ML20244D625

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Transcript of 890411 Meeting in Palo Alto,Ca Re Improved Lwrs.Pp 1-286
ML20244D625
Person / Time
Issue date: 04/11/1989
From:
Advisory Committee on Reactor Safeguards
To:
References
ACRS-T-1729, NUDOCS 8904240038
Download: ML20244D625 (293)


Text

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O UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

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In The Matter of: )

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IMPROVED LIGBT WATER REACTORS )

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PAGES: 1 through 286 PLACE: Palo Alto, CA _ , _ _ _

DATE: April 11, 1989 4 i C e 'v 0 ) y N O ,l

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O HERITAGE REPORTING CORPORATION OficialReporters 1220 L Street, N.W., Suite 600 W4pon, D.C. 2M 890424oose 89042 PDR ACRS (202) 628-4888 T-1729 PNV

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f L 1 PUBLIC NOTICE BY THE l:

2 UNITED STATES. NUCLEAR REGULATORY COMMISSION'SL 3 ADVISORY COMMITTEE ON. REACTOR SAFEGUARDS i -

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'6 7- The contents of this stenographic transcript of the 8 proceedings of the' United" States Nuclear Regulatory 9 Commission's Advisory; Committee on Reactor Safeguards (ACRS),

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l'0 as reported herein, is an uncorrected record of the discussions 11 recorded.at the meeting held on.the above date.

12 No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or 14 . inaccuracies of statement or data contained in this transcript.

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-1 SUBCOMMITTEE MEETING' i, , 2 NUCLEAR REGULATORY COMMISSION 3

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'S- ACRS IMPROVED LIGHT. WATER REACTORS

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9 10 ELECTRIC PRODUCTS RESEARCH INSTITUTE 11 -CONFERENCE' CENTER

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3412 HILLVIEW AVENUE 13 PALO ALTO, CALIFORNIA 14-15 16 TUESDAY,' APRIL 11, 1989 17-8:30 A.M.

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1- MEMBERS '3 RESENT-

.2 .Charl'es J..Wylie, Chairman-

3' James: Carroll
4. William Kerr 5 STAFF PRESENT 6 Herman Alderman

.7 ~Les"Rubenstein.

8 Charles Miller

.9 Bill Long'

.10 David Shum 11- Ralph.Archizel' 12 EPRI:-

13' Gary Vine O 14 Bill Sugnet

'15 Joseph'M. Yedidia-16 Bruce N. Pusheck 17 ALSO PRESENT:

'18  : David Strawson 19 David Leaver

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'1 I N D'E'X.

., Page,

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Proce'edings' 1-l Opening Remarks'by Chairman Wylie. 1 ,

I Review and Preview of' Chapters'of the

'5 EPRI ALWR Requirements. Document-

6. -Dihcussion of Chapters 2, 3, 4-

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7. Discussion of actions resulting from  !

ACRS comments- 57- l

. 3-NRC. Findings.from Review of. Chapter 5 ,

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, Afternoon Session 10 Key. Issues'in Chapters Under' Current '

11 NRC-Lreview i

12 General Discussion I 1

.g 13 Adjournment ,

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Afternoon Session 157 Presentations - resumed 157 5

Overview,. Chapters 5.through 9 and 11 157 Chapter 6, Building' Design and' Arrangement. 158.

Chapter 7, Fueling and-Refueling' Systems 191 Chapter 9, Site' Support Systems .203

' Chapter , Electric Power Systems 221 Chapter 8, Plant Cooling Water Systems- 258

' Adjournment ,

286 Reporter's Certificate. 287 13 14 15 16 17 18

.19 20 21.

22 23 24 25 O

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'O. 9 P-R O C E E D I N-G S 2-000--

j 3 , CHAIRMAN WYLIE: The meeting'will.now come to L

order. This is a meeting of the ACRS Subcommittee on

-Improved. Light Water-Reactors. I'm Charlie Wylie, Chairman of the Subcommittee. Other ACRS members in-

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attendance are Dr. William Kerr. We_are expecting James Carroll to. join us lat'er;this morning. Mr. Herman Alderman is the cognizant ACRS Staff member for today's meetings.

l The purpose for.our meeting is to continue the 11

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12 Subcommittee's. review of the EPRI advanced light water 13 reactor requirements-and document a program and continue O o aieouseio ieu eae seeer e#a sen 1# reeera to eaet program.

We've had several meetings'over the past several years with both the Staff and EPRI, and had several presentations to the full ACRS Committee.

The Subcommittee last held a meeting with the Staff and EPRI on August 9, 1988, and prior to that meeting-we had received the latest drafts of the Staff's SER's on Chapters 1 through 4. We were briefed by the Staff at that meeting on their review of the chapters.

EPRI gave an update report on the program, and made presentations on the revisions to those chapters and O

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2 I a' presentation,on Chapter 5.

2

- At this. meeting,.'we had requested to be brought 3

up.to date,on the earlierichapers, any modifications, 4 improvements, rev)sions to.those chapters, and to be 5 briefed'on the review of Chapter 5. "'he SER on Chapter . 5 6 has not been made'available as yet.to the Subcommittee, 7 and we'll'look forward to'that.

8- Also, EPRI has been requested;t'o'give us an 9 overview on Chapters 6, 8, 9 and 12, and to discuss the 10 highlights of-those chapters.

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11 Tomorrow, or depending'-on h'ow the schedule goes, 12 maybe today, we've requested to be briefed on the status 13- of the severe accident issues for the advanced light water O .14 reactors, and EPRI's comments-on those issues.

15: Also, the EDO wrote to the Commission a SECY 16 paper of 789-013, in which the Staff position on design 17 requirements for evolutionary advanced light water 18 reactors was discussed, and we've requested the Staff to 19 discuss and' comment on those, and request EPRI's response 20 also.

21 We also requested EPRI to comment on the issues 22 related to the ACRS letter which was written on February

.23 of this year, on 10 CFR Part 52, regarding the issues 24 related to the certification of standard design plants, 25 which we raised in that letter. I think that's been made

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3-I aware to' Staff'and EPRI.

2 -3130,' it'.would be advantageous.to the 13 Subcommittee if both the Staff ~and EPRI could advise us -

-4. about the schedule, and what we,mipht anticipate as far as 5 the release of'. additional documents'and the Staff's review 6 and SER's on those, and what kind of progress might be 7 made to the revision to earlier chapters, such as 8 Chapter 1. As.I understand, it is undergoing-.an extensive 9 review andirevision.

10- .I see Mr. Carroll'has joined us, glad to.have 11 you.

12 And I'll ask now whether any of the Subcommittee

.13 members have any comments they'd like to'make before we O' 14 proceed further.

-15 COMMITTEE MEMBER'KERR: I have none.

16~ CHAIRMAN WYLIE: Seeing none, suppose we 17 . proceed, and I'll call on Charlie Miller of Staff tio lead 18 off.

19 MR. MILLER: Thank you, Mr. Unairman. Good 20 morning, my name is Charles Miller, and I'm the project 21 director for standardization for non-power reactorn in 22 NRR. I have the EPRI program under my Staff's review at 23 this time.

24 I'd like to introduce this morning those members 25 of the Staff that have joined me today for the O

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4 1, 'Sub' committee meeting. To my far right is Les Rubenstein,

.2. my supervisor.-- To'my immediate right is Bill Long, the 3 project manager for the EPRI project. And behind meEare 4- Ralph Archizel and Dave Shum from the plant systems branch 5' in NRR.

6 What I'd like to do this morning, Mr. Chairman, 7 is get started with discussion of a recap of of 8 Chapters.2, 3 and 4. We'll.then' turn.the progrcm over to 9 EPRI to make their comments concerning resolution of 10 comments that were made at previous Subcommittee meetings.

11 So without further ado, I'd like to turn the 12 program over at this time to Mr. Long.

13- MR.'LONG: Okay, we have a list of about ten 1 0 14 issues from Chapters 2, 3 and 4 that were outstanding, and 15 some additional discussion is available'from EPRI on these 16 issues. I'll indicate first what the issues were.

17 One of them was the 60-year plant life. The 18 next one was A-17 systems interaction and pressurizer 19 relief tank, reactor coolant pressure boundary, leakage 20 detection systems. Bolting degradation, use of PORV's, 21 reactor coolant pump seals, remote isolation of component 22 cooling water to the reactor coolant pumps and motors.

23 Reactor vessel thermocouple, and 60-year CRD life.

24 These are open issues in the SER's from the 25 earlier chapters.

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LO r j-Gary,'wo'uld you"like'to run'through them, or s

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would.you just;like me:to repeat what's.in your letter?-

.3 - MR. VINE: Our original plan was, I understood, 4 for you to'go through them and us to' respond'. But 5 whatever you're comfortable-'is fine'with me.

6 MR. LONG: Okay. 'I just received your letter 7= 'this morning, but we had discussed these earlier.

8 On the issue of a 60-year plant life, EPRI's 8' intention is to proceed to design the plant for 60-year 10 life, but only request a 40-year review from the Staff.

11 And this' means that we would not be',' in -our SER, be

~12- . addressing the. issue of what changes'are necessary to 13 support a 60-year license.

O. 14 .. We will review the plant as.though it was a 15 40-year application. Is that correct', Gary?

16' MR. VINE: That's correct.

17 MR. MILLER: Mr. Chairman, I'd like to make a' 18 comment.  ;

18 CHAIRMAN WYLIE: Sure.

20 MR. MILLER: I just want to remind everyone that 21 currently NRC is limited by legislation to issuing i l

22 licenses with a maximum duration of >0 years. The 60-year 23 life is an issue that's been discussed in quite a bit of 24 detail recently, and there have been some misconceptions.

25 I just wanted to make that point, because I had  !

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to reiterate many times that we are limited to a 40-year 2 ' life. That doesn't mean that the' Staff-would not 3' entertain reviews for 60 years, but before NRC could issue

4. a license'for.more than 40 years, legislative changes 5 would be needed.

6 COMMITTEE MEMBER KERR: Just for my information, 7 can'somebody-give me-some idea of.how many 60-year-old '

8 generating plants,are now operating in'the U.S.? Of any 9 kind?

10 FROM THE AUDIENCE: You mean fossil or nuclear, 11 or-just --

12 COMMITTEE MEMBER KERR: Any kind of electrical 13 generating plants that'are 60. years old. I mean, is it

'14 one or ten, or_300 or --

15 CHAIRMAN WYLIE: Fossil plants, Bill, or --

' 16 COMMITTEE MEMBER KERR: Any kind of electrical 17 generating plant.

18 CHAIRMAN WYLIE: .There are a lot of hydro 19 plants.

20 COMMITTEE MEMBER KERR: A lot of old hydros, but 21 what about fossils?

22 CHAIRMAN WYLIE: Well, there are some.

23 COMMITTEE MEMBER KERR: I just wondered how L 24 relevant it is to talk about a 60-year-old plant, but l-25 apparently it does have some relevance?

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'1' CHAIRMAN'WYLIE: I think so.

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h COMMITTEE MEMBER CARROLL: I can speak for 3

PGandE,,the' plants aren't running any longer. But.PGandE 4 had several fossil plants that were' retired someplace in 5 the 50-year life range.

6 MR. RUBENSTEIN: Les Rubenstein'of the Staff. I 7 see this as an active area that the NRC is looking.at,.

8 both in the new plants and on the existing plants. We're 9 very actively looking-at how to address life extension,.

10 ~the-Department of Energy has proposed'two plants that they-11 are' going to use as.a pilot project to extend life. And 12 .

we actively have programs.at research on ageing and life 13 extension, as to what.our requirements.would be.

O '14 So I see a fair amount of cross feedback between 15 that program and the. database and the initiatives that we 16- and the industry take'in that area, and the initiatives.

17 that EPRI in designing for 60 years and we in reviewing 18 for 60 years, if an individual designer-vendor requests 19- it, although we would give certainly a 40-license.  ;

20 We obviously have a lot of time, if we get the 21 technical details in place first, to worry about extending 22 the license on the new plants beyond this time period.

23 CHAIRMAN WYLIE: You know, let me just add one

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24 other note to that. From just a philosophical standpoint, 25 the earlier fossil plants, even though a lot of them went PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD, SUITE 240 SACRAMENTO. CALIFORNIA 96827 TELEPHONE (916) 362-2345

L I past 40' years, they were not designed for 40 years. .And l; 2 og. course the boilers burning coal or gas or whatever',

'3 took'a tremendous beating over those years.

4 And it's'a different design criteria with a 5 nuclear' plant, they're designed for this type of service l-6 over long' periods of time.

7 COMMITTEE MEMBER CARROLL: When we're speaking 8 of 40 years, we're talking with the clock starting at 9 issuance of an OL, or --

10 MR. MILLER: Yes. Yes, currently the Staff has

'11 hadiseveral1 cases where we've actually converted the 12- license to 40 years from the issuance'of the.0L.

13~ COMMITTEE-MEMBER CARROLL: Okay.

O 14 MR. MILLER:. I should also say that, you know, 15 in the realm of the 60-year review, one of the 16 considerations'there is the fact that not necessarily all 17' the components in the plant would last for 60 years, but 18 you would design up front the plant to be amenable to 19' being able to upgrade components.

20 Current nuclear generating plants in many cases, 21 it's very cumbersome to try to have to change out certain 22 components, limited by the design of the containment, 23 et cetera. So it's these forward looking items that have 24 come before the Staff by some designers for consideration.

25 MR. VINE: Can I add to that that when we --

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1 Gary. Vine from EPRI - .when we spend a few minutes' .q

?~ 2 ' tomorrow' afternoon talking,about the ageing-issue in

3
response ~to your request, we can cover'some of those 1

4, points.

5 It's my understanding that the' Staff'willfreview-6 the designs submitted for certification for a 60-year life 7 capability, and clearly as we'll show tomorrow, the 8 requirements. document is written with,the' intent that the 9 designers design for a 60-year life. And we think that 10 that's' achievable.

11 There's a difference between reviewingffor 60 112 and licensing forg60, and that's the. distinction you're 13 trying.to make.

14 MR. MILLER: Right. That's the distinction I'm

.15 trying to make. That's correct.

16 MR. LONG: A point of clarification. Are you 17 then requesting that we review for 607 18 MR.-VINE: My understanding'is that you have 19 stated your intent to review for 60.

' 2'O MR. LONG: If requested.

21 MR. VINE: This is the November 22nd letter, it 22 says, 23 "For applications proposing a 24 60-year design life, the Staff would 25 review the designs for a 60-year life, )

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10 notwithinstanding the fact that a 2 40-year license term limitation'is 3

Presently in the regulations." l 4

MR. RUBENSTEIN: That's correct, that's in our 5

MR. VINE: Yes, for the requirements document itself, we would expect the same approach, since we are in 7

fa t setting forth the bases for requirements for a 8

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  • MR. RUBENSTEIN: In particular, we look forward to your designating those features which must be given special attention and interest, that are dominant and important in a 60-year life, and we see this across the 13 (A,) board between life extension and the new designs.

MR. SUGNET: My name is Bill Sugnet.

CHAIRMAN WYLIE: Excuse me. Is the recorder having difficulty with the --

THE REPORTER: No. The microphones don't need to be moved.

CHAIRMAN WYLIE: Okay.

MR. SUGNET: My name is Bill Sugnet, I'm from EPRI. I just wanted to clarify, in our requirements program from the outset, in Chapter 1, we identified as a high level design goal, to design for a 60-year life.

We have co~nsidered, as we've gone through the l

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.11 0' .1 ' various chapters and,elementsiof the requirements, what 2 features had.to be: attended to in order _to design for a 3 ,60-year life, and of course we're continuing that in the 4 later chapters.

5 One example, in response to Mr. Rubenstein's' 6

comment, is the reactor vessel situation. We have looked 7 specifically at the. reactor vessel, which is probably the 8 most difficult component to replace in the plant, g . satisfied ourselves that the materials aspect, the radiati n embrittlement and so forth, can be handled in 10 11 such'a way'that it's satisfactory for a 60-year life.

.12 S I think we are going down that track, and

- 13 we're.g ing about it pretty. seriously.

.;O ,4 MR. TONG: okey. I euese 1 wee mis 1ed, beceuse 15 if I can quote from your' April.3rd letter, which says, "A 16 maximum 40-year operating life should be assumed as the 37

-licensing basis for the ALWR." And that would lead me to

. 18 believe that we'would not give you a request for 19 additional information regarding the additional 20 years )

20 f life.

21 MR. SUGNET: I think we should look into that --

22 MR. LONG: We've got to go back and turn the 23 Staff on to this'. Now we're doing a 60-year review, I 24 thought it was going to be a 40-year review. l 25 MR. SUGNET: If we've misled you, we should go o

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1 back and look carefully.and get back to you and clarify 2 it.

3 MR. LONG: The next issue, the Chapter 1 issue 'I l

4 on-systems interaction. EPRI has proposed some clarifying .

o 5 changes to Chapter 1 for definitions, for systems l

L 6 interactions, adverse systems interactions, and 7 undesirable' result.

8, The Staff has not reviewed the proposed changes, ,

i 9 so we=will have to defer resolution of that issue.

10 'A' Chapter 3 issue on pressurizer relief tank has 11 been satisfactorily resolved, since there is no 12 pressurizer. relief tank in the-ALWR design, the'in--

13 containment refueling water storage tank _will serve as the O 14: Pressurizer relief tank. So we'll be ablef to clean up-15 that item in the roll-up.

l 116 COMMITTEE MEMBER CARROLL: Before going ahead, 17 .could.EPRI give us some flavor of.how they're treating the.

18 system interaction thing, even though you haven't 1 19 completed reviewing it? What did you say in the letter? 1 I

j 20 .MR. VINE: . Well, there are a number of things 21 that we're doing. Many of the more important things to 22 address systems interactions is simply to address what 23 we've learned from the. operating experience in this area, 24 and. design those types of problems out of the systems.

25 For example, we have provided strict separation l I

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1 of each safety division, one from the other. And even 2 within a division, we've provided reasonable separation 3 between redundant trains. We've also done a lot of things 4 in the area of keeping the safety and the non-safety 5 portions of the plant separated, both during construction 6 and operation.

7 The contaminated and uncontaminated portions of 8 this plant, we've provided more reliable power supplies, 9 ar.d probably equally important in Chapter 1, we designate 10 some specific steps that the designer must do in terms of 11 doing a review for potential systems interactions in the 12 design process.

13 COMMITTEE MEMBER KERR: Let me talk about O 14 another kind of systems interaction. For example, if your 15 control system is unreliable, it may call for more 16 reliability on the part of engineered safeguard features.

17 Are you setting any specific reliability i

18 requirements on your control systems?

19 MR. VINE: Yes.

20 MR. SUGNET: Bill Sugnet from EPRI. We haven't 21 established specific reliability targets for individual 22 control systems. We have established top level plant 23 requirements for scram frequency, which I think gets to 24 the same question. And our top level requirement is less 25 than one scram per year average. And we are looking to O

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14 1 . deterministic requirem'nts e in the' systems'to effect'that..

For example, we have~ set requirements in'our

'3 Power generation systems chapters.that secondary: plant 4 components, failure of a single secondary < plant component, 5 sha}lnot.beallowedtocausetheplanttoscram. . This.

w uld'get to issues like single channel control systems'in 6

7l the steam plant that could fail and bring the entire' plant.

down'.

8 9 I wanted to add also to what Gary had said, that 10 we have called for a very thorough probabilistic risk assessment of the plant in the design stage. And in doing 12 thta, we've laid out methods and ground' rules for'that g analysis that require the designer to go all.the way

.through all the hardware and connections in the whole 15 plant, and make sure he understands all.the things that

-16 are- nnected to each other and how they' interact.

47 And I think this.will also tend to ferret out-18 s me f the undesired iriteractions we've seen in the past g between support systems or control systems and the ma n sysum.

20 g MR. LONG: Are we ready for the next issue?

Chapter 3, there is an open --

22 23 COMMITTEE MEMBER KERR: Excuse me. If you're 24 departing from Chapter 2, or maybe you never have been on j 25 , but in the Staff's SER on Chapter 2, page five, there O

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f h 1~ is.a discussion of the turbine bypass capability, and it 2 doesn't say whether the Staff has approved this or 3 reviewed it, it's just given as 33 percent for BWR's, at

'4 least.

5 Does that indicate'that you have reviewed and

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6 approved this, or is it just a statement that this is part 7 of'the design? -It wasn't clear to me.;

8-MR. LONG: .There'is an additional requirement in g- the PWR that the plant be able to ride through a complete 10 generator trip;with the' plant staying on the line to 11; continue to' feed'its auxiliary house loads.

12

'And this will probably set a minimum bypass 13 requirement, and the Staff does accept that' feature of the

'O 14 . plant, that it be able to ride through the -- that is a 15 feature of some existing plants.

.I will defer to EPRI on what the actual bypass 16

'17 spec'ification would be.

18 COKMITTEE. MEMBER KERR:- .No, my question was whether the Staff had set any such requirement, or if it

.19 20 'was-simply a matter of looking at --

21 MR. LONG: No.

COHMITTEE MEMBER KERR: -- the requirement and 22 23 determing that --

MR. LONG: It's a non-safety system, and there's 24 25 no minimum bypass criteria.

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1 . COMMITTEE MEMBER KERR: 'Are.you,f in your review, 2 .then,~you're looking only at safety systems and not at the-3 effect of non-safety systems lon --'Mr.fRubenstein is'

-4 shakingLhis. head no.

5 MR. RUBENSTEIN: Well,.what EPRI has proposed.in-6 the requirements document goes well beyond' pure' safety 7' ' systems. And in the more direct; aspects of your-question, 8 have.we. set a standard for this,-I. don't think we have.

g However, we're reviewing the EPRI' standard,-and I think we 10 agree that it's a reasonable standard, and--it would meet 11 our needs.

12' COMMITTEE' MEMBER KERR: I was just curious on -- )

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. 13 since'in a sense, it's I guess a new requirement on how do l' -( ). 14

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you' review;this, on what basis doEyou decide that it is or 1 15 is~not" accept'able?-

16 t MR. RUBENSTEIN: Well, there are many; aspects of 17 .theIEPRI utility requirement documents that doesn't deal 18 literally with what we'have'to'have for adequate 19 Protection or to meet our safety review or the SRP.

20- And in some cases, we give-non-binding agreement 21 or advice. And it's sort of working together with them.

22 SPecifically, the hard approval would come 23 through the approval of the GE, Westinghouse, and 24 Combustion System 30 design. If they propose something, 25 we would look at it primarily to see if it conflicted with

()

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7p 17 V-1 our other' safety needs, and if it was certainly an 2 enhancement,:we;.would say some. nice'words about it, but 1 3 more on.

t

~4 COMMITTEE MEMBER KERR: Well,.let me be specific. There.is, in'another part of the Nuclear 5

-6:

. Regulatory Commission, a rather large effort that will 1 eventually culminate in a final document ' called NUREG 1150.

7 Are y u g ing t 1 k at the.results of 8.

9

.NUREG 1150, for example, in determining whether an aPPr Priate. turbine bypass does or does not contribute 10 g .significantly to risk?

2, MR. RUBENSTEIN: That's an excellent question.

- 13 We do have a mechanism for feedback and'following the

/

~

.g research program on 1150. And I can give you an example inTanother area,'where~we look very specifically at some' i e'results..

16~ <

.I think to the best'we can, we'll follow the 7_

standard revicw plan, and.our specific requirements, and 18 .

19 e en an emen s, and~ H dere are any vulneraMlWes, I think it'll come out through the specific PRA's that both 20 the designers and EPRI does.

21 It's sort of a very general answer, but we do 22.

have some restrictions on the review.

23 COMMITTEE MEMBER KERR: Thank you.

24 COMMITTEE MEMBER CARROLL: You indicated that 25 O

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the PWR has full. load rejection capability, but not the

  1. ;BWR7 IsLthat correct?

2 f' .

MR. VINE: Let me answer that, this is-Gary Vine. We have in the past, in the earlier chapters, designated ~1ess'than a full load rejection-capability for both designs.

However, on'more recent examination of 7

capabilities, we've' decided to go to more than that. And l 8 in the Chapter 11' document.that's on its way to the Staff 1 9

right now, we:are'specifying 40 percent for the BWR, and a 10 full load rejection capability for the PWR. However, the

.11 full load. rejection-capability is not all turbine. bypass.

12 It's roughly'50, 55 percent-turbine bypass,and 13

( ):- '

14 the rest a rapid rod-insertion, very similar to what Palo Verde has-been licensed,with, and.similar to what 15 Westinghouse submitted, Tin the SP 90 design.

16 i CCMA fTEE MEMBER CARROLL: I would give you a 17 caution. If'you're going to try to meet one scram per 18 year', you'd better put some margin in these systems. I've 19 had a little experience with that.

20 MR. RUBENSTEIN: Let me try and give a i i

21 supplementary answer. I guess the sum total of our 3 22 requirements are in the regulations and reflected in the i 23' standard review plan. And they haven't basically changed. 3 24 )

Except for the advanced plants and the 1,000 1 25- ) l PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO. CAUR3RNIA 95827 mE~ONo ,.> .,34s

/V 7 19 1- megawatts plants, what we've done is, in' November we put .

2 out'a series of. items that were proposed issues for'the 3- evolutionary plants, andLthis is the series of November

'4 . letters which we subsequently went to the Commission on in 5 a SECY. paper.

6 We're now going through the process, and we'll 7 . talk about it, and Dr. Murley spoke about it a litt10 bit 8 before. What those additional items in the design stage 9 should be considered to deal with' severe accident 10 phenomena.-

~

11 And as Dr. Miller will talk about a little later

~

12 today, part 52'added some thing on how to deal with _

13 formally. adopted standardization and some other items of.

'( ) 14- the severe accident policy into a regulation. 'And these 15 .too will be part of the total group of requirements that 16 -one has to meet.

17 This:is, you will have to meet all the generic, .

18 medium and high priority generic safety issues, and USI's.

19 you have to have a PRA.

20 How we deal with the PRA specifically is being 21 worked out now. I expect that Research will put out a

( 22 document and guidance which is very close to what EPRI is 23 doing for industry, on how to wrote the PRA and certain L

g 24 assumption which would be done.

25 So between the general host of regulations, O

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20 the_.-- what I'm going to call the standard,.mostly'within 9

2 the design' basis set of requirements that was in the L

li' l- ,

.3 November letter, the-few.special rules on ATWS.and severe .

blackout, the initiatives'we're taking right now on severe accident, and which we'll be talking about. shortly and in j,

L the'. future in another meeting with the Committee, probably makes.up with Part 52, the sum' total:of the. requirements. l 7

~

for W 1,000 megawatt evolutionary type plants at this time.-

We may look.a little differently as we come into thel passive plants.  !

l- 11 1 1

-COMMITTEE' MEMBER KERR:. On page six'of the same 12 ..

