- ..
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| l
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| '5 from the viewpoint of systems interaction? What do.:I do?.- j 6' MR. THATCHER: We're not giving them guidance on ,
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| i 7 that. ;l tl 8 MR. MICHELSON:' Where~is that' guidance. coming 9 from? You are asking them to do it under the IPE program, 10 maybe.
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| 11 MR .. BAER: No. We said we would give them an 12 option to justify why they weren't doing certain actions. ,
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| l O 13 xa ra^rcasa: re -
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| 14 MR. BAER: Particularly in A-30.
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| 15 .MR. THATCHER; I didn't get that far.yet. Let me 16 get to the A-30 resolution where the IPE aspect ties up. So 17 much for that.
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| 18 MR. WYLIE: I think Carl has got a valid point is,
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| ^
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| 19 you're talking about systems interactions'that affect vital 20 AC instrumentation systems. And where is that going to be 21 done?
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| 22 MR. MICHELSON: Yes. I thought that's what A-17 23 said was going to be done on 128, and I'm just trying to 24 pursue it a little bit-now to see -- because you said 25 earlier today that you're going to tell me during this O HERITAGE REPORTING CORPORATION (202) 628-4888
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| () 420 1 discussion of how you.were bringing A-17 in. Because you 2 agreed that the statement was in the 128 description.
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| 3 MR. BAER: I also said that I thought maybe our 4 statement in A-17 was too broadly written.
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| 5 MR. MICHELSON: Well, I'm not sure it was 6 correctly written at all. But --
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| 7 MR. THATCHER: I think the --
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| 8 MR. WYLIE: It depends on where you --
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| 9 MR. MICHELSON: I'm not sure it's even -- well, 10 I'm trying to figure out if it was narrower than that where 11 do I even find the narrow.
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| 12 MR. BAER: Well, under A-17 looking at operating 13 experience we saw a lot of events involving power supplies.
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| 14 Fair statement?
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| 15 MR. THATCHER: Fair statement.
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| 16 MR. BAER: And what we're trying to do under 128 17 is avoid some of those events. Not all of them but some of 18 them. And certainly the ones we saw anyhow. Not every 19 conceivable one, but I think the major ones that we saw were 20 tied -- were associated either with the questions on the 21 tie-breakers or with lack of maintenance and surveillance a 22 monitoring of batteries.
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| 23 So we took the approach of trying to avoid the 24 situation, not necessarily to-eliminate all possible systems 25 interaction. But to avoid, at least, the situations we saw HERITAGE REPORTING CORPORATION (202) 628-4888
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| . _ - - - . -- ~ .. . =_ . _ _ - _ _ - _ _ _ _ _ -
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| .1 from' operating' experience.t 2 MR. .MICHELSON: .So I. guess what you're saying[is, .l
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| .1
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| .3 at least for the' events that:have occurred before the..IPE 4 person >can at least assure himself his plant lisiokay-from;, <
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| 5 .that?particular' event' viewpoint. Is that.what,you're. -]
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| 6 saying?' u 7 -MR. BAER: I believes--' I think'so. ?Yes.
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| To'my.
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| 8 understanding.
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| 9 MR. MICHELSON: Of course, that's.a very limited !
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| 10 set.
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| l MR. THATCHER.: Well,.I. don't'know what.the IPE:
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| 12- person is thinking.
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| O 13 an aa=a= - ==* ir e ee1 too* ** -
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| ceio= **
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| * 14 we're hoping they will take as a result of 128,.would that 15 hanale the operating events that have'been' observed?-
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| 16 MR. THATCHER: I can't say that'in general, I' 17 didn't look at all the operating events.
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| 18 MR. BAER: But the sort-of things that came up in 19 A-17 is fairly high vulnerability.
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| 20 MR.-THATCHER: Well,-the-certain things that came 21 up in A-17 were losses of power supply and.what happens. A 22 lot of those things, specific actions were taken on such as 23 INE bulletins were written. And threa; people were required 24- to respond that they knew-what happened when they lost a 25 vital bus, for example. That's certainly part of the study.
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| O BERITAGE REPORTING CORPORATION (202) 628-4888
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| p)
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| (_ 422 1 MR. MICHELSON: The instantaneous loss of a vital 2 bus is a fairly easy thing to analyze. That's not what 3 we're talking about here. We're talking about heating up 4 the invertor and certain of the' components start to wander 5 or change states in one direction. Certain change in other 6 direction. And it might change differently next day than 7 the previous day. That sort of thing.
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| 8 That's really, I thought, what you were kind of -
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| 9 thinking about in systems interaction. But apparently, 10 you're looking at just the pure loss of power and everything 11 is supposed to fail safe and you just go through and verify 12 whether that's true.
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| 13 But degraded voltage, for instance, as the voltage 14 drops 30 percent you don't know what's going to happen.
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| 15 Those happens have happened already, too.
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| 16 17 18 19 20 21 22 23 '
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| s,- .423 1 MR. THATCHER: .First of all, I disagree--I know
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| :2 ' exactly what would happen when they instantaneously, lost 3 . power supply.
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| .4 'MR. MICHELSON:- Well, that's being kind. ]
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| 5' MR. THATCHER: That's been proven over and-over 6 again.- But.I will say that we have taken some of those. i 7 concerns you sort of outlined and put them,into the MSRP 8 Program. ]
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| 9 MR. MICHELSON: I' don't think that's a reasonable.
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| 10 place to cope with them. But then don't tell me they are in 11 the 128 Resolution because I don't--or I haven't crossed it 12 yet or you haven't told me yet where it is, if it is. I
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| } 13 would suggest strongly you remove.the statement entirely 14 from 128 and then don't claim you are resolving part of the-
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| .i 15 systems interaction problem there unless you really are.
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| 16 MR. THATCHER: Well, I think-it's part. It's 17 probably that limited set we talked about before. Certainly I
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| 18 if you take a system like this and you close the tie breaker i 19 and take the battery out over here, now you lose this one 20 battery. You are going to lose and cascade across other 21 systems.
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| l 22 And it's hidden in the sense that they shouldn't 23 have had that breaker closed. So I say we've solved some
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| ]
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| 24 limited set. I don't know how to say--
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| 25 MR. MICHELSON: You example doesn't meet your HERITAGE REPORTING CORPORATION (202) 628-4888
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| 1 definition of system interaction as you are looking.at it.
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| 2 That's a straightforward failure mode and effect analysis
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| .3 .you'just--
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| 4 MR. THATCHER:- No. -No,.it isn't. Because the. guy 5 that did the fail mode and effects analysis, we are~ going.to 6 assume.that breaker's closed.
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| 7- MR. M.7CHELSON: -He'does that' arbitrarily. That's 8' the'way you do an FEMA.
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| 9 MR. THATCHER: Well, I don't want to get into'how-10 you do it. But I just said that'if someone.doesn't have 11 controls on those breakers and it's left closed, he's going-12 to set himself up for a hidden dependency.. It's hidden.
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| 13 because he doesn't know that it was-closed.
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| 14 Now, you know, I-don't know what else we can:say.
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| 15 about that.
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| I 16 DR. REMICK: Gentlemen, where we stand in the j 17 presentation, we are at about at maximum ten minutes yet.
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| 18 MR. THATCHER: The resolution is basically this, .
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| 19 and I have a subsequent addition because of'our 20 consideration of IPE.
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| 21 As far as A30 is concerned, there is a number of I
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| 22 questions we are asking industry to respond to.what they.are !
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| 23' doing in the areas of maintenance, testing and monitoring of 24 their battery and DC systems. We are asking the questions
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| 25 because we believe that through industry activities, l O !
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| (202) 628-4888
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| 1 425-1 particularly'INPO,ANECandkEEEhasalsoaddressedthese 2 areas and we think that a. lot of the improvements have l
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| 3 already been made.
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| i 4 'We'are proposing-to gather some information j
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| 5 pursuant'to 5050F that proposes to question:the plants about-6- their' improvements. .And if improvements have not been made,,
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| 7 question the basis for why they don't think'they need to do. 1 8 them.
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| 9 MP. WYLIE: Before you leave that, Dale, let me j 10 ask a question.
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| i 11 In your 5054' letter where you ask does the control I 12 room at this unit have the'following separate independently !
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| 13 enunciated indications for provision of DC power plants,'is 14 that question to be interpreted does the_ control' room-15 operators have available to them this type of information, j
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| 16 or is it in the control room is what you are asking? i i
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| 17 MR. THATCHER:
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| Well, the question is in the-18 control room. But I would think that-- 6 19 MR. WYLIE: I think you've got a problem if that's- j 20 the case. !
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| i 21 MR. THATCHER: Well, understand that the questions i 22 are aimed at, let's say, the ultimate. We understand that !
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| 23 people may group alarms. That's even recommended in some 24 cases. -They may provide local-- l 25 MR. WYLIE: That's normal practice.
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| O 42e ,
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| 1 MR. THATCHER: They may provide--well, I think 2 the--you know, the IEEE, what is it, 9646 or'whatever 3 . numbers?--recommends that they have those same alarms.in the j 4 control room, and I'think--
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| l 5 MR. WYLIE: Some' people do, I know, recommend 6 that, but--
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| : 7. MR. THATCHER: I would say that we are asking for 8- what we think would be the up-to-date best way to do it, but .
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| : 9. we do understand that there.is some possibility that certain 1 10 ' things have to be grouped or that certain' indications may )
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| 11 have to be provided locally as opposed to control room. But ..
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| ~
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| 12 Af indeed that local indication is reflected in some kind of l O 13 enunciation in the main contro1 room that ther een teke c re I 14 of--
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| 15 MR. WYLIE: The thing that bothered me a..little 16 bit when I read it, it implied that these things should be !
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| 17 in the control room. I 18 MR. THATCHER: Well, maybe I should use the INPO. I 19 SOER words. It said "Should be avai'lable to the operator."
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| 20 MR. WYLIE: "--available to ths operator."
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| 21 MR. THATCHER: Mayb'e we should do that.
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| 22 MR. WYLIE: I mean, when I read it, it says, "Does 23 the control room at this unit have this- " That to me says 24 you want it that way. That the Commission wants it that 25 way.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| 427 1: MR.; THATCHER:- Well--
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| 2- MR. WYLIE: And I don't think you'd want it that' 3- way, do you?. The operator can't:do much'about much.of this:
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| 4- ' stuff. .He's got to send somebody out down-to the batteries 5 'to where the: chargers are or'whatever and all he needs;to;
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| : 6. know-is he's got' problems.
