ML20212D314
| ML20212D314 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3089, NUDOCS 9909230068 | |
| Download: ML20212D314 (211) | |
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=l OR!GINA Mare -3orp , OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR REGUI,ATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
Title:
MEETING: SEVERE ACCIDENT MANAGEMENT
~~R C,4 (ACRS)
R E"'Ri C R ! G I N A' ' f TO BJWHITE ,, M ,' S T-2E26 415-7130 THAM:s : l Docket No.: Work Order No.: ASB-300-922 {J 99092300e.,8 990916 PDR ACRS T-3089 PDR LOCATION: Rockville,MD DATE: Thursday, September 16,1999 PAGES:1 - 178 ANN RILEY & ASSOCIATES, LTD.
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( J l 1 L ;- l l i l l I ("~\ b. ! \- /.. ! ! > i i l' ' { $ DISCLAIMER ; I UNITED STATES NUCLEAR REGULATORY COMMISSION'S . h I c G ADVISORY COMMITTEE ON REACTOR SAFEGUARDS k i. SEPTEMBER 16, 1999 s The contents of this transcript of the proceeding , of the United States Nuclear Regulatory Commission Advisory n)
/ . Committee on Reactor Safeguards, taken on September 16, 1999, as reported.herein, is a record of the discussions recorded at the meeting held on the above date.
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1 1 UNITED STATES OF AMERICA , - [ ') 2 NUCLEAR-REGULATORY COMMISSION l U 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 *** 5 MEETING: SEVERE ACCIDENT MANAGEMENT
)
6 7 U.S. Nuclear Regulatory Commission 8 Room T2 B3
- j. 9 Two White Flint 10 Rockville, MD 11 12 Thursday, September 16, 1999 13 14 The subcommitee met, pursuant to notice, at 1:00
() 15 16 p.m. MEMBERS PRESENT: 17 THOMAS KRESS, Chairman, ACRS 18 DANA POWERS, Member, ACRS 19 GRAHAM WALLIS, Member, ACRS 20 l 21 l 22 1 23 I 24 1 25 l i ["T ANN RILEY & ASSOCIATES, LTD. Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 I
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T 2 1 PROCEEDINGS (') t 2 [1:00 p.m.] v 3 CHAIRMAN KRESS: The meeting will now come to 4 order, please. This is a meeting of the ACRS Subcommittee
)
1 5 on Severe Accident Management. I am Tom Kress, the Chairman I 6 of the subcommittee. ACRS members in attendance are Dr. t 7 Dana Powers, Dr. Graham Wallis, John Sieber. , I 8 The purpose of this meeting is to review the 9 modifications proposed by the Combustion Engineering Owners 10 Group to the post-accident sampling system requirements for l 11 CEOG nuclear power plant utilities. l 12 The subcommittee will also review the status of 13 NRC staff and nuclear industry activities pertaining to the 14 issue of control room integrity. Integrity -- is that q 15 habitability? 16 DR. POWERS: Probably habitability. l l 17 CHAIRMAN KRESS: Okay. The subcommittee will 18 gather information, analyze relevant issues and facts and j 19 formulate proposed positions and actions as appropriat,e for 20 deliberation by the full committee. 21 Mr. Paul Boehnert is the cognizant ACRS staff 22 engineer for this meeting. 23 The rules for participation in today's meeting 24 have been announced as part of the notice of this meeting 25 previously published in the Federal Register on August 31st, I i (~] (_,/ ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
3 > 1 1999. I i 2 A transcript of this meeting is being kept and t 3 will be made available as stated in the Federal Register L 4 notice. It is requested that speakers identify themselves, .
..5 speak with sufficient clarity and volume so that they can be 6 readily heard. That basically means use a microphone is
! 7 what that means. 8 We have received no written comments or requests 9 for time to make oral statements from members of the public. l 10' The only comments I might make before we get started is we l 11 had heard previously, the subcommittee did, on Westinghouse 12 Owners Group's request for removal of modifications to the 13 PASS system, and it was based on the fact that it has very 14 little risk significance, if any at all. 15 The questions I would ask the subcommittee to 16 think about is, if it doesn't have any risk significance, 17 then are there other things that we should think about in 18 terms of the need for such a system. And the only other 19 things one has in mind are either defense-in-depth, or ; 20 margins, or utility in management, managing severe 21 accidents, or whatever. 22- DR. POWERS: Let me understand a little better, it 23 seems to me that in the event of an accident, we have got 24 multiple management activities going on. We certainly have
- 25 the activities going on on the site. But we have obviously,
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ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
4 1- for the point where we are relying on information from che ,;/) lN_/ 2 PASS, we have lots of management going on offsite. And your 3 public response, state and local officials, they clearly 4 have information needs in order to marshal their forces and 5 their activities. Don't we have to consider their needs as 6- well? j 7 CHAIRMAN KRESS: I think definitely that is part j i 8 of the consideration in terms of accident management. You 9 know, I included accident management in its broadest sense 10 and that is what I had in mind there. 11 Clearly, the PASS system, where you draw, grab l 12 samples from the RCS and on the containment, has a lot of 13 shortcomings, and it may not be the optimum way to get all 14 the information we need, so we need to think about that. () 15 But, anyway, we'will hear the pros and cons from 16 CE, the Combustion Engineering Owners Group and I guess with 17 that, we will proceed with the meeting and call on Mr. Ray 18 Schneider of ABB CE to get us started on this. 19 Paul will help you there, or Theron will. Theron l 20 is an expert on these things. 21 MR. SCHNEIDER: My name is Ray Schneider, I i L 22 represent the Combustion Engineering Owners Group. I am the l 23 project manager for the task on PASS relaxation, j 24 elimination. Listening to the opening remarks of Chairman 25 Kress and Mr. Powers, we certainly hope to address your ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 LL
E 1 concerns and give a good picture of the role of PASS in f 1
- (~T 2 accident management and how that is performed.
! \_) ' ! 3 There are two presentations. My presentation will 4 talk about the specific PASS relaxation, elimination effort. l 1 5- And following that, Mr. Bice from ANO will give a very I l 6 think nteresting presentation on accident management, the 7 multiple ways that emergency planning is performed at his 8 plant, and the roles sampling, in general, plays in the 9 overall process. 10 My presentation is broken up into four basic 11 parts. To provide the history, I will talk a little bit 12 about the purpose of the PASS elimination effort, the 13 background as to what PASS elimination -- why we are 14 visiting PASS elimination. Then we are going to go through () 15 the key items for the assessment of the post-accident 16 sampling system requirements and why I believe they should l 17 be eliminated and/or modified. And we are going to have a 18 short conclusion. 1 19 What we want to do with PASS elimination is to 20 remove the PASS requirements from the CEOG plant licensing 21 bases, discontinue operation and maintenance activities on 22 the PASS components and, where appropriate, identify 23 alternative non-PASS equipment and procedures to meet the 24 key objectives of the PASS kind of information that we will 25 is useful. I T- ANN RILEY & ASSOCIATES, LTD. { I4 - Court Reporters L 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p. ( 6 1 When you go back to PASS, it is probably () 2 3 worthwhile to move back to the TMI and the post-TMI changes. CHAIRMAN KRESS: Excuse me. Could you give me an 4 idea of how many plants this would affect? How many plants 5 are there? 1 l 6 MR. SCHNEIDER: There are eight members. There is l l 7 about like 12 plants, or 12 to 13 plants in the CEOG fleet. 8 CHAIRMAN KRESS: Thank you. 9 MR. SCHNEIDER: Okay. The post-TMI changes were 10 instituted basically to improve the post-accident response 11 for beyond design basis events. There was clearly an 12 indication that the operators were not prepared to deal with 13 anything that wasn't in their initial normal operation or 14 design basis training. () 15 A lot has been done to further that in the 16 industry. The industry has developed improved emergency 17 operating procedures and, following TMI, certain instruments 18 were added to the plant, the reactor vessel level monitoring 19 system, to be one, and the role of certain instruments like 20 core exit thermocouples were given a higher level of 21 scrutiny for its potential use in following beyond design 22 basis events. ] 23 There has been a lot of work in improved operator 24 training, to understand, interpret and deal with beyond 25 design basis events, in addition. One of the outgrowths was l l h
%, l ANN RILEY & ASSOCIATES, LTD.
Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
7 1 the post-accident sampling system, but it was part of this (~N 2 triad and a lot of the key issues that came out of TMI were \_) 3 really associated, we believe, with the first two. 4 In addition, following in '88, the industry had an 5 introspective review of its severe accident vulnerabilities 6 where each of the plants were asked -- individual plant 7 evaluations, examinations -- were asked to identify those 8 areas that would pose risk, unnecessary risk and improve 9 them, identify them and improve them. 10 And, finally, as an outgrowth of all of this, we 11 implemented severe accident management guidance at all 12 plants in the United States, but particularly it was 13 completed for the CE plants in December 1988. So a lot has 14 changed and understanding of the issues has improved g ( J 15 substantially. %/ 16 The PASS sampling system was intended to acquire 17 information supporting emergency response, accident 18 management and accident recovery actions. It basically 19 required that they look at some coolant chemistry and 20 containment atmosphere parameters, and the PASS information 21 was specifically called out to do core damage assessment. 22 Those were the initial ideas behind why PASS might have been 23 necessary. 24 But very quickly, as early as the early 1980s, 25 there was a rereview of what PASS was being asked to do and (') (_) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
8 1 of its necessity. NRC's contractor study 4330 indicated 2 that -- or recommended relaxation in a number of the PASS 3 requirements, but the idea was tabled because they said, 4 well, it is only a matter of money, and it really wasn't 5 enough money to worry about, and that really wasn't true. 6 And so due to their, we think a weak cost benefit analysis, 7 they tabled the idea. 8 CHAIRMAN KRESS: Is it a lot of money? 9 MR. SCHNEIDER: Well, we will talk about that in 10 the future. Each plant, just the maintenance alone of the 11' PASS system, PASS is known to be one of the most maintained, 12 requiring the most maintenance, basically, in the plant. On 13 a yearly basis each plant, each system is about maybe 80K, 14 plus capital costs, obsolete equipment and stuff like that () 15 for replacements, the overall lifetime value of this 16 throughout our fleet, we estimate to be something on the 17 order of maybe about $20 million. 18 DR. WALLIS: Why is it so expensive? It is a 19 ? pretty simple thing, isn't it? 20 MR. ECHNEIDER: Well, you have a lot of very fine 21 filters, very small needle like sampling devices. The 22 concern is you want to make sure that it is -- it all has to 23 be highly calibrated, because you are reading very, very 24 small sample sizes. And they break down, it breaks down 25 quite a bit. O (_s/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
9
- 1. CHAIRMAN KRESS: In the presentations, will you
'2 give us some idea of what the PASS consists of? Sampling )
3 from the RCS, sampling from containment, sampling from sump 4 water. 5 MR. SCHNEIDER: We are going to be talking about 6 all those issues in a minute. 7 CHAIRMAN KRESS: You want to just know what PASS 8 consists of in the CE Owners Group plant somewhere. 9 MR. SCHNEIDER: Okay. I think like maybe -- yes, 10 I think it will be covered in the presentation. 11 DR. WALLIS: To me, it doesn't look any more 12 complicated, basically, than the kind of thing that happens 13 when you go in for a blood test. I mean you just take a 14 sample and analyze it. It is not a very expensive () 15 16 procedure, or expensive thing.to maintain. procedure gets expensive. Maybe the actual 17 MR. SCHNEIDER: Well, the procedure is expensive, 18 too, because what you are doing is you are asking people to 19 go into possibly high radiation dose regions. 20 DR. WALLIS: Well, that is only when it happens. 21 Maintenance shouldn't be -- 22 MR. SCHNEIDER: Oh , no, right. But the actual 23 maintenance is expensive because you have to continuously 24 keep systems that normally aren't operating, operating with 25 -- I am not the mechanical design person. / ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
1 [ 10 1 DR. WALLIS: Got to keep testing it?
, 2 MR. SCHNEIDER: It has to be continuously -- it 3 has to be. periodically tested. Okay. Because you are I 4 dealing with millimeter size assessments, the assessments 5 aren't easy. Collection is not -- you have to make sure you '
6 do the right amount of flushing. It all has to be very 1 7 highly calibrated. 8 MR. SIEBER: You do have a number of in-line cells 9 in your system as well as being to extract samples, is that 10 not the case? The Westinghouse system, I know has in-line 11- cells, so those require a lot of work all the time to keep 12 them clean and keep them operable. 13 MR. SCHNEIDER: Right. I see what you mean, there 14 is a lot of in-line equipment that also has to be () 15 16 maintained. But we had one down for a cost estimate for all of the utilities to figure out what they actually were 17 spending. And the story I basically say is that when we 18 indicated that we wanted to work on eliminating PASS, it is 19 one of the few systems that you could basically say to a
~20 plant staff that you want to eliminate, where they actually 21 kind of get up and cheer. I mean it is a real nuisance to 22 them. It is a system that, as what they see, requires a j 23 large amount of resources with no apparent benefit. i l
24 DR. WALLIS: That is because it is a bad design, 25 not because its intent is at fault. Maybe it is just , 1 l ("'g ANN RILEY & ASSOCIATES, LTD. l (_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 j Washington, D.C. 20036 (202) 842-0034 i
- 11 L
1 because'it is'a bad design. If it were designed for easier () 2 31 maintenance, it wouldn't'be so expensive. MR..SCHNEIDER: But that is the systems'we have. l '4 But, also, when it comes right down to it, the value isn't 5 there. Regardless of the cost, the value just isn't there 6 in keeping it. 7 DR. WALLIS: I think that is what you have to 8 show. 9 MR. SCHNEIDER: And that is what we will work on. 10 CHAIRMAN KRESS: I think that is primarily what we 11 are interested in.
'12 MR. SCHNEIDER: Right. Right. So, NRC concurred 13 .with the use of the safety -- in the past we have asked for 14 certain-relief on various PASS applications. In
() 15 CE-NPSD-415, we presented arguments for downgrading -- not 16 downgrading, for replacing the containment hydrogen grab 17 sample with the Reg. Guide 1.97 hydrogen analyzers, and for 18 the plants with passive pH control, a recommendation to 19 delete the pH requirements. Both of those were granted for 20 CE plants. NRC also agreed -- 21 CHAIRMAN KRESS: So those two parts are not even 22 part of this submittal? They have already been approved, i 23 those two parts? 24 MR. SCHNEIDER: Right. We are basically including 25 it for completeness so that the committee can understand the l l% ANN RILEY & ASSOCIATES, LTD. ; l. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
12 1 full scope of what we are actually saying.
"2 DR. WALLIS: The pH requirements are not part of
{} 3 the present discussion. 4 MR. SCHNEIDER: We are including the information 1 5 and we are willing to discuss it, but a number of the plants 6 have already implemented it as a result of being granted. 7 The NRC suggested extension of boron samples, 8 provided we have neutron flux measurements, which we will 9 do. So those were the items that were initially on the 10 table. 11 Following that, in 1995, additional or different ' 12 PASS relief was granted for the evolutionary PWR system 80+, 13 and then cince 1996, the NRC itself has been under internal 14 review as to what really is the requirements on the PASS (O) 15 system and what is its value to them. And this is I guess l 16 the culmination of those discussions. 17 Just briefly, why is the CEOG revisiting PASS? ! 18 Well, now that we have finally implemented accident l l 19 management, it became quite clear that we are really -- the j 20 information that PASS is giving us isn't timely, isn't 21 needed and isn't used. And, as a result, we believe that 22 that is -- that was the thing that kind of focused us on, 23 well, why are the resources expended? 24 Use of PASS is not viewed as risk beneficial. 25 That is another issue in that we believe that some of the ANN RILEY & ASSOCIATES, LTD. Q(_ r Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
13 1 information you are going to get out of PASS can actually
/~'i 2 provide overload to the operator, in that the information we t
3 expect to be not correct, or expect to basically not be what 4 they might expect, and they could end up possibly delaying, l l 5- reconsidering or getting confused with interpreting some of l 6 the results. And we will talk about that. 7 CHAIRMAN KRESS: Yeah, we would like to -- go 8 ahead, Dana. 9 DR. POWERS: You believe that, I mean there must i 10 be some reason you believe that they are going to be 11 overloaded, confused. 12 MR. SCHNEIDER: The main concern we will talk 13 about is in the radionuclide, the radioisotope issue. We 4 14 expect tremendous amounts of deposition and plateout in the () 15 lines assessing the containment atmosphere, and the feeling 16 is that the operator is going to be confronted with high l 17 radiation doses in containment based his high rad monitors, 1 18 and he is going to see a lot lower iodine levels in the 19 sample that he is actually pulling out from PASS, and he is 20 going to have to -- l 21 CHAIRMAN KRESS: Are your radiation monitors in 1 22 containment, are they sensitive to iodine? 23 MR. SCHNEIDER: Well, they are sensitive to total 24 radiation level. They don't selectively pick out iodine l 25 versus cesium. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
14 1 DR. POWERS: So how does he get confused by a low 2 iodine sample? (~')\ 3 MR. SCHNEIDER: Well, because he is going to be 4 very expecting very high levels of core damage. The core 5 damage would say you would expect iodine levels around this 6 value, and, of course, we have a core damage assessment 7 which basically says that, given this level of radiation 8 monitoring, given the rad monitors in the containment are 9 reading this level at this time, you expect this level of 10 core damage, he is going to go in and say that level of core 11 damage should produce that much iodine, and then he is going 12 to come out and say I am only picking up this much iodine, 13 so one or the other has got to be off. 14 CHAIRMAN KRESS: How does the PASS system select 15 and look for iodine? (O) 16 MR. SCHNEIDER: I guess they may vary, but there 17 is a chemical analysis that is done. I 18 CHAIRMAN KRESS: A chemical analysis of the 19 sample. 20 MR. SCHNEIDER: I don't know if that is -- is it 21 only chemical? 22 MR. BICE: There is no on-line. I am David Bice j 23 from Arkansas Nuclear 1 and I will just help right out on l 24 occasion. But there is no on-line iodine detection, so that 1 25 does have to be analyzed. l l l AJRi RILEY & ASSOCIATES, LTD. ! f)\ (- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 j' Washington, D.C. 20036 (202) 842-0034 l l l
I i 15 l l 1 DR. POWERS: Surely, they don't do it by chemical I l (T 1
\ ,I 2 analysis. There is no not enough iodine to analyze, is 3 there?
4 MR. SCHNEIDER: I didn't hear all of it. l 5 DR. POWERS: I mean in an extremely hot iodine 6 sample is very little iodine. So, I mean how do you do it l 7 by chemical analysis? I think you would have to do it by 8 gamma analysis or something like that. 9 CHAIRMAN KRESS: There is no gamma to look at. I 10 think you have to do it by -- 11 MR. BICE: They do. They do perform a gamma spec, 12 yes. 13 DR. POWERS: I would think they would have to do a 14 gamma spectroscopy, that is the only way. [J 15 MR, BICE: It is an analysis, it is not chemical, 16 it is gamma spectrometry. 17 DR. POWERS: Well, I guess I am not surprised it 18 is not useful. I mean if we have got a bad sampling system 19 that deposits all the material in the line. 20 CHAIRMAN KRESS: Then what you look at is not very 21 representative. I think that is basically a good point. 22 DR. POWERS: Yeah. 23 MR. SCHNEIDER: But you have got to through the 24 history, though, as to why. 25 DR. POWERS: I mean all it said so far is that l /O ANN RILEY & ASSOCIATES, LTD. I () Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
16 1 they have a bad sample. (~'T 2 CHAIRMAN KRESS: That is what they tell you. L) 3 MR. SIEBER: Not only is it not representative, 4 but it non-conservative 5 CHAIRMAN KRESS: It gives you lower values. 6 MR. .SIEBER: I mean you get lower than the number 7 that is actually there. 8 MR. SCHNEIDER: You have to go to the history as 9 to why the sample systems were designed the way they were. 10 Remember, the TID source term was basically dominated by
/
11 elemental iodine, so the feeling was, okdy, if I heat trace 12 the lines, I can get my elemental iodine out to the source. 13 We now believe that that is not what it is going to be 14 dominated by, it will be dominated by the aerosols and the r^x 15 aerosols won't make it. ? ) x_/ 16 And even the heat tracing isn't quite clear enough 17 that that is going to even be enough to get all the iodines, 18 but the point is, you are going to get a much lower sample, 19 but you design to what we understood the source term to be. 20 We now know more, and that is why we are saying, we are 21 integrating this knowledge into the AMGs and we are trying 22 ;o basically put the knowledge into the operating staff and 23 the technicians, and this additional measurement we don't 24 feel is valuable. 25 DR. WALLIS: Well, I guess we would know if it was (~'N ANN RILEY & ASSOCIATES, LTD. () Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
17
- 1. valuable or not if we knew what it would be used for.
2 MR. SCHNEIDER: Right. And we will be talking [ 3 about that in a minute. David Bice has I think an excellent 4 presentation to follow talking about accident management 5 procedures at a plant and how all of the instrumentation and 6 equipment factors into decision-making. 7- Finally -- maintenance costs. So we have a system 8 that is not used,.not really very reliable or providing this 9 information we are looking for and not inexpensive to 10 maintain. 11 I will go through the list, but we kind of picked 12 .up some of the key issues here. 13 PASS measurements -- one, they are slow for 14 decision-making. The samples you are taking can be quite () 15 displaced in time-for the actual measurement you are making,
- u5 so clearly you can't do it for rapidly changing events.
17 Long time, that may be a little different. 18 PASS measurements are not relied upon in the 19 emergency operating procedures. They are all geared toward 20 in-plant instrumentation'and quick response. 21 Sir.e emergency plans can establish emergency [ 22 action levels primarily on area or site radiation levels, , 23 core exit thermocouples and plant conditions without using i 24 PASS, so you don't need it for defining your event. The 25 emergency plans do not require PASS data for defining ANN RILEY & ASSOCIATES, LTD. O. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
l 18 1 protection' action guidance. It is primarily based on field (} 2 measurement and the amount that you'believe is actually 3 getting out to the public, and you will see why that is more 4 important. 5 SAMGs initiate the Candidate High Level Actions, 6 generally independent of PASS. It's based on generally 7 plant conditions, radiation levels and thermocouple levels 8 and.the like, hydrogen, and CEOG core damage assessment 9 methods can be based on in-plant instrumentation because the 10 methodology.we initially set out for -- 11 CHAIRMAN KRESS: Let me ask you a question about 12 that. 13 If the PASS had turned out to be a really clever, 14 good design and you got timely information, instantaneous, (D) 15 and that it was also good measurements of the fission 16 products, then would these other bullets be true? Would the 17 site emergency plans use them and would the protective 18 actions use them? Are those other bullets a result of the 19 fact that the PASS system is just not a good design? l 20 MR. SCHNEIDER: No , and I will try to give a 21 couple points and then I know David may want to say a couple 22 of things, but the problem with what you are looking for is 23 we believe that'you really want to know what dose is getting 24 out to the public. What PASS is basically monitoring is 25 what you have inside containment. It is not monitoring your ANN RILEY & ASSOCIATES, LTD.
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(ss Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
19 1 major release paths. O %d 2 If you have an ISLOCA, which is a very severe 3 event, it has no way of monitoring that. You can't monitor 4 the steam generator tube rupture releases. All PASS can do 5 at maximum is to monitor the more benign severe accident 6 events. I rean they are not benign events, but those events 7 where containment basically is integral and not much is 8 changing. 9 If you are using PASS to make decisions, such as l 10 even venting, which you have to recognize is the stuff that l 11 when you take an action you are changing the state of the ' 12 containment, if you measure something in the containment i i 13 that tells you my Ib 1 Iodine is low, then you take an 14 action to depressurize the containment, you now have to (Oj 15 basically assume that -- you have to recognize that 16 somewhere that iodine is going to get into the atmosphere 17 and PASS can't do that at the time you are making .'.he 18 decision, and you have to basically take conservative 19 appropriate actions based on how the event has progressed, 20 as opposed to some snapshots in specific time. 21 DR. POWERS: If I take a look at it, the frequency 22 of accidents that will release fission products -- to levels 23 above 1 percent, excluding just routine fuel damage, what 24 fraction of those involve steam generator tube rupture that 25 would bypass the PASS detection systems?
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l l O i l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 i
20 1 ;MR . SCHNEIDER: Guess -- maybe like 5 percent. 2' -The thing is those events are the more significant of the
) '~
3 events that have more. consequences on the public. 4 DR. POWERS: I'll grant you that, but on a 5 ' frequency basis they are a small fraction of the accidents. 6 MR. SCHNEIDER: But on an impact basis, for the 7 important events you are not relying on PASS. For the 1 I l 8 important events, you are relying on your field team 9 monitoring and your containment high radiation -- basically 10 your field-team monitoring for the real important ones. r I l 11 We will talk about this again later, but so while l l 12 you are getting information -- and the thing is, even if you l l 13 know what is happening in the containment, you still don't l-l 14 know how much is actually leaking out until you measure it, () 15 so even-then you are really relying on the field team to L16 basically bring back and say, well this is what is getting l l 17 out. What you are generating are numbers and information, l 18 but it is in terms of impact on the public. l l '19 DR. POWERS: I would think that an estimate based i ! I l 20 on what I know is in the containment, what I estimate the 21 leak rate would be as accurate as a measurement from the l 22 field team. 23 CHAIRMAN KRESS: Probably more so. 24 DR. POWERS: Probably more so, but I just -- , 25 CHAIRMAN KRESS: Getting at the source -- O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
21 1 DR. POWERS: I will try to defend equality before 2 I defend superiority. 3 MR. SIEBER: .That's probably true. 4 DR. POWERS: I would bet. 5 MR. SIEBER: I think one of the drivers here is 6 that under the rules it seems to me that from the time of 7 onset of symptoms of an accident until the Emergency 8 Director is required to run through the EALs and classify 9 the accident is 15 minutes, and in a lot of cases that is 10 anticipatory to the creation of the source term, so the work 11 in the emergency plan is done before you can get a 12 representative sample. 13 CHAIRMAN KRESS: It's a timeliness' issue here. 14 MR. SIEBER: That's right and the driver here -- () 15 and then you have another 15 minutes to give a protective 16 action recommendation and none of that is compatible with 17 the operation of the PASS. system as far as EOPs are 18 concerned or the emergency plan. 19 You have to ask yourself a question. What would 20 the operator do different if he had this information? The 21 answer is probably nothing. 22 CHAIRMAN KRESS: Right. 23 MR. SIEBER: On the other hand, after the fact 24 everybody.wants to know what is in there. 25 CHAIRMAN KRESS: The high radiation monitors in O ANN RILEY & ASSOCIATES, LTD, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 1 the containment, are they designed to read the PID 14-844 2 source term? Are they designed to go to that level? ) O,/'S 3 MR, SCHNEIDER: Yes. That is their primary design 1 4 basis. I 5 CHAIRMAN KRESS: So they can read a full severe 6 accident and -- 7 MR. SCHNEIDER: Right. That is the intent of 8 these' instruments. 9 Let me add a postscript on the CDA method. When 10 we developed Core Damage Assessment methods we actually did 11 four things. We did a core damage assessment that was based l 12 on the core exit thermocouples to a certain level, then we 13 had a core damage assessment that was based on hydrogen, 14 then we had a core damage assessment that was based on r~N l j 15 radiation levels, and the last and fourth tier was having A._/ 16 the core damage assessment based on a detailed radioisotopic 17 breakdown of what they measured from PASS and we now believe 18 that that is not going to come up with -- initially we 19 thought that that was going to be the more accurate of the 20 four. We now believe it is going to be the least accurate 21 of the four. 22 At this point all we are recommending in our core 23 damage assessment methodology is basically drop the fourth 24 one, but the emergency planners and our plants already have 25 a four-tier in place, and so they have the three tiers
/~N ANN RILEY & ASSOCIATES, LTD.
( ,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l l 23 1- already pretty much in place for core damage assessment, and [ } 2 the. radiation monitors are highly relied upon at the higher 3 ends. 4 ' Why do vn! say PASS is not risk-beneficial? I 5 One, it takes resources to run PASS, analyze PASS, )
)
6- and to interpret the PASS results. There is also an ALARA 7 impact. You are sending people at the high radiation zone 8 to take a sample that hopefully you want to do something f l 9 with, but if we are not going to use it, why do that? 10 The sampling itself may pose a potential of 11 releasing radiation to the Aux Building by having some 12 leakage through the sampling systems. It is not unheard of 13 to find a system that does have some leakage, and that is 14 among the things that they have to maintain. () 15 PASS usage may limit access to certain Auxiliary 16 Building rooms because the PASS lines may be run slightly "7
. off the normal sampling lines, and if they run through 18 different rooms it may prevent access during certain
- 19. accidents to certain areas and it may make recovery during 20 certain accidents more difficult.