. -SER,' Chapter 2, fitstffull paragraph there is a. discussion

.. of main. steam isolation valve. behavior, and a reference to it- 14

'~

a main steamline break and a concurrent single active j 15 fallure'one MSIV. Again, the implication being that this 16 4 is being looked at on the basis of a single failure 17 .;

criterion, which I guess you're required to do on the basis of' existing regulations. ,

Have you also looked at this on the basis of, )

say, reliability or risk, are there insights and PRA's that would say, that makes sense in this situation? That.

particular requirement from a risk point of view?

MR. SHUM: No, we have not looked at it with regard to the ability.

l

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1 MR.:RUBENSTEIN:~ .You've_ got to say your name.

-2 David Shum of the-Staff'will answer that.

3' MR. SHUM:' David Shum.. We have not-looked'at it 4 from the ability standpoint.

5 COMMITTEE MEMBER KERR: In the main report of 6 NUREG 1150, and in a number of SECY'es that have resulted,

7. the. Staff, that part of the Staff that has been 8 responsible for 1150 has' talked'about'a number of g: important insights that have been developed from.ll50.

10 Has the Staff used those insights in your review 1'1 of the.EPRI document?" ,

12 MR.'ARCHIZEL: This is Ralph Archizel. We

/

13 basically have"used'the' standard review plan as it exists O 14. 'today,.for performing the review of the EPRI requirement 15 document. . And the existing regulations,.and using the 16 . standard. review plan, we have not'used 1150. In the 17 severe accident area, we've done some work --

18 COMMITTEE MEMBER KERR: -Thank you.

19 MR. SUGNET: Mr. Chairman, if I might, I'd like 20 to add a comment from the EPRI perspective on this issue.

21 When we've developed the requirements document, we've of course called for -- we've established safety 22 23 targets in terms of frequency of core damage and frequency 24 of significant offsite boundary dose.

25 And we have done some high level PRA WORK to O

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'1 assess the. requirements as;we've' established them, to see whether or not they're capable of meeting our' targets.

~

2.

3 So we have~done thisikind~of' risk work in 4- developing.the. requirements, looking for,possible places.

j5 where there is'an: imbalance and correcting that imbalance 1 6 by' design.' requirement. We expect the designers.to 7- continu'e'this' process in more detail-as,the designs: evolve

'8 to meet the requirements.

g . 'Solwe would expect' naturally that the lessons 10 from both. existing risk assessments and those that are 33, done specifically'for these designs would-be fed in by 12 that mechanism,.and would-affect the design.

13 . COMMITTEE MEMBER KERR: Thank you, Mr. Sugnet.

-O 14 MR..LONG - I'd like to also note that we haven't 15 yet received and initiated our review of the 16 instrumentation chapter. We'll be receiving that shortly, 17 but I suspect that may be what you're concerned about, is 18 the instrumentation aspects of the MSIV's?

19 COMMITTEE MEMBER KERR: Well, I'm noc. quite sure 20- what I'm concerned about. Really I'm exploring -- I have 21 heard a good bit of discussion of the important insights

'22 that have resulted from 1150, and I was curious as to 23 whetiher these insights had been useful to you in this 24 pr cess.

25 That was all I was really trying to determine.

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23 1 'MR. RUBENSTEIN: There was a more informal 2 method oflgathering these:in our review process than we've 3 given visibility for.

4- " Wha't we've.done is, we've gone off on.three

~

5 retreat's,/one o'f which was devoted primarily to within the.

6 design basis, and we got' the Staf f who is also.

7 participating'inll50Lin the review, limited though they

~

8 may be-in NRR, off and we went over all the issues that 9 .they saw that were~ relevant that we would utilize as 10- aiding or. enhancing..or~ going beyond the standard review 11 plan.

'12 And'~to the degree that the. November series of

'13' letters emanated from such a meeting, and the items'which

.O 14 'we'll be unfolding over the next few months emanated from 15 a-meeting of the same nature on severe accidents, I would 16_ say more implicitly there's been a fair amount of 17 cognizance of 1150, and the kind of feedback we also get l 18 from working closely with Research and having much of the 4 19 review done by the same people in research. )

20 But formally, in terms of a checklist, one on 21 one, I can't say we've done that.

22 COMMITTEE MEMBER KERR On page seven of the 23 same document, the first paragraph, there is a statement 24 about the third sentence, I guess it's the second full 25  : sentence, that "Waterhammer transient loads are to be

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'1 below the system pressure boundary design limits."

2 How were-these waterhammer transients

.3 calculated, or;is that simply a requirement and somebody.

4 else'has-to make.certain that it's the case?

5 MR. LONG: .That's a requirement to be imposed on

~

6 the plant designer by the EPRI requirements document.

7 COMMITTEE MEMBER KERR: Is it --

8 -MR. LONG: No methodology is specified in the 9 documents.

10 COMMITTEE MEMBER KERR: -- possible, in-your 11 . view, for a designer'to design and be certain that that 12 will be-the case?

13- MR. LONG: Certainly for liquid phased systems.

O 14 Possibly for a two phase system.

15 (Laughter.)

16 MR. LONG: I believe it's possible.

17 COMMITTEE MEMBER KERR: But you aren't sure.

18 MR. LONG: That's correct. The Staff has no

'19 objection to that requirement being in the document.

20 COMMITTEE MEMBER KERR: It's not a question of 21 whether the Staff has an objection to it, it seems to me.

22 I think it's an important requirement, but it doesn't seem 23 to me that it has much significance if nobody is sure 24 whether it can be done or not.

25 And I was puzzed, because I'm no expert on O

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25 1 waterhammer, but in listening to.the people who are, it 2 strikes.meLhs 'being a rather tenuous requirement.

3- MR. LONG: The Staff requires that consideration be:given to waterhammer.

4 COMMITTEE MEMBER KERR: Does EPRI have~any 5

mm nt n the meaningfulness of that requirement?

6 MR. VINE: Well, again, I.think we've l' earned a 7

1 t from operating experience here.

8 COMMITTEE MEMBER KERR: Yeah.

9 MR. VINE: We've learned'that horizontal pipe

. runs that.can be.two-phase are a physical design arrangement that you ought to avoid to avoid some of.the experiences ^we've seen. 'And there are other things that we can do in the design to address the waterhammer issue.

14 So I thin'k it's entirely credible to design away at least the' experience we've seen to date.

MR. RUBENSTEIN: I think the Staff accepts these as reasonable targets which are designed to minimize the 19 impacts of waterhammer, and as opposed to perhaps calculating peaking factors or the hard requirements that we view it somewhat differently.

COMMITTEE MEMBER KERR: Again, somebody else ought to be addressing this, but it strikes me that there is some feeling that waterhammer still can pose a serious threat, and there is also a feeling that we aren't sure O

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, 26 1 that.we know whether we can-_ design so that this is 2 achieved, but somebody'ought to be looking into it. I 3 don't know who,..but -- .

4 COMMITTEE MEMBER' CARROLL: It's a very real 5 problem with these big plants. Another. potential source 6' of it-is:the load rejection.'with'a lot of stored heat in 7 the'feedwater heaters-and you stop the condensate flow.

8 I've had.some personal experience with that. It 9 makes loud ~ noises.

10 One_ question I was kind of curious about in this 11 chapter, and=I'm not sure I can find it again, but you're 12- not specifying necessarily full flow polishers on the PWR 13 plants that's on'page eight? Chapter 2, page eight.

O 14 COMMITTEE MEMBER KERR: Top paragraph.

15 COMMITTEE MEMBER CARROLL: Of the SER.

16 MR. STRAWSON: I'm Dave Strawson of MPR

-17 Associates, we're consultants to EPRI on this. The 18 Chapter 4, the BWR, would require full flow 19- demineralization --

20 COMMITTEE MEMBER CARROLL: Right.

21 MR. STRAWSON: But for the PWR, there was a 22 . fundamental thought, that by requiring full flow 23 demineralization,-we may be adding more complexity and 24 more problems than we're solving. So it goes back in 25 time.

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s 27 1 But-my recollection is that we're, quired at least 2 4 demineral'ization during startup.for initially cleaning the.

~3 condensate,,but ---

4

'f '4.

~ COMMITTEE MEMBERLKERR:- I guess'I don't-5' understand the statement, "There was a feeling'that."-

6 Your' decision surely'wa'sn't based just on a. feeling.

7 .MR. STRAWSON:

. There was a conclusion then.

8~ COMMITTEE MEMBER KERR: Based on what?

9 .MR.-STRAWSON:: On experience with PWR operation,.

10 where there have been many incidents of resin intrusion

-11 and carryover from the resins during startup.

t 12 COMMITTEE' MEMBER:KERR: 'But nobody has operated

'13 a full' flow system up to.now, has he or she, for PWR?.

-O '14 COMMITTEE MEMBER CARROLL: Oh, yeah, yeah.

15 Virtually all of them have full flow --

16 COMMITTEE MEMBER KERR: Okay.

17 COMMITTEE MEMBER CARROLL: What I'm questioning 18 is, why back away from that at this time, from the water 19 chemistry point of view?

20 MR. VINE: One of the things we've done is 21 greatly improve the-requirements for the design integrity 22 of the main condensor, and I think that's part of the 23 answer.- But I don't remember the history of this "24 particular issue. This was decided three years ago, and 25 we ought to be able to get a better answer for you.

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28 y .I'm confident that there'was a. reasonable 2

. evaluation done, cost be'nefit or.otherwise, to come to a

2 3 this conclusion.

COMMITTEE MEMBER KERR: Thank you. That covers 4

my questions on Chapter 2.

5 COMMITTEE MEMBER CARROLL: I had one more issue on Chapter 2. 'I don't see'any discussion of -- it seems 7

to Vacillate around in the industry -- about the issue of.

water induction as a result of failed feedwater heaters, 9

water induction into the turbine and.the potential severe damage to-the turbine.

l- Is.it. intended that these plants follow the ASME 2

guidelines that Hartford steam boiler at least has been 13 pushing for the last several years?

MR. VINE: I do know.that we treat the issue of 5

integrity of feedwater heaters and MSR's in the chapter g and specifically require improved materials. We also address the erosion-corrosion issues pretty thoroughly in this area. Again, can someone help me on the ASME code 19 20 COMMITTEE MEMBER CARROLL: They're guidelines, it isn't a code.

MR. VINE: Okay.

MR. FIDRYCH: We had a requirement in Chapter 2 on that.

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J 29 l' COMMITTEE MEMBER KERR: 'The recorder can't hear.

2 you.

3 :MR. VINE: Lee, if you have something to' help,

~4- we'll need an introduction.

5 MR. FIDRYCH: My name is Lee Fidrych, I'm with 6 S.. Levy Incorporated, I'm a censultant to EPRI on the AFWR-7 program. I thini,. there.is a requirement in Chapter 2 --

8 MR. VINE: We need to get you on the mike here.

9 MR. FIDRYCH: I believe that there is a 10 requirement in Chapter 2 on that' subject. I think we'll 11 have to do a little .aore search on that, but I think there

~12 is -- I'm quite cure the subject had been covered, because 1 -13 I recall it being' discussed.during the meetings.

O 14 COMMITTEE MEMBER CARROLL: Okay.

'15 MR. FIDRYCH: We'd have to take some more time 16 to find'it for you.

.17 COMMITTEE. MEMBER CARROLL: It's-an_ expensive one 18 to backfit, if you don't do it right the first time.

19 MR. LONG: An issue in Chapter 3 was the Staff's 20 concern about guidance for a reactor coolant pressure l 21 boundary leakage protection system. And EPRI has. informed 22 us that that will be addressed in forthcoming Chapter 10.

23 We haven't reviewed the new information. I 24 Another issue of Chapter 3 was bolting 25 degradation. And we have additional information which we LO PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO, CAUFORNIA 96827 TELEPHONE (916) 362 2345

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-1' .have't seen yet forthcoming, and this will be addressed 2 during'the l Chapter 1 roll-up.

~3 COMMITTEE MEMBER KERR: You have.' concern, I 4- think the concern is justified. .What are you - on what basis.are you going to decide that their solution is'or is 5

6-n t acceptable?

7-MR. LONG: It would be standard review plan-8 criteria.

9 COMMITTEE MEMBER KERR: And what are those?

MR. LONG: And standard technical 10 specifications. -l 11 .

12 COMMITTEE MEMBER KERR: For example, it says that something will require that the bolts-be corrosion- -

3 resistant. What does that --

14 15 MR. LONG: Oh, I thought you were talking about 16 Pressure coolant boundary leakage, I'm sorry. The bolting degradation?

17 COMMITTEE MEMBER KERR: Yes, sir.

18 1

g MR. LONG: I dcn't know. We've had to get back i to you on that one.

20 21 MR. VINE: Let me --

MR. LONG: Unless Gary can help.

22 MR. VINE: -- take a try at that one.

23 COMMITTEE MEMBER KERR: No, excuse me. I'm 24 curious as to how the Staff is going to decide. Is that 25 O

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'1 in the' standard review plan, so that.you can -- -

2,

~

MR. LONG: No,.this is a generic safety issue. R 3 COMMITTEE MEMBER KERR-. So you aren't sure how

'4 you will decide-whether their solution is acceptable ~or 5 not at this point?

6 MR. LONG:- I'would have to get back to you on 7 that, I don't'know.  :

I 8 COMMITTEE MEMBER KERR: Okay.

9 MR.'LONG: I don't know what their solution is.

]

10 MR.' VINE: I think.I can help on this one.

11 .There has been'an industry. wide program with close

.12 interaction with the NRC Staff for about, I'think close to 13 a decade now'on'this issue.

O. 14 .There was an agreed-upon scope and resolution 15 requirement set up in the 70's or early 80's. There is a

.16 final report that EPRI has issued as a result of industry-

.17 wide research on this issue, which to my understanding met 18 all the NRC requirements. And this was about a year ago, 19 and I don't know whether the Staff has finally signed off 20- .on all the aspects of this issue or not.

21 If there are outstanding issues, my guess is 22 that they're very minor. I think this issue has been 23 resolved for all plants, or very close to it.

24 It basically deals with -- it started out as a 25 boric acid corrosion issue, and expanded to some other O

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1' questions of bolting integrity, but for the most part the 2' scope of that-original issue has been addressed, and I 3 would assume that the resolution.of it for current plants 4 . would apply to' future' plants also.

5 MR. LONG:- Another issue in Chapter 3 related to-6 power actuated relief valves on the pressurizer.- The 7 ALWR, PWR will not use PORV's on the pressurizer, it will

'8 have a safety grade depressurization system. And will not 9 rely on the PORV's, and spray'for the mitigation of 10 overpressure transients. Is that correct?

11 And this resolves.the issues for Chapter 3 that-12 the-Staff had.

13 COMMITTEE MEMBER CARROLL: Tell us about the O 14 depressurization system. What's it-used for a heat sink?

15 MR. LONG: 'The heat sink for the overpressure 16 system would be the in-containment refueling water storage 17 tank.

18 COMMITTEE MEMBER CARROLL: And this would be

19. capeble of being used in a feed and bleed mode?

20 MR..LONG: Yes.

21 COMMITTEE MEMBER CARROLL: How long would that 22 be effective? Is there enough water to --

23 MR. SUGNET: This is Bill Sugnet from EPRI. The 24 design includes provisions for a redundant safety grade 25 bleed feed cooling system. To operate this system, we O

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1 would manually open conventional gate or globe type valves l

2 .! rom the pressurizer, depressurize the plant to the 3 in-containment refueling water storage tank. The safety 4 injection pumps would take suction from the refueling 5 water storage tank, and deliver water back to the system.

6 This is a closed loop, essentially, that could 7 go on indefinitely. At some point, the heat addition to 8 the tank would require cooling of the tank for continued 9 use of this mode. And I don't have a number offhand for 10 that --

11 MR. STRAWSON: It's a two-hour timeframe.

12 MR. SUGNET: Something like a two-hour timeframe 13 would require initiation of cooling to the in-containment

,73 4 14 refueling water storage tank to control its temperature.

15 COMMITTEE MEMBER CARROLL: And how is that 16 cooled? Heat exchangers outside containment, or --

17 MR. STRAWSON: Decay heat remover.

18 MR. SUGNET: The tank would be cooled by the 19 residual heat removal system, with heat exchanges outside 20 containment.

21 MR. LONG: I think this is an improvement over 22 current generation plants, as far as with a current 23 generation plant, if you had a generator trip, normally 24 the PORV's would lift. In the ALWR we would expect the 25 spray to handle the overpressurization transient, and

(')

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34 1 there would be no relief, effluent relief.

2: COMMITTEE MEMBER KERR: It does, however,.mean 3 less relief capacity in the case of an ATWS, however, does 4 it not?

5 MR'. LONG: I don't believe they have reduced'the

6 capacity of-the system to relief fluid with respect to 7 current generation plants. It's just that there is a 8 -larger pressurizer, and a better spray capability within 9 the pressurizer, so the transients can be' handled 10 without -- the overpressure transients can be handled 11 without coolant relief.

12 COMMITTEE MEMBER KERR: Well,;I don't think that 13 Pressuring spray system is going to help much on an ATWS,

'" and if you don't have PORV's that will actuate 14 15 automatically, it seems to me that you are reducing the --

. 16 MR. LONG: Okay.

17 COMMITTEE MEMBER KERR: The ATWS associated 18 relieving capacity, but I'll wait and see what happens.

19 COMMITTEE MEMBER CARROLL: There are block 20 valves, motor-operated block valves in this system also.

21 MR. LONG: And the safety depressurization 22 valves ^are DC operated, I believe, for the ATWS event, or 23 for'the' blackout event.

24 ~MR. SUGNET: To clarify, with respect to 25 Dr. Kerr's question, I think you're correct that the O

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l 11 ~ automatic opening _ relief' capacity-of the system would be 2 only the safety--valves in.this case, the spring-loaded 3 code' safeties, which would be a slight reduction from a 4 plant which employed PORV's.

5 However, typically the code safeties are 6 considerably larger than the PORV's, so I think it's a 7 small reduction..

8 . COMMITTEE MEMBER KERR: It depends a little bit g- on the reactor = system to which you refer,.I believe. It 10 could be a'significant reduction for some. But again, 11 that's an issue that will come up later, I expect.

12 MR. LONG: Maybe we can get into some discussion 13 about it later, but I believe there is an enhancement in a 40 14- recent-Commission letter, SECY paper, concerning' relief i

15 capacity-for ATWS,.is that correct, Charlie?

16 MR. MILLER: Yes, yes, yes. We've gone beyond 17 the standard ATWS, particularly, for example, we're 18 'looking for adequate relief capacity, and in the case of 19 the BWR, we're looking for reliability analysis on a 20 . manually. operated standby of the liquid control system.

21 COMMITTEE MEMBER CARROLL: And LTOP is handled 22 by-the RHR relief valves?

23 MR. RUBENSTEIN: That's correct.

24 MR. LONG: Chapter 3, issue on reactor coolant I

25 Pump seals. As we discussed at the last meeting in O

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w 36 jb 1 August, EPRI'is proposing to use-seals which would have-a 2 leak rate specification of eight GPM. 'And I believe this 3 -number'comes from a performance requirements that with the 4 seals leaking at this, rate, you would have eight hours 5

.before' core uncovery.

g Staff still is Concerned about the 7

implementation of this.- With such'a seal, then the -- if I can find the risht words for this. If the seal 9

performance can be reasonably guaranteed, they would not-need a piggyback' power source for the injection pumps.

g And we believe-that the issue can.be resolved, but we.Will continue to look at the information that we get-from EPRI 13

.g . COMMITTEE MEMBER KERR: How would you decide if 3, it can de reasonably guaranteed?

g MR. LONG: We will have to look at the I information. We don't'have any detailed information on g the seal design. EPRI hasn't given it to us, they've g given us the position that they will put this 20, specification on these seals, that the plant will meet it.

g And with that seal performance, the GSI goes away.

COMMITTEE MEMBER KERR: Well, it's almost l 22 certain that one can't give 100 percent guarantee that j that's going to occur. And I was just curious as to 1

whether you'd be' satisfied with 80 percent or 99 percent, O

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or maybe you haven't. thought of it yet. But we'll have to 3

' later.

2 MR. LONG: We haven't given that a lot of 3-thought.

4 L MR. VINE: Gary Vine. I'd like to add a couple 1 5' of' points.to this. First of all, there are'recent' tests which have been done by one of the pump vendors to demonstrate a very, very low leak rate over a long pericid of time. But our upproach to this issue is not simply to rely'on'an improved pump seal design.to address the entire issue.

-11

~This is really a subset of the broader station blackout issue. And I think you'll find today and

,f 13.

V) 14 tomorrow,'as.you go:through how we've addressed the-

-station blackout issue, and in particular what we've done with the. component cooling water, and the power supplies to both the charging pumps and the component cooling water

~

pumps.and the like, that you'll see a very broader picture of how.this issue is.being-resolved.

MR. RUBENSTEIN: As you know, Dr. Murley discussed this last' week, and he offered a two-pronged 21 ,

anproach, both a fair degree of focus on-generic issue 23, which is the material properties, and also the susceptibility of the pump failure for the system side.

We haven't established any higher level of O

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1 requirements on the Staff side than the same initiatives 2 that we're looking at for-the operating plants. EPRI may 3 be doing that.. It's possible that what they do.in the 4 advanced plants may contribute toward the solution of the 5 existing plants.

6 . MR . LONG: I think we can say that we will look-7 very favorably upon the provision of the combustine gas

8. turbine alternate power source:in addressing.this issue.  !

9 COMMITTEE MEMBER CARROLL: Does that suggest you n gas tu M nes~are more reliable than diesels?'

'10 qq. :MR. .LONG: .We acknowledge them as being_ diverse.

12 Ne'xt issue,' remote manual isolation of c'omponent 13 cooling, water to reactor coolant pumps and motors. There is a' Staff. requirement with respect-to containment 14 isolation that. requires automatic isolation of lines such 15 16 as cooling water lines that go in and service containment.

And we acknowledge the need to tak.e an exception 37 18 to that automatic iso 1'ation-requirement for such lines as 19 the component cooling water to coolant pumps.

20 The EPRI document will include a radiation l m nitoring instrumentation system to monitor the activity 21 in these lines, and alert the operators if there is a need 22 23 f r isolation. And that should be an acceptable 24 resolution of this issue.

MR. ARCHIZEL: We still have that as -- we want 25 O  ;

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'1' to specifically'y look at the' details of the essental lines.

2 EPRI requested that-essentially isolation valves be 3 Provided with remote manual-isolation, and we want to then 4 specifically, every~ time that's examined -- we have not 5 completed a' review of any particular essential pat.h at' 6

.this point.in timel.

7-COMMITTEE MEMBER ~KERR: How'do you make a-8 decision?

9 MR. SHUM: This is David Shum. For that 10 particular isolation valve to close, we require that'the -

11: leak detector system,,in case the pipe breaks.outside 12 there,'we,will'hav'e, they will be required to be able to 13 Provide enough information for the operator.to be able to g isolate it' manually. For EPRI, they.have not a' wider 15 leakage detection. system to detect leaks, the pipe --

16 MR. ARCHIZEL: We require some additional

_37 information to review the particular-path.

18 COMMITTEE MEMBER KERR: No, but given the 19 inf rmation,-how do you make a decision that something is j l r is n t acceptable?

20 21 MR. ARCHIZEL: Well, something like the reactor coolant pump ~ seals is --

22 23 COMMITTEE MEMBER KERR: No, I'm talking about 24 this particular issue of the isolation of essential; 25 P l ant --

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'1 Mh. SHUM: This'is a very -- the criteria for that has been established, even in the ANSI Standard 76.

2 COMMITTEE MEMBER KERR: What are the criteria?:

.3 MR. SHUM: The criteria is to have-a leak.

4 detection system, t. ) be able to detect if.there's:a pipe break outside of and beyond the isolation valve, so that the operator would have enough information --

COMMITTEE' MEMBER KERR: Does it --

MR. SHUM: -- to isolate that line.

.9 COMMITTEE MEMBER KERR: Does EPRI know about 10 this?

11 -

.MR. VINE: My reading of the issue and this i

. discussion right now is that there's a little bit of a 13 disconnect here.

14

.My, understanding.is that the issue was specifically looking at the possibility that there might be a leak in the pump seal heat exchanger, in which I

primary coolant got into the component cooling water system, and you wanted to.be able to know that you had contamination in the primarily coolant -- I'm sorry, in the component cooling water system, so that you could isolate that. But that there was no --

22 MR. SHUM: That's --

23 MR. VINE: We're not talking about a pipe break outside containment.

25 O

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-1 MR.,SHUM: Pipe break means you're leaking too 2~ much.

3 MR. VINE: But the pipe break we're talking 4 about is in the component --

5 MR. SHUM: :I mean a' leak. You don't know how 6 -much.you're leaking, we don't know where the break.-- you 7 know, you're.' leaking too much, and the operator would be You don't want, you know,' leaking too

~

8 able.to isolate it. s 9 much out without knowing.it.

MR. ARCHIZEL:

~

, .) I. guess the only point I'd like 11 to'make, and this com'es up in Chapter 5, where you

. requested. remote. manual for -- blanket. remove manual.

12 We I

.13 have,that as,open, we'll look at the particular line, and

i(-

V -review them --

$4 15 COMMITTEE' MEMBER KERR: But it sounds-to me as 16 if EPRI and you aren't agreed on what the issue is at this 17 p int, but I guess you can get together.and agree --

18 MR. LONG: The issue on Chapter 3 relates 19 specifically to component cooling water to the reactor 20 coolant pumps. In Chapter 5, it comes up again where they 21 want to make it applicable to all quote " essential 22-systems," not just this system.

23 And the Staff will require that the appropriate 24 instrumentation be provided in the control room to the 25 Perator to manually isolate the --

I

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42 h 1 COMMITTEE MEMBER KERR: This is. based on 2 standard review plan or something like that, and no on a 3 risk analysis?. Is that right?

4 MR. LONG: A case-by-case basis.

COMMITTEE MEMBER KERR: No, but I mean the 5

decision will be made on the basis of not risk or 6

j -reliability, but.of.-a standard review plan.

M R .1 RUBENSTEIN
At this juncture, yes.

8 g COMMITTEE MEMBER KERR: So you know, the reactor is-an advanced reactor,-the review process hasn't gotten

.g very far advanced yet.

MR. RUBENSTEIN
Well, we haven't got into the specifics on the, actual designs. I would agree with that.

13 g But as I Fread the issue, EPRI is looking for some generic relief on essential systems,'and your question about what riteria and how you'd made the decision is quite apt to 16 the point.

We haven't seen their kinds of an argument that g

would support a generic --

COMMITTEE MEMBER KERR: Yeah, but in order to g

make an argument, one has to know what criteria are being used to make a decision. And if the decision -- see, we have an advanced reactor and I would have thought that one might think a little bit' about advanced review criteria where improvements could be made. Maybe you have no 25 O

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1 choice, but to use existing regulations, I don't know.

.2 MR. RUBENSTEIN:

We really --

3- MR.'MILLEE: I think we can get into that more, 4 Dr. Kerr, when we get into the discussion of Part 52. The 1

5- Commission has promulgated that rulemaking now, and give 6 some specifics with' regard to the regulations.