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| 7.' MR. THATCHER: Yeah. I thinkithat they would 8 provide, as part.of their' justification, that exact. point'.
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| >9 That we don'ti' have it in the control room. =
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| 10 The problem is asking the questions in'such a'wayJ 11 that we don't-just get all yes's to everything we ask, 12 because we might as well not-ask the question.
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| 13 So they are trying to give.them a' standard--
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| 14 MR. WYLIE: Turn around and ask them where they.
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| 15 got it.
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| 16 MR. THATCHER: ' Yeah.
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| 17 MR. WYLIE: Say "Where did you get this.
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| 18 indication?"
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| 19 MR. THATCHER: Yeah. And then we get a list of 20 all kinds of different places--
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| l 21 MR. WYLIE: You are going to have to go'back and 22 do it anyhow, aren't you? I mean, if you are.really. going 23 to assess what they've got--
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| -24 MR. THATCHER: Well, the thing is>that--
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| 25 MR. WYLIE: Or do it like you say the SOER says, HERITAGE REPORTING CORPORATION (202) 628-4888
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| O '428 1 and that says does the operator have available to him this 2 information?
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| 3 MR. TdATCHER: I think.I can put those words in.
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| 4 MR. WYLIE: Okay.
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| I'm juist trying. to think! whether -
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| 5 MR. THATCHER:
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| 6 that's going to give me a problem when the responses come7 7 back in the way we look at these responses, because we are 8 trying to eliminate a lot of problems infinterpreting the 9 questions and if someone read that'and said,~"Gea, I'm
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| : 10. supposed to have this in.the control room, but.they gave me 11 a response that, no, I don't but it is available to the-12 operator some other way." I think we would accept that.
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| 13 MR. WYLIE: Yeah, I would think so, because all 14 the operator really needs to know is that the battery 15 charger has problems or losing voltage or what have you, and 16 he's going to have to send somebody down there that knows 17 something about battery chargers and batteries to fix it.
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| 18 He's not going to go out and do it-himself.
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| 19 MR. THATCHER: I agree. I agree.
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| 20 I did.want to point out as far as the IPE goes 21 that as I stated, there's some requests for why they don't l 22 have it, if they answer no to a question. We tried to keep 23 a majority of the questions yes or no answers. Two of the 24 questions involve possible-supporting information to justify 25 a "no" answer as we've been talking about here.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| yO.- 429-I 1l While.we:do acknowlege thatian'.IPE could provideLa; 1: 2. ' vehicle for: addressing USI's' and GI's.' That was shated in 3' the IPE Generic Letter. . So we are proposing to.giveithe.
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| .4 = licensee--as Bob mentionef,4give the licensees the option (of-15' addressing those' questions,.the,ones where1they. provide the!
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| 6- basis,.or maybe go off and do-an evaluationLof;why?they
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| .7 Edon't.think they need something, to do it;under.IPE.
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| 8 Now, I think'that's whatLthe subcommittee was kind-9- of after yesterday--
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| 10' MR. WYLIE: Yes.
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| But' 11- MR. THATCHER: --but help me if:I'm" wrong.
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| 12 that's'the. kind of idea that'we put in it.'
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| () 13 -I'actually have some of the.words,L if you want to 14 look at the words that I'm going to.put'in1the-letter, but I 15 I'm not too sure that would serve any purpose.' q i
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| 16 Do you think that's' helpful?
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| I 17 MR. BAER: I'd be happy to show you the proposed-18 words. -!
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| I 19 MR. WYLIE: Yes, if you have them . l
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| : 20. MR. THATCHER: This. Insert liwould.go in_the l
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| 21 Generic Letter after the point where.we saysthat it's !
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| i 22 required ~ response, we proposeLto state this--that it should 23 be noted--you don't have.this in your package. I just made- ]
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| 24 this.- "It'should be noted that the NRC has recognized that 25- an individual plant examination for IPE, for~ severe accident l HERITAGE REPORTING. CORPORATION ;
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| -(202) ~628-4688 i
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| m_ ___i -
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| t i:
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| (~3 430 {
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| t/ l 1 vulnerabilities, could provide a vehicle for addressing -l 2 unresolved safety / generic safety issues, an' outlined in l l
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| 3 Generic Letter 0020. Therefore, the attachment to this 4 letter gives the option of providing certain supporting l 5 information as part of the IPE instead of supplying it in i
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| .i 6 response to this letter." j i
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| 7 Then in the attachment to that Generic Letter on j i
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| 8 A30, we propose to put after the introduction where we say 9 " Questions," it says you've got to respond to all these 10 questions. We say with "Two possible exceptions. The l 11 exceptions are. For questions involving supporting type i 12 information specifically Question No. 5 and 8, instead of I
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| (} 13 developing and supplying the information in response to this 14 letter, you may commit to further evaluate the need for such i 15 provision during the performance of your IPE. If you select 16 this option, you are required to, number one, so state in 17 response to there questions." That's just to keep our 18 records straight.
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| 19 "And, two, commit to explicitly address Question 5 20 and 8 in your IPE submittal." ;
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| 21 And that's the mechanism of how we see it putting 22 it in, and as Bob said, we basically cleared that through 23 our management which also has responsibility for the IPE>
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| 24 IGA. MICHELSON: Let me ask--when people did their 25 fire effects analysis for these plants, did they--do you t'
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| lll 431 1- know whether or not they considered some of the kinds of 2 questions and issues that you raised and resolved in Generic 3 Issue 1287 4 MR. THATCHER: As far as--well, when they 5 analyzed--you are talking about Appendix R reviews?
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| 6 MR. MICHELSON: Essentially.
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| 7 MR. THATCHER: Okay. Well, the focus there is.the 8 availability of--the fire is postulated and then.the ability 9 to shut down after the fire.
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| 10 MR. MICHELSON: That's right.
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| 11 MR. THATCHER: Okay. If one could state that 12 inventer A is in a certain fire zone and not effected in 13 another fire zone, then I would imagine they probably 14 assumed that inventer B was available.
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| 15 If they were in the same fire zone, they would 16 have to assume they were all destroyed.-
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| 17 MR. MICHELSON: Well, let's assume for the moment 18 that the fire is in the zone that the first inventer is in.
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| 19 However, the fire isn't necessarily involving the inventer 20 yet. It's off to the side a little ways. But it's 21 proceeding to heat the inventer up in the process.
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| 22 That inventer now starts to do certain kinds of 23 things because of the elevated temperature on the solid 24 state components. Now, that's stage one.
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| 25 Stage two the fire may be sufficient such as the HERITAGE REPORTING CORPORATION (202) 628-4888
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| - 9 i
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| _i 432 -4 3' 'other inventer may not be far enough away or the_ smoke:and i i'
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| 2 the heat has migrated over and set.off the fire prot'ection 3
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| in that area and wet down that. inventer and so forth. But 4 we won't'get into_that for the' moment..
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| 5 In the first' zone, as'thatiinventer proceeds;to
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| . I 6 hsat up, are those effects included somehow in doing..an 7: ' Appendix,R analysis to make sure thatiit wasn't now.' causing, 8 things to happen'or not to happen,_you know, to get a~ proper 9 addressing of.the' safe shutdown?
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| 10 MR. THATCHER: I'm no expert on the Appendix R' 11 reviews. You'll have to talk to people.. But.I do 12 understand that not so much that they looked at what.happens ,
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| 13 to the inventer, but.they.-looked at the possibility.that 14 certain equipment could take inadvertent actions.
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| 15 And I personally think that's.probably the way to 1 16 go after it. I don't think you can look at heating the I
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| 17 inventer to 65 degrees and then check it at 66 and 77 and 89 -l 18 and 95 or whatever.
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| i 19 You can find all the different things, but if you. l j
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| 20 do look at what equipment that is involved in, like--I'm j l
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| 21 almost positive, but, for example,.they were required to-l 22 check the circuits that controlled valves that can give you' ]
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| 23 a LOCA,outside containment. I don't know. Probably some of 24 you gentlemen are more expert on.the fire review than I am.
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| i 25 But that's the kind of thing of the inadvertent action that 0
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| 1 HERITAGE REPORTING CORPORATION !
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| _ - _ _ _ - - _ - - - - - - _ - - - - -- - - a
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| i1 llk 433 1 you'd be worried about.
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| 2 MR. MICHELSON: Well, they were required to do 3 that checking on the interface valves. What I'm wondering 4 about is how far back did they look for the possibilities of.
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| 5 having falso signals or lack of a power to close the valve 6 if it was normally open like, say, on the letdown line of a 7 boiling water reactor.
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| 8 MR. TRATCHER: Yeah.
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| 9 MR. MICHELSON: How far b'ack did they chase'to see 10 if they had the power with which to do the job. That sort 11 of thing.
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| 12 MR. THATCHER: I don't know how far back they 13 went. I think the rule specified circuits or something to 14 that effect.
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| 15 MR. MICHELSON: Unfortunately Appendix R doesn't 16 write such kind of detailed rules.
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| Just like we don't have 17 rules on how to do systems interaction.
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| 18 DR. REMICK: Gentlemen, I think we've spent about 19 as much time as we can on this.
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| 20 Mr. Wylie, do you have any concluding comments on 21 this?
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| 22 MR. WYLIE: No. We'll prepare a letter. All 23 right. If anybody's got any input-- i 24 DR. REMICK: Is the staff here for the next issue?
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| 25 As a result of those comments in the ACRS letter, HERITAGE REPORTING CORPORATION (202) 628-4888 s
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| 434 V
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| .]
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| 1 the staff provided the Commission with several options on f 2 how the staff might proceed, and the Commission chose to 3 have the staff prepare a Notice of Proposed Rulemaking i
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| 4 providing two options or alternatives and asking for public
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| 5 comment.
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| 6 Those two alternatives, the first of which was i 7 basically all degrees for senior operators. And the second 8 alternative was degrees for all shift supervisors. In other 9 words, a smaller subset of licensed senior operators.
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| 10 There were about, if I recall, about 250.public 11 comments provided on that Notice of Proposed Rulemaking of 12 which I recall about 95 percent were opposed. q p 13 Recently the Commission therefore decided that it-14 would not proceed with rulemaking. However, it will attempt l j
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| 15 to bring this to some kind of resolution because it's been 16 going on for close to a decade by issuing a Policy Statement 17 in which the Commission would express its views on the 18 subject of. educational requirements for senior operators and 19 shift supervisors. ,
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| 20 And the Commission indicated that it wanted ACRS 21 to address the Policy Statement that was being developed.