21 Due to limitations on the sampling process PASS 22 data we believe can misinform, lead to confusion, possibly 23 result in delayed and unconservative actions. 24 DR. POWERS: All this suggests that it is a really 25 poorly-designed system. O . ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
24 1 MR. SCHNEIDER: All this suggests is that we 2 designed the systems with the current level of knowledge and 3 the level of knowledge may have been premature and maybe the 4 . requirement for PASS was premature at the time. Maybe they 5 should have had more information as to what they actually 6 needed to do the stuff and we believe that when we did 7 accident management, when we revisited the issues we tried 8 to focus on what you need to do the accident management in 9 severe accident space. 10 DR. WALLIS: But one solution would be to say 11' suppose we designed a PASS system now, knowing what we know 12 now, which would not have the disadvantages of the present 13 system. It might have some advantages and give better 14 information, as intended originally -- so one solution if I 15 you fall on your face would be to say let's do a redesign 16 which gets away with the old problems, improves the things 17 which PASS could do before but not very well -- 18 MR. SCHNEIDER: The only piece of the PASS system 19 that probably -- regardless of what you do, you really want 20 to rely on your normal plant instruments that basically you 21 are comfortable with, that you understand how they are going 22 to respond, but the thing is the only even potential 23 long-term value that could have the PASS assessment is in 24 the radionuclide assessment, and the only aspect of that 25 that has any value whatsoever is a post-mortem, so if you
! ANN RILEY & ASSOCIATES, LTD. \ Court Reporters 1025 Connecticut Avenue, IN, Suite 1014 Washington, D.C. 20036 (202) 842-0034
25 1 wanted to basically run your computer codes and say, well, [ 2 here is what happened, did I really predict it right, and 3 are my models really doing a good job when I take them to a 4 prototype kind of event -- and that is not a reason to keep 5 a system of that level of complexity in place. 6 The other thing is -- and we probably could have 7 hit this later -- but the other thing is even when they do, 8 and some of this is anecdotal, but even when they do 9 experiments on environmental -- on releases from fuel, a 10 number of the experimenters have indicated great pains in 11 trying to properly measure the iodine releases due to its 12 activity with certain -- its reactiveness with certain 13 materials and due to the ability for some of these aerosols 14 to play it out in plug lines, that while indeed you might be () 15 able to get more measurements, there is no guarantee that 16 any system you come up with will really bypass all the 17 problems that you are going to have if experimentalists on 18 small-scale systems are having problems. 19 That is a miscellaneous observation, but -- 20 whatever. 21 CHAIRMAN KRESS: If you were trying to just 22 measure krypton and cesium, would you have that same 23 comment? 24 MR. SCHNEIDER: If you want to mear re -- krypton 25 is -- you know, the noble gases are only -- ANN RILEY & ASSOCIATES, LTD. k'_,}/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
26 1 CHAIRMAN KRESS: Krypton is part of the high 2 range.
)
3 MR. SCHNEIDER: Right, and that's.-- I would still 4 question its value but I don't know. I haven't fully 5 thought about krypton. 6 CHAIRMAN KRESS: Current understanding is that the 7 release of cesium is just about the same fraction as the 8 release of iodine. ! 9 MR. SCHNEIDER: Right. 10 CHAIRMAN KRESS: So it could be a surrogate for 11 iodine. 12 MR. SCHNEIDER: Yes. What may not be a surrogate 13 though is that cesium doesn't -- cesium does have different 14 characteristics in terms of its, not so much its -- in the l( ) 15 short term it is going to be the same. In the long term, it 16 behaves differently. Once it is in solution it is 17 different. 18 - CHAIRMAN KRESS: If it gets in long-term, it is 19 entirely different, yes. 20 MR. SCHNEIDER: In the short-term I don't think l ! 21 there is any problem in the plants responding in the 22 short-term. l 23 DR. POWERS: It seems to me that they made a 24 persuasive case that you don't use this at any time in the 25 short term. Now ask me about three and four days in an ANN RILEY & ASSOCIATES, LTD. [( )) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 ( . (202) 842-0034
l l 27 l 1. accident like.TMI where you have had an arrested core melt
/~ 2 and all the PRAs I see following core damage, most of them i .k}/
3 go to an arrest mode. 4 CHAIRMAN KRESS: Yes, that's right.
- 5. DR. POWERS: The conditional probability of' going 6 into an arrest is reasonably high and the question is do you 7 have a permanent arrest or is it a temporary arrest or is it 8 just a slow progression?
l 9 It seems to me that that is the phase where these i 10 analyses are done, and that is the phase where I think I 11 would question using cesium as a surrogate for iodine. 12 CHAIRMAN KRESS: Clearly it wouldn't be a good one j 1 l 13 then. l 14 DR. POWERS: I mean it would be questionable and () 15 16 it depends on what is happening but I think you would want independent monitoring. l 17 CHAIRMAN KRESS: I think you would, but I think 18 having an indication earlier on with cesium could tell you a 19 lot of information on what to look for. It would give you
)
1 20 the initial conditions for your thinking, so it would be ) 21 useful information. You wouldn't want to continue following 22 the cesium and think you are following the iodine. 23 MR. SCHNEIDER: Yes. 24- CHAIRMAN KRESS: It would set the initial l 25 conditions. T ANN RILEY & ASSOCIATES, LTD. i{s,,/ Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
f l 28 l 1 MR. SCHNEIDER: I actually went through this piece 2 of the information, but this is the economic piece of the 3 puzzle, indicating it is a high expense relative system with 4 the issue of a lot of obsolete equipment coming up and l 5 replacing it is getting to be expensive, plus long-term 6 integrated expectation of cost is high. l 7 CHAIRMAN KRESS: Is $80,000 per year something you 8 guys really worry about? 9 MR. SCHNEIDER: What you are basically saying is 10 what is a man and a half dedicated to the system, to repair 11 it, is that basically how you view it? Something like 12 that -- so I mean do you really want to have your staff, 13 dedicated staff, just for repairing a system that you don't 14 really plan on using? () 15 16 I think that is part of it. I mean the other part is if there really is an expectation that you are going to 17 use it and if it does run the risk -- true, there are other 18 issues, right. If it runs the risk of additional releases 19 or if it runs the risk of unnecessarily requiring you to 20 expose people because you just kind of felt that the 21 information would be neat to have, it doesn't seem like it i
. 22 is worth the effort to tie a person up for that.
l 23 What I wanted to basically do was give you the 24 pieces of the PASS. Basically the PASS had five pieces, l 25 five key pieces. I think this is really basically all we I p/ w.,, ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
r' ] 29 1 are asking for. ~ PASS requires a total dissolved gas sample. 6 I 2 We'are recommending eliminating the RCS dissolved gas l 3 sample -- give you a basis. 4 We have already gotten agreement for the 5 elimination of the sump pH sample and we can talk about that , i 6 a little bit if you would like. 7 We have already replaced the containment hydrogen j 8 sample with Reg Guide 1.97 in containment hydrogen monitors 9 and that is in place. 10 We would like to eliminate the coolant boron 11 sample and we would like to replace the radioisotopic sample 12 with a commitment to field team I-131 monitor the -- 13 CHAIRMAN KRESS: Is that outside -- the 14 containment outside? () 15 16 MR. SCHNEIDER: Outside. Do the site monitoring to pick up Iodine-131 if we feel additional information is 17 necessary to provide guidance to the operators. 18 CHAIRMAN KRESS: How does that system work? l 19 MR. SCHNEIDER: Well, a lot of plants already have I
. l 20 this and I think it would vary among the plants. .Some of it i 1
21 could have it a way where they will just collect a sample l 22 from either air samples around the site, various locations. 23 They could bring it into the plant for analysis. Some have ! 24' the ability to analyze it by having certain filters with the ) 25 field team that could measure the Iodine-131 in situ [f ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
30 1 basically as they make the measurement, g' 2 CHAIRMAN KRESS: -So they don't have to wait for a 3 chemical analysis of the sample? They can get something
~
4 online? 5 MR. SCHNEIDER: They don't have to but not all of 6 them have that capability, so that may vary. 7 CHAIRMAN KRESS: The reason I ask is why is that 8 any different from the sample from the containment? Why 9 can't you do that with a containment sample? 10 MR. SIEBER: I think the problem with field 11 monitoring is you send teams out and as we know unless it's 12 perfectly flat and you have a standard fusion that the stuff 13 collects in pockets and whether the field team finds it or 14 not is a question. (v) 15 DR. WALLIS: So it is worse than in containment? 16 MR. SIEBER: Well, the dispersion -- 17 DR. WALLIS: If I know where to look for it -- 18 MR. SCHNEIDER: But field teams are sent with j 19 knowledge of the meteorological conditions and they are sent l 20 with a high level of guidance as to whether to go look for 21 it, but the point is you have to count on the field teams 22 for the most significant events. There is the ability to 23 monitor the radiation plume, so they will chase it until 24 they find it, I would guess. 25 CHAIRMAN KRESS: Is this information then used for l F ANN RILEY & ASSOCIATES, LTD. k_s\
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31 1 the emergency response in some way? 2 MR. SCHNEIDER: Yes. 3 DR. POWERS: I mean it is kind of a peculiarity 4 here. You are very concerned about the possibility of 5 exposure to run the PASS system sampling but you are very 6 _ content to send the field teams out to find this plume, 7 which I think would expose them to the plume. , 8 CHAIRMAN KRESS: I'think by the time you read it, 9 it may be a little late to do an emergency response. 10 DR. POWERS: It could be, but in any event -- it 11 does seem inconsistent. 12 CHAIRMAN KRESS: There seems to be an 13 inconsistency. 14 DR. POWERS: Dave, do you want to take a shot at () 15 16 it? MR. BICE: Let me say one thing there. I am Dave 17 Bice again. l 18 Number one, we need to understand that the PASS 19 system does not have a lot of in-line monitoring capability. 20 Even what you get from there you are going to have to take 21 the time to analyze and you really take a look at any of the 22 specific systems, the time it takes to get the system 23 started up, not to mention the time getting the personnel 24 down there to start it up, take the sample -- which is more 25 cumbersome than using a normal sample system, because now O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 1 32 1 you are taking samples inside lead casks and things of that /~^) ( 2 nature -- and then perform an analysis, which in many cases ! s_- , 3 has to be done offsite because of the radiological dose is 1 l 4 not going to input to your immediate mitigation at all and 5 in my opinion ever. It will never be used as a mitigation ! 6 for the first few days. l 7 Now a field team, sure, they may be being exposed 8 to iodine, whatever, other radionuclides that are airborne 9 out there, but one thing -- it's dispersed. It is not the 10 full brunt radiation exposure you are going to get down in 11 the sample room early on in an accident. They wear the same 12 protective equipment. 13 DR. POWERS: I don't understand that. You 14 presumably have some sort of shielding, some sort of r~s ( %.J
) 15 protection on the sampling system, whereas I have got a guy 16 running around outside with a respirator and maybe a pair of 17 goggles on or something like that, I mean it would seem --
18 I'm pretty sure I know where I am willing to bet the heavier 19 dose comes from. 20 MR. SCHNEIDER: But when they take the sample, the 21 sample is a highly concentrated source. When you have 22 dispersed it, it's already been -- you want to -- 23 DR. POWERS: Yet more evidence this is a really 24 badly designed system. 25 DR. WALLIS: Well, I think also you should have (T ( ,/ ANN RILEY & ASSOCIATES, LTD. Court Reporters , 1025 Connecticut Avenue, NW, Suite 1014 1 Washington, D.C. 20036 I (202) 842-0034 l
33 1 some numbers, not-just sort of a vague thing. If you could
.2 actually convince us that the dose would be less because d("5 3 someone has calculated it --
4 MR. SCHNEIDER: We l .'. , the PASS-system doses were 5 basically estimated at like -- the limit that you are 6 . allowed to give a person was like 5 rem and so that dose 7 between 3 to 5 rem to basically take the sample, which is 8 not -- 9; DR. WALLIS: That's the anticipated dose to the 10 field team? 11 DR. POWERS: That would get up to 25 rems. 12 DR. WALLIS: Your guess is 25 rem -- 13 MR. SCHNEIDER: Up to. 14 DR. WALLIS: Did you guys calculate it? [ 15 MR. BICE: I don't have the field team L 16 'information. I am relatively confident that the field team 17 exposure is still within the limits of 10 CFR, but keep in 18 mind also that you are being exposed, when you take the 19 sample with all the radionuclides inside that sample, even 20 once you draw it, you have got to transport it to an 21 analyzer. You have to perform the analysis, dump it 22 somewhere, and that is -- to me, I don't know -- I didn't 23 bring any exact numbers but I would almost bet that that is 24 an extremely higher amount of exposure than what you will 25 ever get in the field. -{g ANN RILEY & ASSOCIATES, LTD.
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I 34 1 1 1- MR. SCHNEIDER: Let me make one more point. The ('N 2L stuff that leaks out of the containment is not going to leak 'l' (s )- 3 out at much greater than 1 volume percent per day, and in 4 one case you get a very concentrated sample. In the other 5 case'the leakage rate, while it is not good for the public, 6 is a very small fraction of the containment atmosphere a 7 day,-so you are only talking about.even at.best .1 percent 8 of what that source was initially if you were to analyze it 9 close-up. 10 CHAIRMAN KRESS: What that tella me is that the 11 measurement is not nearly as informative as the one with the 12 higher activity because you get a lot more information out 13 of the one with the higher activity because you have got 14 other things interceding,'such as the ability to measure it () 15 16 out in the field, the dispersion, where is it really going, have I found the right place, so the information quantity is 17- not quite the same. I don't know if it is a full 18 replacement. 19 MR. SIEBER: On the other hand, I think that what 20 affects the general public is what is out in the field more , 21 than what is in the containment because you have no good way 22 of_ measuring the out leakage, how it is getting to the 23 outside. 24 I guess the other thing is that watching survey 25 teams in action under simulated conditions the Survey ANN RILEY & ASSOCIATES, LTD. O' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p 35 1 Director will direct the survey team away from activity that
)
2 will give them significant exposure once they find exposure, 3 because if they can tell them what they need to know to get 4 to the plume, they can also tell them what they need to know 5 to get out of that, so that is the check and balance on 6 exposure to the survey team. 7 .The productive action guidelines are made well 8 before the samples would be in. 9 CHAIRMAN KRESS: Are there in-place monitors in an 10 array or matrix around the site so that they can do 11 something about where the plume is? j 12 MR. SIEBER: Some plants had them. They were part 13 of Reg. Guide 1.97. There are a few plants that had the 16 14 monitors in a circle around the plant, but not everybody put [) 15 them in. s-16 DR. WALLIS: If you directed it , if from the I 17 plume in order to avoid their radionuclide uose, it means j l 18 that they are not going to make the measurements. I know, i 19 you sort of approach the plume gingerly and you get one 20 measurement on the edge of it, you don't get a very good 21 ascessment of what is in the middle of it. 22 MR. SIEBER: That's true. But you would know 23 where it is, and what it is. 24 CHAIRMAN KRESS: That was my point about it being 25 best quality. (
\
JuC1 RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034-
l 1 36 1 DR. POWERS: In truth, you know where it was. ' [ ,] 2 MR. SIEBER: Right. It has moved on. 'w/ 3 DR. WALLIS: Well, you know where its edge was 4 without going in the middle. 5 MR. SCHNEIDER: And where it is going and that is l 6 kind of what you have to know. So, we feel that having this 7 available provides more information at least for all the 8 accidents, and certainly for the more limiting ones. 9 CHAIRMAN KRESS: So, really, though, what we 10 should be focusing on for this application is Bullet 1. 11 Bullet 2 is already, in effect, accomplished. j 12 MR. SCHNEIDER: Right. 13 CHAIRMAN KRESS: Bullet 3 is already, in effect, 14 accomplished. So, Bullet 4 we could focus on. And Bullet 5 (m,) 15 is just a reason. So it is Bullet 1 and Bullet 4 that we i 16 are talking about in this proposal? 17 MR. SIEBER: We did indicate that we would talk a 18 little bit about Bullet 2 also there. ; 19 CHAIRMAN KRESS: Yeah, but it is already -- I 20 think I heard that it is already, for the CEOG plants, that 21 that has already been approved. 22 MR. SIEBER: Well, it has been granted in a couple 23 of cases, system 80 plants. 24 MR. SCHNEIDER: No , it has been granted for the 25 CEOG for the individual utilities, a SER has been written. ANN RILEY & ASGOCIATES, LTD. l)\ ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
37 1- MR. SIEBER: Yeah, I read the SER. 2 MR. SCHNEIDER: I don't know if everyor.e has it.
)
3 DR. POWERS: The staff is persuaded that they can L 4 do calculations of pH. 5 CHAIRMAN.KRESS: Apparently there are able to 6 calculate pH. 7 DR. POWERS: In all of its complexity. It is 8 something they are going to have to teach me about, because 9 I certainly can't do it. 10 CHAIRMAN KRESS: I would sure like to see that. 11 DR. POWERS: Yeah, I would like to see that 12 calculation. 13 MR. SIEBER: Well, I question that, too. 14 CHAIRMAN KRESS: But apparently the horse already () 15 left the barn for CEOG. If I heard right, it has already 16 been approved. 17 DR POWERS: Well, the contention here is that 18 they have adequate passive control, and they could well 19 have, I mean given that they have an infinite amount.of base
- 20 somewhere to add.
21 CHAIRMAN KRESS: If they have passive control, 22 then I wouldn't be as -- I would be reluctant to worry about 23 it. I mean I wouldn't have so much worry. 24 MR. SIEBER: Doesn't the pH also affect the source 25 te'm? r ANN RILEY & ASSOCIATES, LTD. Court Reporters
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p l 38 1 DR. POWERS: Oh, yeah, to a big extent. i [' 2 MR. SIEBER: And that is not mentioned in the CE 3 Owners Group paper. It also says that you know what else is 4 in containment, which I doubt. 5 MR. SCHNEIDER: It is mentioned in the second. 6 You know, as I said, when we redid the evaluation, we did it 7 on all the items, and we'tried to give the technical basis. 8 And while some of the discussions may not have come up in 9 the first position, we did try to completely discuss it, or 10 at least cover it again in the most recent submittal. And I 11 am willing to talk a little bit about it if you want. 12 CHAIRMAN KRESS: You might be able to tell us what 13 your passive pH control is. 14 MR. SCHNEIDER: I can tell you a little bit, (q j 15 CHAIRMAN KRESS: That would be my major interest. 16 MR. SCHNEIDER: Okay. I have short summaries of 17 what we are basically saying with respect to RCS dissolved 18 total gas sample. The intent is basically to identify 19 non-condensable gases in the RCS. At this point that sample ! 1 20 has no role at all in accident management and is primarily j 21 preempted by the reactor vessel level monitoring system, 22 which basically indicates the existence of a void and the 23 ability to -- and all of our accident procedures are based 24 on using that kind of information to help eliminate the void 25 and to identify the void, and reactor vessel head vents. It l ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
F i 39 1 also has no real role in core damage assessment. 2 DR. POWERS: Let me reveal a bias that I may have. 3 As I sat through the TMI accident, getting regular sump 4 samples, sampling taken, and I was charged at the time, a 5 young and bright-eyed, bushy-tailed individual, to make core 6 damage assessments based on fission product releases to the 7 sump. And with no small measure of pride, at least I was 8 able to predict the core was damaged at the time, something 9 that the temperature and radiation monitor people couldn't 10 do. 11 So, I guess the bias I have is, yeah, I think you 12 can get a pretty good core damage assessment from knowing 13 where the radionuclides are. 14 MR. SCHNEIDER: I believe you can also get a () 15 16 decent assessment by other means as well, radiation levels, core exit thermocouples and progression, -- event. 17 DR. POWERS: Well, that's another thing, you bring 18 up radiation levels. I mean during the TMI accident, the 19 problem we had with the high level alarms and monitors in 20 the containment is they were all pinning-out. They were 21 bouncing off the top end of the strip chart recorders and 22 they were essentially useless, except to know that there was 23 a lot of radiation. 24 MR. SCHNEIDER: Well, the measurements have to be 25 sufficient to get to high levels of core damage. I don't T ANN RILEY & ASSOCIATES, LTD.
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40 1 know how they were set in TMI. I mean it could just very 2 well be that they -- and, also, the times have changed. I 3 mean in the old days, thermocouples were not read visually, 4 'they were read by using AM meters once you went off the -- 5 or micro AM meters once you went off the scale. And, you 6 know, we even have instructions now for our operating staff 7 to read, using pico AM meters, to read some of the neutron 8 flux monitors to establish the progression of the event. 9 The level of knowledge that the people gained from 10 TMI, and 20 years of NRC research, has been factored into 11 our way of thinking. That while you don't have the specific 12 numbers, there is a great deal of awareness of trending, 13 where things are going, how things got there, much more how 14 issues tie together. And I don't believe you would get into () 15 16 that level of situations where people see thermocouples going off the high end and saying, well, not a problem. I 17 just don't see that anymore. 18 But in those days, they were confronted with 19 something they never expected, never were trained for, had 20 no idea what to make it, and they had a call, you know, they 21 had to count on the bright ones among you to basically guide 22 them. But I think that that information is being factored 23 back into the process. 24 CHAIRMAN KRESS: This particular requirement is 25 looking for hydrogen. Where is the sample from the RCS ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
w-41 1 taken? 2 MR.-SCHNEIDER: This,one would be the hotleg, it 3 would be a.hotleg sample.
- 4. CHAIRMAN KRESS: It is in the hotleg. And it is 15 off of the top of the hotleg or the bottom?
6 MR. BICE: ANO-2 is straight off the side. 7 CHAIRMAN KRESS: Off the side. It generally would 8 be expected to be sampling water then, except very late in a 9 severe accident? E10 MR. BICE: That is its use, generally, is from ) 11 water. 12 CHAIRMAN KRESS: And you are looking for dissolved 13 hydrogen in the water, is what it is looking for? 14 MR. SCHNEIDER: Yeah. () 15 -CHAIRMAN KRESS: It seems like one I could 16 without. 17 MR. SCHNEIDER: Yeah. That was high rn the 18 initial contractor list in 1980, to get rid of. And a 19- number of the people, actually, I think have these connected 20 to high pressure lines, and~it is something you may not want 21 to take a-high pressure line to. I 22 CHAIRMAN KRESS: This is strictly a way to say, 23 hey, I have got hydrogen in here that I didn't think I was
-24 going to have, I have got to think about worrying about it.
25 MR. SCHNEIDER: And I think the post-TMI solution l l ( (_,} - ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
42 1 for putting level monitoring is really the appropriate way [^)
\~J 2 to go.
l 3 MR. SIEBER: Well, actually, that is what the 4 concern was is void formatien in the head. 5 CHAIRMAN KRESS: Right. l l 6 MR. SIEBER: So the level one here does the same. ) l 7 MR. BICE: And as Ray has been saying, the , t 8 operations training has so greatly improved, even without 9 reactor vessel level monitoring, the operators are trained ) 1 1 10 that when they intentionally lower pressure, say, by use of j 11 the pressurizer spray system, if the level goes up, you have l 12 got a bubble. You know, you are expanding that bubble that 13 is no longer in the pressurizer, 3. is somewhere else, so 14 the training operations has nowad..Tr ;s just dramatic fm () 15 compared to what they had back then, much better at severe 16 accident management. 17 MR. SCHNEIDER: RCS and sump pH, that has 18 generally been granted for all plants with passive control. l 19 We still have one plant that doesn't have passive control, 20 but with the dual barrier component cooling water system, 21 and they have generally high pH injection, higher pH levels. 22 But I do want tc talk a little bit, maybe it is 23 worthwhile to talk a little bit about the pH, just for 24 background. Again, it is primarily for iodine retention, 25 corrosion cracking. Its role in stress corrosion cracking
/~'} ANN RILEY & ASSOCIATES, LTD.
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i 43 1 is,'from talking to a lot of the chemists, that unless you 2 get pHs in the high end, really high end, or really low end, 3 it is not really sensitive to pH, and, generally, anything 4 that would retain iodine, if you meet that requirement, you 5 have more than met the stress corrosion cracking requirement 6 or need. L 7' The issue,'the design requirement is that the pH 8 of the system be designed such with all the borated sources 9 being injected into the containment. The pH has to be 10 greater than 7. What we now see from new studies, iodine 11 retention is held quite well all the way down to pHs of 6 12 and maybe even 5-1/2, so there is a lot of margin that is 13 built in. We looked at the issues in system 80+ as an 14 example of the impact of other stuff on the pH control and j) 15 found that its effect was generally small, clearly not 16 enough to actually bring you into the region of high iodine 17 evolution, so that -- 18 DR. POWERS: When you talk about all the other 19 stuff, what are the major sources of the acid coming into 20' this? 21 MR. SCHNEIDER: Hypalon cabling and maybe some PVC 22 insulation, hypalon insulation, nitrous acid being taken in 23 through the' atmosphere. l 24 DR. POWERS: What about the Canadian stuff? 25 MR. SCHNEIDER: I'm sorry? i " f' ANN RILEY & ASSOCIATES, LTD. (,, - Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 , (202) 842-0034 I
1 44 1 DR. POWERS: The Canadians have a bunch of 2 research that says none of those things are important, the 3 real important. stuff in creating organic acids by 4 radiolysis. 5 MR. SCHNEIDER: And you need organic material. 6 DR. POWERS: And they said we have got a ton of 7 it. .The get most of theirs just out of the solvents that 8 are coming out of the paint. 9 MR. SCHNEIDER: And that has to be relatively new 10 paint, right? I mean if you painted the containment years 11 ago, -- 12 DR. POWERS: They said they run 10 years paint 13 samples. 14 MR. SCHNEIDER: I haven't look at that in any () 15 16 great detail. I heard a little bit about it, and I am not,
-- you know, what I was told is that its tails off as a 17 function of time, and after several years, most of the 18 organic material really dissipates, and that if you 19 generally don't paint your containment, yr" know, you don't 20 really have the risk. And I guess they could promise not to 21 paint containments. I don't know how often we do that.
22 DR. POWERS: Well, it is a little bit of a trick 23 question, because it is relatively new stuff, maybe it is a 24 year old and whatnot. The Canadians have been dancing 25 around this for a long time, but they finally came out and
/~ ANN RILEY & ASSOCIATES, LTD.
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45 1 said this is the root cause. And what I am thinking, all (~~) 2 right, Canadians do this, they get a bench of research and I \j 3 they say here is an acid source. As at Oak Ridge, they . l 4 found hypalon, they found that as an acid source. Three 5 years later the guy in Bangladesh, he comes up with an 6 another acid source. And these are very chemically 7 complicated systems. They don't know how many acid sources 8 are coming into the accident. How do we know we have taken 9 care of all of them? 10 MR. SCHNEIDER: Well, the issue maybe is if the 11 design basis, you know, is light and that, you know -- go 12 back. TSP, my understanding is you need something like 13 2,000 to 3,000 parts per million to deal with -- to buffer a 14 typical reactor for, say, 7-1/2 pH, okay. The solubility of j (<-) 15 this thing is like half a million, 600,000 parts per kJ 16 million, whatever. And so if that is really, if those are 17 really the numbers, and you say, well, gee, you know, maybe 18 you need a little bit more TSP at some time if these -- in 19 these events. It is pretty soluble. I would imagine that 20 if you really don't -- if you are sure you don't know what 21 you know, you can always put in a little more. I don't 22 think that you are going to have to -- it doesn't sound like 23 sampling is necessarily the required solution. 24 DR. POWERS: I guess, I mean -- okay, TSP, I think 25 you are talking about trisodium phosphate. /] \,,) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
t 46 1 MR. SCHNEIDER: Yeah. 2 DR. POWERS: Put trisodium phosphate, a little 3 calcium hydroxide leaches in, what does it do to trisodium 4 phosphate? Precipitates calcium phosphate. Okay. It is no 5 longer working. How much calcium phosphate now leaches into I 6 the solution? You have got me, I don't know. I do know 7 .that trisodium phosphate gets stabilized with a little
)
8 sodium fluoride. Very aggressive against concrete, will 9 call calcium hydroxide to leach out. Okay. 1 10 The point being there are so many complications 11 here, how do you go about calculating how much TSP to put in i 12 to begin with? l 13 MR. SCHNEIDER: Right now the methods are 14 relatively conservative we believe and they have a lot of () 15 16 margin. margin. And I think that the issue is it is time and If the stuff -- if we have enough to maintain it, 17 we believe using the large amount of boric acid sources for , 18 the 30 days to keep it above 7, you still have a lot of l 19 margin to keep it down to, what is it? There is a break. 1 20 Let me pull it out. Let me pull it out. Is this the right ! 21 one? l ! 22 I guess this is what we -- this is the general l l 23 trend of iodine evolution versus pH, and we are designing 24 to, say, around here, 7-1/2. And, in time, ultimately, it 25 will pick up, but -- l "g ANN RILEY & ASSOCIATES, LTD. s_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
47
'l CHAIRMAN KRESS: Could you point to it? We can't 2 see it.