7 COMMITTEE MEMBER KERR: Okay.

8 ,

MR.~RUBENSTEIN:) But'specifically down in the 9

nitty-gritty 'of'a system like this, the Staff is using the

10. SRP, and it is up to'EPRI to propose criteria and defend

^'qq it and the Staff - -we're not out ahead of.them in 12'. establishing the additional reliability or operability

,, - '13 criteria, beyond what we have in the SRP and in our' normal 1

14 Proactice.

15 COMMITTEE MEMBER KERR: But Staff is presumably, 16 and I shouldn't say presumably - the' Staff is interested 17 in enhancing safety.

18 MR. RUBENSTEIU: .Yes.

19 COMMITTEE MEMBER KERR: And where it sees a 20' criteria could be changed that would enhance safety, I 21 w uld guess it would want to look at those.

22 MR. RUBENSTE:.N: We do. And where they propose 23 it and they initiate it, we're very responsive, and 24 specifically in the-areas where we've intitiated it, we've 25 got it in the November letter, and a series of letters, O

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44 V and'we have it'--'the Staff doesn't have a great deal of y

authority'without going to the Commission, to-add 2 ~~

requirements to.the evolutionary plants.

3 But we have gone through it systematically.and 4-triedto.[ identify.veryimportant~ features. We probably didn't get down.into this kind of a level.

6' MR. LONG: 'Are we ready for the next issue?

7-Chapter.4 --

C'MMITTEbMEMBERKERR:

O Are we. leaving

~

Chapter:3?

10 MR. LONG: Yes.

COMMITTEE MEMBER KERR: Yes, we are.

MR. LONG: The' draft SER-indicates a concern-3 about deletion of reactor vessel thermocouple, becaues of the --

5' COMMITTEE MEMBER KERR: I think I wanted to ask 16 one question on Chapter 3, and I wanted to -- no, I guess I7 not. But'I especially' wanted to applaud'whoever made the 18 decision that's indicated on page 11, that if I understand .

19 it, provides automatic control of water level at any power 20 - level from hot, no load.-- wait a minute, yeah, to full 21 power. That's feedwater, levelized feedwater.

22 I want to -- finally I want to applaud an 23

. industry that has finally recognized that it is possible 24 to-automatically control feedwater. I had thought the 25 O

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'1 U.S. -- that is absolutely delightful.

'2

- :MR'. SUGNET: .

We appreciate your comment, 3 Dr .s Kerr.;

'MR.'LONG: -I believe we have variable speed.

4

le tric pumps in this case that facilitates that' 5

aPability.

6 COMMITTEE. MEMBER KERR: Every country except the 7

U.S. h.as recognized for some time that this can be done, 8

and-I'm glad to see us catch up. It'll take a while,

.9.

but ---

.MR. LONG: We would expect to see that this would contribute significantly totthe reduction in. scrams, g the use of these pumps.

And we are hopeful, like.the other plants in-the 14 world, of being able to build some more of these plants

,5 also.

MR. VINE: The. bigger. problems of course -- this is Gary Vine. The bigger problems, of course, have been at low power. And what you have to do is to design a 19 control system --

COMMITTEE MEMBER KERR: I know where the problem g

~

is.

MR. VINE: -- along with that --

COMMITTEE MEMBER KERR: I know where the problems have been. Nobody's been willing to go to the PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD SUITE 240 SACRAMENTO, CALIFORNIA 95827 TELEPHONE (916) 362 2345 L: - _:__=_________ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _ - _ _ _ - - _ _ _ _ _ _ _ - _ _ - _ _ - _ _ _ _ __-

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.1 trouble to design an automatic control syc m that will 2 work.

3 ' MR. VINE : EPRI's done that-for both the BWR and 4 PWR and they're. working very well right now. So we're 5 confident that.this.can be addressed for the LWR.

6 'MR. LONG: The issue of vessel thermocouple 7 fr m Chapter 4, the Staff's concerne was about the 8 Potential deletion'of. vessel thermocouple,. based on-the 9- NDT requirements that will be specified'for the vessel.

. 10 The'RD position is that only those' thermocouple 11 that are necessary to comply with operating procedures 12- will be.provided for the vessel. It's unclear to us at 13 this- time just what procedures those would be, and I guess 14 'our remaining concern would be natural circulation.

15 There may be a need to provide thermocouple to 16 ensure that certain vessel limits aren't exceeded during 17 natural circulation,-but there will be a design 18 requirement for a capability for 30 natural circulation 19 cooldown cycles in the PWR vessel.

20 And I would expect that at least during testing, 21 if not permanently, this would require installation of 22 thermocouple.

23 COMMITTEE MEMBER KERR: When you talk about 24 vessel thermocouple, what thermocouple are you talking 25 PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 f' SACRAMENTO, CAUFORNIA 95827 TELEPHONE (916) 362-2345

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A , 47 Q .about?' Help ~my' ignorance. -This is core thermocouple

1' .

y 2 entirely, is.that'--

3' 'MR. LONG: No, these are on the outer --

4 COMMITTEE MEMBER KERR: Oh.

"5 MR. LONG: On'the outsideLof the vessel.

6 COMMITTEE MEMBER KERR: Oh, they're actually 7 against'the surface of the vessel'on the outside.

'8 MR. LONG: That's right. j gl COMMITTEE MEMBER KERR:. Learn something every

'0 1

day. And where are~they physically? ' Top, bottom, all 11 around?

'12 MR. LONG: That's right.

13 COMMITTEE MEMBER KERR: . And it is proposed that O. 14 they not.be installed in this way. Is that --

15 MR. LONG: They are proposing only to install

,16- those that are necessary for operating procedures, which 17 w uld mean complying with the pressure vessel temperature 18 limits, which in some cases -- which may not require any 19 thermocouple at all. If you can just use the coolant-20 temperature thermocouple.

21 I w uld think that at-least during the startup 22 tests that are required when natural circulation is 23 demonstrated to meet the branch technical position on 24 natural circulation shutdown capability, they would have 25 to have a. vessel fully instrumented with thermocouple to O

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-verify that the assumptions'used in the natural l

2 ' circulation' analysis are conservative. But~they may not

~

3 need to be. permanently installed.

4 'But anyway, this issue.will continue to be 5' monitored by the Staff. O don't consider.it closed at-6 this point.

- 7. COMMITTEE MEMBER KERR: On page'seven',.there is

-8 a comment that is part of.this,.I guess. Just above."BWR 9 Core and Fuel," that paragraph, is that what that refers

10. to?

11 - MR. LONG: I don't have it here. Can'you read

' 12 ' - i t?.

I 13 . COMMITTEE MEMBER KERR: " Paragraph'3.3.3.3" or O 14 something " specifies that temperature measurement 15' instrumentation" --

16 MR. LONG: That's-it.

17 COMMITTEE MEMBER.KERR:- - "shall.be provided 18 .only if the" --

19 MR. LONG: Yes.

20 COMMITTEE MEMBER KERR: Okay. And apparently

. '21 the argument was that this had to'do primarily with 22 protection against brittle fracture, and the statement is 23 made, 24 "However, the Staff recommends l ,

25 that protection of the RPV from brittle  !

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e 49 ks) 1 fractures not be eliminated because of 2 improved materials."

3 I didn't understand what the Staff was driving at there.

4 It seems to say that even though you don't need 5

Protection, you somehow need it, and I was sure you didn't 6 mean that. So --

7 MR. LONG: This vessel, I understand, will have 8

a very low copper content, that would provide for a 9

60-year life with a minimum NDT shift, and that because of 10 where this will put the pressure-temperature curves, they 11 may be able to just eliminate the thermocouple on the utside of the vessel for normal operating procedures.

12 13 And the issue I am raising is whether the plant 14 perating procedures will also include natural circulation cooldown procedures. This issue hasn't been addressed 15 16 yet.

l l

COMMITTEE MEMBER CARROLL: I just was in the 37 section on boiling water reactors.

18 COMMITTEE MEMBER KERR: No, it's just above BWR 19 core and fuel. Maybe it is --

20 COMMITTEE MEMBER CARROLL: Oh, maybe it is. No, 21 it's common requirements, I'm sorry.

22 l COMMITTEE MEMBER KERR: I was just curious about 23 what was meant by the statement, 24 25

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50 1 "However the Staff recommends that 2 ' protection 1of the RPVifrom brittle 3_ fractures not be eliminated because of

4. improved material."

5 Maybe EPRI understands that. statement, I don't.

16 MR.-VINE: I think what they're saying is that

.7 even though we'are addressing in a material sense.the PTS

8. issue to the point that it's apparently resolved, and we

.g are confident it's resolved, t'at nevertheless they want 10 to have the instrumentation 1and surveillance. capsule 11 requirements and so forth necessary to monitortthat 12 throughout life.

13 And our own requirements document calls for such 14 m nitoring capability, and surveillance capsule 15 capability, so.--

16- MR. SUGNET: I think that Mr. Long focused this 37 concern-with respect to the natural circulation question.

18 I'm not aware that.we've dealt with that one, we'd 19 pr bably have to go back and look at that in order to 20 resolve this completely.

21 COMMITTEE MEMBER KERR: Okay, thank you. '

22 MR. LONG: I think'the or'ginal issue was 23 whether the vessel material spet fi ations would eliminate 24 the need for an Appendix G and and Appendix U material 25 . surveillance program, and the need for thermocouple. 1 O

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1 And we haven't accepted that, we still cecognize 2 _ that there will be a saeed- to put the specimens in the 3' vessel and have a removal schedule and periodically test 4 them and monitor the shift in the vessel, in accordance 5 with the current regulations.

6 And my understanding is that you do intend to 7 comply with the Appendix G and Appendix H requirements for 8

material surveillance program. I haven't seen a topic 9 paper or anything that would indicate an exception to 10 that.

11 MR. VINE: Our requirements document specifies 12 such systems and capabilities. I don't remember if it 13 specifically refers to.the 10 CFR 50 appendices.

O 14 COMMITTEE MEMBER KERR: Is that because you 15 think it's impossiole to avoid the problem, or you just don't hae evidence that it can be avoided at this point?

16 17 MR. LONG: No, we --

MR. VINE: I think we're intending to follow 18 19 those requirements, from what I understand.

MR. RUDENSTEIN: Let me answer that. We would 20 believe that alloyed design can carry this subject quite 21 22 away. However, we haven't seen that kind of evidence that 23 w uld suggest that it's been proven.

COMMITTEE MEMBER KERR: That seems like a  ;

24 25 reasonable --

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.1 -COMMITTEE MEMBER CARROLL: I'm still. confused

2. about this thermocouple issue <we've just' discussed. That

! 3 'statementJappears in the boiling-water reactor section, 4 and I'm not sure I understand about natural circulation 5 D*8DI"9: f boiling water reactors. I thought that was 6 kind of'how they worked with a little bit of help.

7 MR. LONG: Well, that is --

8 COMMITTEE MEMBER CARROLL: When you were talking g about natural c'irculation testing'--

MR. LONG: I.was-talking about PWR's of course.

10 The last issue is 60-year control rod drive 39 12 life, and I didn't have any comments on this. I think 13 this_ relates to our review being a 60-year. review versus a g 40-year review.

15 Could we go to the next item on the agenda?

CHAIRMAN WYLIE: This might be a good time to 16 take a break, since we had one scheduled at ten, before we 7

move on.

gg MR. MILLER: Mr. Chairman --

HA MA  : Are we ug a ng about 20 Chapter 4?

21 MR. MILLER: Yes. That's what I was going to 22 ask, do you have additional questions concerning 23 Chapter 4, maybe'before we take'a break?

24 25

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y on.page:17. .

.I' gather'that=it.is'being proposed that the 2 moderator temperature' coefficient not be much different 3 than existing moderator temperature coefficients.

4 And I must say that this concerns me a great deal ~, because of the implications for ATWS. -You're 5

1

.saying, because -- particularly with PWR's, I would think 6

that it would not be very difficult, starting' from 7

scratch, to design a system that could ride an-ATWS out, 8 .

.g and you wouldn't have to worry about this.very high reliability'of shutdown systems that is now relied upon.

10 And it doesn't sound to me as if that has 39 urred.

2 MR. VINE: The recluirements document specifies L 13 g that the reactor must have a negative. power coefficient at all times throughout the design life of the plant, under 15 all conditions, 16 COMMITTEE MEMBER KERR: But is it, together with-p 18 a relievin9 apacity, going to be sufficient that if one had an-ATWS, one' simply wouldn't have to worry about it 39 1

very mucM 20 g MR. RUBENSTEIN:

I believe GE is proposing to us that ability, although we haven't'gotten into details.

21 g COMMITTEE MEMBER KERR: .What about PWR?

g MR. RUBENSTEIN: Oh --

MR. .SUGNET: I think, Dr. Kerr, for the PWR we g

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.1 have improved-the moderator coefficient situation,-as Gary

.,1 2 Vine.just. described.-

l3 Certainly you can get stronger-negative feedback.

1 if y u want it, and if you.wa.nt to pay for it --

4 COMMITTEE MEMBER KERR: Yeah.

5 MR. SUGNET: --

-in the plant, and the core 6

7 ec n mics. And'I!think we believe that the values that-we've called for in Chapter 4 of the requirements are 8

g satisfactory'to' meet the plant needs, also to deal with j

the ATWS conditions and to meet the requirements as they y exist right now.

COMMITTEE. MEMBER KERR: I want you to look sometime and see if-you're convinced that one.can demonstrate a ten to the minus five unavailability for the:

9-scram system. And once.you decide you Can do it, I Want you to demonstrate -- I want you to show me how you can 6

g- demonstrate that that's achieved.

If I were a plant operator, I would worry about 18 that. With existing plants, we don't have any choice, 19 perhaps, but with new plants, we do. And that, I think, is something that ought to be looked at very carefully.

g W 11, I think something ought to be done about 22 it, and I just looked'at it. It certainly is going to 23 g cost you a bit'in the fuel cycle, I don't have any idea how much. I think the clever designers might make the 25 O

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(.]) 1 cost.not very much.

2 And it would make me sleep easier at night, if I 3 didn't have to depend on an unreliability of ten to the 4 minus five for demand for the automatic shutdown system.

5 And that's what one sees in typical PRA's today.

6 MR. SUGNET: I don't think it's assumed to be 1 7 that low, Doctor. My recollection is a number more like 8 ten to the minus four range --

9 COMMITTEE MEMBER KERR: Well, go back and have 10 another look. I believe --

11 MR. SUGNET: I'll do that. l 12 COMMITTEE MEMBER KERR: Ten to the minus four s 13 was built into the system some years ago, but --

14 COMMITTEE MEMBER CARROLL: Where is that i

15 addressed? The reliability of the scram system?

16 MR. SUGNET: There is no requirement --

17 COMMITTEE MEMBER CARROLL: You don't have one.

18 MR. SUGNET: Our requirements document placed 19 unreliability of the scram system -- it would factor into 20 the top level targets for both core damage frequency and 21 release frequency.

22 COMMITTEE MEMBER CARROLL: But you haven't j I

23 addressed it per se. j 24 MR. SUGNET: We've not allocated any particular 25 unavailability to the scram system.

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'1 COMMITTEE. MEMBER KERR: There isn't any'_other L

"2= system or subsystem-that I'know'of, at wh'ich that level.of 3 reliability.is required. At least in order of magnitude 4

m re than anything else.

MR. RUBENSTEIN:- To~ help out EPRI, I do believe-5 that_the' actual designs of the vendors have made 6

7 ' improvements. GE has gone through this' dual drive' system hydraulic and electrical, and we'll be.looking at the-8' g

specific numbers. We probably --

O M TEE MEMBER KERR: When-you get to the 10

_qq point where you are convinced that that level of unreliability can be demonstrated, I want to see the 12 demonstradon, m 13 g MR. RUBENSTEIN: I didn't quite get that.far yet. .I said I think they've' improved.their system, and 15 they;have a fair amount of data, but we haven't looked at 16

.it in~the relative depth:to make that conclusion yet.

17 Their numbers,for ATWS,pif you'believe the PRA's 18 in the preliminary presentations that we've had, are very 39 impressive. However, we haven't really reviewed that yet.

20 -

COMMITTEE MEMBER CARFOLL: Bill's point is, up 21 fr nt they're design things you might do, so you're not 22 .

relying on such unreliability.

23 Is the Westinghouse still basically the mag 24 ja k, is that what I'm reading in here? The PWR?

25 O

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57-L1' MR. SUGNET: Yes, the.PWR's,-we plan to use 2 ~ drives'similar to-the current' generation plants,~which are 3 the magnetic. jack.

-4 COMMITTEE MEMBER CARROLL: There will belan ACRS 5 letter coming out this week ab'out our meeting last week, 6 where we talked about that issue,' and about the .

~7 recommendation the. Staff'had made that there be some way 8 to'either put a breaker <in~the power supply from the motor 9 generator: sets, or put a field breaker in, or Charlie 10 likes a co'n trol scheme.that takes'the field voltage off.

11 (That's a Staff recommendation that ACRS 12 concurred in. 1 13 "MR.'SUGNET:- This is as a supplement to the

~

O 14 scram [ breaker opening?

15 COMMITTEE l MEMBER CARROLL: Specifically singles ' <

16 out advanced light water-reactors in the Staff

~. + ,

'17 recommendation'. -ButLthats what' led Bill to say, why are 18' we doing all this, why don't we do things to designs, so

'19 we-don't need these ridiculously high reliabities. I 20 CHAIRMAN WYLIE: I think the point is that I 21 during the early part of the design, it doesn't cost you 22 much to do some of these things, whereas, as you know, 23 that's what your whole program is built on. That you can 24 improve those reliabilities very easily at a small cost.

25 But once the plant's designed, it gets enormous,

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f "m -581 1 ar.d you can't justify it.

2 .MR. LONG: There have been lots of-improvements 3 in the RD. For' example, deletion of the scram discharge.

7, t

~

4' volumes for the BWR's. But how to demonstrate ten to the 5 minus five or something -- that would be a dif ficult job.

6 MR. RUBENSTEIN: The Committee's point is well.

': 7 taken.- The Staff is. limited to the new rule, and a few 8 enhancements. And I'm sure EPRI will consider a 9 reliability goal' carefully in their products.

10 CHAIRMAN WYLIE: Any.other questions? 'Let's 11 take a break until-ten after.

S. 12 .(Thereupon a short recess was taken.)

13 CHAIRMAN WYLIE: Let's resume. .Are we ready for

.O. 14 Chapt'er 5?'.

15 MR. LONG: We've got some issues from'the 16 previous meeting.

17 CHAIRMAN WYLIE: -Oh,'okay. I beg your pardon.

18 (Pause.) i 1

19 MR. VINE: We're going to quickly run through 20 the items that were brought up in discussion of Chapters 2 21 through 4 by the ACRS last week, and maybe share some of 22 the comments back and forth between Staff and ourselves on j 23 responses to these things.

24 -o00-25 MR. VINE: The first item is one of main steam O

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O' 3 line piping supports, and our' requirements' document called ~

for steam' piping supports to-be designed on the basis of

~

( 2

!- 3 lines filled with water.

4 I think the concern may'have partially been due 5

to'a misconception of what we wanted to do. .What we want 6

to make sure the plant is capable of handling is an event 7

whereby the steam lines might be filled with water for a 8

Period'of time, either on steam line overfill or whatever,-

and that the hangers and' supports would be designed to 9

10 . handle such an event.

qq 'And we have talked to various plants, Duke Power in Particular, who currer.cly designs their steam lines to 12.

handle sucht-a load, and we found that there's no real 13 14 pr blems with;..the' design of supports to:be able to do 15 that.

The supports'are a little more substantial, but 16 37 there's no problem with the range over' which the supports have to handle either dead weight or no additional 1 water 18 loading. -And so we will be revising the' chapter to 19 ,

20 clarify that the intent'here is to avoid concern over i

21 verstressing the supports if the steam lines are filled with water, but we don't see a design problem associated 22 with the supports to be able to do that.

23 MR. LONG: The issue was, if it's not clear to

  • 24

-25 y u is that when the lines are filled with water, they

O l

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  • Q' approximately double.in weight, and I guess the concern.

1 f, 2 was, what tension' settings would you use'on the spring 3' . hangers, because each constant support, variable support 4; spring hanger would-have to be set and adjusted for a P_ articular dead. load'or' normal operating load, and I think 5-they've: satisfactorily addressed the issue.

.6 Everything would be adjusted for normal 7

peration, but be~ capable of withstanding the additional-8 .

1 ad. 'So the. hangers, I presume, would be~ set for:--

. 9

.MR. VINE: Normal operation.

10 gg :MR.' LONG: For normal operation, with just the steam.in them.

12 13 MR. VINE: That's right, thank you.

O g -o0o-MR. VINE: Reactor coolant pump oil change 15 aPability. We require that the system have.a -- that the 16 plant have a system that will facilitate changing the oil 37 during the plant shutdown.

18 19 Now,'the' concern was spurious actuation of such a system, and in particular, the possiblity that the 20 I

Perator might be able to remotely initiate some' oil 21 hange system and drain the oil from the pump during 22 1

peration. And that's clearly not the intent. This is a 23 shutdown and maintenance type system for facilitating oil 24 changes more expeditiously and will not be capable of 25 O

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l O 1 being' operated from the control room or.outside the 2 containment.

3 We will revise the language to make sure that 4

this is' clearly stated, and that there will be positive 5 assurance.that no operator action with the plant in 6 ' operation can result in draining the oil from the pump 7 motor bearings.

'8 COMMITTEE MEMBER CARROLL: Can you add oil ~

9 easily during operation?

10 ,

MR. VINE: I don't think so. Dave, do you 11 ' happen to'know the answer to that?

12 MR. STRAWSON: I'm'not'sure.

13' COMMITTEE MEMBER CARROLL: I was just asking.

O 14- MR.-VINE: We can look at that.

15 -o0o-16 MR. VINE: RPV natural circulation cooldowns.

17 As Bill already said earlier today,"we in our requirements ~

. 18 document specified that the plant be capable of handling.a 19 natural circulation cooldown, we designed for that.

20 Obviously, the question comes up, how many 21 cycles can you handle. We looked at this and felt that a

22. number ~ suggested by the Staff of 30 was within the design
23. capability of the plant and therefore we've listed'that as 24 a design requirement. And we'll include that in the 25 roll-up of the chapter.

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.1- COMMITTEE MEMBER' CARROLL: This should' indicate 2' that:it's a PWR ---

Si MR. VINE:

Yes. That's correct.

14 -o0o-5 MR. VINE:'2A', question came up-about zinc'and 6 cadmium plaied: plated mechanical fasteners, galvanized 7 mechanical 1f as teners'. -There was some concern that such 8 fasteners could:be?dr'opped.intolthe fuel. pool area and g possibly put contamination into the coolant.

10 We've lookedLat.this~ issue, looked at the number 11 of fasteners that would have to fall into the pool to 12 create'any noticeable impact at all on contamination of 13 ' primary-coolant as a result of corrosion, and.found that rj4 .theinumber'was so large that this is just not an issue.

15 And-so we're not going to prohibit galvanized mechanical 16 farteners from being used inside containment.

17 COMMITTEE MEMBER CARROLL: How about' mercury 18 vapor lamps?

19 (Laughter.)

20 MR. VINE: That wasn't asked. I'm not sure what 21 our position is on mercury vapor. I don't think we've 22 addressed that.

23 COMMITTEE MEMBER CARROLL: Shouldn't use them 24 any. place that there's any chance of getting it into the i 25 primary system, or into the steam generators on the O

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1 secondary side. Bad stuff.

2 MR. SUGNET: That's.s good comment, we'll take 3 that.into our. Chapter 1 -- I think the Chapter 1 roll-up 4 is probably the proper place.

5 COMMITTEE MEMBER CARROLL: Or mercury monometers 6 are a good source of that also.

7 -o0o-8 MR. VINE: Use of fiberglass. insulation. We

~

9 have some pretty strict requirements about types of 10 insulation that can be used in a plant. We require quick 11 removal insulation, be it reflective metal pipe or l

12 fiberglass with Velcro-type fasteners. And that the 13 insulation design shall assure that containment cump n

i 14 blockage is precluded.

l 15 You can see the rest of the words there. The l

1 16 concern remained to be the blocking of screens and so f

17 forth, which is related to the unresolved safety issue 842 18 that I think was resolved about three or four years ago, 19 making sure that we were in compliance with the Reg Guides 20 and so forth that were the result of that unresolved

, 21 safety issue, t

22 We are in compliance with those Reg Guides, and 23 further we have -- we will be revising the requirement to 24 specifically call for pump sump strainers designed and 25 sized to preclude the clogging of any glass fibers. And 3

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also revised Chapters 5-and 6.

2' COMMITTEE MEMBE'R KERR: Have you --

~

3 MR.. VINE: It's also important to note, and 4 .you'll'see this'when we'go through the Chapter 6 layout, 5 that this'is less of an issue of plant laycut, geometry-6 wise, than it'is on the current plants.

7 COMMITTEE MEMBER KERR: You're sure that that is 8 a requirement that can be achieved by a designer. It's 9 all well and good to say they will be designed and sized 10 to preclude clogging, but can-that be done? If you have 11 fiberglass?

12 MR. VINE: Well,'I think to the extent'that the 13 resolution of the regulatory issue is concerned, we can

~O 14 certainly comply with that, because the current plants --

15 COMMITTEE MEMBER KERR: Look. I'm not 16 interested in regulatory issues as much as I am in how the 17 plant operates. And if a designer is given an impossible 18 task, it doesn't have much significance, does it?

1 y 19 MR. VINE: I believe that the strainers can be I l 20 ' designed, yeah, we've checked this out. And further, as 21 you can see when we go through the layout, this is the 22 accumulation of insulation material that might be broken 23 free in an event is more likely to come in an area where 24 we are not using tlat as a water source for emergency 25 cooling.

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So the strainers are'in a different location,

~

and less1 susceptible to this kind of event. . So we think 2

3

.that thi's isn't going to be:a. problem. And that'the-requirement is achievable.

-o0o-MR.' VINE: Diesel air cooling.- There was;a suggestion that we look into the possiblity of using air-cooling instead of water cooling for the diesels. -We-do currently stipulate that each diesel generator will.have an independent primary cooling water system cooled by component cooling water, and we did look into air cooling, and found that the benefit of air cooling'is.that'you eliminate'a safety grade water cooling system.

O y rhe doweeide 1e thet you edd e fety stede air cooling system. We've looked at the possiblity of direct-drive fans off the shaft, and that appears to be not a very good choice, because of some unreliability problems that have_been associated with that type of a design,.

which puts you into extremely large motor driven fans for the very high flow rates that are necessary, and probably beyond that, for efficiency, you've have to have chillers and heaters to maintain the air temperature at the proper level.

23 And the additional complexity and cost of going this route seemed to be much worse than a cooling water l

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66 O -1 . sys tem . . SoLwe're sticking with a conventional cooling

~

2 water: system, although I should add that we are making.