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| 22 Now, this Policy Statement was actually in large part 23 developed by the Commission offices themselves in contrast 24 to the staff. But the staff, the NRC staff, the EDO staff, 25 has been given the job of pulling this together and bringing A
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| l HERITAGE REPORTING CORPORATION (202) 628-4888 r
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| 1 to ACRS-and so ferth.
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| 2 We had a subcommittee meeting. yesterday--excuse; L
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| 3 me, two days ago--in which we had a lively discussion of the 4 subject. The subcommittee.did not come out with-anyLkindiof
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| : 5. a consensus. Welhad comments?anywhere from varying,fwell,.
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| f if this is so:important that'a: Policy ~ Statement should be; 7 issued encouraging people to get' degrees and not alls senior.
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| 8 . operators get-degrees, but encourage them, some to get them,.
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| 9 then perhaps it should'be aurule.
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| 10 Others were that perhaps thereishould'be a. Policy 11 Statement but this ain't'it. Others were'that "have no 12 objection to a Policy. Statement but I think it could be
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| () 13 written in a page or a page and a half." - 'Other comments 14 were that."I think a Policy Statement should'be issued but I 15 think it could just very simply endorse theTINPO top down 16 approach that they developed on how to attain 17 professionalism in managing nuclear power plants."
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| 18 There were two,on the subcommittee'that I think.
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| e-19 favored, definitely favored, issuance of a Policy Statement.
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| 20 along the lines of the draft that we-were given.
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| 21 There were a number of other specific editorial-22 type of suggestions. Things'1ike if the' Commission is not-23 seeking that all senior operators eventually have degrees, 24 then'they~should point out that they are looking for a mix 25 and so forth. It should be more clearly stated.
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| BERITAGE REPORTING CORPORATION (202) 628-4888 l
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| 1
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| 'O 436 i i
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| 1 Mr. CarrollIseeksnothere, but he had a 2 concern that there's a statement in there which would 1
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| 3 encourage the utilities to hire degreed engineers in entry- I 4 level positions, in operating staff positions. He was 5 concerned that if that meant entry-level positions meaning 6 auxiliary operators, or in other words, non-licensed 7 operators, then the cases of some utilities, because of 8 union concerns and so forth, they could just not do that and I 9 therefore that should be clarified and we actually did 10 propose some wording changes. .
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| 11 My understanding is that the NRC staff has been in ;
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| 12 discussions with the Commission offices after the 13 subcommittee meeting, indicated some'of these concerns. The 14 editorial type of things that were suggested. My 0
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| 15 understanding that they were sure that it was not the intent i 16 of the Commission to issue a Policy Statement which 17 basically said "We want all senior operators to eventually 18 have degrees." That they are seeking a mix. And assurance (
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| 19 that it was not intended that all degreed people come in and 20 be auxiliary operators as that did not make sense.
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| 21 That's my understanding and the staff can correct 22 me if I'm wrong in those discussions.
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| 23 And so the staff feels that they are able to 24 accommodate a number of the comments that-were made at the 25 subcommittee meeting. But the subcommittee is not in a HERITAGE REPORTING CORPORATION (202) 628-4888
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| 1
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| j 1 position where we have a consensus one way.or theLother.- !
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| 1 2- And we had a spectrum.-
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| 3 So the staff'is here. They-are going to tell.us .)
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| l 4 'about the Policy' Statement. l've asked them to emphasize' l 5 the discussion of. the proposed Policy Statement. They are 6 going to give us a little %.- of background but not spend j 7 too awfully much time'on the details of the advance Notice ;
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| 8 of Proposed Rulemaking or too much details on theLProposedL 9 Rule. Those are behind us.-
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| 4 10 What is before us is the Proposed Policy Statement 11 which the Commission has asked us to address and it's my 12 understanding that the Commission wanted.us,to see are there' 13 any major technical clitches in what is being proposed.
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| 14 So with that, I will turn the meeting over to 15 Zoltan and ask that you lead us through the-discussion. ;
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| 16 Do any other of the subcommittee members which to 1
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| 17 make a comment, by the way, at this time?
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| 18 If not, please proceed, Zoltan.
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| 19 MR. LEWIS: Will you at some point--one thing 20 that's always troubled me is the problem that we all know, !
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| 21 those of us who are at the universities, what the-market is l 22 for graduate engineers. And will you address the kinds of 23 engineers that you might get to take these jobs as engineers l 24 compared with what graduate: engineers can-in fact do in the 25 outside commercial world.
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| q 438 V
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| 1 I have a feeling they can get better paid working 2 elsewhere, so you don't want to commit yourself to mediocre 3 degreed engineers, the ones who can't get jobs elsewhere.
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| 4 It's a problem that's always bothered me. Maybe it's not a 5 real problem. But will you address that sort of question?
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| 6 MR. ROSZTOCZY: I certainly can address that.
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| 7 MR. LEWIS: Okay, great.
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| 8 MR. ROSZTOCZY: I'm Zoltan Rosztoczy from the RES 9 staff. We also have here today John Telford and Mort 10 Fleishman, who has been working on both the rule and also ,
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| i 11 the Policy Statement. -I i
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| 12 He wrote the rule which was put out for public I A
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| () 13 comment. He also wrote the version of the Policy Statement. )
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| l 14 DR. REMICK:
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| While Zoltan is getting hooked up 15
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| ~
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| there, I should also point out that in the request for ACRS 16 to review, Professor Roberts specifically asked us to look 17 at the question of encouraging utilities to h1re people with 18 degrees. Should the encouragement be degrees from I 19 accredited institutions, and later on in our discussion Herm 20 has gotten some clarifications of more specifically what 21 Commissioner Roberts had in mind.
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| 22 MR. ROSZTOCZY: What I would like to do today is 23 to make a few comments on where are we today and then 24 summarize briefly the proposed rule that was recently put l 25 out for public comment. Discuss our evaluation of the HERITAGE REPORTING CORPORATION (202) 628-4888
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| 439-1 comments and then turn to the proposed Policy Statement.
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| 2 The proposed Policy Statement is the main part and 3 the important part of the ' discussion because1that's - the one 4- that you are being asked to comment on.
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| 5 And then finally I;will just have a brief 6 . comparison between what would the rule accomplish and what' 7~ do we expect that the Policy Statement,is going to 8- accomplish. So what.are the practical differences _for the 9 . future depending on which way the. Commission.goes.:
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| 10 The Commission, by,the way, just about decided to -
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| 11 .go with the Policy Statement.
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| 12 In terms of.the background,'as it was mentioned 13 earlier, the proposed rule'was issued for public comment.at-14 the end of December. The-comment period' ended'at the end of' 15
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| ~
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| March. We have listed the staff requirements memorandum 16 from the Commission in May, which indicated that the 17 Commission would like us to prepare together with the 18 Commission staff a proposed Policy Statement.---
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| 19 Since that, we have evaluated the comments and-20 also prepared the proposed. Policy Statement-and this is 21 presently on the Commission level for their consideration.
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| 22 Obviously, they are not going to make a final decision until 23 they hear your comments.
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| 24 In terms of the future, what is4 expected--we c 1
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| 25 expect that there will be two actions in the future. One of HERITAGE REPORTING CORPORATION I (202) 628-4888 !
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| (Il 1 them is that the Commission is going to formally withdraw 2 the proposed rule. And then the second one is that they are 3 going to issue the Policy Statement.
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| 4 What was in the proposed rule? The proposed rule, 5 which was issued in December, had basically two options in 6 it. The idea of issuing two options for public comments was 7 that after the public comments, the Commission could decide 8 vhich one of these rules to issue, if either. And possibly 9 also to issue some combination of the two options.
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| 10 The.first option was basically oriented to senior 11 operators. So the-ones who would have had some educational 12 requirements were the senior operators. The requirement was g 13 a Bachelor's Degree in Engineering or Engineering Technology 14 or Physical Sciences.
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| 15 Also it was indicated that there would be a four 16 years grace period and this would be effective only four 17 years after the rule is actually issued.
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| 18 In addition to having the educational 19 requirements--
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| 20 MR. MICHELSON: Excuse me. You skipped over the 21 second bullet. "Other Bachelor's Degrees accepted on a 22 case-by-case basis.,"
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| 23 HR. ROSZTOCZY: That's correct.
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| 24 MR. MICHELSON: Does that mean accepted by NRC or 25 accepted by the utility?
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| O HERITAGE REPORTING CORPORATION (202) 628-4888
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| ~441' 1 MR. ROSZTOCZY: NRC.
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| 2 MR.EMICHELSON: _So youLwould have to review-any 3 -deviation'from.the first requirement?
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| 4 MR. ROSZTOCZY: Yes.
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| .5 MR. MICHELSON:- Okay.- Thank you.:
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| 6 MR. CATTON:' Why isn't there;any-equivalency; 7- statement?
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| -8 MR. ROSZTOCZY: -Yes. The earlier version:had an 9 . equivalency--other requirements had equivalency. statements 10 like I believe the Chief Technical Advisor has An 11 equivalency statement, but purposely there.was a decision 12 not to include an equivalency statement.
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| ( 13- The equivalency normally means that the~ utility,- )
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| 14 on its own, can decide if an individual has!the equivalent a
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| 'i 15 of a Bachelor's Degree and on that basis-proceed with i 16 someone who has no documented degree..
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| 17 This option here would have required that they j 18 must have a degree along these lines and would not accept an l 19 equivalency. It was a conscious decision.
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| 20 MR. CATTON: The. State of California will accept ~a 21 Bachelor's Degree or the equivalent, ,
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| 22 DR. REMICK: Ivan, let me repeat that that is l
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| 23 being presented for background information. It has nothing-24 .to'do with the Policy Statement and debating what should 25 have been in that proposed rule I think is not what we are H3RITAGE REPORTING CORPORATION (202) E28-4808
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| O.
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| l' about.today.
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| i 2 MR..ROSZTOCZY: That's~ correct." lI intend to 3 cover'this just very briefly just to give you an idea of 4 what would have been.in the' rule.. .i S The.other set of requirements which was on the
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| ~6 rule related to experience in the' plant inLorder to achieve.
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| 7 the senior operator: position. 'It included three years of-8 . experience instead of the current two years. And it-9 specified that a certain part of it--like one' year has to be 10 at greater than 20 percent power and six months of it has to 11 be at the plant where the lic$nse is obtained.
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| 12- There was.one other important position. The-() 13 grandfathering that at this date, which is-four years in the 14 future after the effectiveLdate of the rule, and everyone 15 who at that time has a senior operator's license, would be >
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| 16 exempt from this requirement for the rest of his life.