3 MR. SCHNEIDER: I'm sorry. Okav. We are l 4 designing the pH level to be in the 7-1/2 to 8 range and, 5 you know, there may be some decrease over time, but until l 6 you get to about, say, the 5 range, you are still not going 7 to get a lot of iodine evolution. And by the time you do 8 this, most of the iodine has decayed out, iodine-131 had 9 decayed out. So I think -- and to get much below this, you 10 would almost have to basically overcome the boric acid, 11 because boric acid, you know, is about 4 to 4-1/2. So you 12 are really dealing with a very narrow range in this, and to i 13 expect it to go from here all the way down to here doesn't 14 seem to be -- I am not a chemist, but it seems like a long 15 way to go. 16 DR. POWERS: Well, to go from pH 7 to pH 6 is a 17 trivial step. To go from 6 to 5 is 10 times a trivial step. 18 MR. SCHNEIDER: Yeah. 19 DR. POWERS: To go from 5 to 4 is 10 times 10 20 times a trivial step. 21 MR. SCHNEIDER: Okay. 22 DR. POWERS: Okay. So, I mean be careful of how 23 easy it is. Going from 6 to 7 is easy, a good chunk of 24 concrete or a good few hours of nitrous acid evolution will 1 25 make that move for you. (" ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l-l
p , 48 1 MR. SCHNEIDER: Well, but not for a buffered i l') 2 solution, right? For a buffered solution, it will take l \n/ l 3 quite some time?- l 4 DR. POWERS: It has got to come.over the -- 5- ' overcome the buffing capacity. 6 MR. SCHNEIDER: Right. 7' DR. POWERS: At pH 7, you overcome the buffer 8 capacity of trisodium phosphate. 9- MR. SCHNEIDER: Right. But that means -- but you i 10- have to basically go from 7-1/2, I mean that is your big li' barrier. Then you have got to go through here. But the 12 point is that, yeah, you are going to get -- you know, even 13 in the worst case, you are still down to probably this 14 level, which is like a 10 percent evolution. () 15 DR. POWERS: Well, let me ask you about that plot. 16 That says it is I to I2. What if I added on the I minus 2 17 organic iodide? 18 MR. SCHNEIDER: Okay. 19 DR. WALLIS: I don't have a basis for knowing what 20 conversion fraction is tolerable. It may be that .1 is not 21 tolerable because the actual amount is significant for some l 22 'other reason. I don't know what fractions --
.23- MR. SCHNEIDER: Well, this is a function of -- it 24 is really the time this occurs. The expectation is you are 25 going to maintain the pH over long lengths of time. If you j O ANN RILEY & ASSOCIATES, LTD. . (_./ Court Reporters !
1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 l l
49
- 1. go down to these,.you have an eight-day half-life of
( 2 iodine-131. So if this happens at, say, 24 days, its 3 significance is negligible. If it happens at day 8, it is 4 more important. But the expectation of this to happen in a 5 short timeframe, it is just not there. 6 DR. WALLIS: See, I don't have a measure of 7 -importance. I don't know if a 1 percent fraction conversion 8 matters or not, because I don't have a measure of what is 9 important. 10 MR. SCHNEIDER: Well, you are basically dealing 11 -with a source that when you release it, you release iodine 12 to the containment at 50 percent. 50 percent of the total 13 material ends up in the containment. In time, that will 14 decay off as a function of time. If it leaks out, it will ( 15 leak out at .1-volume percent per day. And only this 16' fraction of it will actually be in the atmosphere to even be 17 leaked out. 18 DR. WALLIS: So you have to make a calculation of 19 some measure of leaking out related to this curve or 20 something. So just saying it is small doesn't mean anything
.21 to me until you. relate it to some criterion for something 22 else. -23 DR. POWERS: Let me give you numbers that may 24- help. They may hurt. If you take it about, what, about 25 roughly 100 million curies worth of iodine, so if you have ANN RILEY & ASSOCIATES, LTD.
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50 1 got.10 percent of that up in the atmosphere, you would have
I 2 about 10 million curies. \ ~-]
3 DR. WALLIS: Is 1 million curies acceptable, 1 4 percent? 5 CHAIRMAN KRESS: 1 percent would kill you. 6 DR. WALLIS: 1 percent is still bad, isn't it? 7 DR. POWERS: I think, I mean what -- you get about 8 10 million curies, say, in the atmosphere. Then you are ] i 9 leaking that at, okay, .1 percent per day. You are talking 10 about what, 100,000 curies per day out in the environment? 11 DR. WALLIS: Does that matter? 12 DR. POWERS: That would probably get people real 13 agitated. 14 DR. WALLIS: So we are talking about -- it looks ; I (O) 15: as if the curve is low, it doesn't really tell us anything 16 till you make the kind of calculation that he is making. 17 CHAIRMAN KRESS: Well, if you get Dana's 18 calculation, then you basically meet the dose criterion in 19 10 CFR 100, which is a non-injury criteria. 20 DR. POWERS: Right. 21 CHAIRMAN KRESS: You would get people agitated. 22 MR. SCHNEIDER: And these aren't -- remember, this 23 is going to occur 30 days or so, or a large number of days 24 after. The decay is going to be orders of magnitude lower 25 to begin with. And I am not saying it is ever going to get ANN RILEY & ASSOCIATES, LTD. O_ i Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
. Washington, D.C. 20036 (202) 842-0034
51 1 there. What I am saying is you have a wall. Okay. We are 2 saying there is a boundary as to how worse it can ever get. [G^) 3 CHAIRMAN KRESS: Is this an equilibrium fraction 4 at that pH level? 5 MR. SCHNEIDER: I believe so, but I am not 6 absolutely certain. 7 CHAIRMAN KRESS: So if you remove some of the I2, 8 then you will continue to go from I minus to 12? 9 MR. SCHNEIDER: Oh , yeah, but if you are removing 10 it at .1 percent per day, that is not going to happen. 11 Yeah. 12 DR. WALLIS: I don't know, until you relate it to 13 some kind of 10 CFR requirement, I don't know what you mean, 14 whether it is significant or not. i rs) 15 MR. SCHNEIDER:
%./ Well, initially, it used to be 16 that you would have like 4 percent organics -- it used to be 17 4 percent organics in the source term, in the old source 18 term. Is that --
19 CHAIRMAN KRESS: I don't remember, I think you are 20 right. 21 MR. SCHNEIDER: Okay. And that was released at 22 time zero. So, basically, if you release this at time zero, 23 you are kind of. meeting the old design basis. That is a 24 rough order of magnitude. 25 DR. WALLIS: And you are saying you will never get /~'s ANN RILEY & ASSOCIATES, LTD. '\_,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r:: -- l-52
.1 there in realistic time?-
2L -MR. SCHNEIDER: Right. I mean that is why you put 3- .all the pH' control in. 4 CHAIRMAN KRESS: How does your trisodium phosphate
- 5. get_into the sump? You have bags of it down there?
6 MR. SCHNEIDER: Baskets. ! 7 CHAIRMAN KRESS: Baskets of it. 8 MR. SCHNEIDER: They are supposedly designed to 9 basically be dissoluble in hours. I am not a chemist, I 10 probably going a little beyond where I probably should be 11 speaking, but I wanted to kind of put maybe some of the 12 things in a little bit of perspective. But it is a highly 13 soluble item. You put a lot of it in. The expectation is 14 that, you know, you are putting it in with boric acid, and () 15 16 boric acid is still in the 4 to 6 range. The expectation is that there may be some uncertainties, but there is a level 17 of defense-in-depth'and margin there. 18 CHAIRMAN.KRESS: Where is the TSP put? It is just i 19 in the bottom'of the containment or is it in the bottom of ! 20 the sump?. l 21 MR. SCHNEIDER: I believe it is distributed, but I 22 can't -- 23 MR. BICE: At ANO-2, for example, there are three '
-24 .large, screened baskets located in the -- oh, just a few
- 25 inches above the containment building floor, in strategic i
ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 (202) 842-0034 l-
53 1 locations wehre you would get some pretty good flow rates ()I 2 past them. 3 DR. POWERS: It is always interesting because you 4 have got the sump and that has got -- that is pH buffered 5 and it is nice and basic. You have got the condensation on l 6 the walls, it is not buffered at all. And you have got the 7 iodine in the atmosphere going to the liquid, so it goes to 8 the walls, then just comes right back and partitions back 9 into the atmosphere, until all those wall films can drain 10 down, but, of course, they are always being replaced. So 11 now how much iodine retention do you actually get? I don't 12 know the answer to that. 13 CHAIRMAN KRESS: Good question. That is severe 14 accident analysis. () 15 DR. WALLIS: The stuff on the wall is probably pH 16 about 7, isn't it? It is distilled water. 17 DR. POWERS: No, it is not distilled water, l 18 because it is absorbing a nitric acid out of the air. 19 DR. WALLIS: Absorbing all sorts of things at the 20 same time. 21 MR. SIEBER: Do you folks recirculate the 22 containment sump for your spray system? l 23 MR. BICE: Yes, sir. 24 MR. SCHNEIDER: Yes. 25 DR. POWERS: That is probably the worst thing that ( J ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
54 1 can happen for iodine mass transport, because what you do [} 2 when you go into a circ mode is now you are enhancing the 3 mass transport from the water to the atmosphere by turning I 4 it into droplets that fall through the air, because it is fi saturated. i 6 [ Laughter.) 7 MR. SIEBER: But, it changes the ph of the -- 8' DR. POWERS: Oh, yeah, it makes -- it absorbs lots 9 of acid on the way, too, yeah. 10 DR. WALLIS: We just run one of those codes that 11 predicts behavior -- 12 DR. POWERS: You'll persuade me -- we don't know 13 how ---we tried to use the Wallis. correlation, but it just 14 doesn't work, because it got bad boundary conditions. I'm () 15 sure.it's not the correlation. 16 (Laughter.] l 17 CHAIRMAN KRESS: Okay. We might continue. I 1 18 MR. SCHNEIDER: Okay, thank you. The next topic, ) 19 a little bit about boron sampling. The primary role of 20 . boron sampling is to confirm the activity control during and 21 following the event. Delays in past implementation really 22 prevent it from being used during the accident mitigation 23 phase of the event. An operation of PASS for plant access 24 'during the accident, we covered that before. l l 25 Boron sampling, I would say, is offered in the T ANN RILEY & ASSOCIATES, LTD. s/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I { 55 1 EOPs as one of several means to confirm the activity '. -2 control, but it's also one of the least desirable, because 3 you have to result in personal abilities and -- 4 DR. WALLIS: This accident mitigation phase, let 5 me go back to TMI, I mean, that accident mitigation phase 6 sort of came and went and a lot of uncertainty and didn't I 7 just go away with the first fix. So, I'm not sure how long ) 8 this accident mitigation phase really is. l 9 MR. SCHNEIDER: Right. The -- okay, the operator 10 actions, we believe, don't require -- don't require the 11 boron sampling. There are conservative -- 12 DR. WALLIS: I didn't get an answer. 13 MR. SCHNEIDER: Well, I'm trying to -- I think, 14 ultimately, we'll -- let me get through this. I'll try to 15 -- I'll try to give you more direct -- so, in the -- at 16 least in the early phases of the event, okay, we provide 17 conservative boration guidance and procedures. Significant i 18 boron dilution will be identified, because you know where 19 your borated water sources -- 20 DR. WALLIS: Let's go back to my question here -- 21 MR. SCHNEIDER: Okay. 22 DR. WALLIS: -- accident mitigation phase. You're 23 sort of assuming that you know enough about the kind of 24 accidents you're going to get, that you don't need this 25 PASS, because it's not relevant in the time scale that you ANN RILEY & ASSOCIATES, LTD. V Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r l 56 1 l 1 want information in. But, maybe, there are other sorts of (~')\ 2 accidents, which, like TMI, you get into some region where G 3 you hadn't quite anticipated it and the information really 4 might be useful. 5 MR. SCHNEIDER: Okay. I think what we're saying 6 is we have different methods of getting the information we l 7 want. 8 DR. WALLIS: Which you think you need. j 9 MR. SCHNEIDER: Which we think we need. We think 10 we need to know the activity control and negative start-up 11 rates. We think we need to have control of all the borated l 12 sources and know where they're coming and going, and we l 13 think we have that. 14 DR. WALLIS: This would help, I think, if you made (qj 15 a presentation where you still have -- there would be some 16 needs that you have for information, you listed them all, 17 and you listed something about the levels and the functions 1 18 and so on. And then, you could show how, by doing away with 19 PASS, you still are able to meet all the needs that you have 20 -- maybe you're going to get to that. 21 MR. SCHNEIDER: Well, I wasn't planning on it. l l 22 Let me see if this meets the need. It sounds awfully 23 familiar. I'm not -- 24 DR. WALLIS: Maybe that's in the summing up. 25 MR. SCHNEIDER: Let's see, okay, what we did is we t' ANN RILEY & ASSOCIATES, LTD. ! (],,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 1 57 l 1 looked at all the kinds of events that would challenge the []
%.J 2 -- that would require some assessment to return to 3 criticality and determine what we -- what methods we have to 4 get reasonable confidence that we have sufficient boration.
5 And, basically, we think that neutron flux monitoring will 6 provide the key information of what we need most of the 7 time. The' normal sampling system, under quite a number of 1 8 .these events, will provide a lot of the information for the 9 longer time phase or for the less -- for the less severe 10 events. Understanding the reactivity balance, understanding 11 the boron balance and the boron concentrations provides us a 12 good level of confidence of what we're dealing with and 13 controlling. And so the combination of these three, we 14 feel, gives us a decent amount of confidence that we are -- () 15 16 we know what the reactivity situation is, that the course of some critical -- 17 DR. WALLIS: It looks as if this process is giving 18 you nothing useful at all. 19 MR. SCHNEIDER: Well, because of the delays. The 20 delayed sampling, towards the end, what you're going to get 21 is confirmatory information, which is basically latent 22 transients. You're basically saying, well, okay, I want to 23 put this thing to bed and this is -- and so, let's take a 24 sample and see if it basically fits with what we think. 25 But, that's about the size of it. It's so much more to
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e 58 1 reentry, t-2 DR. WALLIS: Let's say you put it to bed, let's
.((~N) 3 make_sure it's asleep.
4- MR. SCHNEIDER: Right, but the point is that you 5 still have other methods of collecting the same information 6 and the issue is'probably more timing. I mean, we have an 7 active sampling system that just isn't immediately capable 8 of spanning the full range immediately. But, as time goes 9 on , time and knowledge and the sequence of events will 10 provide us guidance as to how to best use that system, if we 11 should need the information. And, you know, maybe you put 12 up -- I guess they -- 13 DR. WALLIS: Are you saying that you have a 14 sampling system, which is a normal one, which could give you () 15 16 the kind of information that PASS is designed to.give'you and it just takes longer to activate or something? Is that 17 the -- 18 MR. SCHNEIDER: No, it's not so much longer to 11 9 activate it. It doesn't have the radiation protection that 20 PASS does, so you can't use it in the same time frame. 21 DR. WALLIS: You can use it early on? 22 MR. SCHNEIDER: Early on. 23 DR. POWERS: So, we're very concerned about 24 exposing our operators to the PASS sampling. We're willing 25 to get the field teams, because we don't like them very l l ANN RILEY & ASSOCIATES, LTD.
' p(_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 59 l 1 much, or we're willing to get our operators with our old
'(j.
It 2 hackneyed system, because it doesn't have any radiation 3 protection -- 4 MR. SCHNEIDER: No , no. 5 DR. POWERS: -- and it's easier to use it. 6 MR. SCHNEIDER: Let me explain. 1 7 DR. POWERS: I'm really confused on this point. 8 MR. SCHNEIDER: Let me explain. You do this. NRC 9 says, I need to give a newspaper blurb to the -- I need to 10 give a blurb to the newspaper. I want you to send someone 11 in and you're going to say, I don't want to send someone in l 12 until it's a certain time. This allows you to send someone 13 in to get the newspaper information out quicker. That's j 14 basically the only advantage of the two systems. It's not l f-~ : (% 15 something that we would expect to be doing or be requiring; 16 it's more that we would probably be asked by some regulator ! 17 saying,-give me a number. Maybe that's -- 18 DR. WALLIS: Maybe the newspaper information is 19 not a trivial thing. TMI, the biggest hazard to the 20 population was the confusing information that came out. l 21 MR. SCHNEIDER: Well, there's, also, the risk that l 22 by sampling in certain areas, you still can get the 23 reason -- one of the reasons the information was confusing 24 is possibly more information came out than -- before people 25 really thought about what they would say and -- you know, I l l ANN RILEY & ASSOCIATES, LTD. D)
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l li 60 1 -- again, I mean, we, certainly, are concerned with doses () LJ 2 and, certainly, we won't send people into the high rad 3 levels and, certainly, we don't want to basically be taking l 4 samples that we don't believe are helping us manage the ) 5 event, manage the public, help the situation. And we don't 6 believe PASS is meeting those requirements. But, we have 7 thought about, you know, what we have and we have gone 8 through the events and kind of figured out, well, you know, 9 we have alternatives and we believe the PASS alternatives 10 are good. And I think that ANO will talk more about how an 11 actual emergency response goes on. 12 So, again, we do use alternative monitoring by 13 neutron flux meters and confirm negative start-up rates. 14 And desired boron samples may be delayed and/or obtained (G 15 when the conditions are acceptable, using the NSSS. Now, 16 what we have done is we have done more studies about the 17 normal sampling systems, to find out more about what its 18 capabilities are and taking into further realms. 19 Okay. Finally, we want the hydrogen sampling -- 20 we want to -- we're recommending replacing the PASS sample 21 with the hydrogen monitors. The containment hydrogen 22 concentration uses the indicator for the amount of core 23 damage and container combustibility. We believe we should 24 retain the capabilities. We believe we can accurately 25 monitor it with Reg Guide 1.97 instrumentation, and most of / ANN RILEY & ASSOCIATES, LTD. (s]/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
t ! 61 L 1 the plants have already implemented this option. The l 2'
-/~'} .N/
hydrogen monitors provide real time data that assists the 3 operators in core damage, core damage assessment, and long 4 before a sample can be collected and analyzed, and are 5 adequate for assessing containment threats -- this is 6 combustibility issues -- and core damage, and are sufficient 7 to support the SAMGs. We rely mainly on those in the Severe l 8 Accident Management Guidelines. 9 I'd like to move on to radioisotope sample, if 10 that's okay. And we've actually discussed most of the j l 11 information in the next three slides, so I can -- I think I i 12 can probably go through it quickly, if you'd like, and then 13 I think'there's a really good presentation to follow on 14 overall accident management. () 15 But, sampling of the RCS, what do we do, where's j 16 radioisotope sampling actually used -- we kind of talked 17 about the various ways we have. For normal operation, you 1 18 kind of use sampling, but you can use normal sampling 19 system. That's like for maybe fuel failure, stuff like 20 that. 21 Accident management, you, basically, are relying 22 on CHARMS and other' signals, basically, in the EOPs. Severe 23 accident management, then, looks at CHARMS, you know, the 24 containment high area radiation monitors. That monitor, 25 site area monitors are for radiation monitoring. And then i
\ ANN RILEY & ASSOCIATES, LTD.
s_- l Court Reporters 1025_ Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 1 62 1 1 in the emergency response, you're interested in establishing [~) 2 levels of alert and radionuclide sampling will currently not
\_/ l 3 be timely or useful. Protective action guidelines are based 1
4 on generally plant conditions and the longer-term guidance 5 could be established with CHARMS and field measurements. 6 And, finally, the core damage assessment does a l 7 post mortem, as I said, using a four pronged approach: 8 using a core thermocouple methodology; a hydrogen 1 1 9 methodology; and a containment high area radiation monitor ' 10 methodology; and the fourth being the radioisotopes. There 11 was an issue we put there for the high level of accuracy and 12 we're recommending deleting it, because we don't think the 13 accuracy is there. 14 CHAIRMAN KRESS: Let me ask you about this ( 15 ( ) hydrogen as a measure of core damage. 16 MR. SCHNEIDER: It's not perfect. It has a lot of 17 -- there's a lot of questions when you use them for that. l 18 Hydrogen can burn. Hydrogen, you know, is not always in the 1 l 19 same location at the same -- you know, we may have some at 20 the core. We provide that as some guidance for them to 21 track and to understand. Using severe accident guidance, 22 some accident management is partially a deterministic tool, 23 but it's, also, understanding the progression of the event 24 and understanding where the operator is supposed to take the 1 i 25 appropriate action and interpret the information that he l l [~} (_/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
63 1 has, as more of a gestalt. The whole thing has to be put in , 2 perspective. 3 Hydrogen, itself, is more -- is probably not a 4 high reliable one, unless you get really high hydrogen 5 concentrations. I mean, if you keep on reading four 6 percent, _it could just mean you have a lot of burning, or 7 five percent. But, there are -- but, if you read four 8 percent and coupled with your thermocouples being, you know, 9 well off scale or reading -- you know, not reading anything 10 rational and you know that your neutron flux is starting to 11 read signals that they shouldn't be reading, because 12 everything should basically be going down, you then can play 13 -- put the whole picture together and say, you know, the 14 core is not in a real good state, look at your containment () 15 16 radiation and say, oh, yeah, it's probably well up there and I've probably lost maybe 50 percent of the core. 17 But, it's a picture. It's really the gestalt. 18 You can't do it on any one alone. 19 CHAIRMAN KRESS: You need the combination? 20 MR. SCHNEIDER: I believe that you -- the best way 21 to interpret the information is by having that. And the 22 concern with radioisotopes is I think that because we're not 23 getting a good sample, because you're not really getting 24 useful additional information to add to the picture, it's 25 not going to help dealing with the accident. If you have [ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
64 1 1 precise numbers, you may be able to do more on the post 2 mortem, well after the event is over, but that's not clear (V) 3 that that's a -- . 4 CHAIRMAN KRESS: When you say " post mortem well 5 after the event is over," are there not a time frame -- is 1 6 there not a time frame for some accidents, in which the 7 accident is not really over, but you've got to make a lot of 8 decisions on what to do? And then your hydrogen has already 9 done its thing and the core has already done its thing, but l l 10 your containment may be still intact and you're try!.ng to I 11 make decisions to -- as to what to do now. Would some 12 . measure of radioisotopes in the containment, for example, or 13 in the sumps or some measure of the sump ph, would that not 14 be a useful thing, if you had that period you had to worry 15 about? 16 MR. SCHNEIDER: We believe that radiation 17 monitoring is clearly a useful thing and we have the ability 18 to do that. We believe that at some point long, long after, 19 should you want to reenter, you know, there should be some 20 -- you know, you might want to use some kind of rampling to 21 get back into containment. 22 CHAIRMAN KRESS: But, you think you can do that -- 23 MR. SCHNEIDER: With a normal -- there's pretty 24 - much confident that you wait until your -- the levels die 25 down to -- there's nothing that reauires -- we don't know of ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
65 1 anything that requires any action to basically be taken. /N 2 And you still have the radiation trending and the off-site b 3 monitoring, so you're protecting the public. You understand 4 the state of the core and you wait until your -- you know, 5 you wait until it's appropriate or reasonable to do what you 6 have to do. 7 When we looked at where the isotopes were used, we 8 found that -- well, the samples aren't used in the accident 9 guidance document. As a matter of fact, they were 10 specifically written out, I think, of the Westinghouse 11 guidance document, because they felt they were even more 12 attuned to this early on. Samples are untimely and would 13 significantly underestimate, so you end up with a situation 14 of potential confusion. Confusion could lead to delays. () 15 16 Delays may lead to non-conservative actions. And we don't l believe now that the CDA is likely to yield useful results l 17 with the existing equipment or necessary results actually. 18 We think we have enough information to go on and do the 19 management. 20 Use of PASS results and additional exposure of 21 plant personnel increases the potential for radiation 22 releases in the Aux Building and we believe it's limited in 23 usefulness, because it doesn't even pick up the key high 24 significant radiation events, where you have to basically -- 25 where you're relying entirely on field teams to do the / ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l
; (202) 842-0034 i
2
t L 1. 66 1 planning and other non-PASS instruments, maybe site related i 2 instruments and vent releases. So, the-ISLOCA and -- [V~') 3' they're not: even an issue. L 4 Therefore, we believe that the elimination of PASS 5 sampling will not reduce plant and public safety. We 6L believe the EALs.will beLdeclared in a timely basis, based 7 on implant instrumentation and plant conditions. We believe
~8 the PARS will be formulated, based on the use of CHARMS and 9 the CETs, in an effective conservative way.- Those 10 projections can be established by analytical adjustments to 11 the area radiation monitors, surveys -- site surveys and
~ 12 vent releases. Field teams will be equipped with I-131 13 monitoring (;pability, which we believe is an additional 14 benefit that we're committing to, increasing scope and
() 15- capability of the dose assessment for all events, not just 16' those that just need containment. We believe, ultimately, 1 17 that the post-accident exposures would be reduced and the 18 core damage will be appropriately assessed without a l 19 'radionuclide base CDA. 20 So, conclusion, one slide: based on our review, i 21 PASS isn't required in our emergency operator procedures. q
.22 It's not relied upon in our severe accident management j i
23 guidance. It's not needed to establish the emergency alert ] 24_ levels. It's not needed to establish short- or long-term 1 25 PARS. It's not used for reentry and PASS can mislead, O ANN RILEY & ACSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
o l 67 1 misinform. And the recommendations to both expand the NSSS ,/ 2 limits and to ensure I-131 site survey capability enhances 3 plant safety. And, essentially, the elimination of PASS 4 would be acceptable and would not degrade the plant 5 emergency preparedness. 6 DR. POWERS: Let me ask a question about the 7 interfacing systems steam generator tube rupture accident 8 sequences, how does CHARMS help you there? 9 MR. SCHNEIDER: It doesn't. 10 DR. POWERS: So, it's no good. So, tomorrow, 11 you're going to come in and say, let us take out CHARMS, 12 because -- 13 MR. SCHNEIDER: No. 14 DR. POWERS: -- it doesn't help with the () 15 16 interfacing system. All it does is -- MR. SCHNEIDER: Well, CHARMS is vital for core 17 damage assessment. CHARMS is vital for -- 18 DR. POWERS: Good for those accidents that you 19 think are so important here, that are risk dominant 20 accidents. 21 MR. SCHNEIDER: Right. I think that the field 22 team and I-131 monitoring, I think, is a real plus to add to 23 that and I -- okay. 24 DR. POWERS: But my point is because I can define 25 accident sequences, which may -- which they are, in fact, (~ ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
68 1 frequently, for some plants, the risk dominant -- the fact 2 those are not frequency dominant is not a basis for taking O(N 3 out a piece of instrumentation, because I can find an 4 accident sequence for every single one of these things that 5 we work on. 6 MR. SCHNEIDER: If that were our sole basis, I 7 would agree with you. 8 MR. BICE: But, we do look at those scenarios, l 9 especially in the case of steam generator tube rupture, we 10 have an actual calculation in the procedure to use the main 11 steam line monitors instead of the inside containment 12 monitors. It does the same projection for us, so -- 13 DR. POWERS: Good. 14 CHAIRMAN KRESS: Other questions? 15 [No response.] 16 CHAIRMAN KRESS: Maybe this is a good time to take 17 a break or should we continue on? 18 DR. POWERS: If we have the promise of a good 19 presentation, then I wouldn't hesitate to take a break now. 20 [ Laughter.] l 21 CHAIRMAN KRESS: I guess my question is do the 22 committee members and other people need a break? 23 DR. WALLIS: I'm going to take a break anyway. 24 [ Laughter.] 25 CHAIRMAN KRESS: In that case, I move for a f' ! ANN RILEY & ASSOCIATES, LTD. (,,f Court Reporters l
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69 1 15-minute break. 2 (Recess.]
/
3 CHAIRMAN KRESS: Let's come back to order and get 4 the meeting going again. 5 DR. POWERS: I'll remind ysa, it's just in 6 session, we're never in order. 7 CHAIRMAN KRESS: That's right. You're right. 8 Thank you, Mr. Chairman. I presume this is Mr. Bice with 9 the pretty colored slide presentation.
.10 MR. BICE: Well, I thought you all were 11 specialist.