3' some; significantLimprovementsL in the reliability; of 4 component cooling water, and essential service water, and 5 we'll-not only have higher reliability here, but we'll 6 also have. sufficient capacity, so.that the water cooling
7 isn't. going to.be any kind of a problem, even at the.

8 ultimate heat sink level.

9 COMMITTEE MEMBER CARROLL: There's a plant a few miles down.the coast that uses air cooling and radiators 10 11 that work pretty well. .

12 MR. VINE: Diablo Canyon?

13 COMMITTEE MEMBER CARROLL: (Nods head.)

14 MR. VINE: Okay. Well, the checking we'did, 15 talking to vendors and so forth and some of the utilities 16 was that this was not the best choice. So we've gone this 17 route. But we can check with Diablo Canyon. I'm not sure

'18 that that was checked out.

19 COMMITTEE MEMBER KERR: What does-independent 20 mean in the requirements sentence? Independent of what?

21 Independent primary cooling water.

22 MR. VINE: Well, we require in our requirements 23 document that for every safety system that has support 24 systems, that those support systems must be independent of 25 other divisions, as much as the basic system is.

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1 For' example, here the individual emergency 2 diesel. generator and all of its support systems must be 3 totally independent, physically, mechanically, 4 electrically, from the diesel and all of the support 5

systems for that other diesel in the other division.

6 There's no, for example, commonality or cross-connect 7

between --

8 COMMITTEE MEMBER KERR: So independent means 9

independent of the other diesel or other diesels, as the ase may be.

10 33 MR. VINE: That's correct.

12 COMMITTEE MEMBER CARROLL: So that ssys, if I 13 have three diesels, I have three component cosling water systems. i 14 15 MR. YEDIDIA: From three divisions.

16 MR. VINE: Three divisions, that's right.

37 MR. YEDIDIA: Three divisions of the essential 18 service water system goes with that.

19 00-20 MR. VINE: BWR thermal hydraulic stability. As 21 y u know, there's a lot of interest in this issue, a lot 22 f activity going on in the BWR owners group and with the 23 NRC Sr:ff and GE on resolution of questions in this area 24 f r current plants.

25 We stipulate in our requirements document that o

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the core characteristics':shdll allow-for stable operation,

.i.e., a decay ratio-:less than on for all expected 2

perating nditi ns. And that the core' design be 3

provided for extended-fuel cycle operation at reduced 4

power,.or reduced feedwater temperature.

A concern was still just generally a lack mof-resolution of the issues, and as you know, there's'still some research going on to assure that the resolutions a d 9

We're continuing to review this issue. -

We think we've provided sufficient requirements to address the issue at this point, but we're waiting to see what comes out'of the additional research on the current plant issues O y to see if enere's ear further tee one fro enee twee we should incorporate'into the design.

15 -

S w 're g ing to leave this open-until we see 16 how all the research turns out.

~ ~

18

'MR. VINE: Electric protective assemblies.

Chapters 4, 5 and 11 specify numerous requirements related to protection of of reactor protection system channels.

And the concern was on the propose elimination of EPA's for the scram pilot valves, that we would somehow indroduce some additional risk to the plant.

A d our response is that we've taken a close 5

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69 0 1- look at'this, and have done a lot of things in the overall

~2 P l ant design to address reliability of reactor protection 3- system channels. And~we feel that the addition of EPA's, 4 given all these other~ things we've done, would not be 5

necessary-and would add unnecessary complexity to the 6 design.

7 We specifically will require dedicated 8- uninterruptible power supplies with dedicated DC sources 9 for each of the four reactor protection channels on the 10 BWR. Also, the scram pilot valves are designed for 11 continuous operation over the maximum anticipated range of 12 v ltage'and frequency variations.

13 And as you can see, the allowable voltage and-14 frequency conditions.are identified and monitored-by-15 systems. So we don't see this'to be a problem.

'16 COMMITTEE MEMBER CARROLL: I was just reading 17 yesterday.an information that is about grounds and DC 18 systems, weren't thought to be of sufficient magnitude to 19 cause any problems, and -- where was that, Charlie, do you (

l 20 remember? I can't remember the plant.

l l

21 But it turned out their ground detection system 22 really didn't detect grounds that would disable'certain j l 23 solenoid valve functions.

24 MR. VINE: We'll take a look at that.

25 COMMITTEE MEMBER CARROLL: That's a current one O

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- 1 70 0 1 that's come out in the last couple of weeks.

2 MR. VINE:' Okay.

3- COMMITTEE MEMBER CARROLL: But a lot of people 4 think that DC systems are very reliable. Grounds'can make 5~

them very unreliable, if insufficient attention is given:

6 to ground detection and how it might impact-components' '

7 that are in the system. And if the operators don't pay 8

attention to DC. grounds.

9 MR. VINE: We'll talk about that a little bit-10 when we cover Chapter 11 later today.

11

- Oo-12 MR. VINE: And the last one was heavy equipment

-13 handling. The concern was in general about handling heavy O ,4 eeuipmene over primery coneeinment end me3or componente, 15 Specific with regard to falure of slings.

16 We've taken a look at the requirements, and believe that we have addressed this issue adequately.

17 18 First of all, as you can see, Chapter 7 requires 19 that at ti'o start of ref ueling, all shield blocks over and -

20 adjacent to the reactor pressure vessel are removed and 21 stored, prior to removing the head.

22 The head is installed at the conclusion of 23 refueling before the shield blocks are moved from their 24 storage position, and the steam dryer / separator and pool 25 O

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I shield blocks are not moved over the reactor pressure 2 - vessel cavity.

3 In addition, all.the major comp'nents,-as.they o 4 are moved from the' reactor vessel during refusing, the 5' dryers and so forth, are all sized and the internals are.

6 set up such that if one ofLthose major components were 7 dropped, it'could not reach the fuel.

'8 We're fully in compliance with NUREG 9 requirements out of NUREG 0612, and we believe that'this 10 issue is adequately treated.

11 COMMITTEE MEMBER CARROLL: For both P and BWR's, 12 'have you gotten the diesels and the component cooling 13 water heat'exchangers, to think of a couple of examples, O 14 out of the turbine buildings, so you don't have to worry 15 about turbine building heavy loads?

16 MR. VINE: They're in a different location. I 17 think-you can see that from the -- well, we don't-have 18 layout drawings in the presentation this afternoon, but we 19 i can make some copies and talk to you about the location of 20 those things. I think you'll see that.that's not a 21 problem.

22 COMMITTEE MEMBER CARROLL: Okay. Because there 23 are some very heavy loads, and if they are in that same 24 building, you've got some real interesting problems 25 complying with 0612. I know that.

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'1 MR. VINE: We.have,a' plan, drawing in'the-2 Chapter 6 presentation this afternoon, I think we.can show 3 that that's not the big problem.

4- That covers.the issues-from last. time. - I think 5 ur list is a little bit longer for today, so we'll have a 6 little bit longer presentation next time.

7 MR. LONG: I would.say that the Staff will be l

8 looking at that-EPA issue, when we review Chapter 11 in.

~

9 the future. 'I don't'know whether their response resolved

.10 the ACRS concerns or not, but they do intend to delete or

-11 remove-the EPA's.

12 These are' items which were.backfitted.to earlier 13' .Pl ants, as a result of-some operating events. But that-14 issue will be subject to further staff review.

15 For our.next discussion, we will be talking 16 about the Chapter 5 issues. I have a list of items which 17 we'll talk about, and I'll put the list up here.

18 -o00-19 MR. LONG: I have copies of that list.

20 (Pause.)

21 MR. : LONG: The'first issue is hydrogen 22 generation and containment hydrogen concentration. The 23 requirements document proposes as an optimization issue 24 that 75 percent metal watier reaction for zirconium in the

~

l 25 active clad, and 13 percent global hydrogen concentration O

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2 combustible gas control systems.

3 That is being proposed as an optimization issue, 4 regardless of various regulations and rules currently in 5 effect or proposed.

6 It's the Staff position at this time that 7 hydrogen generation and control for advanced light water 8 reactors comply with the requirements of 10 CFR 5034 (f),

9 which requires, specifies 100 percent metal water reaction-10 and ten percent hydrogen concentration.

11 As part of Chapter 5, a paper, an RCP. topic 12 paper, has been provided to the Staff with their technical 13 justification for the 75 percent and-13 percent numbers.

14 .The. Staff has reviewed the paper and believes that there.

15 are still large uncertainties, and. currently is going to 16 stay with the position that-the'10 CFR 5034. rule should be 17- met.

18 It's being proposed that a meeting be held, _

19 possibly on the 27th of. April -- was it May -- in which 20 EPRI may present further information to the Staff on this 21 subject.

22 At present this is an open item in Chapter 5.

23 COMMITTEE MEMBER KERR: On what basis does one 24- try to decide between 50 percent and 75 percent?

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conservative deterministic requirement, as opposed to a 2 Probabilistic basis.-

3 COMMITTEE MEMBER KERR: Deterministic, what does 4 determinist'ic'mean?

MR. RUBENSTEIN: -Well, excuse me.. -

5 6 Les Rubenstein. In regards-to the_ amount of hydrogen

~

.7 evolution, one goes through the calculation for hydrogen' 8 overpressure and other gas overpressure-on the 9 containment.

10'

'In--terms of' ignition or the ten volume percent' 11 versus thirteen volume percent, what one looks to~in

'12 interpretation of the research data-from the various

' 13:

-Programs which talk about the transition from deflagration O ,, to.aetonation and these other items. Basically, in terms 1'5 f the 1,000 megawatt, these evolutionary-plants that 16 we're discussing, mostly today it's sort of a moot issue, 17 in:that in the BWR, they've proposed an interted 18_ containment.

In terms of the' Westinghouse design, they've 19 20 Proposed"a fairly large dry containment with igniters, and I believe-that -- someone can correct me if I'm wrong --

21 22 that Combusion may also have proposed igniters.

.23 I'think it's a very important issue that we're willing to entertain for the advanced passive plants. We 24 25 w n't get into surface to volume, containment surface to O

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1 75 O' 1 ' volume, questions.versus the hydrogen.

2 .We do have - .this.is part-of the original CPM-L' 3 rule on the 100 percent, and:lt was adopted by the. Staff 4 in 10.CFR Part 52, which was'the recent rule that was 5 recently promulgated: for standardization.

6 However, what we'll do is -- Dr. Miller and Bill 7- Long have been working with EPRI -- is go back over-the.

8 data one more time.- In the case of: evolutionary plants, 9 we'd probably have to give them an exemption, if someone 10 wanted'it, but it seems ' to be moot, as I've said before.

11' In the case of passive plants, I guess we have 12 some time to work more on the data and see how it would-13 come out.

1 14 MR. ARCHIZEL: Ralph Archizel from the plant 15' systems branch. I'd like to add that the 75 percent 16 requirement is really a continuation of the requirement 17 for. current plants. And'the Commission wanted an enhanced 18 capability to cop 9 with hydrogen in the evolutionary:

19 P l ant, so that the: ten percent is not necessarily 20 conservative, but represents a surrogate well beyond all l

21 the metal clad.

22 In addition, you've got the channel, zirc in the 23 channel, you've got stainless steel in the core, it's 24 basically a large uncertainty and this represents a 25 surrogate value which we're willing to accept. We're not O

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so'willing to accept what..the older plants had at_the-2 75 percent level. And that's a little bit of additional.

3 inf rmation. At this-point we're staying.with the CPM-L

' rule.

4 COMMITTEE MEMBER'KERR: I'm not trying to 5

disagree'with you, I'm just'trying to understand the basis 6

for decision. I note for.. example, that if I understood 7

the SER correctly, that you aren't going to require the

~8 g

TID-14844 source term, which is sort of a deterministic determination of the maximum amount of' fission products 0

g that could be available. .

On the other hand,.you are apparently going to 2

require 100 percent: hydrogen. And I'm just curious as to 13 h y. how -- I' don't know what's realistic for. hydrogen, but ertainly 100 percent is probably not.

15.. ,

And you're going away from.the " deterministic,"-

16 in qu tes, source term, I think, but --

17 MR.'ARCHIZEL: It would.be much grater than 18 per en ,.if y u nsider the steel in the core, and 19 all the stainless. We're just talking 100 percent of the 20 21 MR. RUBENSTEIN: Let's separate them out. I 22 doubt what Ralph said about the uncertainty in the use of 23 hydrogen in the containment design. The Staff will 24 discuss source term, and that's another item that EPRI is 25 O

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l ry 11 1 going to include in that meeting that Charlie set up on l 2 the 27th.

3 See, the Staff's position on source term is a 4 little different, we can talk about it tomorrow in more 5 detail. But we haven't moved away dramatically from 6 14844. It's pretty much for siting, and Part 100, those 7 considerations. We're staying fairly close to the source 8 term as proposed and described in calculations in the 9 Reg Guides.

10 There's some flexibility in there, in 11 negotiation in a few areas, but we're going to talk about 12 it.

13 COMMITTEE MEMBER KERR: I understood the O(_/ 14 75 percent rule, because there you assumed that about 15 50 percent occurred in TMI and 100 percent is all that 16 could occur, so you split the difference, and that's 17 logical.

18 (Laughter.)

19 COMMITTEE MEMBER KERR: But the 100 percent 20 is -- well, it's sort of, what you're saying is, 21 100 percent is really not 100 percent, and so you had to 22 decide on 100 percent of something, and -- okay.

23 COMMITTEE MEMBER CARROLL: A couple of 24 clarifications. You said boilers will be required to be 25 inter --

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.j 78 9 1 MR. RUBENSTEIN: No, no, no. I want to be very 2 careful how we talk about this. EPRI has a requirement 3

that says -- and so does the Staff, you have to control 4

hydrogen. And an acceptable approach would be to intert rt use igniters. And General Electric has proposed 5

interting.

6 COMMITTEE MEMBER CARROLL: Okay. Now, have they 7

8 pr p sed interting at all times, or do they still propose the exemption during startup?

9 MR. MILLER: My understanding is that they would 10 be de-inerted during startup.

g COMMITTEE MEMBER CARROLL: It will be?

12 MR. ARCHIZEL: I think that's some exemption for 13 startup testing. I believe they have exemptions for 14 15 limited startup, and it's cumulative on an annual basis.

COMMITTEE MEMBER CARROLL: That's always --

16 MR. RUBENSTEIN: We accept that risk uncertainty 37 n a time dependent basis.

18 COMMITTEE MEMBER CARROLL: That's always 19 bothered me, because although the decay isn't a big 20 factor, following maintenance and startup, is the time in 21 22 my mind that at least you have a higher potential for having some kind of a problem.

23 On the PWR's, the proposal to use igniters is, 24 25 even though they have a very large containment, is coming O

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t 79 G 1 fromIboth Westinghouse and' Combustion?

2 MR. RUBENSTEIN: I'm sure of Westinghouse, and I 3 don't want to' rely on my memory for Combustion, I think it-4 is.

5 It's probably partly driven by the Staff's 6

requirement on hydrogen. It's not clear that a careful-

~

7 calculation on hydrogen overpressure after the burn 8

wouldn't allow a very large dry to get by, but I-think~the g margin and the desirability of that margin'probably has Prompted them to offer those kinds.of things.

- 10 EPRI may have.a different' view, and they may 3$

12 want to talk to you right now.

13 COMMITTEE MEMBER CARROLL: When we're' talking _

about igniters, I guess I've always felt uncomfortable.

14 15 with: the powered igniters. I would feel a-lot mo're 1'6 comfortable with catalytic igniters, if anybody can figure 17 ut how.to do-_.it.- Is'that actively,being considered in 18 -

these designs that_ require igniters?.

MR. SUGNET: Bill Sugnet from EPRI. Let me just 39 20 make a few brief. comments now about this situation. We've 21 planned to make about'.an hour presentation about what we l

22 have called for and why tommorow on this subject, so I think we'll cover it more thoroughly then.

i 23 1

24 COMMITTEE MEMBER CARROLL: That would be fine.

25 MR. SUGNET: As Bill Long indicated, we have J L

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proposed that'the design requirement be able to

, j accommodate the hydrogen generated from oxydation of 75 percent of the active fuel cladding. .This is not 3

75 percent of the total zircalloy in the plant, rather.

4 75 percent of the cladding that surrounds active ceramic fuel.

6

.j So when we quote percent numbers, we're always speaking in terms of percent active fuel clad,.not in terms of percent of total zirCalloy.or percent to.tal metal, and that's the --

COMMITTEE MEMBER KERR: What would inactive fuel clad be?

MR. VINE: Plenum.

13 h MR. SUGNET: There's gas plenum cladding on the tubes.that's an extension. There are fuel spacer grids 5

that are sometimes zircalloy --

COMMITTEE MEMBER KERR: Okay, you aren't ng se.

l 18 MR.'SUGNET: That's correct. There is zircalloy end fittings --

COMMITTEE MEMBER KERR: Okay, that's enough. I g

understand.

MR. SUGNET: So there is additional metals. And we've required that the concentration of hydrogen in the containment be limited to 13 percent or less, to avoid g

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81 q

concerns about detonability. And tomorrow I'll try and 1

l 2 explain in some detail the bases for those two values.

We believe that with those requirements, a large 3

4 dry containment can be provided that wil be able to meet 5 those retirements without the need for a distributed 6

ignition system throughout the containment, possibly with l 7 the need for some local ignition in places where you might 8 expect concentrations of hydrogen.

9 We prefer not to require an ignition system, 10 Simp l y because it is a complexity in the plant design, and 11 we don't wish to add complexities where they aren't necessaty.

12 We have looked into the catalytic ignition 13 14 Possibilities. There is research.being done there that 15 has some promise, but it's not ready for the market today, and we're following that. But obviously that would be a 16 17 very highly preferred alternative to having powered 18 ignition system, if you could_get to that point.

COMMITTEE MEMBER CARROLL: And our discussion of 99 20 hydrogen and containments led me back to another one of my favorite worries. We talked about mercury and zinc and 21 cadmium and a few things.

22 23 I have always had a very serious concern.about 24 fre n getting loose in a containment. And decomposing to hydrochloric and hydrochloric acid. And I've never been 25 PETERS SHORTHAND REPORTING CORPORATION 3336 BRAD $ HAW ROAD. SU;TE 240 SACRAMENTO CAL FORNIA 95827 TELEPHONE (916) 362,2345

1 .

s 82l O' 3 able'to' convince anybody that was a'real' concern. I throw

.that out for what..it's worth, reminding you that 2

3 Westinghouse:in their standard plant today uses-a. freon

4 air conditioning unit.in the seal table' room, comes'with -

5 the equipment.

6 MR. MILLER: If I could recap, Mr. Rubenstein 7

touched on it, with the promulgation of Part'52 by the-8 Commission last week, they adopted by' reference in the 9 rule that future plants should meet the requirements of 5034 (f) , and the CPM-L rule. 'So at thisLpoint in time,'we-10 33 consider that we're bound by regulation on that issue.

12 And future discussions with EPRI on:that matter will touch l n what institutional hurdles need to'be overcome, if a 13

.0 14 technical argument that can convince the Staffcan be 15 made.

16 MR. LONG: Next subject is fire protection. The

~

37 requirements document cites Appendix R for fire protection 18 and safe shutdown capability.

19 The Staff recognizes that Appendix R was a fix 20 f r facilities already having a construction permit, and 21 may not be considered suitable for future designs. The 22 Staff position is that future facilities have fire areas 23 having three-hour boundaries with hot shutdown capability available in event of total loss of any fire area except 24 25 for the primary containment and control room.

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Q 83 1 And that the provisions be made for smoke 2 removal and to assure that fire extinguishing fluids do 3 not affect the safe shutdown capability.

4 Any discussion?

5 EPRI has not addressed the effect this subject 6 would have on their requirements document at this time.

7 The document as it exists now does indicate that 8 Appendix R separation would be used. And we do not really 9 have a feel for the impact of this position, what it would 10 do to the designs.

11 MR. VINE: We've taken a look at the words in 12 SECY 8913, and we haven't had enough time to discuss this 13 matter in detail with the vendors yet. Our initial sense 14 is that in general the design layout provides at least for 15 the safety divisions, pretty close compliance already.

16 It is in areas like the control room, 17 containment, other areas maybe cable spreading rooms and 18 the like, where I really think we have to probably better I 19 understand what you're looking for, and have more dialogue 20 with the vendors, before we are able to determine what the 21 impact would be.

l 22 MR. RUBENSTEIN: Our early feedback is, you l 23 know, cable spreading rooms may -- certainly contr'ol 24 systems and other things, maybe fiberoptics and low l 1

25 voltage components, so these may not be much of a threat.

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84 O 1 MR. ARCHIZEL: Ralph Archizel from the Staff.. I.

2 guess what we're really looking for somewhat~is for you 3 not to be coming in with one use-of a 20-foot separation, 4 for' example, we don't think'you should.be using th'at in 5 the advanced. plant.

6 In addition, we don't think you should.be coming 7 in with exemptions like water' curtains and things li'.e 8-that in the advanced. plants, like all these existing

. 9 P l ants which would'be designed out of the plant, 10 basically.

11_

MR. RUBENSTEIN: Some of the things we've 12 Perceived that one or two of the. vendors wanted to reserve 13 Appendix R in case in construction, they didn't achieve O

D the separation that we all want in design. And they look

'34 15 to that as a fall-back.

16 That.probably will not" fly.. We're. fairly firm .

17 on wanting these degrees of separation. So I'm not sure 18 there's a hell of a lot of give in'there.

19 MR. LONG: The Staff. position postulates the 20 1 ss of all equipment in a fire area, even if there's no combustibles in there. Could be transient combustibles', is 21 22 the position. So rather than do all of the fire hazards 23 analyses that we've been doing in the past, we bypassed 24 ths.t and just assumed that the whole space and everything 25 in it is lost.

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85 COMIITTEE MEMBER KERR: What if somebody came in 2 with a proposal that one use metallic sheath cables, would 3 Staff position be unchanged?

4 MR. LONG: That's right. That's what I've been t Id, that there could still be transient combustibles in a 5

6 space, and even if all the permanently installed equipment is non-combustible, we would postulate the loss of that 7

8 fire area.

MR. RUBENSTEIN: That's a more deterministic 9

answer. Let me try from where we're trying to go, we 10 started out philosophically trying to achieve very much 33 what we had in safeguards. We'd like to identify a fire 12 area where the loss of all the systems and components in 13 that fire area would not preclude the plant from being 14 able to achieve shutdown by using a train or a system in 15 16 s me other protected fire area.

If it was shielded in such a way that you had 17 tw trains of systems necessary to bring the plant to a 18 hot shutac, >r , I think we'd consider very carefully, my own 3 19 l 20 P i nion is, we probably would not buy it.

It's not necessary at this time to fall back on 21 that kind of a design. The separation for fire protection 22 feeds back very adequately for sabotage, and I think the 23 designers and the utility requirements document people get 24 a lot of their satisfaction of sabotage adherence to 25 O

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1 86 O~ requirements from the fire protection separation rules.

COMMITTEE MEMBER KERR: Does the Staff position.

2 also include interactions from the products of the fire 3

plus the fire extinguishing medium?

4 MR.-LONG: .Yes, sir. The fire extinguishing 5

fluids and smoke removal would have to be considered.

6 COMMITTEE ~ MEMBER KERR: ' Its interactions on 7

8 MR. LONG: I'm not sure of the question, sir.

COMMITTEE MEMBER KERR: Well, I mean,-you're-assuming you've got complete destruction in one fire. zone,-

but the analysis would have to consider the other fire zones as far as smoke and --

13

-%,O/ .

MR. LONG: Yes.

MR. RUBENSTEIN: Yes.

'MR. MILLER: I.think the general philosophy here is to try to. encourage design enhancements that can be much more easily achieved up~ front, as opposed-to the situation that we found ourselves in with Appendix'R,

~

l where it was a case of having an already built plant, and l 20 .1 have to backfit for provisions to try to mitigate the g

consequences of fires.

COMMITTEE MEMBER KERR: No, I would only hope

~

that you would maintain a certain amount of flexibility.

'25 l

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.Because:what you're trying to' achieve is decrease'the' risk

3 f fi'**

2

3 MR. M M ER
Yes.

4 COMMITTEE MEMBER KERR: As well' as t'o formulate a regulation that can be interpreted. And you don't want 5

to do something tidiculous, just'in order to formulate'a-

, regulation,that's easy to interpret. I'm sure you don't 7

want to do that.-

,MR. LONG: I don't think we're talking about'a 9

new regulation.

-MR. MILLER: I don't think tha*.'s~our intent. ,

COMMITTEE MEMBER KERR: Well, I mean, for example, when you assume 100 percent destruction of-13 O 14 everyehing in e u te zome, ehet's eesy ee intergree. uu just forget everything in the fire' zone. I don't know I whether it makes any sense or not. You know, it seems to I. 16 me some thought needs to be given to that and its implications, because all this stuff costs money, and we all lose if we spend money needlessly.

MR. VINE: I'd like to add a point here.' There are two other factors that lom very important-in my mind on fire. And before I discuss them, I just want to say g that we have taken this issue of fire very seriously in the requirements document, and you'll see that we've addressed fire concerns in;a number of chapters, and have, O

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-h- ~1-

,I believe, made some.significant improvements in the 2 design.to address' fire issues', and we'll continue to look 3 at any further suggestions from anyone, industry or NRC, j where the requirements still might have a weakness.

The. two things that are very linportant in my 5

mind are, first'of all, what ILbelieve is a serious 6.

7-misconception ab'out the core damage risk from fire. We

'8' have looked very hard at this issue here at EPRI, and we've_f und that fire is a very important issue for 9

investment protection, and certainly the operating 10

$3

_ experience demonstrates that it's a frequent event that 12 needs to be dealtfwith.

13-We've looked carefully at the PRA's that have been done in this area, and they basically _ assume 14 extremely conservative models, extremely conservative 15 reliabilities for fire protection; equipment, theyfassume 16 37

.no operator action, and a lot o'f other things'that add up to numbers that'are usually, from what we'velseen in a 18 19 couple comparative analyses, two to three orders of 20 magnitude.off.

And I think this needs to be kept in perspective 21 22 as we look at this issue.

The second thing I think we need to recognize is-23 that there's a very, very active dialogue going on on the-24 fire issues, between your external event working group, I l 25 O

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89 1 think is what it's called, and Newmark, and specifically.

2 they are addressing the fire issue.

3 'I think we all ought to be very. aware of what

~

4 comes out of that dialogue. There will be some technical 5 conclusions about what's needed and what's not needed out 6 of that dialogue, and I think there are some lessons that 7 can be learned from.that for us.

8- My only fear is that if there's no flexibility.

9 on.these. issues, that we might find later that-the 10 implication is that it's requiring something of us that's 11 impossible to achieve. And we need to better understand 12 exactly what it'is'you want, so that we can better assess 13 what the impact will be.

.14 . MR. LONG: I might note that we don't have a 15 real strong feel'for the implications of that requirement.

16 The present feeling is that the current divisional 17 separation requirements will provide a lot of what this 18 Position would'requir~e.