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| 17 The second option in the rule differed in terms'of j 18 who would have to have an educational requirement. This'did i 19 not set any educational requirement for senior operators. ,
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| 1 20 Instead, it set educational requirements for the shift l 21 supervisor only, i 22 The shift supervisor for the purpose of the rule 23 was defined to be one individual in each control room. So R 4
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| 24 if you operate two units out of one control-room, it would 25 require.that there would be one designated shift supervisor HERITAGE REPORTING CORPORATION (202) 628-4888 j i
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| i J^N 443 >
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| %-) 1 I -
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| l l 1 to whom the rule would apply. {
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| 2 It again had the four years after the effective 3 date and it had in terms of requirement three options, and 4 one of the three options would have to be satisfied..
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| 5 The first option is a Bachelor's Degree, but this i 6 was a little bit more restricted than in the option because 7 it specified that it was from an ABET-accredited program. j l
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| 8 It would accept instead of the Bachelor's Degree a j 9 professional engineering license issued by the state.- And 4 1
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| 10 it would also accept a Bachelor's Degree, any Bachelor's j 11 Degree, with any major, if it's combined with an AI 12 certificate. The AI certificate is an engineering and j
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| () 13 training certificate that can be obtained through passing an 14 examination. ,
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| 15 in terms of the additional experience requirement, 16 it was very similar to the one that was in Option 1, just 17 replacing the senior operator with the shift supervisor.
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| 18 This is basically what was issued for public '
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| 19 comment. In terms of the public comment, we have received 20 250 comments. 98 percent--a very large fraction--came from 21 the interested parties. Basically from the utilities and 22 from the operators themselves. We got a large number of 23 comments, by far the largest number, from operators.
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| 24 The remaining comments, the remaining 2 percent of 25 the comments, came basically from educational institutions vi HERITAGE REPORTING CORPORATION (202) 628-4888
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| <,' R
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| 1 4
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| l O. 4a l 11 - like universities'and from one citizens group. j 2 The educational--most of the commenters in the{
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| 3: .firstJgroup.were: opposing theirule. The educational' 4 institutions were kind.of split. And the citizens group'was 5 supporting it'.:
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| .6 In terms of the. utilities, the. utilities 1all i
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| ~i 7 opposed it.- Among the. operators, there were aboutiten-8 people who' indicated thatlthe' rule is a. good idea and they I
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| 9 favored thy rule. l J
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| 10 This slide.listsLthe'significant comments that we 11 received. I don't wantLto go through on each of=these.-
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| 12 Let me just point out:some of them. 1
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| () 13 One rather strong. comment thatlwe received from i
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| 14 many directions was that it's very difficult for a worker-15 who is working on shift to attend college on the adde and :)
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| i 16 complete a Bachelor's Degree. It is.just a'very tough ')
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| 17 commitment which lasts for many years..if he's working full 18 time. And it's very difficult.to keep it up for the number i
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| 19 of years that it takes to accomplish it. !
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| 1 20 We have received a' fair number of comments in 21 connection with the' ABET-accredited degree. That it was too 22 specific.
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| 23 We also received a number of comments which j
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| 24 -brought attention to existing labor agreements in the plants '
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| i 25 and the possible interface between those labor agreements-BERITAGE REPORTING CORPORATION l (202) 628-4888 1
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| ,ey 445 V
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| 1 and the training program for degreed individuals in the 2 plants.
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| 3 So after hearing what the comments were, the 4 Commission has decided to proceed with the Policy Statement 5 and asked us to prepare a draft Policy Statement. The 6 Commission and staff are now working together to prepare the 7 Policy Statement that you have a copy of.
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| 8 The main text of the Policy Statement is given in 9 the first paragraph of the Policy Statement and in an 10 abbreviated form as preproduced here in the first bullet.
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| 11 The Commission believes that the level of 12 engineering and technical knowledge on shift has a direct
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| () 13 bearing on the safety of the nuclear power plant which is a 14 belief from the Commission as the underlying reason for the 15 Policy Statement.
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| 16 Accordingly, they believe that the power reactor 17 should have on shift a team of professionals that combine 18 technical and academic knowleoge with plant specific 19 training and experience. And this is the thrust of the 20 whole meaning of the Policy Statement. This is basically 21 what they are after. They are after for a balance between 22 technical training and operating experience on each shift.
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| 23 The shift represents a group of people. They are not 24 specifying how many of these and how many of those you need.
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| 25 They are not specifying how many should have certain CJ) !
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| HERITAGE REPORTING CORPORATION I (202) 628-4888
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| ,I
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| () 446 l
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| 1 educational backgrounds. How many should have other ]
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| 2 educational backgrounds. But they are specifying that every I
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| 3 shift should have a balance of the two. ,
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| l 4 The main underlying reason for this decision is j l
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| 5 that they believe that there will always be a potential for i
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| 6 situations which are not covered through the normal training I l
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| 7 and the operating procedures available to the operators.
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| 8 They will always be faced with unexpected situations and if ,
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| l 9 they have this balance it will become very helpful when they 1
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| 10 face those situations.
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| l 11 They also noted that there will be a long term 12 benefit that if there are individuals who have both the
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| () 13 educational background and the operating experience they 1
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| 14 will have an opportunity to move upward in the organization 15 and in the future occupy important positiens within the 16 utility organization which will be beneficial overall for 17 the utility.
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| 18 The Commission also noted that the industry has ;
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| 19 done various things in this area in the past including the 20 very recently issued principles on enhancing professionalism 21 in nuclear power plants which was issued only three months 22 ago in March, and they endorse in the Policy Statement 23 INPO's principles.
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| 24 The Commission also reaffirms in the Policy 25 Statement the STA position, the way how it has been IERITAGE REPORTING CORPORATION (202) 628-4888
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| 1 established and also reaffirms the Commission's preference 2 for-the dual senior operator atLthe position in the plant.
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| '3 So'all of this together. kinds of puts.forth the 4 . basic goal of the Commission, what they are trying.to-5 accoraplish.
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| 6 In addition to-putting'forth-this in the Policy-7 ' Statement,-they have-done one more thing. They specified:
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| 8 'six specific actions that they expect.or they,encourageithat 9 utilities should take. And these three. specific 3 action 10 -items are shown in this slide.1 11 The first one is development of programs;which-12 would have the operating personnel who.are currently.in the-13 plants and operating personnel in the future who areLinothe l
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| (])
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| 14 plants and who do not have degrees to obtain college 15 degrees. So anyone who is interested,'anyoneLwho is.willing.
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| l 16 to learn more, have a better engineering background, should 17 have an opportunity to do that.
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| 18 The second action, what they recommended is the 19 hiring of college graduates for positions on the operating 20 staff. And this is the area we discussed in some detail 21 Wednesday. The way how the Commission foresees this is 22 basically to produce that balance that was in the first 23 statement. So for a given case on a given plant on a given 24 shift, you have too many people with operating experience 25 and not enough with some engineering background, then you
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| .O HERITAGE REPORTING CORPORATION (202) 628-4888
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| ggg 448 1 would work in the direction to bring more engineering 2 background into that shift.
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| 3 On the other hand, if a given shift has too much 4 engineering background--it has all the engineering 5 background that you need but is short on operating 6 experience, then just as much they would expect that 7 attention would be paid to increase the operating experience 8 on that given team, on that given team of operators.
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| 9 MR. LEWIS: If I can just interrupt for one 10 second.
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| 11 This is just the place where I begin to have a 12 little bit of a problem and don't quite understand. Because llh 13 it isn't as if engineering graduates are monolithic and all, 14 you know, interchangeable. They are not clones. They are 15 not machines. There are good ones and there are bad ones.
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| 16 And I honestly don't know--I'm not making a point, because I 17 don't know. How competitive a job on the operating staff of 18 a nuclear power plant would be for a graduate engineer 19 compared to his other opportunities. Because I would rather 20 get high quality non-college graduates than the bottom of 21 the crop of engineering graduates, and I wonder how that 22 consideration works out in this case.
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| 23 If I were a new graduate of a good engineering 24 school, would I go to this kind of job?
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| 25 MR. ROSZTOCZY: Mr. Carroll at the Wednesday HERITAGE REPORTING CORPORATION (202) 628-4888
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| f
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| ( ). 449 1- subcommittee meeting-was'providing.some information to'the
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| '2 subcommittee along these lines. Wel don't have any' specific 3- -information. It's my: understanding that'in most plants,.in 4 a' typical plant,;the reactor operator position would be
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| .5- comparable to the type.of compensation that engineers 6 graduating from college would get. And the senior operator 7 is definitely; higher than that. And the auxiliary operator 8 are probably below.
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| '9 But it depends on individual programs and depends-l 1
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| 10 on how it is being set up.
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| 11 It's also my understanding that as of today there 12 are some utilities who are hiring only graduates'into their
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| () 13 program. And on the other hand, there are utilities who are 14 not hiring any college graduates. They are just basically--
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| 15 MR. LEWIS: Well, there are two things that 16 motivate a person in taking a-job. One is, indeed, the 17 initial compensation. The other--I guess there are'three.
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| 18 The psychological rewards. But above all, the opportunities 19 in the future. The opportunities for advancement. Not only 1 20 in terms of salary but the chance of owning the company 21 someday. And that sort of thing. And that's presumably 22 missing in this case.
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| 1 23 DR. REMICK: No. I think the leader bullets have l \
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| l 24 some of that where they encourage-- ,
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| 25 HR. LEWIS: I won't press the point but--
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| _ _ _ - _ ____ N
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| , 450 1 DR. KERR: Ihave'h.hesameconcernthatyoudo. .
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| 2 MR. ROSZTOCZY: It would be.our understanding that' 3 at the present time that one is also depends a lot on the-4 individual organizations. And depends a lot on how the
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| -5 interface with the union, the labor agreements, are 6 presently' drafted.
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| 7 I think Mr. Carroll made the comment at the 8 subcommittee meeting that in some organizations, if you 9 enter at a certain level, from there on, when you'enterfit, 10 you are under the labor. agreement. And from there on, 11 everything progresses strictly by seniority.
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| 12 In other organizations,'the same doesn't exist.
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| 13 So in some organizations, it's. easy to progress relatively 14 fast. So if somebody comes in independent,'whether he came .
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| 15 with a degree or without a degree, but if he excels in the -
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| ]
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| 16 job, he has the opportunity to progress relatively fast. '
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| 17 In other organizations, it goes more with the -!