12 CHAIRMAN KRESS: Well, thank you, very much. 13 DR. POWERS: That will move us to think that our ! 14 next plant visit ought to be now. 15 CHAIRMAN KRESS: Yeah. ( 16 DR. POWERS: That destroyed his confidence, didn't I 17 it? 18 [ Laughter.) 19 MR. SIEBER: The three-week one. 20 DR. POWERS: Yeah, the one where we go through 21 everything, where we go through the PRA line-by-line. 22 MR. BICE: Okay, a quick introduction on myself l l 23' and my background. I'm David Bice, representing Arkansas 24 Nuclear One, specifically unit today, even though we're 25 looking for PASS examination for both of our units. A l ANN RILEY & ASSOCIATES, LTD. p(_j e Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
70 1 little background on myself, I'm born and raised in 2 operations; had an SR license now for about 10 years; worked 3 at various other groups, including the emergency response
]
4 organization for the severe accident management stuff we're 5 ' talking about today, outage management, and I'm currently in 6 licensing helping them out, so -- which is really why I'm 7 here today,-because I'm in licensing now for a short term. 4 8 So, how -- instead of repeating a lot of what Ray 9 has gone over, I decided that it would probably be better if 10 we just looked at it from a severe accident management 11 standpoint in an overview type of perspective. So, what we 12 will do is go through ANOs and that really does include both 13 ANO-1 and ANO-2, because the severe accidents are handled 14 the same on either unit. And the intent here is to show () 15 16 that until we get into long-term issue, which was discussed right toward the end, if we can kind of hold off on the i 17 long-term issue some, PASS just isn't there. In fact, 18 really no sampling is there. We'll see just a little bit of 19 sampling take place. So, let's just start with an 20 emergency. 21 We get an event initiated that leads to fuel 22 damage, whatever that might have been. Operations, of 23 course, is the group that's going to take control 24 immediately, enter the abnormal emergency procedures. 25 DR. WALLIS: Now, first of all, they have to know ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
i 71 ( 1 they have the fuel damage. ("T 2 MR. BICE: Well,.not necessarily at this point
\_ j 3 even.
j 4 DR. WALLIS: Why is it -- 5 MR. BICE: This point, they just know they have a 6 transient. 7 DR. WALLIS: Uh-huh. 4 8 MR. BICE: Now, I'm -- 9 DR. WALLIS: They know something has happened; 10 they don't'know what it is yet. 11 MR. BICE: I'm going to go ahead and say this, 1 12 because that's the whole purpose of the PASS, is to -- ' 13 DR. WALLIS: Okay, let's take your point. -- they 14 know fuel -- they have fuel damage, at that point? () 15 16 MR. BICE: No, not necessarily. All we know is we're in a transient, which could lead to fuel damage. 17 DR. WALLIS: Okay. 18 MR. BICE: We don't know yet. At this point in 19 their procedures, they really come off into three different 20 areas. One is the procedure will, as Ray spoke of earlier, 21 ask for sampling, and we'll see how that is used here , 22 shortly. Also, the operations team has to make an emergency 23 class declaration, if one applies; and, of course, l 24 operations assessments, which for the purposes of PASS we're 25 going to limit to core reactivity, hydrogen, and off-site ;
^
ANN RILEY & ASSOCIATES, LTD . s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
I 72 1 releases. Of course, operations does many more assessments
,O 2 than that. 'J; 3 So unlike your handout, I want to try to piece 4 this together one at a time, so that it's a little bit 5 easier to bite into and chew up. Operations has asked for a 6 sample. At that point, chemistry and health physics goes 1
7 down to the normal sample room and radiation levels are 1 8 taken. And once we line up the sample -- because, of 9 course, the sample is not lined up; you really shouldn't see 10 much difference yet. 11 CHAIRMAN KRESS: This is a sample of your -- this l 12 is coolant system? 13 MR. BICE: Yes. Actually, a normal sample system 14 can sample just about anything: steam generators, safety () 15 injections, whatever. Let's say for instance if they get l 16 down there and the radiation levels have not exceeded 17 three-and-a-half rem, now that three-and-a-half rem is just 18 an ANO number that we picked up, that we feel like if we 19 stay below this dose rate, we won't exceed the five rem 10 20 CFR guideline. So, that's the only reason -- that's the 21 only place that number came from, to make sure our personnel 22 don't go over five rem. 23 If it's less than three-and-a-half rem, we'll go 24 ahead and perform the sample, and we can do that up to five 25 percent clad failure. That, again, is calculations that \ i l l i
/~ ANN RILEY & ASSOCIATES, LTD.
k,-)/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 73 1 we've made recently, actually based on this past elimination 2 project, to show that up to five percent clad failure, we [} 3 can take samples from the normal sample system. We don't 4 need PASS. 5' DR. WALLIS: How long does it take to do that? 6- MR. BICE: It takes about 20 to 30 minutes, and 7 that really is more dependant on your flush time than it is
- 8. on the sample time.
9 DR. WALLIS: So,.during that period, the rad i 10 levels could increase quite a lot. 11 MR. BICE: Right. They HPs will stay there with 12 them. 13 DR. WALLIS: So, they have to -- they may abort 14 their sampling, if things get bad. () 15 16 MR. BICE: do have to abort. And we'll discuss what happens if they Again, if they know we've got a precursor 17 happening -- in fact, right here, our lead down monitor was 18 probably still in service. It may have shown some type of 19 fuel accident occurring, iodine is increasing, gross 20 activity increasing, whatever, or the radiation levels may 21 have indicated to the chemist, hey, there's something going 22 on in the rad cooling system. So, they've really got three 23 ways of knowing that this is getting -- the situation may be 24 worsening. 25 Now, like I said, we can get up to five percent O ANN RILEY & ASSOCIATES, LTD. ( ,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
74 1 clad failure samples. All the emergency clad determination 2 cares about is up to one percent. When we reach one d(~'s 3 percent, that's an automatic alert classification; .1 4 percent is unusual then. So, we more than met that range, 5 have been able to get those two classifications that the 6 emergency plan is asking for. And what we decided to do, 7 let's say that we got greater than three-and-a-half rem for 8 hour when we get down there, what we say at that point -- 9 and, again, that number is somewhat arbitrary. We haven't 10 firmed that up to be the number we're going to use, but it 11 looks like it's going to be pretty close. If they're 12 greater than three-and-a-half rem per hour, they're not 13 going to perform sampling, either abort it or not perform it 14 to start with. (s (a) 15 In this even, that's immediately fed back up to 16 the emergency class determination, saying you're greater 17 than five percent, because that's where this number is gone 18 -- equal, is what we receive for a five percent clad 19 failure. If they're greater than five percent, that 20 automatically meets your one percent, emergency class 21 determination, and the control room will consider declaring 22 alert, based on that information. 23 DR. WALLIS: How would they get the one percent 24 otherwise? I mean, hopefully, they'd know that without 25 having to take the sample or even know that they have these ANN RILEY & ASSOCIATES, LTD. O'. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
75 1 rad levels. They'd know the one percent from something 2 else, wouldn't they? (} v 3 MR. BICE: Well, it just depends on the situation. 4 The let down monitor I discussed earlier, can show you when 5 you reach your one percent. But let's say we have a large 6 break loca, that system isolate. So now, we're kind of 7 flying blind for lower event accidents. We're going to have 8 to get a sample then. Now, what if the -- if we get 9 significant fuel failure, we're going to do that in a second 10 how we detect that. But for the low failed fuel events and 11 clad failure events, once this let down monitor goes away, 12 then we're kind of relying on either sample or radiation 13 levels. That's our two give mes. 14 And like I said, toward the end of the discussion, '
/~N
! 1 15 we will get in detail into this long-term sempling box. V 16 But, basically, like Ray had already mentioned, we'll look r 17 at the need for long-term sampling when t.he time comes, 18 whether it be for activity or boron, whittever we're taking 19 the sample for, base the benefit we're going to get from 20 that sample on the dose rate, and make a determination at 21 that point. Again, we're go into that in great detail here 22 shortly. 1 23 So right now, this is really the end of sampling. 24 We're going to stop there, because we've covered our low 25 level events and, basically, we're going to show from this
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76 1 point that we don't need sampling during the actual 2 mitigation from that point on. Then, we'll get into 3 long-term at the end. And that's all this slide shows, is 4' that the next thing we're going to talk about is emergency 5 response organization, which would be staffed in that event, 6 when we've got fuel damage occuring. 7 Let's go over and see what the emergency response 8 organization does for a living.
'9 CHAIRMAN KRESS: This organization consists of 10 state people?
11 MR. BICE: State people aren't part of the site 12 staff; but, yet, that's -- 13 CHAIRMAN KRESS: But, is this your site staff 14 you're talking about? () 15 16 MR. BICE: This is the site staff we're talking here, and we'll talk about how the state comes into that 17 right toward the end. So, this is nothing but our site 18 staff made up of basically people too old to be operators 19 anymore. j I 20 [ Laughter.] 21 CHAIRMAN KRESS: How old? 22 DR. POWERS: I bet he doesn't say that when he's 23 at home. 24 MR. BICE: I may not look that old, but I'm almost 25 out of the game. So, you don't have to be very old. i f"% . ANN RILEY & ASSOCIATES, LTD. () ! Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 I
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77 1 Again, they're split up into three different 2 general teams, when we're focusing only on the PASS issue: 3 severe accident management, we're going to have some people 4 over there going to high-level actions; core damage 5 assessment team; and then we have still our chemistry and 6 HPs working as a team over here, to either get off-site 7 samples. If there's still a low grade event, you can still 8 get the normal sample system on line. Something we're going 9 to see come into this later is if proportionate, the leak 10 has gone out into our Auxiliary Building or out some 11 ventilation path, if that's the case, we've got this steam 12 monitors. All those paths are monitored by steams, and 13 that's a give me. They automatically do your noble gas and 14 iodine calculations. You don't have to do any field 15 sampling at all. 16 There's going to be those rare events where it may 17 bypass those ventillation paths, either through the steam 18 generator that we'll talk about a little bit later, or just 19 a freak hole in the containment wall outside the atmosphere, 20 that's pretty far out there, in which case we'll rely on the 21 field monitor training team, at that point. 22 We'll go down the center first here and talk about 23 the core damage assessment. This is basically run by the 24 reactor engineering part of the emergency response 1 25 organization. And I'm not going to go into a lot more i
)
ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i l Washington, D C. 20036 (202) 842-0034 j
78 1 ' detail, unless you all have some questions, because a lot of
/"' 2 this is repeat of what Ray has already said. But, U) 3- basically, they're going to watch the core. It's a 4 thermocouple response, reactor vessel level monitors, right 5 to cooling pressure, and let me -- let me just throw in here 61 real quick how operations inputs to this. Operations is l
7 trained that if you have say within 10 degrees of superheat 8 on the core external cover, you've got fuel damage. I mean, l 9 you don't get superheated conditions unless you've uncovered l 10 the core. So, there's a lot of training that goes into 11 these things, too, beyond just seeing these bullet items up 12 here. 13 The known cool conditions, which, again, unless 14 you had some type of unexpected event, steam generator back () 15 flow conditions or tube rupture, something like that, these 16 are all going to be boron. There is no additions made to 17 the reactor cooling system, other than boron, on purpose. 18 And then if there are other events going, we'll see later 19 how we account for those less borated sources or even 20 unborated sources are accounted for. 21 The same thing, they use the containment 22 radiation. They can use other area radiation inside and 23 outside the containment building to assess what's happening 24 to the reactor coolant system. Hydrogen analyzer, we talked 25 about. Letdown I just talked about in the last screen. And
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1 Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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79 l 1 a while ago, I commented on a main steam line monitors and (N, 2 how they're used to calculate what's being released during a l
'uJ 3 steam generator tube rupture.
4 CHAIRMAN KRESS: That information can be 5 translated into percent core damage? l 6 MR. BICE: That's correct. And from that -- I 7 CHAIRMAN KRESS: You have curves already that you 8 can -- t 9 MR. BICE: Right. 10 CHAIRMAN KRESS: It's a template you can go and -- l 11 MR. BICE: Basically, they go and get all this 12 information. That's what their procedure has them do. And 13 then, they do a calculation of percent core damage. l I 14 CHAIRMAN KRESS: And they do a calculation or they '
/s 15 just go to a template, where they can just read it?
( ) 16 MR. BICE: I'm not real sure on that. Is a 17 template? Here's an engineer. I'm not an engineer. 18 MR. PRICE: My name is Terry Price and I'm from 19 Palo Verde. And the way we handle this is most of it is 20 templates. I give you the information, the reactor engineer I 21 taking that template and figures out exactly where they're 22 at and what the potential core damage is. l 23 CHAIRMAN KRESS: Thank you. 24 DR. WALLIS: You could, also, automate it. I 25 mean, you've got all the information
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I F i 80 1 MR. BICE: Could do that. t l~/"') 2 DR. WALLIS: That's because this has a direct 3 estimate core damage thrown on the screen. 4 MR. BICE: Could do that. 5 MR, SIEBER: The main steam line radiation 6 monitor,-that's not a required instrument, is it? That's 7 something people add at their own volition? 8 MR. BICE: Well, I don't know if it was at the 9 beginning. I'm trying to think if that's required now a 10 days. Something on the secondary is required, but it may be 11 the end of 16 monitors. I thought it was the main steam, to 12 be honest with you. I thought they are required. It has to i 13 be, because the -- l 14 MR. SIEBER: Your right. l () 15 16 MR. BICE: MR. SIEBER:
-- M-16s go away.
The M-16s are the ones that -- 17 MR. BICE: Have to be tripped. 18 MR. SIEBER: Right. ! 19 MR. BICE: So, they're no good to. Same thing, 20 kind of a template type issue, once we know the percent core 21 damage or have estimated it, we can estimate, here's our 22 content of iodine 131, all without any input from here, if 23 necessary. 24 DR. WALLIS: That's the concentration where? I 25 MR. BICE: What's that? l
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1 H ; 81 1 DR. WALLIS: Where is this concentration you're O- 2 estimating? ' Q) . 3 MR. BICE: They have.a table that goes along with 4 this percent. I 5- DR. WALLIS: But,.where about is it? Is it inside 6 the RCS? 7 MR. BICE: Yes. 8 DR. WALLIS: Or is it in the containment? Or is 9 it -- 10 MR. BICE: This is how much iodine is now being 11 contained within the reactor coolant system, which, 12 conservatively, I guess, could come out into your 13 containment building, and then, if you have a leak path, out 14 into society from there on out. So, again, this is going to -( ) 15 be your initial, very conservative number. In fact, if 16 we're not careful how we use it, if we don't bounce it off 17 off-site analysis, if we don't bounce it off event path, 18 where the steams are monitoring, it could be over 19 conservative. You know, we may ask for a recommended 20 evacuation, when it's not necessary. So, again, this is one 21 tool. What we don't want to do is focus ourselves on these l 22 issues of one thing in the same -- that's all we need. I'll 23 show you how that's used here in just a second, how it all 24 ties together. You see that on your' handout already, kind 25 of cheat on me. l s ANN RILEY & ASSOCIATES, LTD. ("~'/ (, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 h
i 82
~
1 Over here, with the severe accident management r'S 2 guidelines, we've got the people looking at how in the world 3 are we going to mitigate this release; how am I going to 4 control the atmosphere and site containment; and how am I 5 going to mitigate the core damage. Well, to do that, we're 6 going to need some more inft'.mation. 1 7 Now, all of this information has already been 8 supplied to the core damage assessment people. It can, 9 also, be supplied over here to these people. So, they're 10 o#tching the same type of information, just use it in 11 different ways. But, they're really interested in this, 12 because from this and from your iodine, now we can start 13 making off-site recommendations, based on iodine. Now, 14 we're going to get into the fact that most of your PARS has
~
\ 15 nothing to do with what your iodine content is. It has to
[O 16 do with how you're going to deal with the general emergency 17 or not. And we'll find out the general emergency doesn't 18 look at iodine. General emergency looks at do you have a 19 fuel damage event at all, period, and do you have a release 20 going on. So, knowing the specific amount of iodine doesn't 21 keep me from making a protective act and recommendation. 22 We'll see that here in a minute. 23 The site core damage is going to be fed back into 24 these areas here. Atmospheric control is going to be fed 25 back up here. Of course, if you've got a situation where ANN RILEY & ASSOCIATES, LTD.
*O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 h
83 1 1 atmosphere is getting a large amount of hydrogen content, { 2 which I think we're starting to put the bed down, that being 3 a significant contributor, but high containment pressure, 4 anything that has not made the containment fail. 5 Eventually, we need to know that for release mitigation, 6 especially if release isn't going on and there's a potential 7 for it. 8 Show those teams are working together, talking to 9 each other. And then, of course, the people really in 10 charge of mitigating the accident need to know what all this 11 thinking is going on. So, all of this information is going 12 to be put back into operations. Then, we'll talk about what 13 operations does with that information here shortly on 14 another slide. But, again, we can see so far that rather i( ) 15 in-house or out-house sample -- can I say out house -- 16 off-site sampling doesn't -- 17 CHAIRMAN KRESS: Being from Arkansas, I will allow 18 you to do that. 19 [ Laughter.) 20 MR. BICE: I asked if I could wear overalls to the 21 meeting. 22 DR. WALLIS: It might be more credible if you did. 23 [ Laughter.] 24 CHAIRMAN KRESS: I did want to say it's a pleasure 25 of listening to somebody that doesn't have an accent. p ANN RILEY & ASSOCIATES, LTD. ( ,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 s w-
F ! d 4 i 84 1 [ Laughter. ] () 2 3 MR. BICE: [ Laughter.] This is too cold. 4 MR. BICE: But I'm an operator; I'm used to abuse, 5 so I'll take it. 6 Operations assessments, again, we're just going to 7 look at the three PASS related ones. Obviously, operations, 8 there's a lot more than those three things. But, 9 : M tivity, being an operator myself at heart, goes to 10 munber one. Operations is more concerned with their 11 activity than anything else in the world. But, they're 12 always monitoring that. I don't care -- you know, we talked 13 earlier about, oh, what about after the big part of the 14 event is over. We, basically, got control. You're just () 15 waiting on decay rates now, chance to clean up later on. It 16 doesn't matter, Ops is continuously monitoring core 17 reactivity. 18 And I think we've already assess -- I'm not going 19 to go into this a whole lot, I think we're already in 20 agreement that during the initiation of the event, the 21 on-set, the last thing you want the operator doing is 22 waiting on a boron sample to make a decision on core 23 reactivity. You know, he needs to be monitoring the 24 activity right now and take whatever action is necessary to 25 control it. And as an operator, I can tell you, please O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 ) (202) 842-0034 l
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! l 85 f 1 don't tell me to wait on a boron sample. You know, you're
/~% 2 putting me in a world of hurt, in that case. ! b 3 Several ways I can tell it, though, many, many ! 4 different reactivity indications, from start-up rates, log 5- powers and linear powers, pressure temperature 6 relationships. I can tell a restart from a pressure l 7 temperature. Operations are trained on what to expect when ! I 8 a reactor approaches criticality. And when it is critical, I 9 what happens to these indications, if I have a LOCA event? 10 Say, my down comber is voided and the RCS of these core 11 instruments are going to respond the same. I don't have the i 12 water shielding that everybody used to have. So, operations I l 13 are trained to watch reactivity, based on all of these I 14 things, and really never, ever rely on boron. I () 15 16 The only time operations uses boron is during normal plant shutdown, when we're going to shut down
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17 cooling. We'll get a boron sample to say how much do I need 18 to add to take the plant to 200 degrees, and still maintain 19 my five-and-a-half or six-percent shutdown margin. In this 20 case, I'm not worried about five-and-a-half or six percent 21 shutdown margin. I'm worried about being shut down period. 22 You know, maybe I don't have six percent, maybe I've only 23 got three, the main thing is to keep the reactor shutdown no 24 matter what. And they can do -- operations can make sure 25 that happens without the use of the boron sample. i (~ ANN RILEY & ASSOCIATES, LTD. Court Reporters , 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
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86 1 DR. WALLIS: What does computer trending mean? /~T 2 MR. BICE: well, we put in a new computer at ANO a O 3 few years back that's pretty much the state-of-the-art, a 4 lot better than this thing here. 5 [ Laughter.] 6 MR. BICE: Basically, this thing gets inputs from 7 just about everything in the p] ant. It says, " remarkable." 8 When it gets input from these and, basically, I can watch 9 what my start-up rate is doing on a picture trend, I can see 10 if it's gone up, gone down, steady, and that's a lot better 11 than the operators. Because, to ask an operator to watch 12 the signal indication, for instance, you know, he may lose 13 track of that; but, if you put it up on Trend, you know
-14 right now what it's doing. So, it's a real nice thing to
[ 15 have. L 16 DR. WALLIS: He has to call it up or it's there? 17 MR. BICE: We have built screens for this, so 18 whenever we trip, we normally put up one Trend that's got 19 reactivity on it; one trend has got pressure temperature 20 relationships. So, it's just a push of a button and all 21 this information comes up. 22 - I think we've already beat this one a bit, but 23 real quick, at ANO, we're calibrated up to 10 percent 24 hydrogen. We do have scales that can go beyond that, but 25 they're just not calibrated, so they're normally not 1 ANN RILEY & ASSOCIATES, LTD. (} (,, Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 i (202) 842-0034 , 1
m f l L 87 i 1 selected. Recombiners, of course, we would put into service i- ' \s ("}/ 2 at the lower rates of hydrogen content. And the point we 3 wanted to make with this slide here, which there's been some 4 question, at least at ANO anyway, that said, well, what'if 5 it were 12 percent and you guys can only read up to 10. 6 Well, basically, we've already done everything we're going
- 7. to do. ~When we get to.this level, start going up to five ]
8 percent, six percent, our high level actions we talked about 9 in the other screen, have already got us doing every 10 contingency we can do for hydrogen. j
- 11. CHAIRMAN KRESS: What are the things that you do I
12 for hydrogen? I 13 MR. BICE: This is one,'of course. You do this I 14 and this and you may turn that off later, because it's a () 15 16 spark system. We may decided we want to keep spray going, you know, to buffer the hydrogen from being able to pocket 17 on us or something like that. So, I can't remember all of I 18 them off the top of my head, but I can tell you that before 19 we ever reach 10 percent, everything we can do is being 20 done. So -- 21 CHAIRMAN KRESS: Are those in your severe accident 22 -- 23 MR. BICE: That's correct; that's correct. Now, 24 this one is in the EOPs. But, everything -- once you get 25 above this, you're in the severe accident mode then. We l-L (\ ANN RILEY & ASSOCIATES, LTD. l ('j Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
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88 1- initiate'those actions. About!10 percent, everything is initiated, so what~are you going to do if it's 12? Same l 3 thing, so --
~4 CHAIRMAN KRESS: You sit there and wait.
L 5 MR. BICE: - .there's nothing else'you can do. 6 DR '. POWERS: They're going to sweat a little bit. 7 '[ Laughter.) 8 CHAIRMAN KRESS: Run. 9 LDR . POWERS: No , I don't think I'd run.
' 10 MR. BICE: That's one thing I liked about being in 11' ' Ops, as long as you're in the control room, you're pretty 12 safe. Iffthere's a tornado in Arkansas, I'm not going to 13' .the plant.
14 CHAIRMAN KRESS: You were setting us up. 15 DR. POWERS: Don't go to the out house.
.( )
16' [ Laughter.] 17 CHAIRMAN KRESS: You're really uptown if you get a E18 four holer. 19 MR. BICE: Okay. Outside releases again -- you 20 know, chances are, this thing is going to be going through a 21 . moderate path, you know, if we really look at this in a 22 realistic point of view. I mean, these things are 23 ~ marvelous. They can tell you a world of information. They,
- 24 - also, automatically input to -- astrology plume' 25 -automatically, so you know where the plume is going. You ANN RILEY & ASSOCIATES, LTD.
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i 89 1 know what sectors to evacuate even before the off-site field (' 2 teams get'there. So, there's a real good chance you're
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3 going to be monitoring it with one of these. There's at 4 least nine of these, I think, that are on site. 5 You've got the other station. 1 6 CHAIRMAN KRESS: Where do they read out? 7 MR. BICE: They read out in control room and 8 chemistry has a read out, because chemistry does most of the 9 monitoring once we're in a severe accident. And normally, 10 of course, in a severe accident, the chemist is going to 11 come to the control room, so he can tell right away, hey, 12 you've got a plume going here or there. ; 13 We talked about the use of the maintenance team l 14 monitors. There's an off-site release monitor. We can I i I)
\~s 15 quickly do the same thing for just about any other release 1
16 path. The one place where you're kind of left in the open 17 is if you had a hole in the building, straight to atmosphere l 18 -- outside any other building, just straight to atmosphere, 19 and that's where we would have to rely strictly on the 20 off-site field monitoring teams and the information that we 21 knew about the content of the RCS, before we had the 22 release, to kind of put those two together. And real 23 quickly, all we do is put all that information into the 24 emergency response organization operation long-term actions. 25 Let's move on there. Again, just from a PASS ( ANN RILEY & ASSOCIATES, LTD. (, Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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.q-t 90 1 perspective, the biggest thing Ops is going to be concerned
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2 about.now is reactivity control, the elimination of the 3 boron sample requirement from either PASS or NSS. I think 4 we're going to find that, really, we don't need a sample 5 period, whether using PASS or not. He already talked about 1 6 how they controlled reactivity, what they look at. And, in 7 fact, I'm not even going to beat a dead horse, unless you 8 all got another comment there. 9 DR. WALLIS: Well, they don't calculate this. I 10 presume they calculate it for them. 11 MR. BICE: Yeah. Reactor engineering would do the i 1 12 calculation, if there was no boron sample. If they have a 13 boron sample, they can do it themselves. I 14 Let's talk into the events that people really get () 15 worried about and that's where you have a -- a SG tube leak 16' is one of those events. Something that -- there's a lot of 17 times we forget, on a tube leak, it's required by procedure 18 to isolate that same generator. So, it's not like if you've 19 got into a backfeed event that you're going to continuously 20 fill up with undiluted water, so we can fill the RCS, in 21 turn, with that, that's not the case at all. 22 The steam generator, once we gain control of RCS 23 pressure and temperature, we're ordered to drop reactor 24 coolant pressure, to try to reduce the delta-p across the 25 break, whether or not we're putting much water into the ANN RILEY & ASSOCIATES, LTD.
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91 1 generator or back flowing, either one. It's an area where f} v 2 you're talking about, you have a large break LOCA and a tube 3 rupture. It's tough to get to, but we're in a severe 4 accident mode. 5 Now, RCS pressure, for instance, drops well below 6 steam generator pressure, hadn't done a cool down yet, all 7 we've done is lost pressure, so you are in a backfeed event. 8 CE has performed calculations that are currently in the ANO 9 procedures that tell the operator, hey, when you see your 10 steam generator level drop seven percent, you've made a 11 three percent reduction in reactor coolant boron. And the 12 operators know, number one, what the boron was before the 13 transient. They, also, know what's gone into the reactor 14 coolant system. So, that could easily, again, be /~s 15 calculated, either with the assistance of reactor (s_-) 16 engineering or whether there's a spare operator and he could { 17 sit down and do that calculation -- it's not real 18 complicated -- to determine what they're doing to the boron 19 concentration. But, again, you would have to have 20 significant reduction and getting more close to 1c sing all 21 shutdown margin to where you enter a restart situation. 22 One thing that would be handy to know, of course, 23 is, well, what is my boron concentration. I had a tube leak 24 to start with or I wouldn't have been here. Obviously, the 25 water in the generator is not pure water anymore. It's (] (,) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 92 1 borated to some degree. What ir 1*? Well, PASS can't help
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2 me there anyway and the nornal system can. So, what we're 3 trying to show there is that -- it says it's not needed or 4 Ops doesn't need it for rad activity control, because they 5 have other ways of monitoring what has happened. And if 6 there is some significant leakage, tney'll just watch their 7 flex monitors more closely. In fact, I guarantee you 8 they'll designate an operator to sit there and stare at 9 those flux indicators. They do that kind of stuff all the 10 time. ! 11 Now, let's say we have this scenario going on, we ' 12 have some back flow going on, but we lost -- which is only 13 allowed officially to happen on purpose -- I mean, for us to 14 do it on purpose, when the rad coolant pump is running, but () 15 16 either this happened by accident or we lost rad coolant pumps after we were purposely doing the back flow event. We 17 want to restart the rad coolant pump. That's going to get 18 us back in an easier control for the rad coolant pump. 19 Well, the procedure requires us to keep natural 20 circulation in progress for at least 15 minutes before I can 21 even think about starting the pump. That's going to make 22 sure that you have some new transient times there, get that 23 mixing, no pockets of unborated water sitting around. And 24 then it requires me, initially, to start the pump and the 25 intact loop first. So, I get the borated loop going first. ANN RILEY & ASSOCIATES, LTD. O(_) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 3 o
h , l 93 l 1 Then,-I can. start the pump in the other loop that may have
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2 less -- a little less boration and you get that mixing 3 immediately into the core for both loops and you don't have l i 4 a pocket going through the core that going to give you the 5 reactivity excursion that everybody fears. 6 Lastly, another event that people tend to worry 7 about is the station blackout event. Well, this is kind of 8 almost unnecessary even to discuss, so I'm not going to 9 spend -- one thing, I don't have any sampling capability 10 from a station blackout So, PASS does me no good here 11 whatsoever and no sample is going to happen if I'm in a 12 blackout. You talk about reactivity control during a 13 blackout. You just don't cool down on purpose. You're 14 asking to reduce your shutdown margin to do a cool down, but () 15 you have no way of making up for the -- and the reactor 16 coolant system. So the procedures are always going to guide 17 you in a blackout to stay right where you're at, stay in hot 18 standby conditions and wait until you get power back. You 19 have no way of making up any water source through the 20 reactor coolant system. 21 Okay. The.next page in your handout, this is just 22 an example of how samples are not used in our core damage 23 assessment, except, as Ray mentioned earlier, it's a backup 24 to the backup to the backup. This is way -- it's just a 25 confirmatory type situation. It's nothing that we really -- ANN RILEY & ASSOCIATES, LTD. f}/ \__ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
n r 1 l-( , [ 94 I (. 1 and I can tell you from an Ops perspective and an ERO
.2 perspective, especially during the first several days of an 3 event, the information is useless to me. I have no need for 4 it whatsoever.