19 MR.' VINE: Um-hmm.

l 20 MR. LONG: The next issue is the standby liquid l~

21 ' control system requirements.

22 The ATWS rule requires that a standby liquid 23  ; control system for a plant receiving a construction permit 2<4 after 7/26/84, have automatic initiation. The rule also 25 sets minimum requirements for pump GPM injection rates.

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1 Chapter 5 does not specifically reference or 2-invoke the ATWS rule, saying that the ALWR's will comply 3 with it. Nor does it invoke these requirements, and in 4

fact, conflicts with the rule in specifically providing for manual initiation only on the standby liquid control 5

6 system.

Since this is a potential exemption or deviation 7 i fr m the rule, it's an open issue with the Staff for 8

9 Chapter 5.

10 Any discussicq?

COMMITTEE MEMBEP KERR: Does PRA give any 11 12 guidance as to risk involved in this alternative?

MR. LONG: No, but it's the Staff's intention to 13 O

kl 34 request General Electric to provide a reliability analysis 15 f a manual select initiation.

16 MR. MILLER: We've asked General Electric to do 17 that, and we want to be able to look at what they give us n its own merits, and I think as Les said, there's some

, 18 i

flexibility there.

19 COMMITTEE MEMBER KERR: I would say there are at 20 21 least two BWR plants that have been analyzed in 1150, and 22 y u might -- I don't remember the details of what was 23 assumed, but you might want to look at that as well..

COMMITTEE MEMBER CARROLL: For my edification, 24 25 what's the flow rate issue?

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MR. LONG: .The rule specifies ~80 GPM flow rate. .

2 The requirements document puts in a' performance requirement, but no' minimum flow rate.

3 4

. COMMITTEE MEMBER CARROLL: Eighty. gallons a minute _of what concentration, for what size' plant? What

" inventory of Coolant?

' MR . .LONG: Well;--

7 COMMITTEE MEMBER CARROLL: Sounds like a.' dumb 8

ule.

9 (Laughter.)

MR.'LONG: It has caused some problems.

MR. RUBENSTEIN: In the present context, the_one-ABWR.we're talking about is a very mature design,~and we-Oy mer heve eoteen in fect ceuehe og in the sereon on thee 15 E# # ^

  • MR. LONG: Next issue,_ Chapter 5 of the 16 requirements document proposes that the BWR suppression pool have a negligible bypass leakage rate, which would 18 nable the spray system to be non safety grade. With the 19 very 1 w bypass leakage rates, the spray system would not 20 be required to mitigate any design basic event.

21 The current standard review plan requires a 22 safety grade drywell and wetwell spray for BWR's. This is 23 an p n issue in our Chapter 5 draf t SER.

24 COMMITTEE MEMBER KERR: Any justification given 25 O-PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO. CAUFORNIA 95827 TEl.EPHONE (916) 362-2345

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by EPRI for that change? l 2 MR. ARCHIZEL: Ralph Archizel from Staff. I 3 don't know, we haven't gone out with questions on this  ;

4 particular issue yet in addition to'the pool bypass 5 considerations. We haven't been provided a number.

6 COMMITTEE MEMBER KERR: Okay.

7 MR. ARCHIZEL: And we want to compare it with 8 the BWR-2 versus BWR-3, and the ones, and it ought to have 9 some improved capability over the ones, like 100 per 10 square foot or something like that bypass capability. I 11 haven't been able to evaluate that issue yet. We haven't 12 gotten an answer --

13 COMMITTEE MEMBER KERR: Okay.

U 14 MR. ARCHIZEL: In addition, we're interested in 15 the environmental qualifications of the equipment for the 16 drywall spray system, and do they count on the drywall 17 spray system, and do they count on the drywall sprays to 18 be superheating and things like that. So we basically 19 haven't communicated that, I guess.

20 MR. LONG: The next item is the suppression pool 21 temperature monitoring system. Chapter 5 of the 22 requirements document has not clearly described a 23 suppression pool temperature monitoring system that would 24 enable plant operators to determine bulk and local 25 suppression pool temperatures for use during, in O

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-s 93 k_) conjunction with the emergency operating procedures.

1 2 There is a NUREG, 0783, which provides guidance 3 for the design cf a temperature monitoring system, which 4 we believe should be referenced in the requirements 5 document, to ensure an adequate temperature monitoring 6 system.

7 This could possibly addressed in the Chapter 11 8 on instrumentation, if not in Chapter 5.

9 Next issue is use of remote manual versus 10 automatic containment isolation valves for essential but 11 non-ESF systems. The requirements document would allow 12 the plant designer'to provide remote. manual instead of

,_ 13 automatic isolation valve control for essential 14 containment. isolation valves which are not part of ESF 15 systems.

16 COMMITTEE MEMBER KERR: Excuse me. What is 17 meant by " remote manual"?

18 MR. LONG: The operator would hae direct 19 OPen/close controls from the control room.

20 COMMITTEE MEMBER KERR: Thank you.

21 MR. LONG: But it would not be automatically 22 Opened or closed.

23 And as we discussed earlier, the reactor coolant 24 pump component seal cooling line is an example of such a 25 line. The Staff will permit on a case-by-case basis the

/

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1 deletion of the-automatic isolation feature for such 2- systems, but we're reluctant to approve.the current 3 l'anguage in-the. requirements document that would give.the 4

plant designer-control over.this violation of Appendix J-5 of the Part.50.-

6 -Any comment?

7 MR. SUGNET: I'd just like to add from EPRI's 8 perspective, this looks to us in'every case,.it looks like 9- a. trade-off. If we:have a situation that's important to .j 10 keep.an operating. system'on line inside the containment, 11 we have to'make a decision as to whether we want to 12 automatically isolate that.

13 We ooviously have to have the capability to

'O '

14' isolate,.the question is,.when you have an isolatior.

15  : signal, do you require that line to 5: automatically

.16 closed, or'do you leave it open with the capability to 17 close it from the control room.

18 This is some: .s: t< hat we have to have a case-19 by-case judgment made, if ynd have a closed fluid system 20 inside containment, it would seem reasonable that it's l 21 unlikely to have any radionuclei leakage into that system 22 to begin with, and a remote isolation outside should 23 suffice. And'I think that's the kind of position that 24 we're advancing for consideration.

25 gut we realize that we have to look at this on a o )

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I line-by-line basis and discuss it with Staff.

2 MR.'SHUM: 'This.is David Shum. We realize what~

3 you're doing, and'we, you know,-are. aware on some lines-4 that youineed,.you know,'the sense of operations.

'5 However,-you say you don't need to'-- it's all right, case 6 by. case, you know, it's all right, you don't need to have 7 an automatic isolation signal. You can use remote manual.

8 .However, you have to meet the -- I;mean,.what 9 .has been.est'ablished in ANSI standards. -ANSI standards 10 N27176,Eand it does t'end, as we say, that.you have to-II provide leakage: detection systems. And be able to-12 identify just'the line -- so that the operator can 13 manually > isolate.'it. It's..very well described in the ANSI'

.O.

14 standard.s'We have proposed the ANSI standard.

15 COMMITTEE MEMBER KERR: But if somebody should l

16 determine that the ANSI standard was perhaps out of date, 17 .you would certainly list'en to a logical argume'nt, wouldn't 18 you?

19 MR. ARCHIZEL: In addition, we also have TMI 20 requ'irements on diverse isclation of non-essential --

21' reactive coolant pump seals at many plants are still~

22 isolated today on the very high pressure containment 23 signals --

24 COMMITTEE MEMBER KERR: I'm simply suggesting 25 that this is a new system, and one wants to look at

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--O< 1' possible improvements. And'I would hope the Staff would 2 " keep an open mind', and I'm sure it will,.with the 3 Progressive forward looking people that are on the Staff, 4 and I have no doubt thatthat will-be the case.

5 MR. SHUM: Again,' for the time being,'we are 6 reviewing . these EPRI documents against the SRP..

7 ,

COMMITTEE; MEMBER.KERR:' Yeah.

8 , MR. SHUM: .You know, that's.the only place --

g COMMITTEE MEMBER KERR: Well, it's the only 10 place.you have'unless you go to the Commission and say,

, .11 look, it doesn't make~ sense to review this under the SRP 12 exactly, we ought to be"doing it some other way. And the 13- Commission - the people on the Commission don't have the

!\- 14 technical expertise to make some of the decisions that you 15- guys have.

.16 And you know, if you run into an impasse, 17 because of regulations, it's your responsibility to tell 18 .the Commission.

19 MR. ARCHIZEL: I guess at this point it's not 20 . complete designs we're presented with, so it's very hard 21 to examine what particular lines you're talking about.

22 COMMITTEE MEMBER KERR: This may not be the time o 23 to do it. I'm simply saying, dont' be restricted by the 1^

24 fact that the Commission hasn't received a 1ood 25 recommendation from your' guys. They do listen to you, O

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Ive'seen them do it.

1 -

2 LMR.TRUBENSTEIN: We would agree that the SRP is 3 only a starting. point.

4 COMMITTEE MEMBER CARROLL: And' don't wait so-5 long that the SRP becomes.the fait accompli, either.

6 MR.~RUBENSTEIN: .As you can see from the large 7 number of issues in' Chapter 5 that Bill has on the screen, 8 that' many of these are in negot'iation..

9 ~MR. LONG: [The.next issue is use of a single

1 10 isolation valve for lines outside of containment, which

- 11 connect-to the in-containment refueling water storage-12 tank.

13 The~PWR, ALWR's have an internal refueling water 14 storage tank, which is being considered as analogous to a 15 suppression. pool, with respect to isolation valves to the 16 lines connecting, which pass through the containment 17 barrier.

18 When a line conntects to a BWR suppression pool, 19 if conditions are met, we allow the use of a single 20 isolation valve instead of two valves in that line. And 21 the question arises, should the PWR's have the same 22 treatment.

23 And we would like to note, though, in the BWR's 24 the lines are passed outside of containment through 25 controlled leakage compartments. Watertight VSF O

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1' compartments, and it has not been indicated in the 2 requirements document that these same conditions would be 3 met for the PWR's, for which the single isolation valve'is g.

4 being proposed.>

5 .So we feel the requirements document needs to be

~

6 clarified, that if'a single valve'instead of two valves is ,

l 7 going to be used, similar to.the use.in the BWR's you.  !

8 would also have to~ meet these requirements'for the 9 " compartment in"which_the; valve is located, that.would be 10 essentially a tight compartment.

11 MR. ARCHIZEL:' The other alternatives: include 12  ;-like a capsulated containment isolation valve on the 13 exterior to contain, but those are alternative.

O 14 arrangements, when we don't have an inside containment 15 isolation valve.

16 But those also haven't been addressed bylEPRI, 17 which approach are they taking.

18 COMMITTEE MEMBER KERR: .What about the advanced 19 BWR, are you permitting this single isolation valve for 20 the advanced BWR, and have you looked at --

21 MR. SHUM: It's still~under review.

22 COMMITTEE MEMBER KERR: Have you looked at this 23 from a risk point of view?

I 24 MR. SHUM: We looked at it.

25 COKMITTEE MEMBER KERR: Should there be a single PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO. CALIFORNIA 95827 TELEPHONE (916) 362 2345

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. Q'N I isolation valve for BWR?

2 MR."SHUM: We are looking at that. We-still

, 3 have a problem withiit.

lr 4- COMMITTEE MEMBER CARROLL: Is this refueling 5 storage. tank vented to the containment?

6 MR. ' LO'NG : Yes.

7 -COMMITTEE MEMBER CARROLL: That seems to me to 8 be a difference-from a' suppression tank, then.

l.

u 9 MR. LONG: .Why?

10 MR. STRAWSON: It's always filled with-water,'

l- 11 and the line to which'it's found'is -- Dave Strawson -- to 12 us,. it looks very similar to 'the BWR' situation. We have a 13 -line coming from-historically the containment sump,-which 14 in the past had a single isolation valve, contingent on 15 the valve-being enclosed by a leak-tight enclosure.

16 We have made a big change.in this plant, and we 17 have an in-containment tank that will always have water in 18 it. This valve will always see water,.not air, similar to 19 a BWR.

20 And the intent here was to get rid of the tight 21 enclosure around the valve which makes maintenance 22 difficult, access to the valve difficult. We in effect 23 want parity with a BWR.

24 MR. LONG: We've allowed that in BWR's because 25 PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO. CALIFORNIA 95827 TELEPHONE (916) 362 2345

l 100 h the, compartment containing the valve is essentially an enclosure.

2 COMMITTEE MEMBER KERR: I don't.see why you want 3 ..

parity with a BWR. It seems to me what you. want is a low-4 risk. operation.

5

'MR. STRAWSON: Well, we want a. low-risk

,6 . . . . . .

operation, but..a valve which can --

'7 COMMITTEE MEMBER KERR: And if what you're 8

proposing h'as no consequences as far as risk is concerned, I 9

it makes sense. 'But not because you get parity with a-10 BWR.

11 MR. LONG: Have we beat that one to death?-

'12 (Laughter.)

13 MR. ~LONG: Next issue is the elimination of type-C local leak rate tests for valves' enclosed. systems 15 outside' containment, which qualify.as extension of 16 containment. ,

17 Current regulations, Appendix J and also the

-18 ANSI standards require local leak rate test for an 19 isolation valve installed in a piping system which is a 20 closed system outside.of containment. Also in the +

21 standard criteria are defined what you use to qualify a 22 system as a closed system, which is an extension of the l 23  !

containment.

24 The requirements' document optimization would 25

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0 1-eliminate'thez tight seat test, and treat the closed system 2 as'part"of containment during the. integrated _ leak rate 3 test, the typeA' test, and that'would be the only leakage 4 ~ test which the valve sees.

5 And that would-mean that the seat-leakage of the 6 valve is not being' tested, only the pressure boundary or 7 the stem' leakage is being tested.

8 The Staff is questioning this requirement, the 9 deletion of a type-C test. .The present position is that 10 the type-C test should be conducted in these systems.

11 COMMITTEE MEMBER KERR: Just for my 12 illumination. Why does'the integrated test not check the 13 seat-leakage?

14 MR. ARCHIZEL: Because the valve would'be open.

15 It's a closed system outside containment, requires the 16 system be open, filled with water for the integrated 17 type-A test.

18 COMMITTEE MEMBER KERR: Oh, okay, thank you.

~

19 MR. LONG: If the valve seat did leak during the 20 test, it would only leak right back into e,ntainment, 21 because it's just a line coming out of th containment and 22 going right back in. So you need a type-C test to 23 determine if there is seat leakage.

24 Chapter 5 proposes a 30-month local leak rate 25 test interval for the ALWR's, both BWR's and PWR's. This

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I requirement [is'being. proposed in support of 24-month 2 -refueling-cycles.

3

.This would require an exemption to Appendix-J 4 requirements-of Part'50. And we don't have_a mechanism to

-5 incorporate this.into:the requirements document, because-6 it would violate the rule.

7 COMMITTEE MEMBER CARROLL: Have people asked for

'8 such exemptions yet on' existing plants, that people are 9 going't'owards 24-month refueling intervals, or are they 10 just shutting down for a mini-outage betWeen refueling 11 and --

'12 MR. LONG: Staff has received a lot of exemption 13 requests for a temporary exemption to Part'50, Appendix J, O 14 to allow a plant to complete its operating cycle and to 15 . coast down. It quite often happens that these 24-month 16 local leak rate tests are conducted at the beginning of an 17

~

outage. And if a plant runs into a problem during the 18- outage, and the outage runs a long time, then the plant 19 starts up, the run out of time before they've completed a I

20 their cycle.

21 But those are planned 18-month cycles. What the 22 requirements document is doing is proposing planned 23 24-month cycles.  ;

24 COMMITTEE MEMBER CARROLL: Well, there's 25 certainly utilities out there with operating plants that j l

O '

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4 103 1 are moving ins the'directi'on, at least, of 24-month cycles.

2 I suspect you'll be confronting this problem before it:

3 becomes an issue here.

4 MR. LONG: The position of the Staff is that it 5 is sympathetic to this.. What we need is a good technical 6 argument that'this requirement would not. result in a 7 degradation in containment integrity.

8 MR. ARCHIZEL: We have some additional: issues in 9 this are coming up, an airlock test, and the continuous 10 and periodic leakage monitoring. We'd like EPRI to 11 consider the comments as a whole, in terms of providing 12 some type of leakage monitoring, would go a long way 13 toward: allowing us to see clear to relaxing the 18-month, O 14 if you're going for the 24-month interval.

15 COMMITTEE MEMBER CARROLL: Continuous monitoring 16- wouldn't help this issue, but it would help some of the 17 others.

18 MR. ARCHIZEL: It would help this issue.

19 Continuous monitoring, I guess that went a little bit i 20- ahead -- the reason the Staff on the current plants has 21 not required them to adopt continuous monitoring, one of 22 the principal reasons is the frequency of the type-B test, 23 and that being able to detect gross leakages.

24 When you extent the interval of those type-C 25 tests, the relative value of periodic or continuous O

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monitoring,.' containment integrity.becomes-more important.

+.

2 So it would be a factor in favor of allowing larger 3

frequencies of type-C tests.

4 COMMITTEE MEMBER CARROLL: ~ You're talking closed 5 systems, though. How does a continuous --

6 MR. ARCHIZEL: We weren't.' talking closed ---

7 we're talking all containment' isolation valves--

8 COMMITTEE MEMBER CARROLL: Okay.- But it does 9

not help the closed system kind of isolation valves, that 10 was what I was saying. All right.

11 MR. LONG: We don't have hard evidence to 12 indicate whether valve seat leakage degradation is a 13 function of -- to what extent it's a function of time

,O 14 versus the number of cycles which the valve has been 15 operated. We're asking for a technical justification for 16 an exemption to this requirement.

17 And I understand some work is being done in that 18 area.

18 COMMITTEE MEMBER KERR: It seems to me, antoher 20 reason for this kind of test, though, is it certainly 21 would catch valves that had been inadvertently left open.

22 7.m more concerned about that personally.than I am about 23 seat leakage. i 24 MR. ARCHIZEL: The continuous or short-term j i

25 periodic -- )

1 O  !

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-1 = COMMITTEE MEMBER KERR: Oh, any-sort of-test 2' that' really. tests' leakage, suppocedly would . find valves 3 that had been inadvertently left'open. I would hope so.

4 I have.seen.a recent estimate by some group of 5 . analysts that probably there's at least a ten percent 6 probability that failure of containment or of containment 7_ leakage is likely to be caused by valves-inadvertently 8 left'open. I don'.t have.any.way~of demonstrating that 9 this is the case, but when you look at LER's, there's 10 certainly.a reasonable probability that that's going to

.11 occur.

12 MR. LONG:. Next issue is the airlock local leak 13- rate test after' usage versus every six months.

< - 14 Regulations require testing every six months.

15 The requirements document wants to eliminate the six-month 16 requirement and test after the next entry, or next opening 17 of: the airlock instead.

18 Since that is a conflict with current.

19 regulations, we're treating that as an open item in 20 Chapter 5.

21 COMMITTEE MEMBER KERR: Typically, how 22 frequently would one open an airlock?

23 MR. LONG: Beg pardon?

24 COMMITTEE MEMBER KERR: Is there any typical 25 frequency on which airlocks are likely to be opened? 'I O

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i 106 O 1 mean, is it much longer than six month intervals on the 2 average, or --

3 MR. LONG: You would only open it during 4 operation, if you had to make a containment entry to find 5 a leak or a specific problem.

l COMMITTEE MEMBER CARROLL: I think the practice i 6

varies. A lot of utilities make one entry a day, some 7

8 make one a week, someplace in that range, Bill.

9 COMMITTEE MEMBER KERR: Well, help me 10 understand. Would this requirements document then suggest '

11 that af ter every en;ry there vrould be a test? I'm not 12 certain --

13 MR. LONG: No. What it would eliminate is the 14 requirement that we have now that if nobody has opened it, 15 if the airlock has been undisturbed since the last test, 16 you wouldn't have to test it again, just because your six 17 months ran out.

18 MR. ARCHIZEL: But Bill, the fundamental 19 requirement now is that if you've got a series of openings 20 of an airlock, every three days, you can defer it three 21 days, but at that point, you have to perform a leak rate 22 test on that opening. I think we're talking about things 23 like BWR containments that might be closed for four or 24 five months here.

25 MR. LONG: Okay.

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'I - MR. ARCHIZEL:. But if'you have~a series of 2

openings, you don't have to test after.every opening right/

3 now. ~ You do have to within three days of that series, do 4

a-test.

5 COMMITTEE MEMBER CARROLL: I've always bad the 6 belief that.a clever air lock designer could build into 7 -the interlock mechanism a pretty decent test, not one 6 - that's. going to get down to you know, .000000 percent a 8 day,.but at least tell you whether something bad's 10 happened to the seals, or'whatever.

11 MR. LONG: Some of the existing airlocks require 12 that someone go inside containment and attach strongbacks 13' in' order that they be tested.

.O '14

  • Next issue is, I.believe we've already discussed 15 it to some extent, online containment leakage monitoring, 16 TMI Item 2E43. NUREG 1273' discusses some possible means

'17 of providing continuous-online containment leakage 18 moni Mring .

19 This is probably not going to be required as 20 resolution of that issue for operating plants, but should 21 be considered for advanced light water reactors.

22 COMMITTEE MEMBER KERR: What does "should be 23 considered" mean?

24. MR. LONG: As a minimum, it would require that 25 EPRI address, establish a position on each of the O

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(_/

1 potential means discussed in the NUREG of providing this 1

2 online monitoring capability. And make a case -- either {

3 accept it or make a case against why it shouldn't be 4 considered for ALWR.

5 COMMITTEE MEMBER KERR: It seems to me, you 6 ought to tell them beforehand whether you will accept.  ;

7 Because if your position is you aren't going to accept any 8 argument, no matter what they say, you ought to tell them 9 that.

10 (Laughter.)

l 11 COMMITTEE MEMBER KERR: So they won't have to do 12 all this work.

13 MR. ARCHIZEL: I don't think we've made a O 14 decision that we won't accept it yet. I mean, we would 15 like them to --

16 COMMITTEE MEMBER KERR: Have you made it --

17 MR. ARCHIZEL: Beause if they're not going to 18 provide --

19 COMMITTEE MEMBER KERR: Have you made a decision 20 that you might be talked out of continuous monitoring?

21 MR. ARCHIZEL: I guess that's correct. We might 22 be talked out -- we would like them to reconsider it, 23 seriously consider, in light of the other concerns.

24 Reexamine that issue one more time, and give us a strong 25 argument why not.

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109 I COMMITTEE MEMBER CARROLL: I guess we all'.'now k

2 that the Mark Zero, BWR containment, Humboldt' Bay, did

.3 have continuous monitoring. But at low pressure. We -

4 pumped the drywell up'to 20 inches of water, and the 5 suppression' chamber up to ten. inches of water, the 6 difference being so that you could check leakage,from one 7 to the other, as well as external leakage.

8 And we found that' damn useful,:we caught some, 9 quote "open valves." It doesn't.give you a result 10 -immediately that.you can hang your hat on, but in a' day or 11 two, with appropriate temperature and humidity monitors, 12 and measurement of the makeup nitrogen gas and so forth, 13 it's pretty easy to do.

14 MR. LONG: Also the subatmospheric containments 15 essentially have online leakage monitoring. 4 16 COMMITTEE MEMBER CARROLL: Yeah. But the PWR is 17 a little different problem, because you do h' ave to get in 18 there and fuel-failures or-small leaks that are producing-19 tritium are going to cause some health physics problems 20 for the people that have to get in there.

21 MR. LONG: We feel the issue hasn't been 22 adequately explored for advanced light water reactors. It 23 has been explored for operating reactors, but for advanced 24 reactors.we note that other relaxations are being 25 considered for contai'nments at source terms, increased O

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110 I leakage rates for example. And this impacts how we would 2 address this issue, how we'll resolve this issue.

3 COMMITTEE MEMBER CARROLL: Well, I certainly 4 endorse that look, because I'm convinced there's so darn 5 many valves and other booby traps you can get into, that 6 it gives you some real assurance that you haven't got a 7 hole in the containment while you're operating.

8 MR. SUGNET: I'd just like to comment. We 9 understand what the Staff has said, and we are continuing 10 to consider this matter. We think we have provided some 11 significant improvement in the capability of the plant, 12 for example, by requiring that isolation valves be easily 13 accessible by humans, external to the containment, so that O 14 now when we call for an administrative control, for 15 someone to check the valve position, sometimes he has to 16 get a ladder or scaffold to get to that valve. We're not 17 going to allow that in these designs.

18 But we will give additional consideration to the 19 practicalities of what has been suggested, recognize one 20 of our concerns is the feasibility of an online monitoring 21 system for a large containment. And we are always 22 hesitant to add complexity to the plant design. So those 23 are going to be some of our considerations as we look l 24 t.hrough those.

25 MR. LONG: Next issue is the MSIV leakage O

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)' control system for BWR's.- A leakage control system is ---

1

~

2 briefly,.there are two types, a negative system and a 3 1

' Positive system, and these are provided in more recent 4 ' BWR's to controluthe. leakage from the main steam isolation 5 valves, in order to meet Part 100.

6 A Positive system essentially pressurizes the

.7 space between MSIV's so that any leakage would be into the .

8- containment of clean' air, rather than efficient products g leaking out. And a negative system is a fan'which 10 evacuates the space between the MSIV's and. discharges it-

.11 to a treatment system.

12 The requirements document, and also I might add, 13 the ABWR submittal proposes the elimination of these 14 - systems, these piping systems, and.the associated 15 compressors and fans. And Part 100 would be met by taking 16 credit for holdup in the main steamline piping and the 17 condensor. Any leakage'past the MSIV's flows through the 18 steam tunnel and the turbine building,.and into the 19 coadensor.

20 And during that time period, some holdup due to 21 time delay, plus possible plateout after the piping has 22 cooled, would reduce efficient product activity and credit 23 would be used to meet Part 100.

24 But we note the main steam lines and the 25 condensor are not seismic systems, they're not seismically O

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112 7s d 1 qualified, and there's a problem here in that Part 100, 2 Appendix A requires that earthquakes be considered in 3 meeting Part 100.

l 4 So we have an issue here which is currently 5 being studied by the Staff. It's a generic issue, C-8 for 6 Operating reactors, and the resolution of this will be 7 factored into the ABWR requirements document, the 8 ABWR-FDA, and the EPRI requirements document.

9 MR. MILLER: This is an issue that the Staff has 10 under active review. I would say that we are trying our 11 best to try to come to technical resolution of it.

12 There's a recognition that leakage control systems have 13 both positive and negative attributes, gs

\

14 I think Bill's accurately characterized it, that J

15 the hurdle that we're trying to get over now is the 16 regulation hurdle of the interpretation, the traditional 17 interpretation of Part 100, with regard to the seismic 18 qualification of those systems that are not traditionally 19 seismically qualified, but yet credit is needed in order 20 to meet those requirements of Part 100.