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| 18 number of years and it depends less on his abilities. j 19 MR. LEWIS: I won't press the point.
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| 20 MR. ROSZTOCZY: The third encouragement was to j 21 provide opportunities for operators to assume positions in !
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| 22- higher management positions. In other words, those who came 23 up on the operating line and had the operating experience- ;
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| 24 could migrate into other responsible positions in the 25 organization. :
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| O HERITAGE REPORTING CORPORATION (202) 628-4888
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| ,2 451.
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| l 1 The fourth'one is a little bit opposite'of that.
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| 2 This is an encouragement to-provide operating experience:for 1
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| : 3. existing managers. So people who are in management 4- positions, they should have an: opportunity'to' gain operating 5 experience-through qualifying'for an SO license. {
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| l 6 The fifth encouragement is to'have a significant-
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| .7 amount of people on shift who have on-hands operational ,
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| i 8 experience. This is an encouragement'not to move people 9 through just.too fast on the operating part of the 10 organization, but rather try to' establish the positions on -l
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| -11 the operating staff in relatively permanent positions where 12 people will spend a fair amount of their time.
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| 13 So that at any given time there will.be 14 significant amount of hands-on~ operating experience.
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| 15 And finally, they-made one specific statement'in 16 connection with the shift supervisors. They made it a .
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| 17 little bit broader than shift supervisors. They said shift .l l
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| 18 supervisors and other individuals with similar decision-19 making authority have a very important position to fill and 20 they encourage these individuals should have both !
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| 21 educational backgrounds and operating experience in the 22 field.
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| 23 DR. KERR: Mr. Rosztoczy, how'does the Commission 24 ' feel--this says the Commission-encourages this. .It would be 25 more encouraging, it seems to me, if it said something to O
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| V(3 452 1 the effect that if you are going to do this, we won't send 2 any NRC people to your installation for the next eighteen 3 months or something like that.
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| 4 But just to make a statement that the Commission 5 encourages something, it seems to me is sort of hollow.-
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| 6 MR. ROSZTOCZY: Every time when the Commission 7 issues a Policy Statement, they are issuing it with the 8 knowledge that this is not something that is an enforceable 9 item like a rule. Nevertheless, they are well aware of, 10 through past experience, that it has a rather strong 11 influence in terms of how the utilities are going to handle 12 it and what the utilities are going to do. Past experience 13 is every time when the Commission went through the trouble 14 to issue a Policy Statement on a given issue and brought 15 attention to a given issue that there was always a follow up )
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| 16 to it on the industry's behalf.
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| 17 This issue is not new. This issue has been 18 around, as has been mentioned earlier, I think close to ten i
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| 19 years. And the utility industry has already paid a certain l
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| )
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| 20 amount of attention to it. Certain progress has been made.
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| 21 The staff as well as the Commission believes that finishing i
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| 22 this up with a Commission-issued Policy Statement is going 23 to give the appropriate attention with what it deserves.
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| 1 24 DR. KERR: If encourages is a euphemism for
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| ,_ 25 intends to coerce, then I guess it's okay. But if it really k
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| HERITAGE REPORTING CORPORATION (202) 628-4888 t
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| () 453 1 means encourages, I'm looking for the mechanism.
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| 2 HR. LEWIS: Well, there are two reason why I 3 suppose, Bill, I share your concern. There are two reasons 4 why the industry would take it seriously. One is the one 5 you suggest, if it's a form of bribery. Like not sending 6 NRC people there for eighteen-months or something like that.
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| 7 The other is if the industry were to have great respect for 8 the Commission's judgment in these matters and that's 9 probably not a discussable subject here.
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| 10 But, you know, I have great problems with these.
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| 11 things that they are encouraging because there is nothing 12 that I know that tells me that bus drivers are good at (m
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| (_) 13 running bus companies and I know among airlines one of the 14 worst things that can happen is to promote pilots into 15 management responsibilities. It sometimes works, but it's 16 accidental. Normally it's antithetical.
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| 17 The same skills that go with operating something 18 are just not necessarily the set of skills that go with 19 managing it. And I would thiInk that that would run through 20 the mind of the industrial people in how they respond to 21 this encouragement.
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| 22 MR. CARROLL: Well, of course, as I pointed out at 23 the subcommittee meeting, an awful lot of these things that 24 we see on that Vu-Graph are things that the industry 25 themselves have put into the INPO professionalism document HERITAGE REPORTING CORPORATION (202) 628-4838
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| 'l .on how to manage your power plant.
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| 2 MR. LEWIS:-'The minutes have a good rationale for 3 it.
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| 4 MR. CARROLL: Well, I don't know. That.was not.
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| 5 written by INPO staff but by some fairly high-level--a 6 . committee of fairly high-level utility people who think they 7 know how to run their nuclear plant.:
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| 8 DR. REMICK: Are you ready to continue, Zoltan?
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| 9 MR. ROSZTOCZY: Yes. So.these two slides 10 together, the one that I showed before which put the basic:
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| 11- goals forth, and this one which described-the'six J 12 encouragements that the Commission gave.. This is the Policy 13 . Statement itself.
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| 14 The Policy Statement itself is three and a half 15 pages and it provides these two sets-of information that 16 I've presented here.
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| 17 MR. LEWIS: You know, it may or may not be 18 relevant, but it's worth noticing that the Navy does not 19 make a practice of promoting sailors to run ships. It 20 trains people to run ships.and trains other people to 21 operate ships.
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| 22 MR. CARROLL: I believe what's even closer to' 23 home. I can't think of a single Commissioner in the history l
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| 24- of the Atomic Energy or Nuclear Regulatory Commission that's 25 ever stood a watch in a power plant. And yet they are smart HERITAGE REPORTING CORPORATION i (202) 628-4888 l
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| 455 1 enough to run the industry. I'm not sure--
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| 2 DR. REMICK: Do you think maybe they should? Some 3 of them should have?
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| 4 MR. LEWIS: But why is that closer to home?
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| 5 MR. CATTON: Couldn't you achieve all of these 6 things that you want just by making the examination process 7 really tough? l 8 MR. ROSZTOCZYr One public comment was that if NRC 9 feels that certain reactor operators should be trained in 10 certain subjects in addition to what they are presently 11 being trained, then NRC should spell out what those subjects 12 are and include them in their examinations. And do it that
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| () 13 way. And I assume that is a possibility that one could 14 follow.
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| 15 MR. CATTON: I think that would get around a lot 16 of the criticism you are hearing here. If you are going to 17 examine them on it, the utilities certainly are going to add 18 that to their training program and they'll pass those exams.
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| 19 DR. REMICK: It doesn't say they might operate the 20 plant safely though.
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| 21 MR. CATTON: That's true.
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| 22 DR. REMICK: That's where we were ten or fifteen 23 years ago on licensing.
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| 24 MR. CATTON: It didn't work.
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| l 25 DR. REMICK: It sure didn't work.
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| HERITAGE REPORTING CORPORATION (202) 628-4888 i
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| 456 1 MR. ROSZTOCZY: This last slide kind of indicates-2 MR. WARD: We also'saw the other day that 60 3 percent of LER's were (inaudible) errors by the licensed 4 operators.
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| 5 MR. CATTON: Maybe their degrees are in the wrong 6 place. Maybe it should be in maintenance.
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| 7 MR. WARD: It's in here somewhere.
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| 8 MR. ROSZTOCZY: This last slide indicates that 9 what was the intent of the rule and would the Policy 10 Statement accomplish.
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| 11 In terms of requiring degrees for certain 12 individuals, either SO's or for shift supervisors, that rule O 13 inc1udee that reemirement. The Po11cv Statement does not 14 have any requirement of that sort.
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| 15 In terms of requiring more operating experience, 16 this is what I was showing on the earlier slide--three years 17 instead of the present two years. That was included in the 18 rule. The Policy Statement does not address that question, 19 so that would not be accomplished through the Policy 20 Statement.
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| 21 In terms of enhancing engineering expertise on the 22 shift, both the rule and the Policy Statement are definitely 23 going in that direction.
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| 24 One of the major criticisms against the rule was i 25 that it would block the career opportunities for reactor l O ,
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| I BERITAGE REPORTING CORPORATION (202) 628-4888 l
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| () '457 1 operators, in one case, if this is the requirement and the 2 senior operators, if that one is the requirement.
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| 3 We acknowledge that, yes, if the rule would be 4 enacted, then that would have been'one of the consequences l
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| 5 that some people would have been in a position when the 6 career would have been blocked.
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| 7 The Policy Statement kind of resolved that 8 problem. It does not create any blocking because there is 9 no specific requirement and people can progress in the 10 organization without a degree.
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| 11 Another criticism was that the rule would result 12 in greater operator turnover and I think we all recognize
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| () 13 that it would. In terms of the Policy Statement, it's still 14 possible that it will resolve in somewhat greater turnover 15 in operators.
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| 16 Now, what is an optimal turnover rate, I'm not 17 sure if anybody knows. Having a very frequent turnover is 18 probably not advantageous, and the same way, no turnover or-19 a very small turnover is probably not advantageous either.
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| 20 Mhere the rule brings a turnover rate which is 21 roughly what one would like to see, it remains to be seen.
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| 22 In terms of enhancement of upward mobility of 23 individuals who have operating experience, both the rule and 24 the Policy Statement definitely recommend that.
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| 25 And finally in terms of enhanced professionalism HERITAGE REPORTING CORPORATION (202) 628-4888
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| s 458 ,
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| 1 l' of the operators, both of them require.that too. ]
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| 3 2 So you can see that from everything that the'. rule 1
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| 3 has done,'now only about half of them are being accomplished j 4 and some of the biggest problems that we had.with-the rule i 1
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| 5 are resolved here.-
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| 6 One'could'also put a. third column here and say.
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| 7 'that, well,'let's do nothing. .There is no real pressing l i
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| 8 problem. Then why don't we'just leave everything the way it .1 9 is.
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| 10 The way how these entries were faced,.that would! 1 J
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| 11 end up with a column which would be all "no's" all the way.
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| i 12 MR. WARD: I disagree with that. In.fect,'I '
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| () 13 think, for example, the last one, if you put-a column'over 14 there for no action and the last one enhanced 15 professionalism of the operators, I suggest that there'ought 16 to be two "no's" there and the new column would'get the 17 "yes."
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| 18 You know, I don't-know how you assign the "yes's" 19 and "no's" here.