5 This is our emergency plan. This is something the j 6 shiftee will be using when he makes -- starts to get ready 7' to make his protective action recommendations. He can tell 8 by what percent power the core has been at for how ever many 1 l 9 days, what time it is after shutdown, compare that with l 10 radiation readings, and determine what his fuel damage is. 11 Within that fuel damage, he can assess, using help with the l 12 reactor engineers, what's my iodine at. I've got 50 percent l i 1 13 fuel damage, how much iodine can I expect to be in that 50 14 percent. So, again, another internal assessment of what's 15 inside reactor coolant system, which might be a containment i 16 building, if you've got a LOCA. You probably do, if you 17 damaged the fuel that bad. So that if you have a 18 containment failure, you can at least guess, well, this is 19 'what's possible to be released. But, hopefully, the 20 off-site monitoring is going to refine what's actually going 21' out. I 22 Long-tenn sampling seems to be an issue. This is 23 an ANO perspective. It doesn't necessarily represent CE, 24 certainly not you guys. It's the way we look at it. 25 Long-term sampling isn't required for mitigation response. (~ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 E !
4 5 95 1 I think we've made that pretty clear. I'm talking about 2 mitigation of getting control of the core, to where it's now 3 in a decreasing state. Surely, the accident may not be 4 totally over; you've still got to do recovery actions, that I 5 sort of thing. But, it's not getting worse. You know, 6 we've got control now. PAR is not needed. Reentry activity 7 is not. I can use radiation levels for my reentry, because 8 that's really what I care about, what's my exposure. 9 Using the normal sample system on down the road, 10 again, like we said earlier, a case-by-case basis, based on 11 the benefit: what are we using it for; why do we think we 12 need a sample. And there could be some reasons for that. 13 Say, we're going to start the cleanup mode; say this is 10 14 days, 30 days, whatever it is, when we decide, okay, we've 15 got control, let's clean it up now. Maybe it will be a nice 16 thing to know what the radioisotope content is of the 17 reactor coolant system or the flow or wherever the fluid is. 18 That might be a good reason to get it. But, again, I'm not 19 really forced into this. There's nothing that forces me 20 into cleaning up today. Why not wait a week, if it's safer 21 for everybody. 22 The same thing when we get into this next one, 23 well, it sure would be useful to the other sites to know 24 what happened at ANO. Again, do I have to have that today? 25 Not necessarily. I could wait another week until radiation ANN RILEY & ASSOCIATES, LTD. (O,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 t
l 96 1 levels get down. And something else to look at in this
/\ 2 arena, we're in a severe accident, probably half of you guys b 3 l are down there. The NRC is certainly down there. The 4 Department of Health is there. We've got so much input as 5 to how we can get a sample without hurting somebody that 6 it's almost unreal. So, I'm pretty confident we'll get the 7 sample, you know, either using this system or just going and 8 taking a grab sample off an active pipe. But, I think there 9 will be enough brains involved that ad hoc, we can get them 10 -- you know, no problem whatsoever.
11 And sometime I want to go ahead and bring up two, 12 because the PASS systems, you would think, you brought up a 13 design issue and sure -- I'm sure they can be designed 14 better. But what we're talking about is an NRC requirement, () 15 16 this system must be able to do its thing without us getting involved with it, because it's required to be there. So, I 17 can't tell the chemist, you're going to have to go and 18 manipulate these valves, because he would be dead. So, I've 19 got to design this system to where it can do its thing by 20 itself. Well, that means I've got to go from a potentially ! 21 2,000 pound system down to atmospheric, so I can get the 22 sample. So, I've got pressure control devices everywhere 23 that I don't care if we redesign or not, they'll still be 24 there. And pressure control devices just fail all the time. 25 They just do. You have to have over pressure protection. [ ANN RILEY & ASSOCIATES, LTD.
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i 97 1 Rupture' disks, they fail all the time, and you have to have (} 2 several of them, because you have several breakdown points 3 here. 4 So, even with the redesign, you're still going to 5 really show the same things that ANO and all the other CSIs 6 have lived with for years, and that is you have to keep 7 replacing pressure control valves. You get a valve that 8 leaks a little bit, puts this pressure on there when nobody 9 is sampling with.the system. Those are rupture disks. So, 10 you're in your seven day accident. So the system -- to have 11 an automated system like this, I really don't think it will 12 ever work. I just don't think the technology is available 13 to have it out there. 14 Again, at ANO, and I'll just talk about ANO here, () 15 we have temporary shielding staged at the normal sample 16 system. The chemists know where it's at. We haven't 17 written an attachment to go do this yet. This is part of 18 our commitment in our letter that we would do if PASS 19 elimination is allowed. But, we're going to write an 20 attachment or a procedure that says we're in a fuel accident 21 condition, this is how you take your sample. Here's your 22 shielding. This is where you need to put it. Go in there 23 and start your flush, which, by the way, the flush goes back l 24 to a closed system -- it doesn't dump to the floor or 1 25 something, you know, so, we're taking -- we're keeping ANN RILEY & ASSOCIATES, LTD. O.' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 , I I
98 1 control there -- and then get out. Wait outside the room 2 while you're flushing, go back in, take your sample, which
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3 takes 30 seconds, run it over to the analyzer, turn it on, 4 get back out of the room while you're doing the analysis. 5 And the analysis prints out on the remote computer, so, you 6 know, done deal. 7 So, we can get it -- I don't think that when we 8 talk long-term sampling, we're talking about two years down 9 the road. I don't think those rates have to get so low that 10 you can just walk in there like we normally do, during 11 normal power operations. You can still have quite a bit of 12 radioactivity and use this system. I'm very confident of 13 that. 14 And in ANO's opinion, the elimination of PASS, no ( ) 15 impact whatsoever on the health and safety of the public. 16 If by the time we were to actually get a PASS sample, if the 17 system was worth something, analyzed it, got that 18 information out to the emergency response teams, if we 19 haven't taken public action by then, and they probably 20 already sucked in the plume, you know, therm's probably not 21 -- no sense in taking any action then, other than filter. 22 So, we need something a little bit quicker than that. And 23 those off-site monitoring teams that we kind of discussed 24 earlier, all they have to have -- there are some plants -- 25 ANO is not one of them -- there are some plants that have I'N ANN RILEY & ASSOCIATES, LTD. k ,) m Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 P
p 99 l 1 like -- your the chemist of the group, so you go -- there's i j (~ 2 some sodium or something, that they can do the analysis D} 3 right there in their van. It's just as likely I can get an 4 iodine. 5 But, really, you can add just a charcoal filter on 6 your air sampler. Count that charcoal filter, charcoal l 7 sucks up iodine, let's you know what gas is going on 8 through, and you can get a pretty good close estimate of I 9 what your iodine is right there on the spot. Call that in 10 to your emergency response organization and be making 11 decisions with the state a lot quicker that way. 12 So, again, the physical difference is, yes, there 13 are physical differences, but we can accommodate those by 14 delaying the samples. That's what I mean by decay times. () 15 16 Use of our temporary shielding -- basically, writing a procedure that handles it, using what we've got now and not 17 using the PASS. Keep in mind through all of these, what ANO 18 is really saying is other than long-term, we don't need the l 19 sample at all. We don't have to have the sample. l l 20 Chloride stress, we already talked about, and 21 this, also, had your iodine retention in there, which I know ! l 22 that Mr. Powers -- 23 DR. POWERS: Chloride stress, you mean chloride 24 stress for erosion -- 25 MR. BICE: That's correct. l N ANN RILEY & ASSOCIATES, LTD. (/ (s , Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
N ! n . 100 l' DR. POWERS: I was worried about any undue strain 2 on the --
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3' MR. BICE: That's kind of a like an operator term, 4 like ain't. Ph control was already beat together and I 5 think we were the ones beat to death. But -- 6 [ Laughter.] 7 MR. BICE: Talk about reactor engineering in the 8 CDAs. Iodine 131, from the reactor engineering, the RO 9 people,'the field monitoring radiation levels inside the 10 plant, the activity control, obviously no need for a boron 1 11 sample there. Something else I didn't tell you, that we, 12 also, have tables that tell us if you're going to do a cool q 13 down, add this much buron; you're guaranteed to maintain 14 your shutdown margin, if you add this much boron. So, () 15 16. again, we don't have to have a boron sample to do that. We've already got a table that tells us how much to add. 17 We talked about hydrogen. We talked about the 18 long-term sampling is, again, not really required for 19 mitigating your response PARS. Reentry for plant 20 stabilization purposes really is just being a nice to know 21 thing before you went to clean up or certainly for other I 22 plants. And in those cases, we have shutdown discussions 23 with the Arkansas Department of Health over this. The 24 information that they're interested from us, they get 25 without PASS, We don't get that information from PASS that p/ g_ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I
S 4 101 1 we give them and they've already given us a letter saying no
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( 2 problem with us whether you eliminate PASS or not. It has 3 no impact on the State of Arkansas, so -- 4 DR. POWERS: Could we get a copy of that letter? 5 MR. BICE: As far as I'm concerned, you can. I 6 need to talk to my utility to make sure that it's okay with 7 them. And then that's all. I'll let you guys do to me what ) 8 you did to Ray. 9 DR. WALLIS: What's that dangerous looking tower j 1 l 10 on the right there? l 11 MR. BICE: This is radioactive smoke. l l l 12 [ Laughter.] 13 MR. BOEHNERT: It's glowing. 14 SPEAKER: Well, I have a question. All that () 15 16 you've walked through here with the operating procedures and everything, is that typical of all the other CE plants? 1 17 MR. BICE: I believe it is. Terry Price, can you ! l 18 -- j 19 MR. PRICE: This is basically what we do at Palo 20 Verde, the same type of steps. i 1 21 MR. BICE: The CE severe accident management is 22 basically standard, so it's just really a matter of what 23 team does what. 24 DR. POWERS: One of the essential points that you 25 and the pervious speaker make is the time it takes to get a l
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102 1 PASS sample is so long that it's really not useful to you. But when I look at the requirement in NUREG 0737, again is [d
h 2 3 the enlargement of the PASS, it says, " licensees and l 4 applicants shall establish an on-site radiological and 5 chemical analysis capable to provide within three hour time J
6 frame quantification of the following," and it says, 7 "certain radionuclides, hydrogen levels, and dissolved 8 gasses." Does that mean that this has just not been designed 1 9 to meet the requirement? l l 10 MR. BICE: We can do that in three hours. 11 DR. POWERS: Can do that in three hours? 12 MR. BICE: Now, it would cost us everything Ray 13 talked about. Most of our system is obsolete. I guarantee 14 you, about every time we start it up, maybe it's because of 7' ( )s 15 the obsolescence -- I'm talking from an operator point of 16 view here, not an engineer and maintenance -- but we almost 17 always find a leak. The last thing you want in a severe 18 accident is a leak. 19 DR. POWERS: Wrong time to have a leak. 20 MR. BICE: We're talking about a pipe, a lot of 21 pressured control valves, a lot of ruptured disk -- that's a 22 lot of stuff to control a leakage on. You know, it's almost 23 beyond control. So, we can get a sample at that point and, 24 again, it might be useful, in an offset release, if it was 25 there. But, do we have to have it? Is it critical to save [~) ANN RILEY & ASSOCIATES, LTD. (. / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
103 1 the public or save the plant, either one? Our answer would 2 be no. O(~T 3 MR. SIEBER: Just one more question. You showed 4 us one train of operator actions to come up with the 5 classification level and a protective action recommendation. 6 But, there are many, many trains, based on your EOPs that 7 are symptom based, as opposed to -- 8 MR. BICE: Oh, yes. Safety function, symptom 9 base, they're not opposed to taking any certain -- 10 MR. SIEBER: So, this is just a little snapshot of 11 a great bit array of procedures that may have nothing to do 12 with core damage, but has more to do with the probability 13 that you're on a path that will take you to core damage and 14 that's why you want to make a protective action
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(N) 15 recommendation early. So, if you're going to do an 16 evacuation, you do it before the -- those get to the public. 17 MR. BICE: Right. And, again, just the sampling 18 aspect, there's lots more out there going on. 19 CHAIRMAN KRESS: Are there other questions? 20 (No response.] 21 CHAIRMAN KRESS: If not, I guess we'll hear from 22 the NRR staff. 23 MR. BOEHNERT: Dave, do you want to leave the 24 microphone behind? I think you -- are you -- 25 MR. BICE: Do you want it to stay on? I didn't
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E ; ; I ! l 104 L 1 even know if it was working. 1 (~') 2 MR. O'BRIEN: My name is Jim O'Brien. I'm in NRR, V 3 in the emergency preparedness and health physics section and 4 I'll be leading the presentation today for NRR. First, I 5 wanted to thank ACRS for its time taken to review this. 6 We're finding it a difficult issue to go through ourselves 7 and we appreciate your guys input on it. 8 The system -- we've'got a materials and chemical 9 engineering breach, which reviewed the ph, oxygen, 3 10 conductivity, and chloride sampling criteria. Kris 11 Parczewski over here, from the PSA branch, to review 12- continuing hydrogen sampling criteria. We've got Mike 13 Snodderly from the reactor systems branch, which reviewed 14 dissolved gasses. And boron sampling criteria, that was (n) 15 Lambrose Lois, and Mike is going to be standing in for him 15 -- Lambrose is on travel. Jerry Verhmiel was here to 17 discuss it, but he had to go to another meeting. And as I 16 introduced myself before, I'm from the em_ergency 19 preparedness and health physics section. 20 I'm going to keep in numerical order -- I'm going 21 to put up this slide, but I don't think it -- unless you 22 guys want me to, it's worth discussing NUREG-0737 in Reg 23 Guide 1.97. We hit both those issues from the other 24 presenters. l 25 CHAIRMAN KRESS: I think that's a fact. l ANN RILEY & ASSOCIATES, LTD.
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i 105 l 1 MR. O'BRIEN: This, also, I'm not going to spend I 2 much time on, except to note that the NUREG CR-4330 [ } ! 3 contractor report was a 1986 document. I think Ray had 4 mentioned 1980. That was a 1986 document, just to kind of 5 correct the record there. And Ray, also, mentioned a SECY 6 93-087, concerning advanced plants, the previous combustion 7 engineering report. And as you guys are aware, or I think 8 you're aware of, we presented to the full committee our 9 review of the Westinghouse submittal on post-access sampling 10 .back in May. 11 CHAIRMAN KRESS: Let me ask you about the first 12 bullet up there, regulations margin of safety. They l 13 reviewed the PASS system and the requirements for it, in 14 that program? 1 () .15 MR. O'BRIEN: Correct. 16 CHAIRMAN KRESS: And they concluded it was -- 17 MR. O'BRIEN: Marginal improvements to safety. 18 CHAIRMAN KRESS: So, what -- did they not follow 19 up on that or do anything about it? 20 MR. O'BRIEN: Well, I think there was a Pacific 21 Northwest Lab report, contracted by NRR. 22 CHAIRMAN KRESS: So, it was a report to -- 23 MR. O'BRIEN: To the staff. 24 CHAIRMAN KRESS: -- the staff. 25 MR. O'BRIEN: And the staff never took any action ANN RILEY & ASSOCIATES, LTD. OA Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I il t 106 1 .on it afterwards, r - 2 CHAIRMAN KRESS: Okay. i 3 MR. O'BRIEN: They, also -- l ' 4 CHAIRMAN KRESS: But, they concluded this one was 5 more -- of marginal importance to safety? 6 MR. O'BRIEN: They did, the PNL staff did. NRR, 7 there's.nothing on the record, what their position was on 8 .that -- that determination, except.that they reviewed it and 9 published it. 10 ' CHAIRMAN KRESS: But what's their definition of 11 safety in that? 12 MR. O'BRIEN: In that report? 13 CHAIRMAN KRESS: Uh-huh. 14 MR. O'BRIEN: I don't know. But, I'll tell you ; () 15 16 what they looked at, they looked at the same things that were looked at with these folks, with the emergency response 17 actions taken, based upon this information or absent the 18 information, in planning the response. And maybe in a 19 qualitative way, they were looking at the impact to the 20 public, mitigating actions on-site and off-site. 21 DR. POWERS: They didn't have an importance to 22 safety meter on it, and this was on some scale and not 23 meter. 24 MR. O'BRIEN: Yeah. It sounds like there's a -- 25 when you say " marginal," where does it fit in there. There l l (-') ANN RILEY & ASSOCIATES, LTD. Court Reporters
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l i 107 1 was nothing explicitly presented, in that regard. And as 2 Ray pointed, they, also, made a conclusion that it was not a 3 cost -- there was not a large cost associated with PASS, at 4 the time. So, they -- NRR didn't take any action in there. 5 One think I'd like to point out in the last I 6 bullet, as far as the Westinghouse report, as we discussed 7 before, the main issue there was for a number -- most of the 8 sample points were requested to take them out of the 9 licensing basis, but there was an indication there that a : 10 couple of them at least will be maintained for long-term 11 recovery purposes, but outside the licensing basis. As 12 regulators, we review that as the systems are -- will not be 13 available for use, because there's no assurance that they ! 14 will be maintained if they're outside a licensing basis. i 15 CHAIRMAN KRESS: Understand. 16 MR. O'BRIEN: Okay. A couple of points I wanted 17 to bring before you. Next, I'm going to go through each one 18 of the sample requirements and go through what our 19 conclusions were on the submittal. One thing I wanted to 20 point out is that PASS has many masters or many purposes, 21 both on-site accident mitigation and, also, off-site. So, 22 we have people with different focuses involved in the 23 review, some of them are on-site and me, in particular, 24 looking at the off-site impact. So -- 25 DR. POWERS: But, are you looking -- talking to O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
E n l 108 1- the people responsible for the outside emergency planning () 2 3-and asking them how they use the information from the PASS sampling? 4 MR. O'BRIEN: The effects of the last slide, that 5 is what we intend to do. We have not, at this point, but we 6 want to send a letter out to them. This presentation goes a 7 little bit different than the last one, when it comes to 8 radionuclides. . When I get to that, we'll address where 9 we're at with it. 10 Okay. This one is Lambrose's, which -- he's not 11 here, but it involves dissolved gasses, which includes the 12 hydrogen, and our position is acceptable to eliminate from 13 PASS. Plants -- they all have, and there's a couple of 14 reasons put down here regarding RVLIS and the use of a head () 15 vent and, also, recognizing that there's a large time delay. 16 I'm going to kind of go through a couple of these fast. I'm 17 going to try to get to the ones where we may be touchier. 18 If anybody stops me, we'll go back, if necessary. 19 DR. POWERS: Now what they concluded when they 20 said on this one that the delay between sampling and 21 availability, the result is that the required three hours 22 was just too long of a time. 23 MR. O'BRIEN: Correct. 24 DR. POWERS: Now, it wouldn't matter what kind of 25 system that they had, if it was three hours, three hours is ('N N ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
E I 109 1 just too long? [~ MR. O'BRIEN: LJ) 2 Right. 3 MR. SNODDERLY: Dana, this is Mike Snodderly from 4 the staff. I would clarify that more as the secondary 5 reason. I think the primary reason is that one of the main 3 6 reasons for that was to determine the composition of the 7 void, if it would occur. And with the implementation of the 1 8 RVLIS, you have much better knowledge of whether the void 9 has occurred or not. It doesn't tell you about the 10 composition; but with the reactor vessel vent system, you're 11 going to relieve that void. 12 DR. POWERS: There's not going to be a void to 13 begin with? 14 MR. SNODDERLY: Right. So, therefore, the need to r% 15 () know the composition is not as necessary as before. 1 16 DR. POWERS: Well, it sure would be a lot more I 17 comforting if the staff would write down, we don't think the 18 information is needed, rather than saying other things that 19 are secondary. 20 MR. SNODDERLY: Sorry; that's a good point, Dana, 21 and we'll correct that for the full committee. Thank you. 1 22 DR. WALLIS: The RVLIS tells you that there are l 23 voids. It doesn't tell you what's in them. It could just 24 be pure steam. 25 MR. SNODDERLY: Yes, Graham, I'm sorry if I didn't [D ANN RILEY & ASSOCIATES, LTD. \m ,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r e . 110 1 'make that clear. Yes, it tells you the void. It does not , 2 give you the composition. But -- l (')'i 3 DR. WALLIS: So, it doesn't answer the question 4 about dissolved gasses at all. 5 MR. SNODDERLY: But, you're going to -- you're 6 going to relieve that void with the reactor vessel head vent l 7 immediately, right? We're not_ going to -- at TMI, there was 8 a big concern, because what is in that void and is it 9 hydrogen and could it combust and is that something to be 10 ~ concerned about. So -- but now, today, how we would 11 approach it, we would immediately relieve the void. Now, if 12 that system doesn't work, then we're in a -- there could be 13 some value there and then -- but, that's -- that would go 14 for dissolved gasses, as well as hydrogen. () 15 DR. WALLIS: I think the concern really was voids 16 in a vessel rather than dissolved gasses, is that what l 17
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you're saying, the original concern? 18 MR. SNODDERLY: Yes, that's my understanding, 19 hydrogen in the void, and the dissolved gasses, of course, 20 would allow you to give some idea as to core composition or 21 the amount of core damage. Dana can probably -- 22 DR. POWERS: Well, I mean, certainly at TMI, there 23 was a bunch of hooey about whether the hydrogen could , 24 combust and whatnot. I mean, that was nonsense. What we 25 were really worried about was we have a void, was it ANN RILEY & ASSOCIATES, LTD. i Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ! Washington, D.C. 20036 l (202) 842-0034 , 1
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I l 0 i 111 1 growing, and we were going to interfere with coolability.
N 2 And that's what you worry about now; you don't really care (d 3- whether a void is made out of krypton gas or hydrogen gas or 4 feromethyl hoo-hoo. It's whether you have a void or not.
5 MR. SNODDERLY: Right. 6 DR. POWERS: And when you've got a level of l 7 indication -- 4 8 It's not the hoo-hoo, you want to know where the i 9 fero came from. 10 It comes from the same place the oxygen came from 11 and the TMI void with sustained combustion -- out of 12 somebody's imagination. But with the head venting system 13 and the level indicator, you get rid of this thing, okay. 14 And so, you know, times have passed us by. () 15 DR. WALLIS: So, you're saying the motivation for i 16 knowing specifically about dissolved gasses has really gone 17 _away? 18 DR. POWERS: Yeah. That's arcane stuff. You just 19 wouldn't mess with it. If I've got a void, I mean, get rid 20 of it.
- 21. DR. WALLIS: But, if they dissolved, they're not a l
22 void yet. 23 CHAIRMAN KRESS: It's just the potential. 24 DR. POWERS: I mean, this was inferential, And we 25 did have problems with cycling pressures giving us evolution i I
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I I i f 112 1 to gasses that was interfering with level indications and N 2 things like that. There were lots of interesting things, . () l\- ' 3 but it's history. I 4 DR. WALLIS: So, you're saying there's a better ) 5 knowledge of what's going on and what you need to know. 6- DR. POWERS: And it's because of head vents. 7 MR. SNODDERLY: And.the ability to mitigate the 8 void. 9 DR. POWERS: Yeah. 10 DR. WALLIS: So, it's better knowledge of what's 11 important and it's better hardware -- 12 MR. SNODDERLY: To get rid of it. 13 DR. WALLIS: -- to remove the original concern, 14 which was based somewhat on misconceptions anyway? 15 DR. POWERS: l( ) There was no misconception. The void 16 that grew would eventually interfere with ability. There's 17 no question about that, that would happen. 18 DR. WALLIS: But, it wouldn't -- but the original 19 concern was -- 20 DR. POWERS: There was a lot of stuff in the paper 21 about explosions and nobody had any good sense. 22 MR. SNODDERLY: There wasn't enough oxygen. 23 DR. POWERS: Not enough oxygen for anything in 24 there. -I mean, the oxygen -- it was 10 to the minus 10 l l 25 atmosphere. l ANN RILEY & ASSOCIATES, LTD.
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113 1 CHAIRMAN KRESS: There was never an explosion. l
/"'\ 2 DR. WALLIS: Well, the best. thing to prevent the
!U 3 explosion would be to keep it in there. 4 DR. POWERS: Sure; sure. I mean, instead of l-5 having a 28 psi pop inside containment by preventing it, you 6 would have had a 56 psi pop. That's a huge difference. 7 CHAIRMAN KRESS: The explosion issue came about, i 8 because somebody. thought this was being really illogically 9 produced. 10' DR. POWERS: Yeah. 11 CHAIRMAN KRESS: And there, you would have the 12 oxygen; but, that was ridiculous. l 13 MR. O'BRIEN: All right. Next -- I grouped a lot 14 of the samples together when they were related: RCS oxygen, () 15 16 RCS ph, RCS chlorides, and RCS connectivity measurements, l which were -- I'll use the word " required," specified in l 17 either Reg Guide 1.97 or NUREG-0737. CE owners group has 18 justified removing those samples and we've -- our review of 19 it, we believe that's acceptable. The rationale for our ) i 20 position is that information used to evaluate the potential , i 1 21 for stress corrosion cracking in stainless steel, the 22 information is useful determining -- evaluating the 23 potential for stress corrosion cracking. Most of the 24 incoming water will be from the containment sump, which is 25 ph controlled. ANN RILEY & ASSOCIATES, LTD. l l O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p i O I I 114 1 DR. POWERS: Now, that's the one that gave us
~N 2 pause earlier.
[O i 3 CHAIRMAN KRESS: Yeah. I 4 DR. POWERS: Okay. They put the 5 'trisodiumphosphate in there now. Tell me what the ph is. 6 MR. O'BRIEN: This happened to me last time, too. 7 DR. POWERS: It's you; yeah, it's you. We're not 8 going to let you come talk here anymore, if you're going to 9 drain our batteries. 10 CHAIRMAN KRESS: You'll have to bring your own 11 batteries form now on. 12 DR. POWERS: Since they've cut our budget, we've 13 got to put -- we're going to require speakers to bring their 14 own batteries. Okay, tell me the ph. w. 15 MR. O'BRIEN: Okay. This is, of course, easy for 16 me, because I'm not the lead reviewer on it. I'm going to 17 turn it over to Kris. You would just hear inadequate 18 information from me, I'm sure; maybe from Kris, too, I don't 19 know. 20 MR. PARCZEWSKI: I'm Kris Parczewski in the 21 material and chemical engineering branch. What is your 22 question, I'm sorry? 23 DR. POWERS: Okay. They've got a bunch of baskets 24 of trisodiumphosphate in there. We dump this water into the 25 containment sumps. What's the ph? l
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115 1 MR. PARCZEWSKI: It's calculated to determine the i 2 amount of trisodiumphosphate just to -- 3 DR. POWERS: How much trisodiumphosphate is there? 4 How much is absorbed on surfaces? How much is precipitated? 5 How much is actually in the solution? 6 MR. PARCZEWSKI: Well, they're taking a very 7 conservative approach. They assume it's all there. 8 DR. POWERS: Okay. The very conservative approach 9 is to assume all the trisodiumphosphate is precipitated -- 10 MR. PARCZEWSKI: Yeah. 11 DR. POWERS: -- or absorped on surfaces. Now, 12 what's the ph? 13 MR. PARCZEWSKI: No, the trisodiumphosphate would 14 dissolve. If it doesn't dissolve, the solution is salt. () 15 DR. POWERS: As soon as it sees calcium, it l 16 precipitates as calcium phosphate. As soon as it sees iron, 17 it complexes to form phosphate. As soon as it sees zinc -- 18 MR. PARCZEWSKI: They are required -- they are i 19 required to test it, making sure -- they're taking the 20 samples of them and they test it for the quality of the i 21 salt. After they measure the salt -- so, they make a l 22 chemical analysis of it. 23 DR. POWERS: That's not the question. The 24 question is, we've got it in the sump now. The sump has got 25 all kinds of garbage coming into it. It's leaking calcium
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l !. L 116 I L 1 - hydroxide out of every piece of concrete that it touches. l 2 .It's got rust falling into it. It's got the zinc primer on [ l i 3 the paints that it's exposed to, all of which are reacting 4 with phosphate. In.the meantime, I've got nitric acid
.5 coming in from the radiolysis. I've got hypolon 6 decomposing, generating hydrochloride acid. They have Claro
~
7 Wren's right. We've got every ketone, God's creation being 8 turned into acidic acid and formic acid in the solution. I 9 just want to know what the ph is, in the face of all of 10 those things. Going to a ph curve, going to an acid 11 dissociation constant for a trisodiumphosphate is step one, 12 I will admit. But, it don't help very much to get the ph. 13 So, now, what's the ph?- 14 MR. PARCZEWSKI: Probably, it would be difficult () 15 to determine exactly. But, do we really need to have a 16 really very accurate determination? It's just a matter of 17 determining is it a basic or is it acidic. I mean, this is 18 really basically to try to establish. 19 DR. POWERS: And I'm still asking what is the ph. 20 And, no , it's very, very, easy to determine what the ph is. 21- You put an electrode from Beckman instruments into the 22 solution and you do a readout on it. 23 CHAIRMAN KRESS: That's the issue. 24 DR. POWERS: That's the issue right there. The 25 calculation is too complex for me to do. f o g ANN RILEY & ASSOCIATES, LTD. (_/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 o .