21 MR. ARCHIZEL: I guess the only thing I'd like 22 to just clarify, any system which we're trying to use to 23 mitigate design basis accident historically -- the 24 classical definition of accident mitigation systems for 25 the design basis accidents are the rules of Part 100, so l

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1 y u ne.ed safety related seismic equipment to mitigate 2

design basis accidents. And that's the part you need an 3 ****PDI " E f*

4 The rulemaking allowed use of a non safety 1

related, non-seismic system to mitigation design basis 5

a id ts.

6 COMMITTEE MEMBER CARROLL: I have one other 7

concern, and that would be, if you do have this sort of g leakage, is the idea you're going to have some mechanism for keeping some vacuum on the condensor?

MR. ARCHIZEL: As I remember, the issue that EPRI is going to consider, like in the loss of offsite power for BWR's -- excuse me -- this is a total loss of O u offeite gewer, end they're seine to heve no vecuum in the condensor, and the calculations deal with just the volume holdup, and it would come out --

COMMITTEE MEMBER CARROLL: You're going to have noble gases coming out all the turbine seals, and a very i g badly contaminated turbine building in that ca'se, for whatever that's worth.

MR. RUBENSTEIN: Well, we see it as dominating in t.erms of the BWR source term. In other words, the current tech spec of eleven and a half standard cubic feet per hour that you put on an MSIV for leakage, it Contrasted with the 640 that the requirements document O

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o 114 1 has, or the>100 or 150 that GE needs to meet the Part 100.

2 But'as Charlie ssid,.we're very receptive to

'3 looking.at this,'there's probably a tenuous path where we 4 .can mutually' agree technically that it's workable, but we

-5 have a little bit of working on ourselves to see how we 6 deal with it' regulatory.

7 It.may be that we can just sweep 1it into the 8 design certification hearing.

9 MR. MILLER: Mr. Carroll,"your concern has been 10 recognized by the technical review staff. They translat'ed 11 it from the'effect of tradeoff, and you're going to get 12 some impact on occupational exposure, should someone need 13 to get into that space to perform some other kinds of O '14 duties.

I 15 COMMITTEE MEMBER CARROLL:- Well, furthermore,  ;

i 16 it's'probably a ground level release also, to the extent 17 stuff'gets out.

18 'MR. MILLER: We're wrestling with this problem 19 right now, and trying t'o come to a resolution of it.

20 MR.-RUBENSTEIN: And we would hope EPRI 21 addresses it when they come in in a couple of weeks, if 22 they have any additional information on it.

23 MR. LONG: Next issue is the effect on severe 24 accident capability of use of leak before break and 25 subcompartment pressurization analyses.

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115 0-_ The recent changes to GDC-4, broad scope 1_

2 amendment, specifically. permits the use of leak before 3 break and for use of analyzing pipe restraints, and-in 4 containment subcompartment pressurization analyses.

-5 'And since subcompartment pressurization is often 6 controlling in the design of internal structures in 7 containment, this will result in reduced margins in these

~

18 internal structures. And the effect this might have on

g. severe accident capability is a question our reviewers 10 presently have as an open item in Chapter 5.

11 EPRI has not yet seen this issue or been 12 presented with it, no I don't think they would have 13 anything to say about it at this point, but this is a l- O 14 concern.that we will be presenting to them when we issue 15 . Chapter 5.

16 COMMITTEE MEMBER KERR: When you say-they use 17 leak'before break, does'this assume that they don't assume 18' any break at all, that the leakage detection will catch 19 it, sr do they as'sume some sort of break, but'just not a 20 double-ended instantaneous guillotine break?

21 MR. LONG: You would assume the fracture that 22 results from your-LBB analysis, which would certainly be 23 much less thagn a double-ended guillotine break.

24 COMMITTEE MEMBER KERR: So you do assume some 25 break, but just not the double ended instantaneous --

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116 Q-1 MR. ARC!iIZEL: For all practical purposes, I 2 don't think ycu're really talking about a situation where 3 you're really going to have local pressurization of any 4 substantial impact on the break you're talking about --

5 COMMITTEE MEMBER KERR: No.

6 MR. ARCHIZEL: One of the principal concerns 7 we've had in this situation would be a local 1

8 pressurization where the containment wall was one of the i g -- subcompartments included the containment wall, where 10 the containment function might be jeopardized by a leak l before break. In that instance, we don't believe that 11 12 le k before break should be used for,that subcompartment, 13 and they should analyze a guillotine break. For 14 example --

15 COMMITTEE MEMBER KERR: Well, there might be a 16 situation in wich that local pressure would be greater 17 than the design pressure for the containment.

18 MR. ARCHIZBL: Right.

19 COMMITTEE MEMBER KERR: Is that --

20 MR. ARCHIZEL: And so the subcompartments 21 including the containment wall, we would not want the leak 22 before break used in those compartments, as an example, 23 COMMITTEE MEMBER KERR: Thank you.

24 MR. LONG: Also, if it could affect, say, the 25 performance of the suppression pool, cause loss not only O

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of'the drywell wall, but of the' suppression pool or 2 something else'that was' required to mitigate a severe 3 . accident.

4 COMMITTEE MEMBER CARROLL: I.would note that 5 from last mo' nth's ACRS meeting, there is a letter.on'the 6 subject of' leak before break, in which'I guess we say that 7 we think the Staff and at least Combustion Engineering, 8 who wants to extend leak before break, ought to sit down 9 and talk'about these things.

10 The Staff did indicate a willingness to at least 11 considerL exending' leak before break to things other: than 12 what's in the present rule. And I personally think.ttere 13 are some places that might be appropriate.

14 .- IMR. LONG:' This use of leak before break is also

~

15 an 1ssue with' respect to the chugging condensation p [16 oscillation' loads for~the suppression pools. It's not 1'

L 17 clear from the wording of the broad' scope amendment 18 whether leak before break should be applied to those 19- -particular loads.

20 I think the requirements document, the way it 21 reads now, would imply that you could take credit for leak 22 before break in analyzing those loads. And the Staff has 23 sent a letter to the steering committee, indicating that 24 further thought is needed on that subject.

3 25 Next issue is PWR containment design leak rate.

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I' Current regulations and' standard review plan do not

2 specify containment total leak rate limits, but. permit 3 leakage-rates subject to the constraint of meeting 4 Part,100.

5 However, standard practice as typil. led in the 6 standard techical specifications indicates that PWR 7 containments should have a leak rate of .1 to .2 percent 8 per day, and BWR's .5. percent per' day.

9 EPRI is proposing that the PWR version of the 10 ALWR's be-allowed to c leak at essentially the BWR leak 11 rate, half a percent per day. The Staff considers that 12 this..would be a. relaxation in current criteral that.should 13 be treated as'a'-- I' don't want to say, it's a less

-O 14- conservative feature of advanced light water reactors.

15. 'And we.think'that the' containment' integrity of advanced -

16 light water reactors, should be comparable or better than I- 17 current standards.

18 That was very difficult to phrase right. Is 19 that what we're trying to say?

20 (Laughter.)

21 MR. RUBENSTEIN: Yes, yes.

22 COMMITTEE MEMBER CARROLL: I guess I'd like to 23 see people look at that leak rate in the context of 24 overall risk. You know, we put all this emphasis on 25 getting down to these minute containment leak rates, and l

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.119 1 yet we,=out of'the other' side of our mouths, say,'oh, 2 well, there's all kinds of ways that containment ~can fail.

3 And I just don't think the two are logically. ]

j 4 hanging'together any more. Those low leak rates'may.have

]

l 5 made a lot of sense before we were. talking - when we were I 6 talking in the design bases accident arena, but now th'at 7 we're really also looking at severe accidents, I'm-not 8 sure they're consistent.

9 'MR.'RUBENSTEIN: The Staff to some degree does i 10 review and' license the plant primarily within the design 11 basis accident arena. And uses PRA and risk as guidance.

'12 So we're limited in that way. And we doimake the

.13. distinction between that and severe accidents.

14' So we're very careful to keep it' separate in our 15 own mind quit'e.a bit.

16- COMMITTEE MEMBER.KERR: Is EPRI proposing to 17 design the containment on the basis of the design basis

'18 accident, the traditional -- they ought to be ashamed of 19 themselves.

20 COMMITTEE MEMBER CARROLL: How can they call 21 themselves a research organization?

22 MR. RUBENSTEIN: In defense of EPRI --

(- 23 (Laughter.)

24 MR. RUBENSTEIN: This is an evolutionary plant  !

l

25. that we're talking about.

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1 COMMITTEE MEMBER KERR: That is indefensible. I 2 mean, John O'Hearn wrote an op ed article once called "The l 3 Assumption that Nuclear War Can't Happen." And he said 4

that this was our basis for our defense policy. q 5

This to me is;a philosophy that says, seve.

6 accidents can't happen, and so we continue to design containments based on the design basis accident. I would 7

8 have thought that a forward looking, progressive 9

organization like EPRI would not be caught dead with such 10 a position.

11 MR. VINE: I don't --

12 COMMITTEE MEMBER KERR: I find it incredible 13 that this long after 1400 and TMI-II, we're still

()

(~s 34 designing containments for a design basis accident. That 15 makes no sense at all.

MR. SUGNET: Dr. Kerr, I think that EPRI is a 16 17 f rward looking organization, I think this program is a 18 forward looking program. We've attempted to improve these pl nt designs in all respects. Understanding'that we're  !

19 20 principally after a technically excellent generating 21 plant, and so we do have concerns about reliability of 22 power production.

And we've tried to balance those with adequate 23 24 attention to both prevention and mitigation of accidents.

25 And in tomorrow's meeting one of the morning items is a O

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121 presentation on our' philosophy about our design. basis, and q 3

ur treatment as to' accidents. So I'll look forward to 2

y ur mments_at that point.

3 COMMITTEE MEMBER KERR: I will wait until l 4

tomorrow.to repeat what.I just said.

.(Laughter.)

COMMITTEE MEMBER CARROLL: But 'I would say to-the issue of'tihe PWR leak rate, that people spend an awful-

'8

-lot:of-time meeting the letter of the tech specs to.try.to get the leak rate.down there.

And as a practical matter, I':a not sure it's really contributing a hell of a lot to safety. It's using up a lot of manpower of radiation exposure, but I would O y re 111 e coerese e 1oox et it ero e riex verevective, roe kn~>w, what contribution to risk is the difference'between a' tenth of a percent per day at design pressure and one percent per day.

MR. SUGNET: I'd like to just make a couple of additional comments on this.

19 One is that the question of leak rate is really tied to a lot of other questions related to the source j term, the assumptions in the dose calculation and so i 22 )

forth. And so we have to consider those as a set i 23 I together, and I think we're doing that.

The other comment is that the real intent here 25 O  !

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.1 was'that we recognize that there was a considerable amount 2 of containant. leak ratie recest required, and a.

~

3 considerable amount of effo.rt working on valve. seat 1eak 4 tightness,nin' order to be able to meet.those very, very 5 stringent. leak rate criteria.

6 And-so'what we're looking-for in this design is 7 the. ability to back off just a little. bit on the leak.

8 rate, to make it more practical for the plant owner to 9 show that he meets the required leak rate conditions.

10 COMMITTEE MEMBER CARROLL: Sure.

-11 MR. SUGNET: So we're going to try to show for a 12 slightly relaxed leak rate, that we still have a situation 13 where we.can meet the regulatory requirements,-in terms of 34 the regulations, and also from a risk perspective, .to show we don't have a risk problem. I 15 16 MR. ARCHIZEL: One of the things we really had 17 in Chapter 5 was this balance between mitigation and 18 accident prevention. And specifically, with the increased 19 leakage outside containment, the basis for that leakage 20 was the reduced source term.

21 S what you've done is basically allowed --

22 you'll go from .1 to .5, based on a new source term, much 23 lower values, eliminate all these -- and we accepted this, 24 because that was the concern that we had with this plant,  !

25 and to compare it, the value of this containment to the O

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-( <- l 1 existing containments caused ~us some~ great. concern. 1 H

2 . COMMITTEE ~ MEMBER KERR:- But look, I'mean, you're 3 dealing with a' source term to calculate your offsite dose, 4' that can't possibly occur.if your ECCS works. And you're~ j 5 . basing the~ containment design on the assumption that the 6 ECCS works.

7 I mean, it .just --- it's a situation that to me 8 is -- well, I won't use the term " Alice'in Wonderland,"

9 but it's reminiscent.

10 MR. DAWSON: cKirby Dawson. I think we may be L11 doing ourselves a disservice. I'think Dr. Kerr asked this 12 same basic question in a meeting some time ago in 13- Washington.

14 COMMITTEE MEMBER KERR: ' Yes, sir.

15 MR. DAWSON: Whether or not we were still using l

l 16 the design basis. accident as the basis for the design.

17 EPRI has what they've labeled a three-part 18 design basis. The first part being what they call the 19 licensing design basis, the second part being' risk 20 evaluation basis, and a third that is kind of equivalent l

21 to investment protection.

22 Included within the risk evaluation basis is the 23 capability of the plant to respond to severe accidents.

24 And so within the way they're describing the design basis, 25 the' answer to your question is that the licensing design O

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124 1 ba' sis looks at the traditional design basis accident. The 2 ' risk' evaluation basis,'which includes such things as'the 3 capability of the. plant to withstand anadiabadic burn'of 4 100 percent of~the hydrogen generated by 75 percent of the 5

fuel clad, such things'as that.

6 S I felt like I wanted to clarify that point.

7 Whether it clarifies it or not.

8 MR.-VINE: You'll hear more about.it tomorrow.

g COMMITTEE MEMBER KERR: Thank you.

MR. LONG: Give PWR's equal treatment with 10 gg BWR's. I gather that's what's being asked for on that 12 issue.

13 Next issue is need for PWR post-LOCA pH control.

14 In December the Staff issued a revised standard re' view 15 P l an, which permits the elimination of the hydroxide 16

. chemical spray additive for PWR spray, acknowledges that I it's n t needed to meet Part 100, and it could be deleted.

17 18 However, the standard review plan continues to 19 require.a chemical additive for pH control for 20 .intergranular stress corrosion cracking of stainless steel 21 P i ping in the containment. The sump should be maintained 22 with a pH above seven, under post-accident conditions.

23 The requirements document has eliminated the 24 chemical spray. It doesn't provide, though, for any 25 trisodium phosphate or any additive for post-accident pH O

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- 125 1 control of the; refueling water storage tank. So this 2 issue has to be addressed, and it hasn't been -- no basis

3 for elimination of the pH-control, post-accident pH 4 control, has been provided.

5 And I might note that in the SP-90, they've got 6 18,000 pounds of this dry chemical in baskets in the 7 containment. And what it does is, it gets wetted by the 8 spray, dissolves and maintains a positive pH in the 9 refueling water storage tank. So it has to be considered 10 for the requirements document.

11 COMMITTEE MEMBER CARROLL: I'm not following 12 what you're saying. Positive pH, you mean --

13 MR. LONG: Above seven.

(O> 14 COMMITTEE MEMBER CARROLL: Above seven, okay.

15 And what was in the basket?

16 COMMITTEE MEMBER KERR: Baking soda.

17 COMMITTEE MEMBER CARROLL: Is that right?

18 MR. LONG: Trisodium phospate, I believe.

19 COMMITTEE MEMBER CARROLL: What's the acidic 20 component that's requiring this neutralization?

21 MR. MILLER: Boric acid.

22 COMMITTEE MEMBER CARROLL: Okay, all right.

23 MR. SUGNET: Let me just comment quickly on 24 that. We've considered that matter, we think that the 25 sump pH control is really not an immediate issue, rather a (s

%-)

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.Q '1 longer term issue in t'erms of both corrosion' concerns;over-

~

2- theclong haul,'and also in terms of reevolution of 3' elemental iodine from water'.

l.

R 4 We think that in both cases you could handle

-5 'this,on an' accident recovery. basis, so in our-6 requirements, we've called for sufficient connections to-7 the-tank to be able to adjust pH, provide chemical 8 treatment, whatever is necessary, but not any explicit 9 P l ant feature that deals with this by itself.

But obviously, we need to continue to discuss 10 this with Staff.

11 12 COMMITTEE MEMBER KERR: How many thousand pounds f this, 18,0007 13 .

14-MR. LONG:- Eighteen thousand pounds in'the

.,, S,-,0.

16 -

COMMITTEE MEMBER KERR:- Nine tons. It takes 37 that much? I guess it does.

18 MR. LONG: Next item is charcoal absorbers. The 19 requirements document proposes to eliminate charcoal from 20 control room and-containment cleanup systems. The basis 21 as stated in the requirements document is studies cited in 22 NUREG 0696, which indicate that iodine fission products 23 are primarily in particulate rather than elemental or m lecular form, and therefore the charcoal would be 24 25 ineffective.

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127 g' .

1 And the BWR suppression pool scrubbing,'and.the 2 PWR" spray, would be much more effective for iodine 3' removal.

4 The 'taf f has long term plans to revise the TID

'5- Reg Guide assumptions on iodine chemical species, butlis 6- 'not~at this time ready to permit charcoal deletion.

7 The Director of NRR wants advanced light water 8 reactors to be able'to meet Part 100 with the traditional 1.

9 TID and Reg Guide 1.3 and Reg Guide 1.4 source term assumptions. But we'll negotiate realistic source terms

11 .for severe' accident protect' ion.

12' COMMITTEE MEMBER KERR: Part 100 includes the 13 control' room, is that --

14 MR. LONG: 'To clarify the issue, the traditional 15 TID and Reg Guide 1.3 and 1.4 source terms say that 16 93 percent, I believe it is, of the iodine is in gaseous 17 form. And the NUREG 0696 studies indicate that it's going 18 to be predominately cesium iodide. And charcoal does not 19 effectively remove gaseous iodine. And water is very 4

20 effective for the particulate for cesium iodide.

21 So the requirements document is reflecting this 22 knowledge by proposing the deletion of the charcoal, and 23 giving the credit for the suppression pool and in the case ,

24 of the PWR the spray, for removal of iodines.

25 If we stick to the TID source term assumptions, O

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1 1 we have'to' stick'with_ gaseous iodine, as assumed at 2 :93 percent, which means we would have to retal'n the 3 charcoal.

4 COMMITTEE MEMBER KERR: Do you find that a 5 convincing _ argument?

6 MR. VINE: No.

-7 (Laughter.)

8 .MR. SUGNET: Let me just quickly comment from g our_ perspective, first, Dr. David Lever, who has been.

10_ working on'this issue for us, is going to make a 11 Presentation tomorrow that I think will try to explain our 12 Position in full. But briefly, first of all, from a 13 Philosophical standpoint, we think'there's been so much U 14 industry research effort expended in the source term area

~

15 in the past decade, that we should try to take advantage 16' of that, where there's a reasonable way to do so.

17 We think there is enough evidence at this time 18 about the chemical species that we can relax certain 19 assumptions and certain descriptions of the~way these 20 things progress.

21 We do not propose at this time that there should 22 be a change with respect to TID 14844, which we think 23 simply describes the amount of radionuclides produced, but 24 it doesn't comment on the chemical form. The regulatory 25 guides 1.3 and 1.4 do comment on a chemical form. , j O

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ l

129 (f We would propota that those be relaxed somewhat, and we would propose that the extensive charcoal filtration that exists in certain parts of the plant 3

systems be reduced in recognition of what we think the 4

scientific evidence suggests about the chemical form.

5 COMMITTEE MEMBER KERR: Now, the Staff has 6

explained to you that regulatory guides are not 7

regulations, surely, so that they don't have to be 8

relaxed. All one has to do is to present an alternative 9

that is acceptable to the Staff, and it's perfectly legal, {

10 '

and -- it may be impractical, but it's legal.

11 (Laughter.)

12 MR. SUGNET: We understand that, Dr. Kerr.

13 Nonetheless, we have to reach agreement with the Staff in

( ) 14 order to proceed. That's what we're about now, and we 15 hope that we will further discuss this at the late April 16 meeting that we've scheduled with the Staff on this.

17 But you'll get a fuller discussion of what 18 exactly we're proposing tomorrow.

19 COMMITTEE MEMBER KERR: What you said was that 20 the Director of NRR wants these new plants to meet 21 Part 100?

22 MR. RUBENSTEIN: Basically for these three 23 evolutionary plants, we want to stay fairly close to 24 14844, and Part 100.

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'130 4

However, it's clear that we're willing to work with EPRI and industry to use all their source term 2

initiatives in meeting their design goals of ten.to the

.3 minus five core' melt frequency,'of' containment failure 4

probability of ten to the minus one, and their significant release. fraction, or their safety goal of ten to minus six at the site boundary, or the half mile of 25 REM.

7 So under severe accident conditions, in meeting those goals, I don't think there's any doubt that we want l

to work closely with them in using these initiatives. We want to go very slowly for this generation of these three plants, in looking at changes, either to the Reg Guides 1.3, 1.4, or.the Part 100 considerations. It's 13 0 14 worked we11 cor e tone time.

COMMITTEE MEMBER KERR: But as both EPRI and I-point out to you, you don't have to change 1.3 and 1.4.

MR. RUBENSTEIN: I understand.

COMMITTEE MEMBER KERR: They're not part of Part 100.

MR. RUBENSTEIN: Well, when we get into the BWR, you get into condensor holdup and the seismic applicability. In this particular instance, we have more l' flexibility.

I 23 l COMMITTEE MEMBER KERR: And incidentally, TID 14844 is not part of Part 100, except in a footnote, O

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, 131 1 and that's a for-example, as-I remember.

2 MR. RUBENSTEIN: ,Okay. But I don't want'to say.

3. that the door is absolutely' closed on these items.

4 MR. LONG: The next issue is suppression pool.

~

5 fission products. scrubbing, relates to the source term 6 issue. What decontimation factor for. iodine should~be 7 applied to the suppression pool.

.. 8 A recent'new edition to the standard review plan g does. recognize that iodine fission product scrubbing in 10 the BWR suppression pools'and authorizes decontamination 11 factor up to ten, without additional Staff review of the 12 methodology used in taking credit for meeting the Part 100 13- dose calculations. And it specifically references the

-0 14 spark code for use.

15 EPRI and initially GE came in proposing 16 decontamination factors much higher than ten, one hundred 17 in fact. And since.this relates to the chemical species 18 of iodine, this is an open issue.

1g If we're going to assume-the Reg Guide iodine 20 chemical species, then the decontamination factor would l

21 have to remain at about ten, or additional justification 22 would have to be presented for a higher decontamination l 23 factor.

24 COMMITTEE MEMBER KERR: Is this assumption of 25 the Reg Guide form of species for the sake of tradition, O

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L 1 or because of some. scientific belief that it is likely to I

2 be that.way?

3 MR. RUBENSTEIN:. I think it's in our case for.

4 lthe'said of tradition, for this. review.  ;

5 COMMITTEE MEMBER KERR: I'm'not'against 1 l 6 . tradition, I'm just curious.

7 COMMITTEE MEMBER CARROLL: What's the current 8 BWR practice with respect to-pH control of suppression j g pool water?

1 10 MR. FIDRYCH: That's essentially the same as the 11 reactor water itself, which is essentially neutral.

12 MR. LONG . There's no boron, -it's not addressed.

13 MR. FIDRYCH: It's maintained at that' water

- 34 purity,by a cleanup demineralizing system.

15 COMMITTEE MEMBER KERR: Did you get his name?

16 THE REPORTER: Yes.

17 MR. FIDRYCH: Fidrych is my name.

18 MR. LONG: Next issue is timing of fission j g product release. The Staff has acknowledged that the 20 TID 14844 assumption that fission products are

. 21 instantaneously available~for leakage from containment at 22 time zero is overly conservative.

23 (Laughter.)

24 MR. LONG: The analysis provided by EPRI as part 25 of Chapter 5 indicates that accident sequences having a O

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D1: ' fission product release earlier than one hour are of such

.2 extremely low probability that they should;be neglected.

3 The' Staff has'long term low'priorit'y plans to 4 address this over-conservatism, but has not provided new 5 criteria to replace the existing criteria.

6 'Our'present position is.to assume the 7 Instantaneous release for doing the Part 100 siting 8 calculations.

9 COMMITTEE MEMBER CARROLL: When you say " fission 10- product release," are you still maintaining that a rapid 11 depressurization could release some part..of.the gap 12 activity?

. 13 MR. LONG: It takes zero time for the transport O 14, .of.the fission products from the pellets to the 15 containment penetrations through which the leaktge occurs.

16 COMMITTEE MEMBER CARROLL: But I'm saying --

17 MR. RUBENSTEIN: It's not' mechanistic. It's an 18' assumption, it's not mechanistic.

19 COMMITTEE MEMBER CARROLL: The present

20. requirement.

21 MR. RUBENSTEIN: Yes.

22 COMMITTEE MEMBER CARROLL: But I'm talking l 23 about, if you're going'to relax that, are you still going

-24 to have gap activity coming our earlier than an hour?

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1 COMMITTEE MEMBER KERR: I don't think he's going 2 to relax it.

3 MR. RUBENSTEIN: 'Let me make.a clarification

.4 here overall, for EPRI and the Subcommittee. We-haven't 5' Published our. SER yet, and some of the positions that 15 Bill Long is giving.today are primarily Staff input 7 Positions to the SER from the' tech review groups. I'm not 8 sure Charlie's .been all at ease cn::I have myscif, let.

9 .alone run them up to senior management in addition.

10' So I think some of it's coming as'a surprise to 11 EPRI in terms of feedback, but we wanted to take the 12 opportunity with the subcommittee to-surface these issues 13 .very early,;and many of them will get closed to additional

&'a 14 discussions _between EPRI or~the designers and the Staff.

15 Some will remain, and we'll be happy to come 16 before you with our final positions on those if we find a 17 great deal of difficulty in meeting the EPRI position.

18 COMMITTEE. MEMBER KERR: I am encouragesd, 19 -though, that EPRI'has recognized.the existence of severe 20 accidents, when they-recognize that the sequences don't 21 produce fission products for about an hour. Eventually 22 ~ they're going to find out about these containments and 23 . sever,e accidents, too.

24 (Laughter.)

25 l.

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,O -COMMITTEE MEMBER KERR:.'So' progress'is being 1.

2 made.

3 COMMITTEE MEMBER CARROLL: Let me rephrase what 4 I was trying to get at. Does EPRI still. consider gap 5 activity coming out, in'what they're proposing?

6 MR. LEAVER: I'm Dave Leaver with Tenera. For 7 the design basis type events, the gap activity doesn't come out for an hour, 8:

g COMMITTEE MEMBER CARROLL: Does'not come out.

10 MR. LEAVER: The'one-hour criteria was based.on 11 - the' initial failure'of rods. That was when the first rods 12 started to fail, at about an hour. When you look at the 13 entire' spectrum of accidents, large.LOCA, small LOCA,.with 34 the exception of ridiculously low probability accidents,.

15 .you don't get any release of fission products into.the RSC 16 for about 60 minutes..

17 COMMITTEE MEMBER CARROLL: And a rapid 18 depressurization of the RSC is not going to produce --

19 MR. LEAVER: That's right. Under design basis 20 condition, where with single failure and ECCS Works, you 21 will not have rod? failing under those conditions.