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| 20 MR. ROSZTOCZY: I'm not sure-if I follow that. If' 21 the Commission issues a Policy Statement and brings to their 22 attention of the entire industry, including all the 23 utilities, that they should enhance professionalism among 24 operators =in the operator rank, then why would that end'up 25 with a "no" and if they don't do anything, end up with a HERITAGE REPORTING CORPORATION (202) 628-4888
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| I ). 459 1 "yes"?
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| 2 MR. WARD: I suggest that', you'know, part of 3 professionalism is--an important part of it-is taking pride 4 -and becoming involved in.the work'of your profession. And 5 this attachment of a requirement for an engineering degree:
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| 6 for a job that is essentially not an engineering job,'I 7 think is kind of unrelated to that. >
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| B I'm not saying it very well, but I sure believe.
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| 9 MR. LEWIS: I think you are probably right. .I'm-10 not so sure that the word " professionalism" is the.right 11 word here anyway, because we are not talking about a 12 profession in the same sense that being a lawyer is a '
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| ) 13 profession. Oh, we are kind of. mixing things up.
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| 14 MR. WARD: Yes, perhaps.- But whatever the word 15 means, I think there's something called professionalism of 16 nuclear power plant operators or professionalism of:an 17 airplane pilot.
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| ~
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| 18 MR. LEWIS: There is, but it's--
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| 19 MR. WARD: And I'm not sure that either this rule 20 or the Policy Statement really promotes that.
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| 21 MR. LEWIS: No, no. I agree with you that those 22 bottom four "yes's" should be "no's." And the only thing 23 that--but whatever is in them should also be in the third l
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| l- 24 column.
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| 25 MR. CARROLL: Well, I would argue that--
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| HERITAGE REPORTING CORPORATION (202) 628-4888
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| (O_/ 460 ,
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| i 1 MR. LEWIS: I don't think they have any impact.
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| 2 MR. CARROLL: I would argue that do nothing with l 3 the qualifier that back pay is sent to each C30 and beat l
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| 4 each CEO over'the head at the INPO CEO's meeting with !
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| 5 principles for enhancing professionalism of nuclear 6 personnel. I would say that your third column would be the 7 same as the Policy Statement column in terms of its 8 practical effect.
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| 9 MR. LEWIS: Whatever you put in there you should 10 put it in the third column.
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| 11 MR. ROSZTOCZY: If in some form, if in some form 12 the Commission would endorse the INFO statement then it
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| (_) 13 would accomplish it. It doesn't necessarily have to be.a 14 Policy Statement and would basically accomplish the same 15 thing.
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| 16 MR. CARROLL: But for those who haven't read the 17 Policy Statement in detail, in fact it does endorse the INPO 18 professionalism document.
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| 19 MR. ROSZTOCZY: And finally one more comment is 20 that we kind of reread the letter that you gentlemen wrote 21 two years ago in connection with this issue. Admittedly 22 that letter is two years old. You might have somewhat 23 different views now.
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| 24 And if we go down along this-line as it's listed 25 here, then in terms of degree requirement, you did not HERITAGE REPORTING CORPORATION (202) 628-4888
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| > 4, -.o i <
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| 1 reccmmend.that, so your answer was a "no" for.that. To 2 ' require more operating experience, I believe you did not l 3 address that. So we don't'know your views on that one.
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| 1 4 In. terms'to enhance engineering expertisefon i
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| 5- shift, you-strongly recommended that.
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| l- 6 In termsLof problems that existed with the rule,. '
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| 1 7 'you recommended'that-we work with the. industry and try to' 8 resolve them. Working with tho. industry and trying to i 9- resolve.them, we are arriving to a "'no" 'here saying that one :
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| 10 should-try to. avoid blocking the career of these.
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| 11 In terms of turnover rate, a frequent turnover is l
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| 12 probably not helpful.
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| ( 13 And in terms of the last two, I.believe you f L /
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| 14 endorse both of these. So in a' sense, the Policy Statement 15 as it stands lines up very close to your recommendation that 16 you recommended to the Commission back two years ago.
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| 17 The Commission is waiting for your comments as of l
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| 18 today and they will be taking it.dnto account before they l 19 make their final decision.
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| l 20 DR. REMICK: Thank you, Zoltan.
| |
| 21 MR. ROSZTOCZY: That' completes my presentation. ]
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| 22 DR. REMICK: That was a very good summary of the.
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| l 23 Policy 2tatement and we'll open it up for discussion.
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| 24 Any further discussion? I 25 MR. CARROLL: Zoltan, did you give any more HERITAGE REPORTING FARPORATION )
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| : h. 462 1 thcught to.the comments'I made about the fourth paragraph on 2 page 9; namely the--
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| .3 DR. REMICK: Jay,-you weren't here when I went.
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| : 4. over that. The NRC staff had gone back to the Commission 5 staff and they agreed that.it was not the: intent that 6 degreed people be hired in at entry level if.that-meant 7 auxiliary operated and.in those cases where it was not 8 -possible.
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| 9 And'so they agreed that they thought those I
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| 10 editorial changes that we talked about two. days ago would be 11 acceptable.
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| 12 MR. CARROLL: Okay. The only other con. ment that I 13 had was--it kind of came up at the subcommittee meeting--
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| 14 would it clarify the Policy Statement any to--where'you 15 start using the term " shift supervisor" to parenthetically.
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| 16 give a little definition of it, the senior management. person 17 in a control room or something like that?
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| 18 My problem with it is some of the utilities have 19 different names for management people on shift. Shift 20 supervisor, shift foreman, operating supervisor, shift 21 manager, and--
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| 22 MR. ROSZTOCZY: That's a. good cc.,mment. Let us ,
| |
| 23 look at the exact wording. The place where it's the most.
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| 24 -important in the Policy Statement itself when it gets to the l
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| 25 shift supervisor, then the term used is shift supervisor or '
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| HERITAGE REFORTING CORPORATION (202) 628-4888
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| l i - , .
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| , ...463.
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| '1 other-personnel with similar responsibility. The purpose.ofL
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| : 2. that~was to try to catch:this_thatLyou=.are mentioni g. ;But:
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| I:am.sure'that'slnot the only place when itlenters int'o':the- 0 4 whole package, so let'us.look'at'itfagainiand[seeLifJsome, j
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| 5 clarification 11s i needed.
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| f 6 'MR., CARROLL:
| |
| Okay, good.-
| |
| ? DR.-REMICK: -There might be someldifficultylthere, 8 Jay, because of' shift. manager:and in'the1caseLot
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| .9 Commonwealth scree, I'm not sure you mean those persons--
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| 10 MR. CARROLL: In the case of what now?'
| |
| 11 DR. REMICK:. Commonwealth hasla' scree which iaL 12 somebody;above shift supervisor and,sof: course,:theLahift-( 13 manager that we heard.about at Peach Bottom is somebody 14 that's--
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| 15 MR. CARROLL: That's the guy I think they are 16 talking about.
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| 17 DR. REMICK:' . :No, I don't think so.
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| 18 MR. ROSZTOCZY: We woutsd be. talking in termez of
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| .q 19 the shift-supervisor along the same' lines'how-it falls in 1 1
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| 20 the rule when thers was a former definition of-it..L And the. j 21 former definition was that it would be the person.who'is:in 22 charge of the shift in a contro1~ room. That one person in 23 the control room in charge of the shift. l 24 HR. CARROLLI And for a two-unit-' plant-- ,
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| l 25 MR. ROSZTOCZY: It could be one or it could be -j 2EERITAGE REPORTING CORPORATION j (202) 628-4888 i i
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| I 464 1
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| 1 two,. depending on the organization. ,
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| 1 2 DR. REMICK: 'Or.it'could'be'one guy with two shift' l 3 foremen, oneLfor each unit, reporting to him. 'I 4 MR. ROSZTOCZY: _ That's right. ;
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| : 5. MR. CARROLL: It's really the-senior management-6 person on the shift.
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| I 7 DR. REMICK: .Okay. I agree.
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| 8- Any-further discussion?. If not, this 9 subcommittee, wcs seem to have diverse views. Dr. Kerr 10 suggested that the subcommittee chairman should write a 11 letter as he thought it should be. And people can take pot' 12 shot at it and write differing opinions if we can't come to 13 resolution.
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| 14 With that in mind, Herman, do you want to hand out 15 a--we have a time for reading, if you'd like?
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| 16 Oh, one thing I should mention before we get into q 17 that, the informa ion we have is that Commissioner Roberts 18 questions whether the Policy Statement on degree 19 requirements should specify a degree from an accredited 20 institution or simply a degree. He notes that'the NRC 21 doesn't specify a dogree from an accredited institution for :j 22 its own employees. He's concerred that utilities may have 1
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| 23 Arranged degree programs with non-accredited institutions i l
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| 24 for their employees, and this may create a problem. !
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| 25 So I think his concern is if an indication that 1
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| ~
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| .1 the preference is for people from accredited institutions, 2 that some utilities might have already made arrangements fbr:
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| 3 people to get. degrees from institutions that are not. !
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| 4 accredited and this might b= a problem.
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| 5 MR. CATTON:- If it's'non-accredited, you can get a' 6 mail order from the bach pageHof a. magazine.
| |
| :7 DR. REMICK: The institution?
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| 0 MR.-CATTON: You see degrees in everything frem 9 non-accredited---
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| 10 DR. REMICK: It's not'a degree we:are talking 11 about. An accredited institution.
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| 12 MR. CATTON: Well, that's whyLI think it should be
| |
| ) 13 accredited.
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| 14 DR. REMICK: Oh, I see what you are,saying. .Okay.
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| 15 MR. CATTON: I mean if it's not accredited I can j l
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| 16 just mail off ten dollars.
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| 17 MR. LEWIS: Well, in fact in another context, I 18 looked into a place in Los Angeles and I;can buy a Ph.D.,, l 19 example, for $250.
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| 20 MR. CATTOM.: Yes.
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| .i 21 MR. LEWIS: For California, that seems high to me. ;
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| 22 DR. REMICK: I think we can go off the record now u
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| 23 on our discussion. ;
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| 1 24 (Whereupon, the proceedings'were concluded at 4:40 25 p.m.)