Y 1 i j7 y E 117 1 CHAIRMAN KRESS: It's still uncertain. Too many l ( l 3 DR. POWERS: I don't even know the masses I've got I 4 to work with, okay. I know the acid dissociation constant 5 is at two significant figures, but I don't know what M to i 6 put in there for the molar amounts, okay. But, a ph meter 7 is one of the simplest things. I mean, they've been around 8 since the 1920s. Mr. Beckman has made a fortune off of 9 those suckers. 10 DR. WALLIS: It doesn't require anybody to go in 11 and stick it -- 1 12 DR. POWERS: Nobody has to go in there. l 13 CHAIRMAN KRESS: I believe you can just stick it I 14 in there. r ( 15 MR. PARCZEWSKI: Well, I don't believe, in this L. 16 condition, ph measurement would be very accurate, even if 17 you have instrumentation. 18 DR. POWERS: It's going to be more accurate than 19 my calculation, because I can't start on line one on my 20 calculation, because I don't know how much 21 .trisodiumphosphate I actually have in the solution. 22 MR. PARCZEWSKI: But, I think ph, before they 23 determine that quantity of sodiumtrisophosphate, they run 24 actually the test. I agree with you, test only using boric 25 acid from there.
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p 1-1 118 1 DR. POWERS: Okay. So, they've hired a reactor, 2 they melted that sucker down, and they checked the ph in 3 this trisodiumphosphate throughout that, and they said l 4 that's going to be applicable. I mean, what test is useful 5 here? 6 CHAIRMAN KRESS: You can't do one. 7 DR. WALLIS: It seems so easy to have a ph meter 8 and it doesn't have many of the disadvantages of your other 9 PASS systems. So, what's the incentive to do away with it? 10 MR. SIEBER: Well, you don't have one now, so it 11 would be a new one. 12 DR. WALLIS: It would be a new requirement? 13 MR. SIEBER: It would be a new requirement. 14 DR. POWERS: Well, only for these guys. () 15 16 MR. SNODDERLY: This is Mike Snodderly, again. think I'd like to approach it from another angle and that I l 17 would be to say, first of all, I think that the key is, if ! 18 we think we have not accounted for all of the acid sources 19 appropriately, then the time to correct for that is now. In 20- other words, if we don't think we have enough 21 .trisodiumphosphate or sodium hydroxide, then we should be 22 going back and looking at the fact, do we need more. So, I 23 think what Kris was saying was that we think we've done an 24 adequate job of providing enough buf fering solution to take ! 25 care of the boric acid and provide a aump with a ph greater ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 washington, D.C. 20036 (202) 842-0034
F l l l l l 119 j l 1 than seven. I I (~N 2 And now, what would be -- now, assuming that, l sj 3 let's say we can agree on that and put that aside for a 4 second, now what would we do with the sump ph measurement. l 5 In other words, we're in an accident. It's 12 -- you know, j I 6 12, 24, 48 hours, seven days in, and, you know, are we going 7 to be able to add more buffering solution. And I guess ; I 8 that's why we're -- then, that would take me back to the 9 first argument and say, if we think we haven't accounted for 10 the sources, then the time to add the additional buffering 11 solution is now, not after the accident. I I 12 DR. POWERS: I mean, that's -- Mike, that's ! 13 certainly an approach you can take. But the problem is that 14 if you sit down and you ask me how much trisediumphosphate (q , 15 should I put in there; and I say, well, gosh, it's a very
%J 16 difficult thing for me to come up with, because I've got all l
17 these guys around the world doing experiments, they're t 18 finding things that I never thought of before. And I say, 19 now, have they done enough experiments to think of 20 everything else; and I say, well, gee, I don't know. I 21 mean, they've thought of an awful lot of things and I can do 22 an awful lot of things here. 23 The problem is that suppose -- now, suppose I'm in 24 an accident and I'm trying to advise the state about things. 25 It's a very subtle business here. It comes along and says l ' i, ()) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
e i l 120 1 I'm three days into the accident and I think everything is ( ) 2 .over and I want to tell the local authorities, hey, you can 3 ease back; the worst is over; containment has held up just 4 great; we're not going to get anymore radiation, because 5 everything is in the sump. And then, I've left out an acid 6 source. And now, all of a sudden, I get a lot of 7 partitioning coming in from the atmosphere and I get a 8 pretty healthy -- I get Graham's 10 percent partitioning 9 into the atmosphere. You know, I think they're going to be 10 a.little agitated at me, especially when they find out that 11 I could have avoided getting in that trap with a Beckman ph 12 meter. 13 See, I -- it's a problem of how confident do you 14 ~ want to be in the face of a tremendous amount 'of technical () 15 uncertainty. These radiation effects -- people know lots of 16 separate things. They don't know what complicated systems 17 do. 18 MR. PARCZEWSKI: I think, presently, some of the 19 plant, at least, consider the effect of nitric acid 20 generated and of hydrochloride acid from the composition of ! 21 the insulation. Those two factors are being considered. I 22 You are talking about some other factors that might get i 23 involved. That's a problem I've not considered, j 24 DR. POWERS: And I think -- I mean, you create a
'25 list here and you can say, okay, you've taken into account :
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121 1 hypolon. You've taken into account nitric acid formation. 2 You can call up Claro Wren and find out what she really 3 believes about methoethyl ketone. You can probably talk to 4 Brian Baucher about iron absorption of phosphate and boric 5 acids and whatnot. After you've gotten this list then and I 6 say, now, are you really, really confident that you've got 7 them all, yeah, I think you have a hard time saying yes. 8 Because, we thought of taking the fact that the i 9 zinc primer forms a complex compound with the phosphate. It 10 just sucks phosphate right out of the solution. I mean, 11 yeah, you can go into the literature and you sure enough 12 find that some German chemist in the 1820s found out all 13 about that and crystal structures have been done on the 14 thing. But, people didn't. And does it mean now that () 15 16 people have thought about it, that they've caught all those things that can happen? I don't think so, not unless we're 17 in the business of melting down reactors to test things. 18 And it's very difficult. 19 CHAIRMAN KRESS: What was your -- I got 20 distracted, what was your response to Mike's comment that, 21 well, if you had the ph meter, you took a measure, what then 22 would you do? 23 DR. POWERS: Well, I think that's one of -- it's j 24 really in the business of accident management. 25 CHAIRMAN KRESS: Yeah. l (~N ANN RILEY & ASS )CIATES, LTD. l (s Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 I h a
L c C" i l I l 122 1 DR. POWERS: You're saying, gee, I'm going acid. 2 CHAIRMAN KRESS: It gives you information. l 3 DR. POWERS: And I know what that means, if I 4 start going acid. And I had better take activities. 5 CHAIRMAN KRESS: You better think about it. 6 DR. POWERS: And now there's a legitimate argument 7 that can be made that says, let me over foam this. I don't
-8 know what reactions will occur, but I know what their 9 stoichiometries are going to be, the upper and lower bound.
10 I'll put enough phosphate in this darn thing to -- { 11 CHAIRMAN KRESS: No matter what happens. 12 DR. POWERS: -- no matter what reaction takes 13 place, because all I have to do is get out a couple of half 14 lives. And, yeah, I'll still partition a little bit of 15 ( }) iodine up there; but, I mean, it gets to the point of the 16 ridiculous. But, I can't tell if that's been done, okay. l 17 And pretty soon the amount of -- I mean, trisodiumphosphate 1 18 in a plant is not the world's easiest thing to take care of, 19 especially -- 20 CHAIRMAN KRESS: You have to replace it every now 21 and then. I 22 DR. POWERS: -- if the staff comes along and says, ! 23 well, now, do a solubility test for me and do a solubility 24 kinetics. You know, you're paying for a ph meter several 25 times over with each one of these things. i l ! ANN RILEY & ASSOCIATES, LTD. O l l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l ! t
i F f 123 1 MR. O'BRIEN: Dr. Powers, in regard to this, is l 2 the focus on the RCS or the sump? 3 DR. POWERS: It's really the sump. 4 CHAIRMAN KRESS: It's really the sump. 5 MR, O'BRIEN: Because, I know -- 6 CHAIRMAN KRESS: We don't really care about the ph 7 in there. 8 MR. O'BRIEN: -- a lot of the issue seems to be 9 not taking the RCS samples with the pressure breakdowns and 10 things like that, that were being discussed, rather than the 11 sump, which should be at a lower pressure. 12 DR. POWERS: Yeah. I think -- I think you're not 13 really too concerned about the RCS. I mean, I can see an 1 14 argument for worrying about it, but nobody has up until now, () 15 16 so I'm not going to pick up a new crusade here. enough of a problem on this one. I've got 17 CHAIRMAN KRESS: I was really worried about stress 18 corrosion cracking during -- 19 DR. POWERS: I know you're staying up late at 20 night. 21 CHAIRMAN KRESS: That really bothers me. 22 MR. PARCZEWSKI: I think stress corrosion cracking 23 is not a big issue, because it's a very slow process. 24 DR. POWERS: That's what he was saying. 25 MR. O'BRIEN: We will have enough for me to grab /~' - ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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I ! l e l 124 l l 1 the slide with the containment sump and maybe that will be i l (x 2 the focus of just -- we've already done it maybe, but I just (~ l 3 want to highlight it on my notes as the issue. RCS boron, 4 the position is it's acceptable to eliminate from PASS and 5 the rationale for -- this is that boron issue, it's a backup 6 for other indicators of the criticality concerns, as was 7 discussed by the other presenters. 8 I'm going to try to get through -- I've changed 9 the order just a little bit, I apologize, just because I 10 want to get through the easier ones first -- or the easier 11 one. 12 DR. POWERS: It may be so easy that we slid right 13 through that one. 14 [ Laughter.] 15 MR. O'BRIEN: That's what I'm putting it towards [) v 16 the end. The containment sump, I think we've hit most of 17 it. But, this one, containment atmosphere hydrogen, 18 containment atmosphere oxygen, we consider acceptable to 19 eliminate from PASS, because there's a hydrogen monitor, 20 which can provide the real time indication, which is really 21 what we want. 22 DR. WALLIS: How did oxygen get in here? 23 MR. O'BRIEN: In Reg Guide 1.97, I believe it was 24 for BWRs. But when I was looking through it, it was, also 25 -- when I was looking through the list, it was, also, PWRs. l
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9 i l i 125 1 Why, it doesn't make sense. ( . \g) 2 MR. SNODDERLY: It's a more important parameter 3 for BWRS, but I think they just included it for both. 4 DR. POWERS: I'm sure that the argument -- I'm 5 sure that the arguments went this way: if there's a lower 6 limit on hydrogen combustibility, on oxygen, as well as 7 hydrogen, and somebody said, wei' maybe we better find out 8 whether there's oxygen here or not. 9 DR. WALLIS: Where is it going to go? 10 DR. POWERS: It's affected by lots of things. 11- DR. WALLIS: A lot of it gets sucked in to make a 12 difference? 13 DR. POWERS: Yeah. 14 MR O'BRIEN: Containment sump boron, we find it 15 acceptable to eliminate from PASS and it's really the same (~
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16 rationale as provided for the RCS boron, for other 17 indicators, and also estimation for the knowledge of 18 sources, water additions to the sump. 19 DR. WALLIS: Now, what is the estimated? Does 20 this mean someone has to actually go and make a calculation, 21 or is it something that is easily predicted in automatic 22 way? I'm concerned about people making calculations all the 23 time of these things, when they're trying to manage an 24 accident. l 25 MR. O'BRIEN: I don't' know if you can address (~T ANN RILEY & ASSOCIATES, LTD.
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l 126 1 that, because this is really Lambrose's area, more than (gT 2 mine. But, if you don't have better -- 3 MR. SNODDERLY: I'm sorry, Graham, could you 4 repeat the question? 5 DR. WALLIS: It seems to me that when -- there 6 were several times you said people can estimate by, I don't 7 really think these people should be asked to make 8 calculations -- 9 MR. SNODDERLY: Yeah, Graham -- 10 DR. WALLIS: -- unless it's automatic. I mean, it 11 should be fed into a computer and out comes the information 12 they need, not -- someone shouldn't be off in a corner 13 making calculations. 14 MR. O'BRIEN: The main issue is whether or not () 15 there is a low boron level, not exactly, you know, what is 16 the ppm. What went in the reactor was at higher levels than 17 what is, you know, in your reactor to begin with. So, yeah, 18 boron going in, which is at a high concentration, and it was 19 already -- 20 DR. WALLIS: But, you said boron is known from 21 something. 22 MR. SNODDERLY: Yeah, I was just -- that's what I 23 was going to try to address. 24 MR. O'BRIEN: I was going to tell you that's 25 probably the better way to put it. The source is -- and i f'T ANN RILEY & ASSOCIATES, LTD.
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L ? 3 li 127 1 this is really meant to be there, in case you had to put it (~) 2 non-borated sources, that you can estimate it if you had -- j
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3 if you did that. 4 MR. SNODDERLY: I guess, Graham, what my 5 understanding is that your key boron sources are going to be 6 your reactor order storage tank and your accumulators. And 1 7 you know their volumes, you know the sump volumes, and a lot i I 8 -- so, your accident management guidelines and, perhaps, Mr. l l 9 Bice can help us here, that that's all precalculated and { 10 done ahead of time, so that you'll know -- you know how much 11 boron you have, you know your RCS volume and all your 12 accumulator and tank volumes and you know what level that 13 would correspondent to in your containment sump. And any 14 level greater than that would -- therefore, would have to IT V 15 have come from additional sources, and you assume it would 16 be diluting that boron and that's precalculated. Is that 17 the case of calculation, the way it exists? 18 MR. BICE: That's true in the case where -- in 99 19 percent of your cases, where you've got boron being injected 20 through the safety systems, whatever, if you had one of 21 those outlying events, I guess, where you had diluted water 22 going in, steam generator back flow issue, and a blackout, 23 it would be really far-fetched. We have people on the 24 emergency response organization assigned to do nothing but ' 25 calculations. That's their own function in life. It's not O ANN RILEY & ASSOCIATES, LTD. (_,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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128 l L 1 like you're taking away the emergency response, because I 2. l b) 3 you've now got this engineer sucked up doing this calculation. That's his job, to support operations and to 4 perform those calculations. So, it's not an unusual burden 5 that we don't expect to see. 6 DR. WALLIS: Those calculations are performed 7 under hectic conditions and often have errors that slip into 1 8 them. 9 MR. SNODDERLY: Dave, could you help us -- for l 10 ANO, is that done ahead of time, because I know at other l 11 plants, it is done ahead of time? In other words, 12 containment sump levels, according to -- like RCS volume 13 comes to x level, plus reactor storage tank takes you to x 14 plus y level, and so you know all that is precalculated. () 15 16 MR. BICE: Yeah. All I was saying was that if you had a dilution source also in there, that that, of course, 1 17 wouldn't be precalculated, because you weren't expecting 18 that. j 19 MR. SNODDERLY: True. 20 MR. BICE: And you might have to set -- if you 21 wanted an exact number, you would have to sit down. But, 22 the dilution is going to be so low -- the RCS volume is 23 actually so low, compared to the massive amounts of RWT 24 water, surge tank water that's going in there, that you can 25 pretty much say whatever it was in the RCS is nil. I've ] ('%) . ANN RILEY & ASSOCIATES, LTD. I
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U i n i n ', 129 1 basically got 2,500 ppm in there. Well, you just use a
~) 2 quick concentration calculation for that. I don't know if I
-(V 3 -- 4 MR. SNODDERLY: That -- I believe -- sorry. 5 DR. WALLIS: Well, I think the proper -- I'd like , 6 to see-something more like, you know, baron is accurate -- 7 is sufficiently accurately known or something, rather thne 8 estimated in this way. That's all. 'I'm just trying -- I'm 9 looking for reassurance. 10 MR. SNODDERLY: That's a good point. And I was 11 just trying to assure you that this is something that has 12 been thought of ahead of time and well known. 13 MR. SIEBER: Well, the fact, though, is that you 14 have other means of determining how close you are to ( ) 15 criticality. For example, you do have instrumentation -- 16 CHAIRMAN KRESS: Which is why you want boron -- 1 17 MR. SIEBER: Yeah. And boron is not a direct 18 measure, because if the core reconfigures itself in some 19 way, who knows what the shutdown margin is after that. 20 DR. POWERS: It's the ultimate instrumentation 21 that makes the difference here. 22 MR. SIEBER: Right. 23 DR. WALLIS: Using the core as the instrument? 24 [ Laughter.] l 25 MR. SIEBER: One portion of it. l
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130 1 DR. WALLIS: It's a pretty expensive instrument. 2 DR. POWERS: ~Not for this application. 3 MR. O'BRIEN: Next is containment sump chlorides, 4 which.is combined with the ph. There's a grouping here, but 5 I believe there are two to three issues, as far as 6 chlorides. The reason that we find it acceptable to 7 eliminate containment to sump chloride measurement is 8 because they can be estimated from the chloride content of 9 incoming water. 10 DR. POWERS: I find that stunning, since the 11 chloride content or incoming water must be pretty low. I'm 12 sure that just the contamination that comes about from other 13 sources must be h dominant source, as well. 14 MR. O'BRIEN: Maybe better put is that it -- maybe () 15 16 I'm going beyond where my expertise or knowledge is at -- is that the chloride is important for stress corrosion cracking 17 and at those levels, we can estimate it, if it was going to 18 be of a concern. 19 DR. POWERS: That understands why -- I mean, I 20 understand the chlorides stress corrosion cracking. Now, 21 why you're concerned about stress corrosion cracking is a 22 little beyond me, at this stage. But, it seems to me that 23 to say I can estimate how much chloride is in the water, 24 because I know what the content of incoming water, 25 especially into the sumps, I would just assume that the ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
~ i 131 1 contamination sources would be a huge concentration in the
/\ 2 incoming water. Sweat from all the workers that have beea U
3 down there, chloride that just contaminates everythin~ Known 4 to man down there, it would be a much bigger source of 5 chloride. 6 MR. SIEBER: When you look at the safety 7 evaluation report, which is MA-5661, for this, it talks l 8 about brackish water, seawater plants, and I think that if 9 you have a -- 10 DR. POWERS: Seawater would bring in chloride. 11 MR. SIEBER: It would bring in chlorides big time 12 and I think that that's really what they're talking about in 13 the slide, as opposed to, you know, fresh water or sweat. 14 DR. WALLIS: How much water are they concerned () 15 16 about? If it's swea.t from workers, it may be absolutely minuscule, really unimportant, compared with something like i 17 seawaters. I don't know the order of magnitude of the 18 content you're worried about. ! 19 MR. O'BRIEN: That comes in NUREG-0737, when it 20 required you to do this. And I don't remember exactly, but 21 it had -- this was a 24-hour sample, taken after 24 hours, 22 and it depended on the type of plant, whether it used 23 brackish water as its chlorine source and whether it had a i 24 single barrier to introducing that water into the 25 containment or if there was a -- ANN RILEY & ASSOCIATES, LTD. { Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
E l 132 1 MR. PARCZEWSKI: Presently, I think it's required [~h 2 to take 24 hours, if it is brackish water. If it is normal N~ Y 3 water, it's 96 hours that's required. 4 CHAIRMAN KRESS: I have a question similar to 5 Mike's: if you had that information, what would you do with 6 it, if you measured the chloride? If you had to measure it, 7 what would you do with it? 8 DR. POWERS: It's real simple, what we do is the 9 trisodiumphosphate we've got in there, instead of putting 10 them in boxes, we'll put them in little silver jackets -- 11 CHAIRMAN KRESS: And let it eat the way through. 12 DR. POWERS: Yeah. We've got a solution here. 13 CHAIRMAN KRESS: I really don't know why we're 14 measuring it.
) 15 DR. WALLIS: What is the answer to this?
16 MR. O'BRIEN: Well, I think the answer -- I think 17 Kris said, it's a concern with the phs. The stress 18 corrosion and cracking is a function of the ph. 19 MR. PARCZEWSKI: Yes. 20 MR. O'BRIEN: Therefore, you control the ph. 21 MR. PARCZEWSKI: But the stress corrosion cracking 1 22 is not there. 2? CHAIRMAN KRESS: But, it goes back to stress 24 corrosion cracking. 25 DR. WALLIS: How long does this stress corrosion [3 ANN RILEY & ASSOCIATES, LTD. (m / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I
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133 l 1 cracking take? 2 DR. POWERS: Well, stress corrosion cracking -- 3 CHAIRMAN KRESS: Goes pretty damn fast. 4 DR. POWERS: Yeah, a very fast process. 5 MR. SIEBER: Right. 6 DR. POWERS: But, why I would be terribly 7 concerned about it, when I know the amount of core. 8 DR. WALLIS: It's going to crack. 9 MR. SIEBER: Yeah, and the stress is much reduced 10 when it's shutdown. 11 DR. POWERS: Yeah. It does seem simple now. The 12 levels'of chloride that you need, very normal operation, you 13 can get enhanced at fractions of a -- 14 MR. SIEBER: That's right.
! 15 CHAIRMAN KRESS: Absolutely. But, that's 16 controlled during normal operation.
17 DR. POWERS: I mean, that's why we keep -- that's 18 why we keep the chloride content in coolant water and it's 19 for long periods of time. 20 CHAIRMAN KRESS: So, we don't agree with your 21 rationale, but we agree that you don't need it. 22 DR. POWERS: We don't agree with the requirement. 23 CHAIRMAN KRESS: We don't agree with the l 24 requirement. 25 DR. WALLIS: This is only preliminary. In your i l ANN RILEY & ASSOCIATES, LTD.
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n 134 1 1 final findings, you've got to clear this up to make it more 2 obvious what the logic is.
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3 MR. PERALTA: We're talking about pmi action 4 items, going back to NUREG-0737 and Reg Guide 1.97. What is i 1 5 the connection of the interface there between the two? And 6 for example', in the case of ph, how is that parameter 7 categories in Reg Guide 1.97? 8 MR. O'BRIEN: I'll let Kris -- you focus on that. ) l 9 MR. PARCZEWSKI: Well, the -- 1.97 requires taking 10 the ph. I 11 MR. PERALTA: How would they - they have 12 different categories for the significance -- from the safety 13 perspective, they have different categories: one, two, 4 14 three, and so forth. () 15 16 CHAIRMAN KRESS: MR. PERALTA: I think it's -- I think it's C category. I don't 17 remember exactly, but explain as to how -- why the 18 importance of it. What is the critical significance of 19 measuring ph? 20 CHAIRMAN KRESS: Now, is that outlined in 0737? l l 21 MR. PARCZEWSKI: I don't remember, j 1 22 MR. PERALTA: Well, it's outlined in Reg Guide 23 1.97. 24 CHAIRMAN KRESS: 1.97. 25 MR. BICE: If I could interject real quick, having l l 1 ANN RILEY & ASSOCIATES, LTD. l \ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 I Washington, D.C. 20036 (202) 842-0034 h L n i !
l l i i 135 i i done the ANO submittal, myself, I'm 99.9 percent sure that i 2 all categories for the very low, you know, need, except for ! 3 boron. That was a brave, that was "B" for bravo for that 4- one. 5 MR. O'BRIEN: Yeah. The categories, I don't 6 think, sir, so much as safety significance as use, also. 7 For instance, category D was for accident assessment and 8 it's not necessarily safety significance. And the other 9 categories, maybe mitigation, were more direct. So, I'm not 10 sure safety significance is the correct -- 11 DR. WALLIS: Do you have a safety significance 12 meter? 13 MR. O'BRIEN: Yeah, this was a type E -- the ph 14 was a type E -- type E. And, unfortunately, I just have a (d
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15 bit of the document, so I don't have exactly what that -- 16 DR. WALLIS: This type E is someone's -- what's 17 the measure that puts them in the various categories? 18 MR. O'BRIEN: Yeah, for instance, this is release 19 assessment and it has to do with what that parameter was to 20 be used for, whether it's accident mitigation and other -- 21 other. 22 MR. PERALTA: Your safety, do you even address 23 . that? Do you go back to and discover what the intent -- the 24 purpose was and why this is not significant? 25 MR. O'BRIEN: We can improve the safety evaluation ANN RILEY & ASSOCIATES, LTD. Os ; Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
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I { f 136 1 and make sure that's in there. I know I addressed that, at /' 2 least in part, in the -- for the radio nuclide, where we k 3 said it was.used for accident assessment in the safety f4_ evaluation, and that was a reflection of this. So, we can 5 do that and address it for each of the issues. 6 MR. PERALTA: I think it would help. 7 MR. SIEBER: The safety evaluation is more 8 complete than the slides are. We're being mislead a little 9 bit. 10 CHAIRMAN KRESS: Yeah, we're given a summary. 11 MR. SIEBER: Yeah. The slides don't say 12 everything that the safety evaluation does. 13 MR. O'BRIEN: Yeah, I think what I'm finding out 14 is-it is probably more that I need to put on the slides, so 15 that these discussions are a little bit clearer or answered I [J) 16 up front and I'm more succinct on them, because I'm not 17 guessing what I wrote. 18 DR. WALLIS: We had the discussion earlier today 19 about the level of sophistication of the licensee submittal 20 ' compared with the level of sophistication of the staff 21 evaluation. I'm not sure that I get a wrong feeling here 22 that the staff knows more about this than the licensee and 23 is, therefore, in a good position to be sure that the 24 licensee has covered everything. If you're scrambling to 25 keep up with the licensee, that's not a good situation to be l ANN RILEY & ASSOCIATES, LTD. gg/ g'_, l Court Reporters
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137 1 in. /\ 2 MR. O'BRIEN: yeah, I would agree with that b 3 totally. 4 DR. WALLIS: I would like the assurance, whenever 5 this comes around again, that you're really on top of that. 6 MR. O'BRIEN: Well, I think part of the problem -- 7 maybe not part of the problem -- but part of the issue is 8 that we have more than one reviewer, as far as this. So, it 9 may sound like I'm not -- and I will fully admit, I am not 10 an expert in all of these areas. And another that I would 11 also add to the confusion is two factors, that there's not a 12 lot of documentation when it comes down to the Three Mile 13 Island action items on what exactly the purpose is. It's 14 very succinct. We are making assessments, based upon j () 15 16 history and knowledge of where we are today and it's not as complete as we would like it to be. But, we'll take that 17 into account. 18 Okay. The reason I mixed up slides, besides to 19 cause confusion, was to kind of break this presentation into 20 more on-site issues and then try and maybe focus on off-site 21 issues a little bit, which is more my area of 22 responsibility. And I kept this one last, because it 23 contained the sump, which kind of -- which torders on the 24 off-site issues. I think we talked about that already. I 25 wasn't going to speak to that, at this point right now, but ("% ! ANN RILEY & ASSOCIATES, LTD. (_) l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 2 84 - b3 l 1 ,
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!i n i 138 1 I just wanted to bring that up that we heard on this issue 2 already.