22 COMMITTEE MEMBER KERR: Wait a minute. I 23 thought you were talking about accident sequences, and now 24 you're talking.about a design basis accident.

25 MR. LEAVER: We're talking about all accident

'( )

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l 136 O 1 . sequences-that we consider to be --

~

2 . COMMITTEE MEMBER KERR: Okay. .

3 MR.-LEAVER: I'll use the word " credible;"

4 COMMITTEE MEMBER KERR: You're.not. talking aboui.

5 .a design basis accident analysis.

6 MR. LEAVER: -No, sir. Not limiting'this to a 7 large LOCA.

~8 COMMITTEE MEMBER KERR: Credible', now that's.an 9 interesting word.

10 MR. LEAVER:' Well', I'he'sitate'to use the word 11 " credible," some people would argue that even the.

12 accidents we're.considering are not credible. But'we've 13 used a' probability cutoff which'is very, very low. Clearly..

you can. postulate things that could happen that could

$4.

15 result in fission product release sooner'than 60 minutes, 16 but'we believe"that.those thing,are just simply not

17. credible..

18' In fact, I believe those words are used in 19 10 CFR 100.,

20 MR'. - LONG : Dave, I think you've got me confused 21 .now. For the[ design basis accident, mechanistically the 22- - fuel doesn't fail at all, the accident's terminated.

23 '. But for doing the Part 100 analysis associated 24 with the design basis accident, are you proposing, or are 25 you not proposing a one-hour delay?

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1 MR. LEAVER: Yes, we're proposing a;one-hour 2 delay for the Part'100,-that's right.

3 MR. LONG: 'That's what I thought. Next time is 4 containment. leakage as a function of pressure.. Our 5 November letters to EPRI and the NSSS vendors acknowledged 6 that the Staff would be willing to treat fission product 7 leakage from:the containment as a function of the  :

8 differential; pressure.between the pressure inside the 9' containment'and the environment.

10, Implementation of this. position would require 11 addressing new testing requirements, and developing a~

12 Pressure versus leakage relationship. We would expect 13 EPRI and the. vendors to come back to us with a proposal on 14 how they would implement this in doing the dose 15 calculations, and any proposed changes in testing

16. requirements.

17 We would also like to know how it.will affect 18 those calculations. And the. exclusion zone distance and 19 the site boundary and all the effects of it. So we're 20- waiting for something on that, but we've acknowledged this 21 Position.

22 No comment?

23 Next issue is generic issue D-2, ECCS design.

24 In 1972 ACRS initiated D-2, which is titled "ECCS

-25 Capability for Future Plants," to explote new approaches O

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1- to'ECCS design.. Chapter 5.of the RD specifles many new 2 ECCS features, such as elimination of recirculation 3 injection switchover, and elimination of piggyback 4 injection pumps.and series alignment,'and provision of l

direct vessel injection.

5 And in sum total, looking at all'of the features 6

in the context'of the~overall requirements document, it's 7

the Staff's positior. that.the requirements of D-2 are met 8

9 by.the RD,.by the proposed ECCS features, for both the BWR 10 and-the PWR.

l Issue A-45, station blackout -- oh, 44. We 11 l

consider the~ station blackout issue being satisfactorily 12 addressed through compliance with the rule and the. Reg 13 Guide, and'through the'PRA analyses, and the addition of 14 the alternate. gas' turbine power sources, as this will 15

. satisfactorily resolve the generic issue for the EPRI 16 requirements document..

$7 COMMITTEE MEMBER CARROLL: What you're saying 18 here is you're going.to have one diesel per safeguards 19 division, is'that your word? Plus a gas turbine?

20 21 MR. SUGNET: That's correct.

22 MR. RUBENSTEIN: .The EPRI requirement goes beyond the station blackout rule, and we laud them in 23 giving us this extra margin.

24 25 COMMITTEE MEMBER CARROLL: At what does the gas O

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139' 1- turbine get'to a point where it.can accept load?.

2' MR. VINE: ' Two' minutes, by'our; requirements 3 document.

4 COMMITTEE MEMBER CARROLL: And what is its apability?

5 MR. VINE: We're-going to cover that in detail 6 .

this afternoon, but it's.a very large gas turbine, capable 7

8 f carrying both non-safety loads as.well as a full safety 9

division.

COMMITTEE' MEMBER CARROLL: A full safety 10

$g . division?

MR. VINE:- That's right.

12 COMMITTEE MEMBER CARROLL:- Okay.

.13 MR. SUGNET: We-thought =that a forward looking 14 organization.and a forward looking program ought to 15 16 pr vide such additional impro.vements-for the overall capability of the plant.

17 COMMITTEE MEMBER CARROLL: .Now, is it'a. gas 18

turbine that the utility could use as a peaker?. Or does 19 ,

it have to be --

20-1 21 MR. VINE: Question?

COMMITTEE MEMBER CARROLL: Historically, you 22

.can't use your diesels for system load.

23.

MR. VINE: For peaking, that's right.

24

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D 1 ~ COMMITTEE MEMBER CARROLL: Could the gas turbine 2 be used?

3 MR. VINE: The gas turbine is designed and laid 4 ut.such,that it-.could be,' and we're hoping that there's some opportunity for dialogue on its use. Some of the 5

6 utilities who have advised us on this feel very.strongly that we ought'to have the capability of using the gas 7

turbine for peaking, and other utilities would prefer not.

8 _

to use it for peaking. So it's-an option that some'may 9

10 want to. exercise ~and others not.

gg But,we've designed it into the system such.that it could be'.

2 COMMITTEE ~ MEMBER KERR: In commenting on this, 13 y u said, I~believe, that in satisfying the resolution of

'14

-- they satisfied this;by A-45 and th'e PRA. I thought I 15 heard --

16 MR. RUBENSTEIN: 'They satisfied the station 17..

blackout requirements of A-44, and goes beyond it, in that 18 the alternate diesel only would have to be diverse 19 a coriding to de --

20 COMMITTEE MEMBER KERR: I thought I heard some 21 mention of a PRA, did I not?

22 23 MR. LONG: EPRI has met with us and proposed, 24 -

described the features for the electrical system. We haven't yet received the volume, I believe it's 25 O l l

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-e 141 1 Chapter 10, on 'the electrical system --

2. MR. VINE: Eleven.

3 MR. LONG: Eleven, but we've received advanced 4 information describing improvements to the battery system,

5. the DC system and the chargers, and: independence in those 6 systems. And based on that information, and based on 7 meeting the rule, we'think the issue A-44 has been met for 8 Chapter 5.

9 COMMITTEE MEMBER KERR: Are the requirements 10 independent.of the' predicted system reliability, the 11' offsite system reliability?

12 MR. SbGNET: Yes. The requirements are 13 specified independent of 'the predicated offsite power grid 14 reliability. However, we think we've got' a pretty good 15 estimate of that reliability.

16 Let me also comment, Dr. Kerr, with respect to 17 your. question about the relationship between tne PRA and 18 these criteria, that when we did our initial development 19 of the safety system design requirements, and then did 20 some high level PRA evaluation of the plant, the systems 21 improvements had reduced the likelihood of most of the 22 front line system related failures, to the point where 23 both AC electrical failures and DC electrical failures 24 'were prominent in the core damage frequency contribution.

25 And that was a stron; motivation for our O

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('s. ~

1 determination that both'the combustion turbine capability 2 be provided, and also that certain~ modifications to the DC 3 system'be provided. Those will-be described'more fully.In 4 the presentation on Chapter 11.

5 COMMITTEE MEMBER KERR: Thank you.

6 MR. LONG: For issue A-45, decay heat removal, 7 this issue is being addressed for operating reactors by_

8 the individual plant examinations, and for future 9

reactors, by the PRA.

10

- The requirements document will include a PRA 11 guidance document.as'an appendix to Chapter 1. It will 12 Provide extensive. guidance for a PRA. And we anticipate

=13 that through the PRA, A-45 is resolved for the ALWR.

14 COMMITTEE MEMBER KERR: This-guidance document ~

15 is something prepared by.you.or by EPRI?

16 MR. LONG: By.EPRI.. And we consider that it 17 goes beyond what an IPE does, and will satisfy the 18' requirement for-Chapter 5.

19 Next issue is the use of the'ANS 5.1. decay heat 20 curve. Decay heat assumptions are presently prescribed by l 21 a branch technical position in the. standard review plan.

22 The requirements document wishes to take exception to the 23 decay heat curve prescribed in the standard review plan 24 and the branch technical position, which has large 25 uncertainty factors and use the ANS 5.1 decay heat curve.

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143 01 1- The ANS decay heat curve has been accepted by 2 the Staff for use in ECCS Appendix K analysis, and what.

3 the requirements document-is doing is extending the use of 4 that curve for longer. term.use, such as an ultimate heat 5 -sink and RHR heat exchangers.

6 This is acceptable to the Staff.. So we're not 7 talking'about a rule change, just a change, a deviation 8 from the standard review plan.

g .We note thatisome conservatism is taken out by 10 - using the ANS curve, which'is less conservative with 11 respect to decay' heat generation than the branch technical 12 position, but the ANS curve has been benchmarked against 13 the origin' code and is~still~ considered sufficiently 14- conservative for the design of the decay heat removal 15 systems.

16 Next. issue is the diesel generator 20second

' 17 start time and 40-second load sequencing time. The 18 current standard technical specifications specify-start 19 and load time limits for diesel generators. Typically 20 diesels are expected to start in, I believe, ten seconds.

1

21. The requirements document would extend this to 22 to 20 seconds and extend the loading sequence time to l

L 23 40 seconds, subject to being shown in the LOCA analysis 24 that these are acceptable start times.

25 This is consistent with the new draft Reg O

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- 1 Guide 1.9, which does not place specific limits,. but just 2 defines that acceptable start and loading times be used.

3 Consistent with the draft Reg Guide, this is acceptable l

4 .for the_ requirements document also.

5 COMMITTEE MEMBER KERR: In order to demonstrate 6 that this will satisfy.ECCS requirements, will the 7 instantaneous double ended pipe > break assumption still be 8 used, or --

9 MR. LONG: Yes.- EPRI is still proposing to use 10, the Appendix K analytical methods required. I haven't 11- seen any optimization paper's to the contrary. t And EPRI 12 -studies have indicated that they can meet those analyses, 13 with these load. times. And we'll verify that during

~

14 . individual design certification reviews when they come to 15 us.

16 MR. SUGNET: And let me point out for the 17 Committee's benefit that some of this relaxation comes 18 from the fact that there have been f1'uid systems 19 improvements in' terms of the ratings of equipment and the 20 flow delivery, so that we can get this kind of relaxation, j 21 The objective, of course, is for higher diesel 4 l

22 generator reliability, to avoid the very fast start, very i

23 start load. j 24 COMMITTEE MEMBER KERR: I don't have any problem j 25 with these times, I just wondered if you could achieve it O

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'( ) 1 within a standard Appendix K analysis. Apparently you can.

I i

2 MR. SUGNET: Yes.

3 MR. RUBENSTEIN: You've also added a little 4 margin to the core, so --

5 MR. SUGNET: Yes.

6 MR. RUBENSTEIN: You might want to point that 7 out. Their stored energy is going to be down, what, about 8 15 percent?

9 MR. LONG: Next item, elimination of core spray.

10 The BWR would not have a core spray system. Based on 11 elimination of the recirc system, meaning that we would 12 not have the postulated.large double ended guillotine 13 break, since there is no external recirculation piping, G

/ the core spray system would be deleted.

14 15 Regular safety injection would be retained, and 16 would be subject to standard Appendix K analysis. This is 17 acceptable to the Staff.

i 18 MR. SUGNET: Let me clarify for the Committee's 19 benefit. What we talked about is simply deleting the 20 spray header. The system is maintained in the plan, and 21 it's a high pressure injection system, as a flooder. The 22 system is still there, the only thing that's been deleted 23 is the spray header itself.

24 COMMITTEE MEMBER CARROLL: So now you don't have 25 t O

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1 146 1 to argue with people on the Staff about spray 2 distribution.

3' MR. SUGNET:' Yep. The principal motivation for

~

'l 4 this change is to avoid having a large complex piece of 5

equipment ~insid'e'the reactor; vessel that has to be-removed 6

and ma'intained and inspected and could be subject to failures and so'forth.'

7 OMM M EE MEMBER MERR: hat's an interesting 8

interpretation of the large break LOCA. You say because 9

y u have climinated recirc pumps, there'can<be no large 10 g LOCA.

MR. RUBENSTEIN: The recirc pumps are.taken 2

3 inside on the.ABWR. And they're -- well', they should say h it better than me, but all the' piping'that comes in and out is above the core level. i

.M . N  : a d y, w m the plant 16

p. configuration as described, the largest break is a steam line failure. And this is a high failure, above the'cc,e, 18 s y u w uldn't require this core spray. There are other 19 liquid lines attached to the vessel, similarly all of 20

.g those are above core level, so that the spectrum of ECCS 21, breaks would not require this spray system.

COMMITTEE MEMBER CARROLL: -Is any postulated 23 break that's below the core small enough that you don't 24 have.to worry about it?

25 O

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/g 147 U 1 MR. SUGNET: That's correct.

2- MR. LONG: Next item, PWR emergency feedwater 3 system design. This refers to the Davis-Besse emergency 4 auxilia y feedwater system safety issues.

5 The Staff is proposing to consider those Davis-6 Besse issues resolved in the RD for the advanced light 7 water reactor PWR, based on the improvements in the j 8 auxillary feed water system described.in Chapter 5.

9 COMMITTEE MEMBER KERR: Is there any formal or 10 informal requirement on availability of the emergency 11 feedwater system any more.

12 MR. RUBENSTEIN: Yes, I believe it's ten to the 13 minus four, or ten to minus five, it's still in the n-

~

14 standard review plan. However, they may have set a'better 15 target.

16 COKMITTEE MEMBER KERR: Did you know that you'd 17 set a better target? Or did you know you had a target?

18 MR. SUGNET: We don't have an explicit ,

19 requirement for emergency feedwater unavailability. We 20 have, as you can see from the system arrangement, made 21 improvements to the system, primarily by providing a two 22 division capability that has diverse power supply drivers 23 in both of those two divisions.

24 We think that will yield an unavailability that 25 is better than the current generation plants, and O

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.O -

1 particularly better in the event of unavailability of AC 2' . Power;to drive the' motor pumps.

3 COMMITTEE MEMBER KERR: _ Well, you know, .

4 Mr. Rubensteiri was very caref ul 'in' this statement. He 5-said a' target,,not'a requirement.

L 6 MRR LEAVER: .To<some' extent the core damage 7 frequency requirement of. ten to the'minus fifth would 8; f rce you to have a very good system. And'so in that 9

sense, we -- .

I 10 COMMITTEE' MEMBER KERR: I'm not trying to push gg for a:standardfrequirement, in fact, I wasn't even sure

-12; what-the. current Staff position is for operating plants.

13 At'one time I've heard of ten to the minus four-to ten to

g the.minus five, which'by the way I don't understand,

-15 but --

16 MR. RUBENSTEIN: Later on, or some other time, ,

37 I'd be happy'to explain that.

l 1

18 COMMITTEE MEMBER KERR: Okay.

19 MR. SUGNET: But the direct answer to Dr. Kerr's 20 question is, we don't have an explicit availability target q 21 f r that system, we've got a better emergency feedwater l

22 system, and.we also have a design in lead feed capability. j 23 S verall --

24 COMMITTEE MEMBER KERR: Better in what sense?

25 Y u mean your calculated availability is better?

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149 g .. p MR.;SUGNET: Our calculated availability is 1

1 better.

2 COMMITTEE MEMBER CARROLL: When you.say diverse 3

p drivers'in the two divisions, what is that?

4 MR.'SUGNET: The requirements specifically call for.a motor pump and a' steam turbine pump in each of the i two redundant divisions.

7 COMMITTEE MEMBER CARROLL: No' diesel driven.

8 MR. SUGNET: No, we do not call for any diesel driven.

'10 COMMITTEE MEMBER CARROLL: Okay.

MR. ARCHIZEL: Additional improvements -- Ralph Archizel. Having improvementsfin the discharge heat 13 A generator, and separate storage tanks for emergency V 14 feedwater, not the common storage tanks, in our review we've concluded it's an enhanced design over current boiling water reactors.

COMMITTEE MEMBER CARROLL: The motor operated discharge valves, in case they are inadvertently closed, q can be reopened?

MR. ARCHIZEL: I think you can survive for 30 minutes with no operator action, because --

MR. RUBENSTEIN: From my own personal experience of looking at the analyses of a lot of the other PWR's of current vintage, I would' guess they're into very low, ten O

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to the mint $s five or whatever, based on their design.

2 COMMITTEE MEMBER.. CARROLL:- Can we come and see the test you're going to run to prove that?

3 MR. RUBENSTEIN: Just"a guess.

4 MR. MILLER: Mr. Chairman, the next series of -i items, although contained in some of the Chapter 5 discussion, also'are integral to, I think, the. discussion we're going to have tomorrow morning on the severe accidents. And if it's okay with EPRI, l'd like to propose th e at the time we discuss those. Issues' tomorrow morning, maybe'we could visit these items.

I think it would be more fruitful'to do it in l the context of that discussion.

13 O 14 CaA1RMAN WYt1E: Good goine.

MR. MILLER: What I would like to'do, though, is maybe we could close before lunch with maybe hitting the bottom on mid-loop operation, I think that might be appropriate to finish the-' discussion this morning on that.

19 COMMITTEE MEMBER CARROLL: We've also got another page.

MR. LONG: This is one through four issues.

COMMITTEE MEMBER CARROLL: Oh, I'm saorry.

]

MR. LONG: You want to go to mid-loop 25 Perations? l O

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U. 1 'MR. MILLER: Yeah. I'think we can have some of 2 those interim ones' tomorrow morning in the context of the 3 severe accident discussion.

4 MR. LONG: The r;eneric issue, the generic res lution'of the mid-loop operation issue calls for 1 5

6 Procedural-improvements, instrumentation improvements for the currently operating reactors.

7 The Staff would like to see the potential for 8

9 these events, the actual physcial capability for them to-occur to be designed out of ALWR's. This could

-g conceivably be done by revising the physical arrangements f the coolant pumps, the loops, and steam generators.

12 This may only be feasible for passive plants, 13 n

V g but for evolutionary plants it should be considered and addressed.

15 Se tion 5.2.3.1 and 5.2.3.1.5 of the 16 g requirements document spe'cifies design features that will significantly reduce the probability, but not necessarily 18 preclude the possibility of mid-loop operations events.

39 _

The features described in the requirements 20 document include addressing anti-vortexing and anti-air 21 entrainment devices. The provision of specifically 22 arranged or specally arranged drain lines to be used 23 during operations when the RSC vessel level is lowered, 24 and the elimination of certain selected high point vents 25 O

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152 from the system.

1 2- The Staff recognizes these' requirements would 3 'significantly reduce the' potential or the probability of.a 4 mid-loop event. Some di'stussion should be provided to the

.5 ' Staff, though, over what' changes could be made~, and what:

6 the: impact would-be,.of redesigning'the primary coolant 7 system so'that~it would not be possible. The situation 8 would not even be a potential possibility.

9' COMMITTEE-MEMBER CARROLL: One. issue ACRS had 10 was the' resolution of that issue. We've asked to be kept in formed on, was the ability to close up a containment, 11 12 if you did get"into a problem.of this nature. And that's 13 something:that could be looked at in the design.

(~')

v'

14 For' example, a containment equipment' hatch is a 15 hell of a lot' easier to put on and make sure it's. leak-16 tight under these conditions, if it was pressure sealing, 17' as opposed to one that's on the outside,- where pressure -

18 tries to dislodge the seal.

19 Did EPRI look at horizontal steam generators at 20 all?

21 MR. SUGNET: We have looked at horizontal steam 22 generators, mostly in the context of the smaller, more

~23 Passive designs that we're considering, that is an 24 iteration beyond the evolutionary points we're discussing.

25 We have opted not to go in the direction of I l

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153 O- 1 horizontal' steam generators. The primary considerations 2 are twofold.

3 One, we believe that the operating expe'rience 4 indicates that lower temperatures and heat fluxes in the steam generator are an important~ key to steam generator 5

6 reliability, and that's independent of whether it's a 7

vertical or horizontal unit.

-8 Secondly, from the standpoint of a the devil you-9

.know versus the devil you don't know,'the industry has considerable experience with the vertical type units. We 10 11 think we've resolved many of the problems and issues related to those units, and we want to be.able to continue 12 t take advantage of the-database that's accumulated on 13 those to guide us, as we go forward from here.

14 S f r those reasons, we chose not to go in the

.15 direction of horizontal steam generators.

16 COMMITTEE MEMBER KERR: In no sense am I an 97 expert on heat exchangers, but I'm told that people both 18 fr m the chemical industry and non-U.S. nuclear industry 19 have had much less trouble on horizontal steam generators 20 than we have had with vertical ones. And that indeed, 21 Pe P l e in the chemical industry advised against vertical 22 steam generators to begin with. . The foreign experience 23 being Russian.

24 MR.'SUGNET: We have looked at the Lovitia plant 25 O  !

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(_/- We 1 experience, which is the Russian horizontal units.

2- noticed that if you look at the temperature and heat' flux 3 considerations,~that they are much lower than some of the 4 vertical ' units that today are being driven.

5 The other item that really.has to do with the 6 distinction between the horizontal units is the ability to 7 keep sludge and-other things from collecting on the tubes 8- and tube support plates.

9 We think we've attacked that from a steam 10 generator design standpoint, even the newer vertical 11 units. So we think we're on the trail of the root causes 12 of some of'these problems.

When you say much

~

13 COMMITTEE MEMBGR CARROLL:

14- lower heat fluxes, are you talking about the kind of gross 15 heat fluxes that were designed into San Onofre I and 16 Connecticut Yankee, back down to that level, or --

17. MR. SUGNET: I haven't done a point-by-point 18 comparison, but I can tell you that our specification of a 19 limit of 600 degree temperature for a pressurized water 20 reactor, in conjunction with the desire on the part of the 21 designer, to keep the steam pressure high, to keep his 22 steam cycle efficiency high, will result in considerably 23 lower heat flux than we have in the mid-generation 24 Pressurized water reactors..

25 How low exactly, I'm not sure.

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1 CHAIRMAN WYLIE: Were you going to comment on 2 the recommendation of the Staff on the mid-loop operation, 3 or is'this the first time you've had to --

l 4 MR. VINE: This is the first time.

1 5 CHAIRMAN WYLIE:. Oh, okay. You've been hit cold j

6 with that one.

7 MR. VINE: Further requests, and we'll just take 8 a look at that.

9 COMMITTEE MEMBER CARROLL: If you look at the 10 value impact' statement that went along with the resolution 11 f the mid-loop issue, I don't remember who did it, I 12 think it was BNL, wasn't it?

13 Their contention is that about half of the core

<~

14 melt risk results in mid-loop operation, for your standard 15 BWR plant.

16 COMMITTEE MEMBER KERR: As somebody commented at

$7 a recent ACRS meeting, it turns out that almost anytime 18 anybody does an analysis of one of these problems, that 19 about 90 percent of the core melt probability is 20 associated with that problem.

21 MR. VINE: I studied that particular report very 22 closely and found a number of flaws in it.

23 COMMITTEE MEMBER CARROLL: yeah, but I don't 24 think it's a trivial issue.

25 MR. VINE: No, we've taken that --

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,1 COMMITTEE MEMBER CARROLL: Particularly if you 2 want to postulate putting nozzle dams in in the wrong 3 place at the-wrong time, and doing a few other things.

4 MR. VINE: We've done similar analyses here at 5 EPRI and have found it to.be significant, and it's worth 6 addressing, and we think we've done a pretty good job 7 already.

I 8 COMMITTEE. MEMBER KERR: I must say, I thinhk if

?

I 9' the-risk were really that high, one ought to do more than 10- just make sure you can close up the containment.

11 CHAIRMAN WYLIE: Okay, is this a. good time for 12 . lunch? Why don't we break, then, and come back at 1:40.

13' (Thereupon-the lunch recess was taken.) .

O 14. --oo0oo--

15 16 17 18 19 20 21 22 23 24 25 O

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157 1

AFTERNOON ' SESSION 2 __ogo__

3 CHAIRMAN WYLIE: Let's resume the meeting.

.4 MR. VINE: At various points, as the agenda was 5 being planned for today, we added a chapter or two to this 6 afternoon's schedule and now we're up to presenting to you 7 every chapter in the back past chapter five with the 8 exception of one and that's chapter ten.

9 Chapter ten is managing interfaces; it's not done 10 yet, we hope to have it done this summer and so we're going 11 to give you a presentation on every other chapter this 12 . afternoon. Included in this'. list of chapters that we'll 13 brief you on is chapter 11 which hot off the press just 0 14 came out yesterday and so this is'a chapter that unlike the 15 others, staff has never seen that, all before in the 16 December January timeframe, the ones we're talking about 17 this afternoon.

18 Now in the package that's been handed out here 19 the first 13 slides past this introductory slide are one 20 page summaries of each of the 13 chapters. Now, those one 21 page summaries give you really three things. Number one, 22 ~a rough summary of the scope of that chapter; second, some 23 of the key requirements and design features of that chapter 24 that we think are most important to appreciate in terms of 25 their significance to safoty or availability or their D 1 V

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158 1 significance in terms of change from current design, and 2 finally at the bottom is the ststus of when the chapter was 3 published, issued to the NRC, and when the DSER was issued.

4 Now, I'm not ,Joing to go through those 13 slides; 5 they're there for your reference to try to get these 6 chapter numbers in your mind and to get a better 7 appreciation for the scope of each of the chapters. We're 8 going to . jump right into the first three chapters that 9 we're going to'present and to alleviate a lot of difisrent 10 people jumping up and trading.off back and forth, I'm going 11 to ask Bruce Pusheck to start off and cover chapters six, 12 seven,-and nine, skipping eight; and then I'll do 11; and n 13 then Joe Yedidia will do eight, 12 and 13.

U 14 We're not necessarily going to be spending equal 15 amounts of time on these chapters. We're going to try to 16 emphasize those that are the most important to safety, the 17 ones we think will bring up the most questions and the ones 18 we think we really need'to clarify for you and explain in 19 more detail. So, Bruce. We've got a couple slide 20 projectors here in case there are some places where we're 21 going to try to show a drawing and'some words at the same 22 time.

23 MR. PUSHECK: That's me, Building Design and 24 Arrangement is the title of chapter six. The purpose and 25 scope of chapter six is to define the plant arrangement O

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1 requirements for BWRs and PWRs. And the text defines those 2 requirements which deal principally with the arrangement of 3 the buildings and equipment within them. Also included are 4 sketches to illustrate what the requirements are. The 5 sketches at the present time are very preliminary form and 6 do not necessarily reflect all requirements. In other 7 words, some of those things with the requirements are in 8 there.