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| i HERITAGE REPORTING CORPORATION (202) 628-4888
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| _ _ _2
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| .w.. >
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| r I
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| 1 CERTIFICATE 2
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| 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulbtory' Commission in the matter 5 of:
| |
| 6 , Name: 350th'ACRS Meeting 7
| |
| 8 Docket Number:
| |
| 9 Place: Bethesda, Maryland 10 Date: 6-9-89 11 were held as herein appears, and that this is the. original 12 transcript thereof fer the file of the United' States Nuclear
| |
| ' ~
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| 13 Regulatory Commission-taken stenographically by me and,-
| |
| , 14 thereafter reduced to typewriting by mo 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, ,
| |
| / -
| |
| #.ifkf,ff 18 /s/ " /tf/4 %
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| IRWIN L, bOFFE RRY 19 (Signature typed): :
| |
| 20 Official Reporter 1 21 Heritage Reporting Corporation 22 23 24 l 25 i)
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| N Heritage Reporting Corporation .;
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| (202) 628-4888
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| | |
| n O
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| USI A-17
| |
| " SYSTEMS INTERACTIONS" PRESENTATION TO THE'ACRS-FULL COMMITTEE OF THE FINAL RESOLUTION OF-USI A-17 O
| |
| JUNE 9, 1989 D. F. THATCHER, TASK MANAGER R. L. BAER, BRANCH CHIEF DIVISION OF SAFETY ISSUE RESOLUTION -
| |
| l OFFICE OF NUCLEAR REGULATORY RESEARCH l
| |
| l SLIDE 1
| |
| | |
| a
| |
| * < i O
| |
| INTRODUCTION a
| |
| j AUGUST 1988 -
| |
| ACRS AGREED TO ISSUE'FOR PUBLIC COMMENT (ONLY LICENSEE. ACTION WAS INTERNAL FLOODING EVALUATION) q SEPTEMBER 1988- -
| |
| STAFF SENT CRGR REVISED FINDING ON FLOODING (BACKFIT) !
| |
| OCTOBER 1988 -
| |
| CRGR AGREED WITH STAFF PROPOSAL !
| |
| q CVEMBER1988 IPE GENERIC. LETTER ISSUED (EXPLICITLY ,
| |
| INCLUDES' INTERNAL FLOODING TREATMENT)
| |
| DECEMBER-MARCH -
| |
| STAFF PROPOSED ALTERNATIVE OF INCLUDING 1988-1989 A-17 INSIGHTS INTO. IPE AND NOT ISSUIll '
| |
| FOR PUBLIC COMMENT MAY 1989 -
| |
| CRGR MEETING, AGREED WITH FINAL -
| |
| RESOLUTION.
| |
| SLIDE 2 l
| |
| l 1
| |
| | |
| J
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| [i.: .
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| O A-17 PROGRAM-4 OVERVIEW' DEFINED /SCOPED THE ISSUE PERFORMED A NUMBER OF TASKS BASED ON DEFINITIONS i
| |
| (3) FORMULATED A NUMBER OF TECHNICAL FINDINGS CONSIDERED A NUMBER ~0F ALTERNATIVES FOR RESOLUTION
| |
| 'l CONSIDERED ONG0ING RELATED ACTIVITIES DEVELOPED A NUMBER OF PROPOSED RESOLUTIONS PRESENTED PROPOSED RESOLUTION TO ACRS IN AUGUST 1988 1
| |
| DEVELOPED A FINAL RESOLUTION 4 O stiot 3
| |
| - __o
| |
| | |
| ^- 7 O DEFINITION 1
| |
| )
| |
| ADVERSE _ SYSTEMS INTERACTION (ASIl o SINGLE, COMMON CAi!SE o PROPAGATION BETWEEN SYSTEMS THROUGH HIDDEN'OR UNANTICIPATED COUPLING o LEADING TO UNDESIRABLE RESULTS e
| |
| FAILURE OF REDUNDANT PORTIONS-0F A SAFETY SYSTEM O
| |
| FAILURE OF A SAFETY SYSTEM BY A NON-SAFETY SYSTEM
| |
| ' INITIATION OF AN EVENT AND i
| |
| o FAILURE OF A SAFETY SYSTEM-o FAILURE OF A CRITICAL OPERATOR INFORMATION l INITIATION OF AN EVENT WHICH REQUIRES ACTIONSlDF THE PLANT OPERATORS OUTSIDE THE CONTROL ROOM AND DISRUPTION OF ACCESS TO THESE AREAS. J O su ot 4 L l
| |
| l
| |
| | |
| l TASKS-o SEARCH OPERATING EXPERIENCE AND ESTABLISH. TRENDS, PATTERNS j 1
| |
| o REVIEW SYSTEM INTERACTION STUDIES DIABLO CANYON INDIAN POINT 3 MIDLAND 1
| |
| o REVIEW WORK ON METHODOLOGY
| |
| () -
| |
| PROBABILISTIC RISK ASSESSMENTS )
| |
| METHODS COMPARISON AT IP3 DIGRAPH AND FEMA / FAULT TREE 0THER CANDIDATE METHODS o REVIEW PAST AND ONG0ING ACTIVITIES
| |
| )
| |
| ACRS ]
| |
| LABORATORY STATE-0F-THE-ART REVIEWS INDUSTRY INITIATIVES O sua s
| |
| | |
| FINDINGS asas
| |
| -- PLANT SPECIFIC IN NATURE-PLANT SPECIFIC IN RESULTS/0VERALL IMPACT-HOWEVER SOME' PATTERNS OBSERVED A LARGE NUMBER OF ASIS ALREADY ADDRESSED' SEARCH METHODS MANY AVAILABLE SOME BETTER FOR SPECIFIC TYPE OF ASIS TO DO OVERALL PLANT SEARCH NEED COMBINATION A COMPREHENSIVE SEARCH'IS COSTLY AND NO GUARANTEE
| |
| () ALL ASIS WILL BE FOUND A PRA CAN FIND ASIS OPERATING. EXPERIENCE DOES UNCOVER THEM AND THEY D0 RECEIVE ATTENTION MOST COST EFFECTIVE APPROACH APPEARS TO BE A FOCUSED SEARCH GENERAL DIFFICULT TO ADDRESS BECAUSE IT IS A SUBJECT AREA RATHER THAN A FOCUSED ISSUE
| |
| - NO CONCRETE, GENERIC SOLUTIONS TO ELIMINATE CONCERNS ASIS WILL CONTINUE TO OCCUR
| |
| ()
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| SLIDE 6
| |
| | |
| A-17' PROPOSED RESOLUTION
| |
| () (PRESENTED TO ACRS~- AUGUST 1988) o N0'NEW REQUIREMENTS o- ' GENERIC LETTER TO ALLLLICENSEES PROVIDE THE BASES FORiRESOLUTION OF USI A -
| |
| PROVIDE INFORMATION ON LESSONS LEARNED FOR:USE IN OPERATING EXPERIENCE EVALUATIONS REQUEST CERTIFICATION OF FLOODING EVALUATIONS o PROVIDE LESSONS LEARNED ABOUT ADVERSE SYSTEM INTERACTION FOR PRAs e
| |
| ACKNOWLEDGE RELATIONSHIP OF USI-A-46 ON SEISMIC
| |
| {) QUALIFICATION -
| |
| o PROVIDE POWER SUPPLY INTERACTION INFORMATION TO GI-128 ON ELECTRIC POWER L o DEVELOP OTHER CONCERNS FOR SEPARATE. TREATMENT MULTIPLE SYSTEM RESPONSES PROGRAM ,
| |
| o ACRS RECOMMENDED ISSUING THE RESOLUTION FOR PUBLIC COMMENT-4 SLIDE 7 1
| |
| | |
| () MODIFICATION TO RESOLUTION REGARDING INTERNAL FLOODING / WATER INTRUSION 1
| |
| .o GENERIC LETTER 88-20 ON INDIVIDUAL PLANT EXAMINATIONS (IPEs) ISSUED NOVEMBER 1988 EXPLICITLY INCLUDES INTERNAL FLOODING o A-17 PROPOSED TO PROVIDE INSIGHTS TO THE IPE IPE GUIDANCE TO REFERENCE A-17 TECHNICAL FINDINGS AND l INSIGHTS ON FLOODING AND WATER INTRUSION (NUREG-1174 APPENDIX) i 4
| |
| j SLIDE 8
| |
| | |
| = ,
| |
| USI A-17 FINAL RESOLUTION o ISSUE GENERIC LETTER PROVIDING:
| |
| )
| |
| BASES FOR RESOLUTION OF A-17
| |
| | |
| ==SUMMARY==
| |
| OF INFORMATION FOR.USE IN EVALUATION OF OPERATING EXPERIENCE 1
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| : o. CONSIDER INTERNAL FLOODING.AND WATER. INTRUSION IN IPE l
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| .i o N0 NEW REQUIREMENTS o NO PUBLIC COMMENTS TO BE SOLICITED d
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| ()
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| o ISSUE: .
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| i COMMISSION PAPER FEDERAL REGISTER NOTICE j NUREG-1229 NUREG-1174 (PUBLISHED MAY 1989) l 1
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| 1 o INFORM CONGRESSIONAL COMMITTEES .
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| SLIDE 9 1
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| J
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| 1 O
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| GI-128 ELECTRICAL POWER RELIABILITY l
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| PRESENTATION TO THE ACRS FULL COMMITTEE OF THE RESOLUTION OF GI-128 O
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| JUNE 9, 1989 D. F. THATCHER, TASK MANAGER l R. L. BAER, BRANCH CHIEF DIVISION OF SAFETY ISSUE RESOLUTION
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| ~
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| OFFICE OF NUCLEAR REGULATORY RESEARCH I
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| O 1
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| | |
| x ..