(~)) \_ 3 Is there anymore we need to talk about on 4 containment sump ph? 5 CHAIRMAN KRESS: I think we've covered it pretty 6 well. 7 MR. O'BRIEN: Okay. But, we do consider that as 8 also an off-site issue with the revolvization, and that's 9 why I wanted to -- it's kind of maybe a better order to put 10 my presentation -- break it up, so this is the last issue, 11 because it kind of goes from on-site to off-site. And I 12 think in some respects that that hasn't been completely 13 addressed in some of the submittals and issues. It is 14 addressed, but I think there's a lot of -- there's a lot of /% 15 (J) sensitivity to this issue. 16 One thing, and I step back and I think about the l l 17 -- what is out there in a nuclear power plant that can 18 affect the public. It's radionuclides. 19 CEAIRMAN KRESS: Your job is to worry about l 20 radionuclides. 21 MR. O'BRIEN: It's radionuclides. And we think 22 it's important to be able to assess that and be able to 23 sample that. Maybe it's just ascetic, if you can't say, 24 well, how exactly will you use it. Well, you've got a tank, 25 you don't know what's in it, but now you cut off the pipe ANN RILEY & ASSOCIATES, LTD. [^'/ (s s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
U f 139 1 that said'you could sample it. ' /} V 2 DR. WALLIS: I thought the folks in the emergency 3 response center here and they've got the reporters, who are 4 beating on the door, saying what's going on. 5 MR. O'BRIEN: Yeah. l 6 DR. WALLIS: They want answers to certain 7 questions. They're not the same questions as the guys 8 managing.on-site have. 9 MR. O'BRIEN: That's correct. 10 'DR. WALLIS: And they may be asking questions ) 11 about the things you were just proposing to do away with. 12 MR. O'BRIEN: Correct. And that's why we wanted 13 -- we want to take all of that into consideration. We think 14 there are -- when you think about -- () 15 16 DR. WALLIS: Have you looked at that? Have you gone into that situation with the people here, what kind of 17 questions they're going to ask? l I 18 MR. O'BRIEN: Yes. In fact, I'm a member of the 19 team that asks those questions. 20 DR. WALLIS: You're not going to ask questions 21 that cannot be hnswered? 22 MR. O'BRIEN: Well, they're alJays going to ask 23 questions that can't be answered. 24 DR. WALLIS: They can be angry, because they don't 25 get the answer. l l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
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f b H 140 1 MR. O'BRIEN: 'And they will always be angry at 2' that, too. So what we want to do is we want to make sure 3 that we have an informed decision here, so we're including 4 these parties in our decisionmaking. That doesn't mean ! 5 necessarily this capability must be -- 6 DR. WALLIS: Has someone from the emergency response center or tem or whatever have signed off on your 8 proposals here to do away with these measurement? 9 MR. O'BRIEN: We have not -- we have not -- the 10 safety evaluation, we have not proposed that, at this point. 11 But, yes, we have involved the emergency response center in 12 this analysis. Specifically Rick Castleburg was one of the 13 guys involved in this. ) 14 DR. WALLIS: And they don't have any objection of 15 you doing away with these measurements? j 16 MR. O'BRIEN: No , they have not. 17 MR. SNODDERLY: It is clear -- 18 MR. O'BRIEN: We're not necessary proposing, at 19 this point, to do away with that. j l 20 MR. SNODDERLY: Yes. Is that clear, Graham? l 21 Right now, the present SER is not granting them to allow to 22 remove the radio nuclide capability. We don't agree with 23 their request. 24 DR. WALLIS: I got the impression you were going 25 along with them. ANN RILEY & ASSOCIATES, LTD. \ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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'l CHAIRMAN KRESS: no,. no, this one -- not on this 2 issue. They haven't made up their minds.
3 MR. SNODDERLY: Thank you, Tom, that's a better I I 4 way to -- l 5 MR. O'BRIEN: Yeah, this is one that, believe me, 6 I've heard four different sides to the story -- more than 7 that, and we're, also, interested in the ACRS's opinion on 8 this, very much so. Because, it's an issue that I think
'9 doesn't always come into -- is there something written down 10 that'you can point to and say, yes, you need that or is it 11 other issues, too. So, we're trying to explore as many j 12 issues that could come up in this and trying to put 13 ourselves in a position maybe when we were at Three Mile or 14 maybe next week if there is an accident, what information
() 15 would be -- would really be pertinent, trying to place 16 ourselves. And that's what we do all the time, being an EP. 17 Sometimes our existence is questioned, because there's never i 18 going to be an accident, right? But, we , in NRR, believe 19 that the defense in depth forces, and the only way you can 20 have defense in depth is to say -- our job is to say that it 21 . happened and what we would do to mitigate it. 22 DR. POWERS: This committee does not question the 23 value of that kind of approach and NRC being prepared to 24 respond more effectively. You never question that. 25 CHAIRMAN KRESS: Well, let me ask you a question ANN RILEY & ASSOCIATES, LTD, O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034
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N 1 142 1 on this. You have the high range radiation monitors in ("' 2 containment and you have the hydrogen monitors in 3 containment. How useful are those to you in determining 4 what range of fusion products are.actually causing the 5 readings you have there and can you decompose that into a 6 good guess as to what the composition of those fusion 7 projects might be, if those were the only two information 8 you had? Plus, you've also got the temperatures of the core 9~ and you know what went on to the core. 10 MR. O'BRIEN: We have an expert in that area. You 11 guys know Steve LaVie. He's the dose assessor, as part of 12 that emergency response team, and he just bellied up to the 13 table, so I think he wants to -- 14 MR. LAVIE: If we could do all of our assessments ll 15 in an equilibrium condition, it would be very, very easy. V 16 CHAIRMAN KRESS: What do you mean by an 17 " equilibrium condition?" 18 MR. LAVIE: Where the accidents progress far 19 enough along, where the nuclides have reached an equilibrium 20 situation in the containment, the assessment could be very, 21 very easy. 22 CHAIRMAN KRESS: I'm not sure whether -- 23 MR. LAVIE: Okay, I'll try to back it up. 24 CHAIRMAN KRESS: Yeah. l 25 MR. LAVIE: Without doing the numbers, and these 1 1 /~s ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I ;
E 1 I J 143 1 are very rough type of things, as I can take normal tech () 2 3 spec activity and dump it into the containment of a 1,000 gallons a minute and get a rad monitor reading, I could take 4 one percent core damage at 10 gallons a minute and get the 5 same rad monitor reading, okay. There's a multiple of 6 variables involved in that assessment. But the containment 7 rad monitor reading is not always the best indicator. 8 There was another example, where the staff is 9 concerned in this area, is about a year after the accident 10 at TMI, there was an event that occurred in one of the 11 southern plants, where they inadvertently cross connected
'12 their RHR system with their containment spray ring and 13 pumped -- I think it was 80 gallons reactor coolant into the 14 containment atmosphere. They had two high range monitors;
() 15 one. read 110 rem, the other read'10. Now, as an emergency 16 response manager, I would like to know which one of those 17 monitor readings is correct. Now, my release hasn't started 18 yet, so my spings and all my ethyl monitors, my ventilation 19 monitors are meaningless to me. I would like to have 20 information what's going on in that containment. 21 Now, I don't need to know the iodine out to two 22 significant places. But, I would like to know is iodine 23 there. So, the reliance on the containment dome monitor as 24 a high range monitor is not always well placed. They're 25 great instruments. I'm not saying to take them out. But, ANN RILEY & ASSOCIATES, LTD. Q(_/ Court Reporters 1025-Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 4
l a 144 1 they are one data point and the problem is, in some cases, (' N 2 you get two of them. There's an old Chinese proverb, a man i \s t 3 that has two watches doesn't know what time it is. And 4 maybe the PASS sample -- we'll be able to get a PASS sample 5 here,-usually that particular piece of information that lets I 6 you know whether the 110 is correct or the 10 is correct. 7 In that particular case, both of the monitors were 8 subsequently shown to be~ operating correctly. The gasses 9 stratified in containment. 10 CHAIRMAN KRESS: Does the PASS sample help you 11 any, because this may be another spot or two. Does the -- i 12 would the PASS sample resolve that issue for you? If you ! 13 took a PASS sample, you'd get a third number, which might -- 14 MR. LAVIE: That's correct. ! () 15 CHAIRMAN KRESS: -- determine all three of them. 16 MR. LAVIE: But, as an emergency response manager , 17 being asked whether or not I want to evacuate out to 10 I 18 miles, I'd like to have all the pieces of data I can get my 19 hands on. ; 20 CHAIRMAN KRESS: You'd like to know, before you 21 make that drastic step, wouldn't you? 22 MR. LAVIE: Right. And not all of these 23 evacuations are going to -- sometimes our emergency planning
- 24. mind set in the agency, and it's unfortunately, is to beat 25 to death with this time equal zero, other than breaks loose
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I" l l l [ 145 1 and happens. When, in reality, the progression of the l 2 accident is going to be much slower, and maybe you have time I [ 3 to keep that PASS sample. But.if the sample isn't there at 4 all, you can't get it. L 5 MR.-O'BRIEN: Just one point there to make sure it 6 is clear that, and I think it is in the safety evaluation -- 7 but to make it clear the initial protective actions that are 8 recommended by' licensees are done on plant conditions and 9 typically through our guidance two miles all the way around 10 and five miles downwind on either side of the plume with 11 respect to direction. It is after that that these samples j 12 would really become, perhaps come into the decision-making 13 process when they are trying to evaluate what is the 14 potential doses to the public. () 15 The_same thing is field team, but you take your 16 initial actions. Maybe your field teams weren't out there ; 17 yet, and then you play all that information into determining 18 whether those initial protective actions were adequate or 19 should be expanded. You are never going to reduce them 20 until well after everything is figured out but you may 1 21 decide that you can go forward on it. 22 MR. SIEBER: Let me ask Steve a question. The 23 difference between a direct atmosphere radiation monitor l 24 reading in containment in the PASS sample has to do with the 25 plate-out and the sample line. Can they be adequately i
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0 t 146 1 corrected or are they a function of what the material is, () 2 3 the age of it, and how do you do it? MR. LaVIE: Sampling iodine has always, as 4 mentioned earlier, always been a troublesome thing because 5 it.is so reactive. Maybe you won't be able to base it on 6 the containment atmosphere sample, but the other samples, 7 the iodine solution in the reactor coolant system is a 8 liquid sample. I don't think I am going to have as much 9 plate-out. 10 MR. SIEBER: That is true but the liquid is not 11 necessarily available for release so until such time as you 12 breach the containment one way or another and it becomes l 13 available for release, you really don't know what you have. 14 MR. LaVIE: True. If I am dealing with a () 15 situation like the example I mentioned earlier where you 16 have the two containment monitors giving you totally diverse 17 indications is if I could find out that my reactor coolant 18 activity is in the range of 1 percent, 2 percent, whatever, ) 19 then I have another datapoint that indicates that my 100 rem 20 monitor is reading right and that I perhaps now should be 21 considering perhaps extending the protective action. 22 As Jim pointed out, the initial action of course 23 is automatic based on plant condition, but is the two mile 24 or five mile downwind adequate? This is the decision I am 25 making now. ANN RILEY & ASSOCIATES, LTD. O( ,/
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I e 147 1 MR. BICE: If you all don't mind, I would just ("') L.) 2 like to interject from a utility standpoint, again this is 3 another datapoint. You don't know if it is good or bad. 4 Chances are there is a leak if you have got core damage 5 somewhere, and there's a 99.9 percent chance we are not 6 sending someone in the containment building to find out 7 where that leak is. We don't know where it's at. We just 8 know there is a leak, so now I am taking a sample off one 9 point and hoping that that is the right point and making a 10 protective action recommendation off of that -- that is just 11 as crazy as using any other single datapoint, so we don't 12 see the value where the sample is really going to say yes, 13 you definitely need to increase this power, you need to 14 decrease it, you need to evacuate here. It tells us n 15 nothing. (] ) 16 Sure, if we could go out and get 200 datapoints, 17 that is just more info. The more info the better. Nobody 18 can argue that. But where does the sensibility of it stop? 19 From the utility's aspect it stops right here to where the 20 radionuclide sample isn't any more confident -- you know, 21 doesn't provide us any more confidence level than anything 22 else we have already got and probably a little less than 23 anything else we have got, so do I want to keep this whole 24 system, spend all this money just to maintain a radionuclide 25 sample? Because you can do away with the chlorides and pH /~ ANN RILEY & ASSOCIATES, LTD. (s /T Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20s J (202) 842-0034 L _
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, 1 148
-1 and everything else. I still have to spend the same amount l
[ 2 of money to keep one sample so either we do away with all of 3 them or we still have it all and we have all the financial 4 burden. We still have all the people being used to go get 5 it, all the negatives we talked about, so I just wanted to 6 put that in, t l 7 CHAIRMAN KRESS: Let me ask you, while you are up
)
L 8 there, how comfortable would you be with using the high 9 range radiation monitors and the hydrogen monitors along 10 with all the information you have on the core temperatures 11 and pressures and how comfortable would you be in using that 12 to gauge what is in your containment and how much is there? 13 MR. BICE: Well, I think I would look at that more 14 from a response. What are we going to do when we find out () 15 16 anything is in there? To meet the general emergency criteria, we don't have to know what is in containment. l 17 DR. WALLIS: That's your problem, I know, but i 18 think of the person who is responding to the public. Here 19 are these television reporters asking someone what is in 20 that containment plume? 21 MR. BICE: The bottom line is going to be what -- 22 DR. WALLIS: He can't just waffle. He's got to 23 give some answer. 24 14R . BICE: Okay, so is it everybody's guess here 25 that an answer such as, "We believe we have damaged 5 l l ANN RILEY & ASSOCIATES, LTD. Court Reporters ' 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 ! (202) 842-0034 i
149 1 percent of the care" -- you know -- "we have got 5 percent 2 failed fuel" -- that's unacceptable? f~'} w_- 3 DR. POWERS: That is not going to help him at all. 4 He is going to say he wants to know should I -- 5 MR. BICE: So I am talking to an expert here is 6 what you are saying, somebody who knows about iodines -- 7 DR. POWERS: To a fairly knowledgeable person who 8 probably is not an engineer but a knowledgeable, rational 9 individual who has to make a decision on whether to send the l 10 kids home from school or not. 11 MR. BICE: Correct. 12 DR. POWERS: Okay? Now he knows he is going to 13 send the kids home from school and there isn't going to be 14 anybody there for them. 15 MR. BICE: At what point? What info is he looking [V) 16 for to make that decision, an iodine content? 17 DR. POWERS: He doesn't know. 18 MR. BICE: Exactly. 19 DR. POWERS: He wants to know whether he should 20 send the kids home from school or not. Now he is going to 21 ask you is there a significant potential for a radiation 22 release from this plant such that I should send the kids 23 home from school? 24 MR. BICE: And if we are going to talk potential, 25 I think we can say yes. I may not know how much, but I know [N ANN RILEY & ASSOCIATES, LTD.
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I l 150 1 the potential is there. 2 DR. POWERS: I think you answered Dr. Kress's i (} 3 question. 4 MR. BICE: And based on Arkansas, I'll just throw 5 this in real quick, Arkansas Department of Health responds
- 6 -for a full evacuation every time. Once we tell them we have 7 an accident, they are evacuating. They could care less what 8 the numbers are.
9 DR. POWERS: That's right. 10 MR. BICE: They are going to go conservative every 11 time, so they don't have the political ramifications a 12 utility has by doing that. They are going to failsafe. 13 DR. POWERS: I think that answered Dr. Kress's 14 questions. ( 15 CHAIRMAN KRESS: I think it did too. 16 DR. WALLIS: But it doesn't answer mine quite so 17 easily though. 18 DR. POWERS: That is not an unusual situation. 19 CHAIRMAN KRESS: Your questions are never easy. 20 What was your question? 21 DR. WALLIS: The NRC people have to be on ; 22 television if there is a major accident answering questions I l 23 from reporters who are quite sophisticated sometimes and 24 they are going to ask questions such as what is in that j 25 containment building. And what is he going to say? ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 200.36 (202) 842-0034 A
i 151 1 MR. BICE: Okav; but if we know what the /~' 2 radionuclide content is in the containment the best he could V} 3 say is we have'the potential of releasing enough radiation I 4 to cause a 10 rem per hour field at such and such a point. 5 It is just a potential. What will actually get 6 released he still doesn't know. 7 DR. WALLIS: The reporter has heard of iodine. He 8 is going to say how much iodine is in that containment? 9 DR. POWERS: They are going to say "a bunch." 10 MR. BICE: And once the leak occurs, how much gets 11 out. 12 DR. WALLIS: So he has got to have enough 13 information to answer those sorts of questions. 14 MR. BICE: To me for the NRC to step out and say () 15 we have the potential to release 500 rem of this stuff, or 16 this much iodine or whatever, is causing the public to panic 17 when you create the hole in containment. Not all the iodine 18 is going to get out and so they are going to have to be 19 political with their answer anyway. I don't think they wan 20 to give specifics. 21 DR. WALLIS: That spokesman is the person we 22 should ask. 23 MR. BICE: Well, that would be for sure. 24 DR. WALLIS: Is that spokesman going to be happy 25 with the kind of information he is going to get by doing ANN RILEY & ASSOCIATES, LTD. s_/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 a 1
l 152 1 away with the PASS system? I"') G 2 MR. O'BRIEN: Or she. 3 DR. WALLIS: Or she -- well, whatever, the person. 4 DR. POWERS: This man or his boss is going to be 5 the one to do it. 6 MR. O'BRIEN: Right now it's Chairman Dicus until 7 the new Chairman comes in. 8 DR. POWERS: We can go over and ask Greta when she 9 is comfortable and when she is not, eh? 10 DR. WALLIS: I think it is very important that she 11 is going to be made uncomfortable by some decision of the 12 agency. 13 MR. SCHNEIDER: Ray Schneider. Can I cut in for 14 just a minute? t
%j) 15 Regardless, even if you had a measurement, I mean 16 the thing is what you are measuring is -- you know, we are 17 estimating based on the radiation levels generally the 18 amount of iodine, and you want to or can turn that into, 19 well, based on the amount of iodine, did you fail a lot of 20 fuel rods or did you just fail a few fuel rods and melt them 21 thoroughly? This isn't going to tell you that either.
22 It will tell you how much iodine you have and you 23 are estimating generally that. You know that when you start 24 failing fuel rods you are going to have a lot of the noble 25 gases that are going to escape instantaneously with 5 /T ANN RILEY & ASSOCIATES, LTD. \s-) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L i
r, 153 1 percent of the iodine. That you know.
'N So the question is, well, exactly how many rods (J 2 3 have you actually failed? Well, in some cases if you ended 4 up melting a rod and not failing it, you really can't 5 tell with any sort of -- estimating 25 percent or 30 percent 6 releases of iodine -- but you know enough to take the l l
7 appropriate action to do the right thing and basically send ] 8 the kids home from school or do what you have to do to take 9 the right protective action. 10 I think that should basically give them enough 1 11 information -- ) I 12 DR. WALLIS: So we are just going through saying 13 all the users of the information will have enough 14 information with your proposal, because I don't want to IV I; 15 leave somebody out who needs some information he is not 16 going to get or she is not going to get because of doing 17 away with the PASS system. 18 MR. SCHNEIDER: We believe that you are not going 19 to lose the information -- or you are not going to lose 20 information that you would necessarily need. That is not to 21 say that there isn't someone who would want more. 22 DR. WALLIS: I am just asking who "you" is. "You" 23 is not just the people at the plant. Just make sure you 24 cover all the people who might need the information. I 25 MR. SCHNEIDER: Right. (~ ANN RILEY & ASSOCIATES, LTD. (_,h) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 I Washington, D.C. 20036 (202) 842-0034 c
i: i 154 1 DR. WALLIS: And you are going to do that when you I'N 2 come with a final recommendation? d 3 MR. O'BRIEN: Yes. Let me continue on here. We 4 will get to that point. 5 I think the limitations associated with PASS samples have already been discussed, and we have to agree 6 7 that there are limitations with these. Some of these you 8 might say were not intended previously because there were 9 requirements in NUREG-0737 for being able to take 10 representative samples for minimizing plate-out and so j 11 forth, but that being what it may be, I think those systems 12 are what they are out there, with their inaccuracies, with 13 the plate-out concerns and so forth. 14 Also the use of PASS information will be kind of 15 sequence-specific. Some sequences it may become more useful (N) 16 than others. I think that has been discussed also, where 17 your sample points are and so forth. There may be other 18 indicators that provide information more useful than PASS 19 given the sequence. 20 So that is the difficult part of the staff's -- 21 part of the difficult part of the Staff's work. We have 22 been working on this for a long time. It would be nice to 23 say we had a decision. That wouldn't take in your comments, 24 but I think we are getting closer. 25 DR. WALLIS: What more do you need to know before /) ( ,< ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
II v i 155 1 you reach a decision? What information would make the i 2 decision clearer in your minds? 3 MR. O'BRIEN: I think that the remaining piece of 4 information is -- let me get to the next slide and I'll f 5 promise to get back to that. 6 DR. WALLIS: You say you have been working on it 7 for a long time and you are almost there, so it must be 8 because something is perhaps lacking on it. 9 MR. O'BRIEN: I don't think this is necessarily 10 going to be simply just a technical decision. There is a 11 lot of different inputs. 12 DR. WALLIS: You're going to bring in something 13 awful like individual judgment? x 14 MR. O'BRIEN: I hope it is not individual. I 15 DR. WALLIS: It's going to be a personality
,.J 16 decision? j 17 MR. O'BRIEN: To continue, I think the answer is 18 we, the Staff, are not expecting any additional information 19 to make our decision. I think it is just -- l l
20 MR. SMODDERLY: Jim, that's true. Let's go 21 through these slides. 22 MR. O'BRIEN: Right now we are considering options 23 for sampling criteria. The first one and last one -- the 24 first one is maintain what we have, the last one is 25 essentially -- I'm sorry. The third one is what CE is /^ ANN RILEY & ASSOCIATES, LTD. (,)) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i e! 156 1 recommending. /~' 2 The second one here is to relax the sample time U) 3 because the constraints in the exqple time, for awhile there 4 seemed to be the issue, not so much -- and especially with 5 Westinghouse -- it seemed to be the time rather than taking 6 the sample itself, so we're looking at that with the 7 capability to enhance field team capability to ascertain the 8 radionuclide concentration. 9 The fourth one is simply just eliminate the PASS 10 completely, all the other samples and everything, and that 11 is -- no ties or criteria on extra field team issues. We l 12 think that it is good to provide the spectrum here of what 13 we are considering. What we have done or are underway of 14 doing is -- to answer your question, the other piece of ( ) 15 information that we are looking to get is from the state 16 government organizations who would be responding to the 17 event, so we are informing the state government 18 organizations of these options and asking if they have any 19 concerns with these options, because those are the people 20 that will not have the PASS information. 21 DR. WALLIS: The applicant seems to claim that 22 PASS has no value, therefore it is a clearcut decision. If 23 you are dickering on this decision it must mean that you are 24 balancing pros and cons and maybe you are not quite sure how 25 to weight certain things. Is that the situation? /~N ANN RILEY & ASSOCIATES, LTD. kss Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
157 1 MR. O'BRIEN: Yes. 2 DR. WALLIS: Do you see values to PASS that you G 3 don't quite'know how to weight against the design and -- 4 MR. O'BRIEN: Yes. One of the main values of PASS 5 you can consider is this is a capability. Whether or not ! 6 you had any other requirements on it, just have the 7 capability. Forget the timing and everything else. You 8 have sample capability. 9 DR. WALLIS: If that's not justified, there is no 10 use for it and having a capability is hard to justify. 11 MR. O'BRIEN: I think that there is 12 justification -- well, that is where we are trying to get 13 to 14 I think part of it is can you tell me exactly what () 15 is going to happen during an event, who is going to ask 16 what. I don't know if that is true or not. I think you 17 have the capability to get this. You are going to get rid 18 of that capability and then somebody will ask the question. 19 Do we want that? Is that something you can sit there and 20 write that is the only reason we are going to have PASS. 21 DR. WALLIS: I think you can't do it on the basis 22 of somebody might ask something. You have got to look at 23 some specific person needing some specific information. 24 MR. O'BRIEN: That's correct, and what we think, 25 the information that is needed, and I will try and reiterate ANN RILEY & ASSOCIATES, LTD. Gi Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 158 1 that, has to do -- if we do it from a simple technical i b' / 2 perspective -- it has to do with protective action 3 recommendations to the public, which are based upon dose 4 consequence analysis after the initial public action is 5 taken, and that this information could be used to refine } 6- those dose assessments. 7 Now there's a lot of arguments to say that it will i
)
8 not be useful to refine those dose assessments, and that is 9 the technical discussion. 10 CHAIRMAN KRESS: Let me ask a question. You 11 mentioned that if you kept one of the PASS requirements, you 12 might as well keep them all because the same problem -- does 13 that comment also apply also if you were asked to keep a 14 requirement for the PASS just to sample from the containment () 15 16 and forget about the RCS altogether? MR. BICE: Just from the containment sump, you
'17 mean?
13 CHAIRMAN KRESS: Yes. : 19 MR. BICE: Basically it still uses the same piping , 20 once you get to the PASS system. The only piping you would ! 21 be bypassing is what is coming from the reactor coolant leg 22 itself going through the penetration room. The rest of the 23 system would still have to be upgraded, all the obsolescent 24 stuff replaced, the leaks, pressure control valves, whatever 25 you need. There is a pump down there, by the way, that /T ANN RILEY & ASSOCIATES, LTD. (,,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
[ i i i 159 1 pumps this up to the PASS system when you are taking an
- /') 2 atmospheric sump sample, because there is no pressure to
%/
3 drive it, so the costs are still going to be there. Maybe 1 4 you will save a hair on the costs. You know, I can't really 1 1 5 tell you how much, but --
)
6 CHAIRMAN KRESS: The aggravation and everything I l 7 else -- 8 MR. BICE: The aggravation is still there and j 9 again any information, any capability is -- you would almost 10 have to say it's good even though it could cause confusien, 11 like Ray talked earlier, it may not always be good, but if 12 you have the cc.ibility, why get rid of it, so the question 13 is we can't really look at that because nobody can really 14 argue that. I) \J 15 Any time you have extra capability, keep it -- but 16 we are arguing is there a big enough benefit to keep it 17 based on the cost, the headaches, everything else that goes 18 into it, what is the real benefit of keeping it. 19 CHAIRMAN KRESS: One other question on that. The 20 equipment is all there and installed, right? 21 MR. BICE: Correct. 22 CHAIRMAN KRESS: When we talk about eliminating it 23 here, are we talking about jerking out the equipment and 24 throwing it away or just stop maintaining it and stop 25 testing it? ,/~h ANN RILEY & ASSOCIATES, LTD. (,,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 a U i
F l
!! i 160 1 MR. BICE: Now I can't speak for all plants.
) 2 Really it costs money to take something out of the system, l 3 so generally most plants I believe are going to leave it in 4 place. However, if it-hasn't been leak checked, if it 1 5 hasn't been maintained -- 6 CHAIRMAN KRESS: You can't rely upon it. 7 MR. BICE: -- they are not going to use it. You l 1 8 will never convince us to use it because we assume we will 9 be dumping water somewhere -- 10 CHAIRMAN KRESS: Might as well take it out, in 11 other words. 12 MR. BICE: Right -- so it shtaldn't be any 13 difference from this aspect. 14 MR. SIEBER: I am curious about one question. () 15 16 I looked on page 3 of the Owners Group Report. has a table of cost and most of these arguments are based on It 17 this and it talks about anticipated short-term capital costs 18 for upgrade and then the footnote says Y2K upgrades and 19 replacing aging equipment and ANO 2 seems to have $580,000 20 for ona unit, $830,000 for the second one, which is 21 outstandingly higher than everybody else. Is something 22 wrong with your PASS system that those costs are so high? ) 23 MR. BICE: What we have got at ANO is we have got i 24 two duplicate main mirrored PASS systems. They are both 25 exactly the same even though they are two different types of ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 n b.
F , 161 4 l 1 plants. Some of the stuff is shared. Some of the computer i L 2 hardware and stuff can be shared -- you know those things (J"'i j 3 all go into one RX computer and that sort of thing, so you l l 4 don't double the cost, and where you get into the l ! 5 obsolescence issue is u_most everything at ANO is obsolete
]
6 right now -- the pumps are obsolete, the valves are 1 j 7 obsolete, what in-line meters we have, like I think on 8 hydrogen, is obsolete, requiring constant repair. l l 9 On Y2K issues, when you get into that it is really i l 10 a work-around for ANO. The system will still operate past l 11 the year 2000 but we have to do a lot of manual staff to I l l 12 make it work, like all the dates on your printouts are going 13 to be wrong -- silly stuff like that -- but it since it is l 14 an official document you have to spend a lot of man-hours to l () 15 correct that stuff, so Y2K, no, we don't have to go fix that 16 but obsolescence is a huge issue for both units. 17 MR. O'BRIEN: I can wrap up and then field further 18 questions. Essentially we agree with the Owners Group that 19 it is acceptable to eliminate the PASS sample capabilities 20 for the samples that are listed there, essentially 21 everything except for radionuclide sampling in which we are 22 considering the four options which I discussed and that we 23 are coordinating with FEMA and with the state emergency 24 response organizations to inform them of those options that l 25 we are considering to see if there is any impact that they
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l i 162 1 .see on their emergency response. () 2 3~ CHAIRMAN KRESS: from the committee? Do you have any other questions I 4' DR. WALLIS: And you are getting really good input l I -5 from the emergency response folks here? 6 MR. O'BRIEN: Correct. 7 DR. WALLIS: When you come back with the final 8 thing to us? 9 CRAIRMAN KRESS: We have these guys on the agenda 10 for the October meeting. 11 DR. WALLIS: It's very quick. You are going to 12 solve this in.two weeks? y 13 CHAIRMAN KRESS: They are probably going to have 14 the same issues but I was looking for my agenda because that s-(y) 15 is the next item on our agenda is to decide what we want to 16 have presented and how much to the full committee and the 17 full committee, it looks like we have about an hour and a i 18 half holding for this, and I am suggesting we divide that up 19 about 45 minutes to CE Owners Group and 30 minutes for the 20 NRR. I don't know if that is the right breakdown or not, i 21 but the question is that doesn't use all the time but it l l 22 leaves a few minutes for us to ask questions. i l 23 The question is what should we ask to be presented I I 24 l to the full committee? l l 25 DR. POWERS: It seems to me that it is useful to h ANN RILEY & ASSOCIATES, LTD. [~'l A-m Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L - [
Il Y 163 1 have the perspective that we got from the CE Cwners Group. ( 2 CHAIRMAN KRESS: Absolutely. 3 DR. POWERS: I think you have interrogated the 4 speaker closely and I was delighted with the presentation by 5 David Bice. I thought that was an excellent presentation, 6 but I think it augmented our understanding of the CE Owners 7 Group presentation, but I think that is the heart and coul
-8 of the application being made here, and l' think we have got 9 to schedule ANO on one of our plant visits so we can go down 10 and see what David does most of the time. He seems to know 11 the plant backwards and forwards.
12 But I think we have got a bigger challenge here. 13 It is clear to me from the presentations that were made by 14 the CE Owners Group and the WOG PASS systems have been () 15 poorly designed and maintained to provide the information 16 that was sought when the original requirements came down. 17 It is not entirely clear to me what the original intent was. 18 I think the requirements are in bad shape here, that maybe 19 they weren't to address either the emergency action levels 20 or the near-term accident management activities, because 21 they certainly aren't, and maybe that wasn't the real 22 intent, but it is clear to me that the technical 23 sophistication of the licensees is now such that most of the 24 uses of them that I could anticipate are satisfactorily 25 addressed by other means, so I think we have to go about ANN RILEY & ASSOCIATES, LTD. %_ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
E O , 164 1 this issue generally with the Commission. () V 2 They've got to really go in and look at these 3 requirements again and, you know, we should formulate a 4 response in a generic kind of format. I think the Staff 5 needs to go in and assess what they really wanted to get out . I 6 of those original requirements, decide whether they really l 7 need it anymore, and if they do need it, that kind of 8 information, it is information about the plant damage 9 states, the accident, and they should formulate the q 10 requirements in terms of the information they want and not 11 in the means by which the licensee should get it. 12 What I see here is every single thing that is 13 being asked is the licensee has done something, the accident 14 management strategy to get that information not using this
/~N i 1 15 PASS system. %/
16 Now the one area I have great differences with 17 ev rybody on is this pH business and the long-term iodine, 18 because, quite frankly, I do not believe the iodine 19 partitioning curve that was put up by the CE Owners Group. 20 I think that is a thermal curve. I don't think it takes 21 into account radiation effects. I don't believe pH 7 is 22 adequate for preventing partitioning of iodine. I think 23 that is a myth that comes from looking at thermal analyses 24 and neglecting organic iodide formation. 25 But nevertheless, there is a pH that will do that (T ANN RILEY & ASSOCIATES, LTD. \s ,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i l 165 1 and I think pH monitoring is not difficult to do. () s_- 2 I think that I liked what this speaker said, that 3 they need to look at what the other agencies had to say, and 4 I am not sure it is any value for them to come to talk to us 4 5 until they have that story to tell us about what they found { 6 out from the emergency response people on the information on 7 plant-damage states that they want. 8 CHAIRMAN KRESS: Do you think then having them I 9 come back to us in the October meeting may be a bit i 10 premature? 11 DR. POWERS Well, I think we can handle it with l 12 maybe a subcommittee chairman or a 10-minute summation. The ; I 13 last slide you used says the whole story, I think, that you 14 presented to us: Here are the things that we think are . 15 ( acceptable and here's what the issue is that we are pursuing 16 right now. I mean I think it is a very brief presentation i 17 but I think we as a committee need to go in, spend some time ) 18 ourselves -- maybe we can get Juan to help us here -- to go 19 back and look at what the rationale for the PASS was in , 20 -0737 and look at the rationale that arose in NUREG CR-4330 21 that said it was marginal to safety and prepare some advice 22 for the Commission generically rather than going through 23 these things one at a time, because it is certainly not 24 carrying out the original mission. 25 On the other hand, it looks to me like the ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i' i j
f- l 166 l' licensees have done -- have found some way to address all
.%p) 2 their needs that they anticipate they will have without '
1 3 using the PASS system, so the only outplayer is this -- the 4 player of what people need offsite for planning, scheduling, 5 and staging emergency responses. 6 I have a feeling that the kinds of questions that I l 7 those people are going to ask are not answered by the PASS, 8 that they are answered much more by the kinds of information 9 that the licensee is asking himself in his accident 10 management plan. Do you have radiation in the containment? l l l 11 Yes or no? Is the containment going to fail? Yes or no? l l 12 It is not do I have 10 percent of the iodine or 45 percent
- j. 13 of the iodine. They don't know. They don't care. They I l
14 want to know if they have got a problem they have got to 15 address and when. 16 CHAIRMAN KRESS: Let me say this. We have -- the l 17 Staff has before them a specific application. 18 DR. POWERS: That's true. 19 CHAIRMAN KRESS: And they have to act on it, and
'20 it's better not to wait too long. They are going to get all 21 the information they can. They have come to some 22 preliminary -- or some conclusions and it is almost like 23 yeah, we think you can eliminate this PASS for the CEOGs.
24 We are not quite sure yet about the fission products but 25 probably also there. C l ANN RILEY & ASSOCIATES, LTD. ( . I Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 i 4 I_
f ! l I 167 ) i 1 I agree with you there's a bigger issue. It is a (^} G' 2 generic issue. Do we need pH measurements? Do we need 3 radionuclide measurements of some sort? It is clear to me 4 that PASS is not going to give you either one of those and 5 it is not a good way to do it, so I am inclined to think we l 6 have two different issues. 7 One of them is the question of the need for PASS 8 in the CE Owners Group is one immediate question. The other 9 question is should there be some requirement for pH i 10 measurement and should there be some requirement for fission 11 product measurements that are different than what we now 12 have because the PASS just won't do it. 13 I tend to look at them as two separate issues, and 14 at this time I agree with you. I think we need to think 15 about it generically and decide on what to tell the [G 16 Commissioners, but at the moment I want to come down on the 17 one question -- what about the CE Owners Group request to 18 eliminate their PASS system? Can we act on that and can we 19 tailor the presentation that we need at the October meeting 20 to just address that issue, and then take up the other issue 21 as a separate thing, or are they intertwined? 22 DR. POWERS: Do we have a specific proposal from 23 the Staff that closes the issue or is it "yes, but" -- 24 MR. O'BRIEN: As far as the CE Owners Group? 25 One of the things as management level right now is () Aj ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 n N
R 168 1 a SER similar to the one you have'except that it holds in ! L 2- abeyance the radionuclide. It goes ahead and approves (} l 3 everything else. 4 MR. BOEHNERT: Westinghouse is in the same 5 -position, aren't they?. ; 6 MR. O'BRIEN: Correct. So it would be for both. 7 It says those other samples would be acceptable to be 8 eliminated'and that we are still interacting witn the state-9' organizations on the radionuclide. The idea for that was to 10- provide the licensees with relief that we feel comfortable 11 with right now. ! 12 The amount of relief-rmly not~be a'large amount, 13 from what we are hearing. I am not sure exactly -- i 14 DR. WALLIS: Not much relief, because they would () 15 16 still have to sample. MR. O'BRIEN: They would still have to sample. 17 There are some samples which I think are difficult. I know 18 that at Millstone they have problems with dissolved oxygen 19 <and went over some things to get rid of that sample in 20 itself, just because it caused them operational concerns. 21 It was a startup issue for Millstone, believe it or not, and 22 instead of being held up, they eliminated that, quote, "part 23 of the system." 24 CHAIRMAN KRESS: Are we convinced that sampling -- 25 when you sample with the PASS system you are sampling out of i ANN RILEY & ASSOCIATES, LTD. s_ Court Reporters 1025' Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i b
t i l f 169 1 the sump water. { 2 MR. O'BRIEN: Your PASS sample has three N-l 3 locations -- the sump water, the RCS, and the containment i 4 atmosphere, so there's three different locations. 5 CHAIRMAN KRESS: There is one spot in the 6 containment atmosphere the sample is from? 7 MR. O'BRIEN: Is it one spot? Okay. 8 DR. POWERS: Two out of three isn't bad. 9 CHAIRMAN KRESS: Not too bad -- one out of three 10 really is what that is. 11 Is there any consideration given to an option that 12 says we don't think this is a good way to determine fission 13 products in containment, either of these sampling with one 14 spot from the containment through a PASS system or from the () 15 sump, and you can go ahead and eliminate that if you do it 16 another way, and give them some options on other ways to do 17 it? Is that under consideration? 18 MR. O'BRIEN: Yes. I believe -- certainly if they 19 proposed something, if it is a better system it is a 20 no-brainer. That would be fine with us, but I think when 21 you border on those kind -- I don't know if there is a 22 system that would be better. 23 I know you have talked about the gamma monitors 24 and -- 25 - CHAIRMAN KRESS: And I had in mind you didn't l l
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i 170 l' sample,.you just flowed the containment atmosphere through
' /~'N. 2 it and had a readout.
U 3 MR. O'BRIEN: But this was all internal to the
'4 containment.
5 CHAIRMAN KRESS: All internal to the 6 containment -- not -- no sampling at all basically. 7 MR. O'BRIEN: I don't know if that would be 8 something -- it sounds expensive. 9 CHAIRMAN KRESS: It sounds like it would be 10 expensive, yes. 11 MR. O'BRIEN: So I ami sure that, 'you know, the 12 costs are already $80,000 a year for maintenance and I am 13 not sure how much for the capitals but -- 14 CHAIRMAN KRESS: And they already have the high r (%;) 15 range radiation monitors, which does tell you I think quite l 16- a bit. 17 MR. O'BRIEN: Yes, and we agree with that. There 18 is a lot of information out there regarding what would be 19 potentially available for release. This is just one extra 20 piece of information.
'21 CHAIRMAN KRESS: An extra piece of information.
i 22 Well, I think maybe we ought to concentrate on the CEOG l 23 request at the full meeting and in that case we would need 24- something of both of these presentations. i 25 We obviously can't use all of them, because we l l-l
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171 1 don't have that much time. I think you could almost do your 2 presentation in about 30 minutes if you shortened it a bit. 3 MR. O'BRIEN: Last time you gave me 10. 4 [ Laughter.) l 5 CHAIRMAN KRESS: I am going to give you 30 this 6 time. I think most of whac you say, you know, maybe you 7 want to fix some of your slides -- 8 MR. O'BRIEN: I think we need to work on our 9 safety evaluation and get it more succinct. 10 CHAIRMAN KRESS: This is what CEOG wants; this is 11 our conclusion; this is why. I think that was good, and if 12 you could maybe plan on that sort of presentation also. 13 I don't know what you do about the radionuclide 14 and the pH one when you get to them. I would save those for 15 the last two parts of your presentation. 16 As far as the CE Owners Group, maybe about 45-50 17 minutes' worth. Can you -- 18 MR. BOEHNERT: That's total time so -- l 19 CHAIRMAN KRESS: Total time. 20 MR. BOEHNERT: The total time is that. 21 CHAIRMAN KRESS: Can you condense your 22 presentation and basically get your message across as to why 23 you want to do this, why it is a real problem to you, and
-24 especially what you have in place to have the job done 25 without this -- the committee is going to be interested in ' /~' ANN RILEY & ASSOCIATES, LTD.
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E I fr i 172 1 why don't I need'this, because you have got it doesn't do 2 the job for you and you have got these other indicators that 3 are -- more timely -- I would stress this timeliness. I 4 would go into how you go-about developing the needs for the 5 protective action plans and the emergency response. i 6 DR. WALLIS: I would like a clear exposition of ; I l 7 who needs what information at what time in order to make the 4 8 decisions they have to make. 9 CHAIRMAN KRESS: Yes, that would be helpful. 10 DR. WALLIS: You can lay this out very clearly. I 11 think you can probably make a good case that you have enough 12 information now from other sources. You certainly have it. 13 The thing I am not quite sure about is whether there isn't l l 14 somebody else who is involved who has needs for information [ ) 15 who hasn't really been brought into the decision-making 16 enough. 17 You looked at it too much from your point of view. 18 The Staff looks at it perhaps too much from their point of 19 view. I like the idea of bringing in the states or other 20 people who may have different needs for information and make 21- sure they are covered. That is what I would like to see l 22 done. 23 It may well be this can be laid out clearly in the 24 time available. l 25 MR. O'BRIEN: We were hoping to get this i i l T ANN RILEY & ASSOCIATES, LTD. j
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i l j 173 . 1- information out to the states next week and we could i 1 2 certainly, if we don't hear back, we can at least ask them 3 at this Florida meeting if they have any early feedback and 4 get some feedback. I 5 CHAIRMAN KRESS: Yes. You are not likely to hear 6 back from them by the October meeting but you -- 7 DR. POWERS: They may need to scratch their heads 8 a little bit. 9 MR. O'BRIEN: That's probably true.
-10 DR. WALLIS: I would also like the assurance from 11 your own emergency response people -- really crystal !
12 clear -- that the information is there and there isn't going 13 to be something given up which has value. If it is given up 14' and it has value, I.would like an assessment of what the () 15 16 value is we are giving up. MR. PRICE: This is Terry Price from Palo Verde 17 again. 18 I know this came up several months ago about the 19 state regulators and we sent them not only a request but a 20 copy of the CE report, and they reviewed it and came back to 21 us and said they had no problem with the elimination of the
- 22 ' Post Accident Sampling System as we have it defined here.
23 CHAIRMAN KRESS: That's one state. 24 MR. O'BRIEN: That's a second one. Arkansas -- 25 CHAIRMAN KRESS: Arkansas had the same -- i i ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i L - [
I' l 174 1 MR. O'BRIEN: -- had the same thing. {
'2 DR. POWERS: It is not going to be a surprise to 3 me to find inconsistency here because I don't think they 4- asked that kind of question. They asked a different kind of 5 question. It is just not dependent on this kind of 6 information.
7 I think the key to it is the technical level of 8 . sophistication and the licensee has gotten much nigher than 9 it was in the time of the TMI. They have gotten to the 10 point that they can formulate responses that are adequate to 11 the state. Somehow we need to get this into this mix and 12 make sure that that is all true -- make sure the people 13 charged with planning, staging and scheduling emergency 14 response don't have some critical information need. () 15 I think it is universally true that the 16 sophistication level of the CE Owners is now high enough 17 that they have found ways to give the information probably 18 of adequate accuracy. 19 CHAIRMAN KRESS: And on a more timely basis. 20 DR. POWERS: Well, yes, and on a time scale when 21 they need it, too. 22 DR. WALLIS: You need that just to get public 23 confidence -- so when here is a requirement that came in 24 after TMI, seemed to make sense at the time, now knowing 25 what we know today doesn't make so much sense -- what is it u ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I i 175 1 that's happened in the intervening time which makes us more 2 confident today than we were then? 3 MR. O'BRIEN: And one thing to kind of interject 4 here, the issues that we are going to the state with are 5 just focused on radionuclides. 6 CHAIRMAN KRESS: Yes. 7 MR. O'BRIEN: I think if you send the whole 8 report, you are going to get buried in boron and 9 dissolved -- and this one I hope will focus it, and we 10 really are trying to place the blandest picture as far as 11 taking no positions - "This is what the NRC -- we are 12 providing them what we think are the facts and uses as we 13 see it and see if they have any concerns with any of the 14- options. 15 CHAIRMAN KRESS: I think that is the right way to 16 do it. ) 17 DR. POWERS: I think you have done the right thing 18 there. 19 DR. WALLIS: You've got a reasonably friendly 20 audience here. I think you ought to try to make your 21 presentation so that someone who sort of more hostile who 22 says "And there goes the NRC again, giving up some 23 requirement" -- you have got to make sure that you have got 24 good arguments there so that that person doesn't see some 25 weaknesses.
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I l l 176 1 MR. O'BRIEN: You're right. DR. WALLIS: So make it clear that you are making 2 3 the right decision to somebody maybe less receptive than we 4 are. If you can make that -- but then we'll certainly buy 5 it. 6 MR. O'BRIEN: Well, like I said, there's many 7 people involved in this and there are some people who are I 8 firm believere in the information and its use too, so I am 9 charged with' evaluating everybody's opinions in this, j 10 DR. POWERS: I think we can be confident that the , 11 people that came up with those requirements originally had l l 12 some rationale for it, but I think we can also be confident l 13 that times have evolved and new strategies have come up and 14 new understanding has come up and we shouldn't be reluctant () 15 16 to go back and change things. MR. O'BRIEN: Right. 17 DR. POWERS: Now the question comes up if our 18 strategy is to deal with CEOG Owners Group, and it sounds l 19 like it is going to be a letter a lot like the WOG letter -- ; 20 CHAIRMAN KRESS: Yes, that's what it sounds ! 21 like -- well, I suspect it is not even going to be -- 22 DR. POWERS: Well, maybe a little more histrionic l 23 in points, but I still think that we have a generic issue 24 here and I think we have got to ask the Planning and 25 Procedures Committee to come up with time to deal with the ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 i L_.
r 0 177 1 generic issue. I am not sure -- I think we will have to
, 2 check the various constraints on us, but I think we can 3 write the -- we can address the generic issue by ourselves.
4 I am not sure we need any more help. I think we have got 5 enough help here. 6 CHAIRMAN KRESS: I suspect that's true. 7 DR. POWERS: Again I think maybe Juan can help us 8 by going back to those two topical reports and pulling out 9 the salient information for us, but I think we need -- I 10 think we ought to get on top of this. I mean this 11 definitely looks like a set of requirements that needs to be 12 re-evaluated and at the very least made performance-based 13 rather than prescriptive. 14 CHAIRMAN KRESS: I agree. () 15 16 Okay -- is that enough guidance for you guys to come to us next October, the 1st of October? 17 MR. O'BRIEN: Yes. Just as a side point on that, 18 it's interesting to bring up the issue, is that there is 19 that item which was a NUREG item became codified for 20 advanced plants, and so when you talk about it generically 21 there's some regulatory aspects to it too. 22 CHAIRMAN KRESS: For advanced plants. 23 Well, with that, I am going to recess -- not 24 adjourn -- I am going to recess, because this subcommittee 25 continues tomorrow. ANN RILEY & ASSOCIATES, LTD. s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i i 1
1 i 178 l 1 (Whereupon, at 5:16 p.m., the meeting was
.O 2 recessed, to reconvene at 8:30 a.m., Friday, September 17, I \
3 1999.] 4 i 5 1 7 l 8 9 l l 10 l 11 12 13 14 15 16 l 17 18 19 20-21 22 23 24 I 25 l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 j 4 u [ , l
I
}
REPORTER'S CERTIFICATE This is to certify that the attached proceedings
} before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: MEETING: SEVERE ACCIDENT I MANAGEMENT l l l I CASE NUMBER: PLACE OF PROCEEDING: Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. ('y i { l,f\ \ ,' Y ()! '!. s Jon Hundley Official Reporter Ann Riley & Associates, Ltd.
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1 l O Relaxation of NUREG-0737 Requirements for Post Accident Sampling System 1 Ray Schneider ABB/ Combustion Engineering Owner's Group l Presentation to ACRS Subcommittee on Severe Accidents l l September 16,1999
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O l CEOG PASS Elimination Project l e Purpose o Background e Assessment of Post Accident Sampling System Requirements , e Conclusion l l l l gSTION ENGNEENNG OWNERS = := pma GROUP ABB O
1 Purpose Eliminate the post accident sampling system (PASS) in all CEOG plants:
. Remove PASS requirements from CEOG plant licensing bases
> Discontinue operation and maintenance activities on PASS components
> Identify alternative non-PASS equipment and procedures, as appropriate, to meet objectives USTION ENGNEERNG C.VNERS GROUP
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l Background l 1 Post TMI many changes were instituted to j improve plant post accident response and operator preparedness for beyond design basis events
- Improved Emergency Operating Procedures and j Instrumentation I
. Improved Operator Training in Beyond Design Basis events
. Implementation of a Post Accident Sampling System
. Introspective review for Severe Accident Vulnerabilities (GL 88-20)
> Implementation of Severe Accident management Guidance (completed December 1998)
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1 1 o V . Background (cont'd) i Post Accident Sampling System o PASS intended to acquire information supporting
> emergency response,
> accident management and
> accident recovery actions e Required sampling of reactor coolant chemistry and containment atmosphere parameters e PASS information to be used for core damage assessment u_.---.
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O a l l Background (cont'd) e Necessity for PASS requirement has been open question for decades:
. NUREG-CR-4330: intemal NRC review (1980)
- Recommended relaxation of several PASS requirements but tabled idea due to belief costs of maintaining PASS were not significant
- CEOG Submittal CE-NPSD-415 (1993)
- NRC concurred with use of safety grade containment hydrogen monitors to replace hydrogen grab sample & deleted pH requirements.
- NRC suggested extension of the boron sample time to 8 hrs was acceptable with neutron flux measurement
. PASS relief for System 80+ (1995) 1996 Nm.. Generic - , - - - letter
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on-- PASS relief A under discussion b O
I n/ 'y Why is CEOG Revisiting PASS Relief? e PASS information is not needed for accident management e Use of PASS iS not viewed as risk beneficial e System maintenance costs are high and rapidly growing l I l l STION ENGINEERNO OWNERS GROUP
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\v) Why is CEOG Revisiting PASS Relief? PASS information is not needed for accident management Overall Evrajation of Use of PASS within Accident Management Strategy Shows:
- PASS Measurements are too slow for decision making
- PASS measurements are not relied upon in EOPs
> Site Emergency Plans (EPs) can esti.blish EALs on area and site radiation levels, core exit ternperatures without using PASS
> EPs do not require PASS data for defining Protective Action Guidance
- SAMGs initiate Candidate High Level Actions (CHLAs) independent of PASS
- CEOG CDA methods can be based on in-plant instrumentation g3710N ENGINElmMG OWNERS :r===GROUP ABB
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r 1 1 O v l I l Why is CEOG Revisiting PASS Relief? e Use of PASS is not viewed as risk beneficial: 1 1
> PASS operation diverts resources away from accident management
- ALARA impact
- use of Pass results in significant post acodent doses RCS sample Nnes poses potenial for release of radiation in auxiliary building PASS usage may tirrut access to certain A8 roorns
> Due to limitations on sampling process, PASS data may misinform the operator; leading to confusion, and delayed or "non-conservative actions" l
STION ENGINEENNG OWNERS GROUP **'
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Why is CEOG Revisiting PASS Relief? i (cont'd) ; i i 1 e System maintenance costs are high and r9pidly growing: l
- surveillance, maintenance costs are high-$80 K/yr/ plant
> obsolescence issues increase repair, replacement costs
> resolution of Y2K issues require significant capital expenditures
- training on complex and obscure procedures
= integrated lifetime savings in excess of $20,000,000 for CEOG N% _... o_,_,
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1 O
I p i O CEOG proposes that the following changes l eliminates the requirement for PASS e Eliminate RCS Dissolved gas sample e Eliminate Sump pH sample e Replace Containment hydrogen sample with : RG 1.97 in containment hydrogen monitors e Eliminate Reactor coolant Boron sample e Replace Radio-isotopic sample with commitment for field team I-131 monitor i r Sump pH and Hydrogen monitoring changes were previously '
, f requested by CEOG'(CEN-415) and approved by NRC?
urnON ENGINEllWMQ OWNERS GROUP O RCS Dissolved Total Gas Sample Recommendation: Eliminate PASS reauirement e Originally intended to identify potential for non-a condensable gas in RCS e Sample has no role in accident management
. Non-condensable void elimination procedures rely on:
- teactor vesseljevel monitoringystem (RVLMS)
- pressurizer and reactor vessel head vents
. Not required for CDA e Pass requirements for total gas measurement not risk beneficial
. Sampling process poses risk of radiation release to AB
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(v-) l RCS/ SUMP pH Recommendation: Elimhiate Sumo oH sample l e Coolant pH impacts stress corros'on cracking and iodine retention. e pH of CE units well controlled. All units but one employs passive pH control sufficient to ensure long term pH >7 for post-accident conditions. Remaining plant has dual barrier CCW with known pH. I e Proposal to eliminate pH requirement for TSP plant granted in 1993. r-=
*110N ENGIMENNG OWNER, GROUP ' * " "
Agg O l RCS Boron Samples Recommendation: Eliminate Boron Samplina Recuiremej e Confirm reactjvity control duri:1g and following event e Delays in PASS implenientation prevent it from being used during the accident r; litigation phase of the event. o Operation t.,f PASS further restricts plant access during an accident. e Boron sampling is offered in the EOPs /EOls as one of several means to confirm reactivity control. Sampling least desirable j attemative due to radiation exposure and is not required for accident . mitigation. EZo,~e 1 q0 _ .._G _ , _,
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O l l
r l 1 [ . . I I l O 1 RCS Boron Samples (continued) Recommendation: Eliminate Boren Samolina Reauirement e Operator actions / decisions do not require boron sampling
. Actions in EOPs/EOls provide conservative boration guidance and procedures
. Significant boron dilution will be identified via addition of unborated/under-borated water sources. )
l . Hot leg sampling locations limit use; results may be misleading e Altemate reactivity control monitoring via Class 1E Neutron Flux meters used to confirm negative startup rate e if desired, boron samples may be delayed and/or obtained via the NSS for events with lower levels of core damage. U530N ENGINEERHeG OWNEAS GROUP
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- Containment Hydrogen Sampling l
Recommendation: Replace PASS sample with RG 1.97 H2 monitor e Containment hydrogen concentration used as an indicator for the amount of core damage and containment combustibility and therefore measurement capability should be retained. l e Containment hydrogen concentration can be adequately monitored via RG 1.97 hydrogen monitors (modification previously approved l by NRC). Most CE plants have previously implemented this option. e Hydrogen monitors
- Provides real time data that assists operators in Core Damage Assessment (CDA) long before a Pass grab sample could be collected and analyzed l = are adequate for assessing containment threat and CD
= are sufficient to support sAMGs
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I 13 U 1 Evaluation of Radio-isotope Sampling e NormalOperation , e Sampling of RCS via Normal Sampling System { e Accident management
. EOP Guidance / Actuadon Signals based on Safety Grade Containment High Radiation Area Monitors (CHARMe).
. SAMG uses all available equipment. CHARMe, vent monitors and site area radiation monitors used for radiation monitoring e Emergency Response
. Radiation levelet Reid samples used along with other indicators to estabilah Emergency Action Leveis (EALa); Radionucilde camples are not timely
. Protective Action Guidelines (PARE) Initlauy based on plant conditione. Longer tonn based on trending of CHARMe, Field Measuremente, etc.,
. CEOG Core Damage Asseeement poet-mortem uses a four pronged approach which considers CETe, and Hydrogen,aiong with CHARMS and Radioisotopee.
Qg ENGINEEmMG OWNER 3 Git 00P
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i Evaluation of Radio-isotope Sampling l Recommendation Replace containment radionuclide camole with a commitment to utilize I-131 field samplina. 4 e Radionuclide samples not relied upon in any accident procedure or guidance document l e Samples are untimely and will significantly under-estimate airbome iodine / cesium due to aerosol deposition and plate-out.
> Will lead to confusion and possible delays
> May lead to non-conservative actions.
> Use in CDA not likely to yleid useful results e Use of PASS results in additional exposure of plant personnel, limits plant access and diverts manpower from Accident Management e increases potential for radiation releases to the auxiliary building e Limited in usefulness.
ISLOCA and SGTR releases with non-PASS instruments and field (not assessed using PASS) ** - 5 USTION ENGINEEmWG 0WNERS GROUP O 1
O b Evaluation of Radio-isotope Sampling l e Therefore... Elimination of PASS Radioisotope Sampling Will Not Reduce Plant and Public Safety:
. EALs will be declared based on in-plant instrumentation and plant conditiem
. PARS are formulated via the use CHARMS and CETs.
Dose projections are established via analytical adjustments to ARM readings using site surveys, and vent releases. Field teams can be uniformly equipped with I
- monitoring capability (safety benefit) thus, increasing scope and capability of dose assessment for ag events.
. Staff post accident exposures will be reduced
. Core damage will be appropriately assessed without a radionuclide based CDA.
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O V CONCLUSIONS I e PASS not required in EOPs e PASS not relied on in SAMGs e PASS not needed to establish EALs e PASS not needed to establish short or long term PARS e PASS not used for re-entry e PASS can mislead and misinform o Recommendations to expand NSS limits and ensure 1-131 site survey capability enhances plant safety IIm i aC a____ m ac5?? Sbac0?g$$gg% ~ eg ma q0 _. e _...o _, _, er==
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