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| O~
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| I GI 128 INTRODUCTION AND BACKGROUND i
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| i o INTEGRATION OF EXISTING' ISSUES RELATED-TO^
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| ELECTRICAL POWER GI 48- "LCOs FOR CLASS 1ELVITAL INSTRUMENT-BUSES IN OPERATING REACTORS" GI 49 " INTERLOCKS.AND'LCOs FOR REDUNDANT-
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| ' CLASS 1E TIE BREAKERS'' ,
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| GI A-30 " ADEQUACY OF SAFETY-RELATED oc SUPPLIES" o INTEGRATED PROGRAM BECAUSE OF INTERRELATIONSHIPS- )
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| i VITAL Ac INSTRUMENT BUSES -(48) AND oc SUPPLIES (A-30) CAN USE TIE BREAKERS (49)' i i
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| oc POWER SUPPLIES (A-30) FEED THE . VITAL INSTRUMENT BUSES (48) ,
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| l i
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| O
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| O RELATIONSHIP 0F GI-128 TO OTHER ISSUES l
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| o USI A STATION BLACK 0UT o USI A SYSTEMS INTERACTIONS O o USI A SAFETY IMPLICATIONS 0F CONTROL SYSTEMS l
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| 1 r
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| i O
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| O GI-128 RELATION TO USI A-44 STATION BLACK 0UT o COPING WITH SB0 RELIES ON STORED .nc POWER (A-30)-
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| o oc TO Ac CONVERSION (INVERTERS) NEEDED FOR' CRITICAL Ac LOADS (GI 48) o POTENTIAL CROSS CONNECTIONS (TIE BREAKERS)'
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| NEEDED FOR ELECTRICAL DIVISIONS (GI 49) o CAPACITY OF BATTERIES T0 BE ADDRESSED BY COPING ANALYSIS UNDER A-44 ;
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| i d
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| _.__.___.__-_..___m__
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| | |
| .O GI-128 RELATION TO USI A-17 SYSTEMS INTERACTIONS USI A-47 SAFETY' IMPLICATIONS OF' CONTROL SYSTEMS o NUMBER OF SIGNIFICANT EVENTS HAVE INVOLVED 1 LOSSES OF VITAL Ac AND oc l o LOSSES LED TO PLANT TRANSIENTS, LOSS OF SAFETY EQUIPMENT, ETC.
| |
| O l
| |
| o IMPROVEMENTS IN oc, VITAL Ac AND. DIVISIONAL CROSSTIES CAN HELP REDUCE FREQUENCY AND )
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| I IMPACT OF POWER LOSS j
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| | |
| () GI-48/49 BACKGROUND o VITAL AC INSTRUMENT BUSES ARE DESIGNED TO SUPPLY CONTINUOUS AC POWER TO CRITICAL ELECTRICAL DEVICES, SUCH AS; CONTROL SYSTEMS INSTRUMENTATION )
| |
| SAFETY SYSTEM LOGIC I o TYPICAL PLANTS INCLUDE MORE THAN ONE BUS TO MEET SINGLE FAILURE o POWER SOURCES TO THE BUSES INCLUDE:
| |
| O INVERTERS .
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| REGULATED TRANSFORMERS o ELECTRICAL BUSES (B0TH AC AND DC) MAY INCLUDE INTERCONNECTIONS (TIE BREAKERS) FOR SPECIAL OPERATING CONDITIONS o CROSSTIE CAPABILITY MAY EXIST BETWEEN REDUNDANT SAFETY-RELATED BUSES OR BETWEEN MULTIPLE UNITS AT ONE SITE WHILE THESE CROSSTIES CAN PROVIDE FLEXIBILITY, THEY CAN COMPROMISE THE INDEPENDENCE OF SAFETY-RELATED ELECTRICAL G> DIVISIONS
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| | |
| 1 O
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| GI 48 AND 49
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| | |
| ==SUMMARY==
| |
| OF SAFETY CONCERN l l
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| o LOSS OF Ac AND oc ELECTRICAL POWER CAN LEAD'T0:
| |
| TRANSIENTS-VIA. CONTROL SYSTEMS LOSS OF INFORMATION:TO OPERATOR' LOSS OF REDUNDANCY IN SAFETY SYSTEMS o SOME PLANTS MAY NOT HAVE RESTRICTIONS ON CONTINUED q PLANT OPERATION WITH VITAL AC POWER BUSES (OR THEIR SOURCES) UNAVAILABLE g SOME PLANTS MAY NOT HAVE RESTRICTIONS'0N. CONTINUED OPERATION WITH TIE BREAKERS CLOSED {
| |
| o WITHOUT ADEQUATE CONTROLS, PLANTS COULD BE OPERATING INDEFINITELY IN SITUATIONS WHICH COMPROMISE PRESUMED DIVISIONAL REDUNDANCY AND INDEPENDENCE o VULNERABLE TO LOSS OF 0FFSITE POWER OR RAND 0M FAILURES.
| |
| OF ADDITIONAL POWER SOURCES l
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| 0
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| o GI 48/49 RESOLUTION
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| ~
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| o TO PREVENT OPERATION IN SITUATIONS WHICH COULD DEGRADE THE INDEPENDENCE OF. SAFETY RELATED ELECTRICAL EQUIPMENT,. TECHNICAL SPECIFICATIONS
| |
| -i AND SUPPORTING PROCEDURES SHOULD BE INCLUDED AT ALL PLANTS.
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| 1 o TO CONFIRM COMPLIANCE WITH THESE EXISTING REQUIREMENTS A 50.54(F) REQUEST IS PROPOSED T0:
| |
| i O -
| |
| VERIFY THAT THE TECH SPECS INCLUDE j APPROPRIATE PROVISIONS AND j l
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| VERIFY THAT THE PLANT PROCEDURES INCLUDE CORRESPONDING CONTROLS l I
| |
| o BECAUSE ELECTRICAL DISTRIBUTION SYSTEMS ARE'VERY PLANT SPECIFIC, A BASIS FOR NOT NEEDING SUCH PROVISIONS MAY.BE. JUSTIFIED AT SOME PLANTS. l l
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| 0
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| I q
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| O i
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| MODIFICATION TO IMPLEMENTATION 0F GI 48 AND 49 ~
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| l 1
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| o GENERIC LETTER NO LONGER REQUIRES TECHNICAL SPECIFICATION ADDITIONS l
| |
| 1 o REQUIRES PLANTS TO CERTIFY:
| |
| O -
| |
| HAVE PROCEDURES, OR HAVE ESTABLISHED BASES FOR NOT INCLUDING THEM o ONLY A CERTIFICATION l
| |
| o FUTURE TECHNICAL SPECIFICATION IMPROVEMENTS SHOULD INCLUDE THESE ASPECTS O
| |
| l
| |
| | |
| II GI A-30 BACKGROUND o SAFETY-RELATED DC POWER SUPPLIES ARE DESIGNED TO PROVIDE AN ONSITE SOURCE OF RELIABLE ELECTRICAL POWER FOR FEED TO VITAL AC EQUIPMENT ELECTRICAL BREAKER CONTROL CONTROL SYSTEMS 4D o TYPICAL PLANTS INCLUDE MORE THAN ONE SAFETY-RELATED DC j SOURCE TO MEET SINGLE FAILURE 1
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| o POWER SOURCES TO DC BUSES INCLUDE BATTERIES AND BATTERY CHARGERS l i
| |
| o ALTHOUGH SAFETY-RELATED DC SYSTEMS ARE DESIGNED T0 BE HIGHLY RELIABLE, SOME FAILURES HAVE OCCURRED 1
| |
| o FAILURES OF CONCERN INVOLVE COMMON CAUSE PROBLEMS AND FAILURE TO ADEQUATELY DETECT THE EXISTENCE OF BATTERY-RELATED PROBLEMS
| |
| = = ~ _ _ _ _ _ - _ _ _ _ . _ _ _ _ - _ _ _ _ _ _
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| | |
| . . J j
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| i i
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| O 1 GI A-30
| |
| | |
| ==SUMMARY==
| |
| OF CONCERN f o LOSS OF oc SUPPLIES CAN LEAD TO )
| |
| .i TRANSIENTS ,
| |
| 3 LOSS OF INFORMATION TO OPERATORS 1 l
| |
| LOSS OF SAFETY SYSTEMS ,
| |
| l k
| |
| 9 SOME PLANTS MAY NOT INCLUDE-RECOMMENDED PRACTICES IN AREAS OF TESTING, MAINTENANCE AND MONITORING
| |
| )
| |
| l O
| |
| | |
| R GI A-30 RESOLUTION O 4 o TO IMPROVE oc POWER SYSTEM PERFORMANCE, THE 1 STAFF DEVELOPED A NUMBER OF RECOMMENDATIONS FOR IMPROVEMENTS IN.
| |
| MAINTENANCE TESTING MONITORING ;
| |
| j o INDUSTRY (THROUGH INP0, NSAC, AND IEEE) HAS ALSO O ADDRESSED IMPROVEMENTS IN THESE AREAS o TO GATHER INFORMATION TO CONFIRM THAT UTILITIES ,
| |
| HAVE IMPLEMENTED THESE IMPROVEMENTS, A 50.54 (F)
| |
| REQUEST IS PROPOSED T0: u QUESTION PLANTS ABOUT THESE IMPROVEMENTS i
| |
| I
| |
| - IF IMPROVEMENTS HAVE NOT BEEN MADE, QUESTION l THEIR BASES FOR NOT INCLUDING THEM o SUBSEQUENT GENERIC ACTION OR PLANT-SPECIFIC ACTIONS MAY BE NEEDED O
| |
| | |
| O GI A-30 GENERIC LETTER-IPE OPTION o REQUIRE RESPONSES TO NINE QUESTIONS MAJORITY ARE YES/N0 ANSWERS TWO QUESTIONS INVOLVE POSSIBLE SUPPORTING INFORMATION TO JUSTIFY A "N0" ANSWER O
| |
| o ACKNOWLEDGE THAT AN IPE COULD PROVIDE.A VEHICLE FOR ADDRESSING USIs AND GIs o GIVE LICEi1SEE OPTION OF ADDRESSING THOSE TWO QUESTIONS AS PART OF THE IPE O
| |
| | |
| .. +
| |
| . P V
| |
| ORNL_DWG B6 4100 ETD a
| |
| OFF SITE [ DIESEL GENERATOR SET Tf(
| |
| SOURCES.
| |
| #AIN hk[NN '
| |
| GENERATOR 4160V 13US
| |
| *d --
| |
| (E i I 4160-480V ALTERNATE SOURCE 480VAC BUS n 1
| |
| , ,,, A ,,
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| I -
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| " ~8' 480-120V d M l
| |
| I IBATTERY I
| |
| , CHARGER TM T STATIC V-REG.
| |
| r / 120V
| |
| (' 125VDC BUS
| |
| . l _DC LO, ADS_ _ ,
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| i i
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| ' -t ' STATIC ;
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| INVERTER I (
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| RACK g ST A14 C 1RA_NSJER g SW.7
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| ;r7- , f r- -, ; , f
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| ~~ ~
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| -~ ~ --
| |
| MANUAL l j BYPASS ~~ s-SWITCH H T .T TI l t__________ ______________I A
| |
| 120V V_ ITAL _AC B_US I I I i 120V AC SUPPLY FOR INSTRUMENTS
| |
| & OTHER VITAL CIRCUITS ,
| |
| i Fig. 3.1. Typical vital instrumentation and control power supply
| |
| 'sy s tem. Source: J. S. Bhatti, Investigation of Failurea in I&C Pouer q Supply Hardo2re, NSAC-44, Nuclear Saf ety An 1ysis Center, Electric Power Research Institute, December 1981. Used with permission.
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