9 Building structural load combinations for 10 structures and equipment are not reflected in the chapter, 11 as might be suggested by that title. So there may have 12 been some confusion on that. The staff was asking

<3 13 questions about structural design and analysis which are U 14 not dealt with in this chapter. It's in chapter one.

15 A lot of interest in the area of building design 16 and arrangements.and utilities, A&E organizations and so 17 forth. The next area, just to indicate the kind of 18 interaction, the chapter was developed over about a two-19 year period, and results of that process, after two graphs 20 were developed, there were about 900 copies developed by 21 the reviewers.

22 Interfacing programs include the DOE structural 23 program and the chapter was issued in late November 88 to 24 the NRC Staff for review and subsequently received about 25 45, 50 comments on that chapter. Those are in the process PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO, CAUFORNIA 95827 TELEPHONE (916) 362 2345

160 1 of developing responses. q n 1

2- The chapter's concerned principally with certain .I 3- areas including constructibility and maintainability of the -

'4 plant, and these indicate some policy statements that point 5- .to those areas.

6 .' optimization of. space is' extremely,important for 4 7 access and' construction and operation. . The chapter does 8J require maintenance studies to evaluate the proper. location, j 9 for equipment, equipment removal, access for repair and as-10 a matter of fact there's even a sample evaluation program 11 included in;the' appendix, I believe'it's appendix E.

12! The emphasis is on' design simplicity because we 13 believe that's' going to lead to the overall' low cost of.the.

O 14 plant.

' Sabotage is addressed insofar. as physical 15 . separation, separation by divisions is accomplished, this 16 is not the' principal chapter =for addressing that subject, 17 but it is one of the concerns.in terms of laying out the 18 plant.

19 Standardization, extremely important and vital in l 20 terms of ability of utilities to realize all the benefits 21 of. design engineering process, hopefully to optimize the q 22 design and improve the constructibility. To achieve that 23 it requires standardization of the systems, P& ids and 24 standardization of.the components as well.

25 Even more recently as we were involved in a I l

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. workshop on' modernization, put on-by' DOE, itfbecame quite

,2 -

apparent that standardization, even of the modularization,

. 3: . modular-designs becomes'very important..

4 COMMITTEE' MEMBER CARROLL: P& ids bring up one of 5 my favorite hobby horses here. As P& ids developed.in the 6 Lfossil and nuclear' business and plants became- more 7 complicat'ed, P& ids-.seemed to become a designer's tool-'and

. people ignored the ultimate user of those, the people that

~

8' l' 9 have.to operate the power plant and I know in the case of 10 my former employer, what we ended up with was totally.

11 ' useless as an. operating tool. We had to draw our own.

.12 l Have [you gotten . operating people's input into l

13 what ' these' P& ids i ought ' to look' 'like to make the right I - -O . .

'14 compromise between what the.gerators are ultimately going 15 toLneed and what's handy for the designers to have?

16 MR. PUSHECK: Of course, the requirements 17 document. establishes system function requirements through 18 the ' actual P&ID development, but yes, chapter one

-19 absolutely requires an interaction between operators and 20 designers for developing design, as well as for the 21- constructor being involved totally in making sure the thing 22 was. constructed, but yes, early involvement is important 23 from the. conceptual design standpoint.

l- 24 COMMITTEE MEMBER CARROLL: I'm just talking about 25 what the P& ids look like. I assume what you're describing O

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is_ going-to take place, but you can make PCIDs very useful 2 to.the design disciplines. Oh, for example, one of the 3 i things PG&E did was to put together piping diagrams without d 4

any instrumentation on it because that's what was handy for ]

5 - the pipers, and instrumentation wasn't in the form of

)

t 6 diagrams, it was in the foun of a lot of books of ']

(

7- paperwork. And what -- by the time people got ready to

{

8 operate the plant, they said, this is hopeless, we can't i 9 carry ' a wh'eelbarrow load of books and drawings to the i

10 plant, we need something that operators can really use.

{

11 If' you think about it before you start laying 12 these out and establishing formats .ane stuff, you can 13 probably .' satisfy both organizations' ne reds , both the 14- designer and the operator. I 15 MR. FIDRYCH: Is- there anybody in PG&E wo enn 16 talk to to get-more detailed information on this. Because 17 right Lnow I don't see anything like what you described 18 going on. I'd like to know later.- l 19 MR. ARCHIZEL: If I can make a comment, you know 20 operational type drawings that derive from the P& ids are 21 typically made after several years of operation when the 22 plant finds it can't use the P& ids, but I think you're 23 suggesting you take the P& ids and make operational I

24 drawings. Many utilities have this. You don't need the i 25 line sizes and things like that for an operator, but you O

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.Q) 1 need the instruments. I guess what you're implying is they 2 should have a standardized operational and coordinate that 3 with'the P& ids up front.

4 COMMITTEE MEMBER CARROLL: Yes, and-so when you

5. get ready to ste -t the plant up you have something you can 6 use. Larry Womack, the assistant plant manager. for 7 operations at Disblo would be a good guy to talk to.

8 The 'othm: thing I'm wondering about which is sort 9 of related to this is has thought been given to, by the 10 time the design is complete you have something to maintain 11 configuration management, whatever that is, through the 12 life of the plant? Is the design going to be done in a way 13 that databases are established on structured systems and ,

14 components that can be kept up to date and that sort of 15 thing? That's a very important topic nowadays. If you 16 start right you can end' up with a package that just 17 smoothly flows into the operational phase.

18 MR. 'PUSHECK: Well, certainly configuration 19 management is an'important topic and -- involved with the 20 nuclear construction issues group in that developing 21 methods and new processes for configuration control and 22 guidelines for them have resulted, I believe, and we're 23 planning to reflect those in here. One other area, and I 24 don't think it's gone in fully is chapter one is common 25 databases for the plant and that will be extremely O

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'important requirement since the' initial issue of' chapter.

2 one there has been a. lot-taken place in the' industry in -

3' this program andwe certainly intend to establish 4

requirements for integration of that database involving all 5 the subcontractors. Through that database to maintain more

.6- clarification of design changes.

' 7. MR. VINE: The original' version o'f chapter one 8

which is three ' years old now. called for a design line-9 classification system and a comprehensive documents 10 management system and at least this level of detail already

.11 and you have in chapter six a great deal of additional 12 ~ documentation for maintainability and so some of that other material lwill be integrated into chapter one.

~

, 13 O 14 . COMMITTEE MEMBER CARROLL: It's something in my 15- mind that, really ^ needs . to' be done up front, o

'therwise 16 there's <the potential ' dichotomy that the designers get into 17 that~ database what they need during the design phase of the 18 plant.and if'you'd'really~ thought about it up front you.

19 could put in the kind of stuff that the people have got to 20 operate ~and'. maintain and are going to ultimately need, too, 21 like what vendor manuals apply to this or that, I can think 22 of hundreds of examples.

23- MR. PUSHECK: Before we leave this one, the point 24 I was trying to emphasize is while this chapter does not 25 deal with systems, per se, but it reflects what's done in

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1-the design of the. system.and the components and to maintain 4

2

the standards on it, which really can be used from plant to f 3

' plant to plant, it's extremely important that those things-

]

4 .be sta'ndardi' zed and they not be changed.  ;

'5 Some of the key requirements cover the. Plant .

1 J

q 6 listed'here;,I'll be getting into.some of these in more

7. detail in subsequent slides.

.8 Design for operation and maintenance.- O'n e of the 9 things mentioned earlier is'~how are ' we, assuring 60-year 10 plant life and important to change of' components which is 1

S 11 recognized most' clearly that those are not to remain for j 12 entire plant life, is the failure of removal, so there's a lot of attention,' requirements established for -- hatchways

.O '13 14 -and; evaluation.of the. major' component rules to:make sure

15. that they can . be removed . from the plant and replaced 16 without' undue' difficulty. : Containment for example, for the 17 PWRs removal.an'd-replacement with steam generator within 18' the 120 day period.

19 A lo't-of attention paid to ' equipment lay down 20 space and some of .the major considerations in the 21 containment; internal- arrangements, reflected a lot of 22 interaction with utilities and getting their input on what 23 they felt was extremely important in terms of providing lay 24 down space inside for tools and disassembly of components.

25 MR. RUBENSTEIN: You know, in terms of lay down j OL PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO, CAUFORNIA 96827 TELEPHONE (916) 362-2345

q 166 V 1 space when we went through the Toshiba operation for the 2 ABWR they had on the computer the ability to go into a pump 3 and disassemble the pump on the computer with appropriate 4 size, with all the places to take off the housing and they 5 walked us through the operation.

6 Similarly with a good CAD and CAE operation they 7 were able to show us the equivalent of the P&ID if you 8 wanted to look at piping, they would take down the 9 structural parts and take out the systems and look 10 literally at maybe what's left of the piping subsystem. So 11 do you have any requirement.s to drive the designers to 12 doing in addition to configuration management, P& ids on 13 disk storage and CAD?

14 MR. PUSHECK: Yes. As a matter of fact it's 15 expected that computer aided design will be used for 16 modeling the plant facilities as well as the systems design 17 and that three-d models will be basically created on CAD in 18 which you can make drawings, or view the entirs three-19 dimensional drawings, take photographs of it and so forth, 20 entire database will describe the physical plant and there 21 is a requirement for that.

22 MR. RUBENSTEIN: I'm really talking now to lay 23 down space. They literally were able to use a computer to 24 demonstrate the lay down and disassembly of a pump in a  !

25 relatively small room. In addition when we looked at it we k

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1 sawL a .-' hundred percent disassembly. .of the turbine on the-2~ turbine ~ floor. So I just -- some of:these are standards to' '

3~ start with.

4 MR. PUSHECK: Yes, I think I'did mention in our 5 appendix E we have a maintenance? study requirement. We.

6: <have not done the study, but staff requirements. Imposing 7 on the plant designers the requirement to demonstrate how t 8 -to remove that equipment. I don't specifically . recall

9 whether it says there should be' drawings on the database as to pertains to all ' the lay down. -Can't recall, but it 11 .srtainly sounds like a good idea.

12' MR. FIDRYCH: We did say that drawings would be j 13 prc6uced but we didn't say how.

~

14 COMMITTEE MEMBER ' CARROLL: With your -high 15 availability goal I guess one other thought you might look.

u 16 at, given'some of the disasters that have happened in the 17 industry with generators, particularly one vendor that I

18. can think of, have 'you made it easy to have a spare 19 generator and ~ do a total' generator replacement if you 20- destroy a generator?

21 MR. PUSHECK: The steam generator --

22 COMMITTEE MEMBER CARROLL: No, the main 23 generator.

24 MR. YEDIDIA: Chapter 13 has ' requirements for 25 replacement of all parts, lay down for the parts of turbine i

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and the generator, but there is no special provision for a 2 disaster--

3 MR. PUSHECK: He's talking about spare parts, as 4 I hear him.

5 MR. YEDIDIA: They're definitely removable.

6 COMMITTEE MEMBER CARROLL: No, what I'm saying if 7 you wipe out the lining in a generator, you're looking at 8 at least a six-month outage for a relined and there are 9 utilities that have purchased spare generators from an 10 availability improvement point of view and think they can 11 change out a whole generator in about a month, so you've 12 picked up five months.

13 MR. VINE: We have, in chapter one, requirements

('l 14 that impose on the design sufficient capability including 15 the necessary lay down space to replace any component in 16 the plant other than the reactor vessel itself, and even 17 the reactor vessel has some nominal requirements and 18 discussion of them in chapter one on the possibility of 19 replacement.

20 So that covers the question of replaceability and

21 lay down space to do it.

22 COMMITTEE MEMBER CARROLL: Traditionally we 23 haven't put big enough cranes in turbine buildings to take  !

24 a generator in and out, special equipment--

25 MR. FIDRYCH: We do specifically say the crane O

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capability-has to be sufficient- to take out the largest 2

L 1'

components of the turbine generators and we do specifically E 3 call for lay down space at the generating site plus other 4- parts.

5 COMMITTEE MEMBER CARROLL: I'll bet your crane

6 isn't big enough to pick up the stator, Lee.

7 MR. FIDRYCH: Well, the largest component, so--

8 l COMMITTEE MEMBER CARROL1: Most people interpret 9 that to be the. field.

10 MR. YEDIDIA: We'll look into that. There's one 11 item that.maybe I should mention in advance of discussion i

12 of chapter 13 is that there is a requirement for having the 13 three low stages of the turbine all identical so that one I

14 spare can be kept for 'all three of them and I don't 15 remember if there's a similar requirement for the stator, 16 you're talking about the rotor of the generator or the 17 stator part, which?

18 COMMITTEE MEMBER CARROLL: Stator.

19 MR. YEDIDIA: I don't think that there is a 20 requirement for having that spare, but there's requirement j l

21 for being able to remove it. )

22 MR. PUSHECK: Under design construction there are 23 several items listed there which is --

performance i 24 document, segregation of safety from nonsafety systems has 25 an advantage of avoiding a lot of the QC inspection on O

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170 1' nonsafety items, just.because something happens to be in 2 the same area. Modularization extremely important and even

3. from the standpoint of standardization because as we 4

learned very recently, some larger moclule concepts where 5 equipment and structural modules come together, the 6 structure becoming a permanent part of the plant, 7 consideration of piping and conduit and so forth is very 1 8 important~ 1 9 Start-up testing --

10 COMMITTEE MEMBER CARROLL: You made the comment  !

11 about segregation of safety systems from nonsafety, given 12 the thinking we're hearing about on ACRS about the 13 maintenance rule, I'm not sure that distinction's going to O' 14 last much longer. There's the maintenance rule, as it's 15 presently drafted, is going to bag in all balance of plant 16 systems that could have an impact on safety and that's 17 pretty loose wording.

18 MR. PUSHECK: Because of their proximity?

19 COMMITTEE MEMBER CARROLL: No, --

20 MR. PUSHECK: Or because of their interaction 21 with the system?

22 COMMITTEE MEMBER CARROLL: No, because they may  !

23 challenge safety systems if they're not properly 24 maintained; and when you go as far as saying, okay, we'll .

25 worry about it from a maintenance point of view, I guess G

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'l'ogically yo'u should be worrying about it from a design 2 point of view and an' operating point-of v'lew and a' lot'of:

3 ~other' ways.

4 -I guess my point is that I'm1 not sure that the 5- nice' clean lines we've had between safety systems'and'other j 6 things are~ going to stay that way too much longer.

7 MR. - VINE: You're probably - right to a large 8 degree in areas like maintenance and so forth. There are 9 still, .within the regulations, very specific rules for what 10- has to be done in terms of QA/QC, certain requirements that 11 have to be met for'. safety. systems that are not imposed on 12 nonsafety systems and we're maintaining that separation 13 theme throughout all the chapters, not just in the layout.

O- 14 area.

15 .So it is important for the utilities.to maintain 16 that separation even though maintenance rule, I guess, goes l

17 in a different direction.

18 COMMITTEE MEMBER CARROLL: No, my point was that 19- the maintenance rule is the first shot fired in that war.

20 I suspect that we may extend QA to some of these systems.

l 21 MR. RUBENSTEIN: We have no- rulemakings or l

22 pressure coming from-the staff in that way at this time.

23 You will, both.-in maintenance and in the full scope of the 24- . design that's in.part 52 which Charlie will talk about 25 tomorrow, there is some pressure, but that's limited.

- O.

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1 COMMITTEE MEMBER CARROLL: Didn't sound very 2

limited to me last week when we were talking about the 3 maintenance rule.

4 MR. PUSHECK: I gather the same question lies in 5 other people's minds. We'll comment on it.

6 Startup testing was felt to be an extremely {

7 important area to get involvement early in the project from 8 a schedule standpoint, also ties in with decisions on 9 modularization, defining how the modules are constructed 10 and designed, from a standpoint of system delivery and 11 completion of those modules.

12 I'm going to talk a little bit about the primary 13 containment; in this presentation I don't think we can O-V 14 touch much on the other buildings, except I will drag out 15 a couple of hastily made slides to give you an impression 16 of the sketch we have in the chapter.

17 On requirements for both BWR and PWR, chapter 18 five. You heard those issues here. So one of the big 19 areas we emphasize particularly the PWR I should say and 20 has affected the PWR arrangement, access and lay out space 21 inside the containment, the PWR most of the components are 22 moved outside of the containment.

23 Structural design, again covered in chapter one.

24 So the emphasis here is principally on constructability 25 features in the chapter.

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Containment hydrogen mixing, cover requirements 2I for not closingiin compartments? and providing ' certain 3

criteria for venting all the areas and: avoiding- 'of 4' . trapping hydrogen.

5 Treatment in terms of reactor. cavity functions,-

6 for. both~ operational and accident considerations and 7 showing some sketches on that. Functions, accident' area,

'8 'ncluding i retaining the core debris and covering the com 9: with' water, for cooling, and then protecting the 10 containment leak barrier.

11- The last three bullets on there-just indicate 12- some of the considerations on the issues we talked about this mornip~ ohich were extremely important and affect this.

O' '13 '

14' chapter.in terms of finalizing requirements of chapter six 15 and influencing some of the drawings.

16 CHAIRMAN WYLIE: Is that fairly long as far as 17 development goes,.such as the reactor cavity--

l 18 MR..PUSHECK: Requirements--

19 CHAIRMAN WYLIE: --containing the cooling core, 20 yes.

21 MR. PUSHECK: Yes, the requirements are c

22 addressed; as far as the detailed design, those are l'

l 23 developed in the standards --

24. CHAIRMAN WYLIE: Okay.

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.0 1-stray core debris-in the reactor' cavity. That's something

1 2 -like two-tenths a square foot.per. megawatt. Square meter?

3 MR. STRAWSON: .022 a square foot.  !

4 COMMITTEE MEMBER KERR: What is the significance 5

of the last. on the last slide' of cover the debris with 6 water? ' Does that mean that no matter what' stage of'the 7' accident, if;you'have. debris on the floor that you can get

~

8 water, you add water?

9 .MR.'PUSHECK: Yes. In other words, we haven't

10. . determined whether you add water, makes -- decision to put 11 the water-in before.the core might be in that cavity or 12 whether it's added later.

13 COMMITTEE. MEMBER KERR: You're simply saying it 14 needs to be thought about then?

15- MR. PUSHECK: Making a specific requirement that

.16 - water, emission of water into the cavity can be [

17- accommodated by the' design.

18 COMMITTEE MEMBER KERR: What does accommodated 19 mean?

20 MR. PUSHECK: Specific design provisions.

21 COMMITTEE MEMBER KERR: So you can get water in, 2?- or so that when water goes in consequences can be 23 accommodated?

24 MR. PUSHECK: A means of getting water in and --

25 COMMITTEE MEMBER KERR: Are you prepared to take I

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the pressure-force that might accrue if,you do?

2 MR.~PUSHECK: .Yes, we are. q 3 ~

COMMITTEE MEMBER KERR: You're designing the 4 containment for that?

5 MR. PUSHECK: The containment is designed for the 6 pressure that comes out of the design basis. accident.

7 COMMITTEE MEMBER KERR: I'm not talking about.a 8 design basis accident, I'm talking about a situation that 9 might' occur if you'had hot debris on the floor and no water-10 and now you add water.

Il MR.-VINE: Dave's not here. I think we've looked 12 at that and' try to answer that for you tomorrow, but I 13 think that's included in the analysis, it's within the 14 design.

15 MR. LONG: This was discussed two or three weeks 16- ago in Bethesda and your consultant's position was that 17 -there's no benefit to be gained by delaying putting the 18 water'on the core. The core is on the floor. You can add 19 it immediately and rapidly and that does not increase the ,

20 threat of pressurization over what it would be if you were 21 to delay and add it slowly. I l 22 There seemed to be a question of whether it was ,

23 desirable to actually delay putting the water onto the 24 core, the core is on the floor.

25 I also would like to point--

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l- COMMITTEE MEMBER KERR: Whose conclusion 'was 2

this?)

3 MR. LONG: That was EPRI's consultant and I can't 4 remember. 1 j

L l- 5 i

MR. VINE: Was it Dave Leaver? We'll-have to 6  : answer that. question--

7 MR. LONG: I'd like to point out, too, that the 8

General Electric approach is to use passive fusible plugs 9 for those lines.that put the water on the floor, and in l

10 that event the water would not be there before the core, i

11 the vessel failed, put the core on the floor.

12 With- the EPRI approach of the requirements

=

13 document'the operator has control and.he can put the water O 14 in the cavity ~when he's ready to.

15 COMMITTEE MEMB1;R KERR: Well, he has control only

_ 16- if he ~ has water. It's possible, it seems ~ to me in

- 17 principle, at'least, that thero could be a situation in 18 which you didn't have water, the stuff gets on the floor 19 anu now you have the water supply -- now what does he do?

20 21 MR. VINE: We need to chow you the system that 22 provides that water and the redundancy and reliability of 13 ' it . It's not an outside tank. For the PWR it's the in-24 cc:ltainment refueling water storage tank. The water's 25 right there, it's e.lready ready to go and in the case of PETERS SHORTHAND REPORTING CORPORATION j 3336 BRADSHAW ROAD. SulTE 240  !

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1 the BWR, it's the suppression pool.

2 MR. PUSHECK: As a matter of fact the next slide 3

illustrates just what .we've been talking about. Let'me '

4 back up for just a minute to cover this slide which kind of 5 describes the BWR' containment which has as its basis the GE 6 ABWR design.

7 The containment, first of all it's a suppression 8 type containment, suppression pool that surrounds the 9 drywell; the drywell is essentially in two compartment 10 areas, upper and lower drywells and the drywell boundary is 11 essentially that bold line that you see. The suppression !

12 pool for a sev6re accident function can be used as a source

'13 of water for emitting water directly into that cavity.

14 Now we had not made that a requirement and if, at 15 this particular time, that that be a valve or there be 16 redundant valves there, that is certainly one way we saw of  ;

17 satisfying this requirement.

18 COMMITTEE MEMBER KERR: What is the point in i 19 haviing two separate kinds of containments, one pressure 20 suppression and one a large dry? Have you concluded that 21 there isn't any way to decide which of the two is better?

22 MR. VINE: I think we've concluded that the best 23 containment design for PWR is a large dry and the best 24 containment design for BWR is pressure suppression system.

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-- 1' perform cost .eva1uation, the ' economics ' of .a- large dry 2

containment \ifor a =PWR.-

There Lhas been 'a lot of 3 investigation [ by General Electric and various architect and 4

engineers.have worked with't. i They; essentially.always come 5- to'that conclusion from the-standpoint of economics, and , j 6 .other - considerations. ' :I guess principally dealing with 7 -discharge of steam lines inside pressure--

8 COMMITTEF-MEMBER:KERR: ' Since the'PWR now has a

-9 suppression pool,-from what I. gather, -- ,

'i 10-MR.-PUSHECK: No, it's primary. function is not

'11: ~ one.of. suppression.

12' COMMITTEE MEMBER ~ KERR: It might not . be its 13 primary function, but there it is.- A lot of water. ,

14 MR.-PUSHECK: It's.there but --

15 COMMTTTEE MEMBER CARROLL: . It'isn't big enough 16 'for.a design basis. y 17 MR. STRAWSON: The PWR has a lot of water in 18 containment; it does not,have a drywell that forces in the 19' event of a break a , release from reactor coolant system 20 through that water.

21 COMMITTEE MEMBER KERR: I'm simply wondering if 22 anybody's going to have the -- I hesitate to use the term 23 guts, so I won't -- to try to find out which of these i 24; different things is better, if there is one that's better, 25 from a safety point of view, from an economics point of

O <

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1 view.

2L "When these containments were~ originally designed 3' they _ were m dedigne'd for largoJ break and . some of us now 4

.believe that ~ conta{nments should L be' designed .for - other . -i l'

5 ' purposes.. -And I ~ think saybe" itL'will- be the next-6 genebation,.I guess it'is! the next generation of reactors

~

7 are not going' t'o have ! containment anyway, maybe the 8 question will .go away, but it would' seen to me that it 9

would be worth pursing.

10: MR. RUBENSTEIN: I think in the case:of the BWR 11 as we'll . talk about tomorros,- the design in _ terms of 12~ containment functionality has three or four levels, they've 13 got the des 3gn pressure, they've got;a rupture disk, they 14 l have' a ' harden ; vent and they have 1 the ultimate . rupture 15 strength of the containment. And that should' deal with the 16 ' spectrum of both with and external to the design basis.

17 However, I')1 let you go on,-

18 MR. PUSHECK: Yes, you can see the configuration 1'9 -of this because .it's very small and only essential

.20 components which are felt needed to the inside containment.

21 are inside. This has the benefit of reducing the radiation 22 exposure to operation of the other components. If the 23- containment were larger it would add t. lot of it, yes, but 24 it would require putting components inside there that we 25 don't need in the inside containment and'the surrounding O

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.bdilding.

.2 '

= MR. RUBENSTEIN: I would. add that your question

3-is well t'aken'andiprobably they" start to converge'a little 4

.d more, in terms of the. passive plants, both in. terms of size.

5- .and the' nature of the' passive,' cooling containments'in.SBWR' 6 *

[and AP600. Someone may want to address.that.

-7 1 MR. JOHNSON: ' I 'can't. resist. My name's Chuck 8^ Johnson, I'm ' a consultant ' to EPRI. I-have studied this

,- 19 containment situation.between PWRs and BWRs; I'm convinced 10 .now .it's driven' by economics. Traditionally the BWR.

11 started with very large primary system in terms of the mass 12 and' the - energy contained in it. This drove.the design g 13~

toward the vapor-suppression system.- You're correct, over-

- Q :14 time the BWR system has co:ne down . in size, that's' the L15 energy stored -within 't i per ' megawatt has decreased, 16 becoming ..very ~ close the' PWR, to parity. with r,aking H 17 plausible putting a BWR in dry containment and not coming-18 up with an economic penalty.

19 This particular design, by my calculation, has 20 _about a 10 percent . penalty in terms of a volume of a 21 containment or the product of the volume times the prescure 22 of the containment in favor of the PWR.

23 As another feature that's come up in the recent 24 past, and that is the amount of hydrogen generated. Per 25 megawatt the BWR has considerably more zirconium in the O

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/m 181 (f i i core, so you get a lot more hydrogen. The prospects of 2

being able to tolerate a 75. percent reaction, 13 percent 3

detonation limit in dry containment would force the BWR to 4

a very large containment, or to some type of burning 5

device, which the old WR program has been against, has not 6 wanted to go that way. 'So that's two reasons.

I I've got one more final shot at this. I'm not

,8 trying to say that the vapor suppression system is a bad 9' system. There are reasons why you don't use it on a PWR.

10 The PWR primary syctem is a distributed system and it's 11 quite awkward to wrap a drywell vapor suppression system 12 around it. The ice' containment was the only attempt I know 13 of that started to do that and it was not particularly 14 successful. I don't want to hurt anybody's feelings, but.

15 So that would indicate that historically there's been 16 pressure to go in the vapor suppression direction even for 17- the PWRs.

18 So I'm convinced that as of now we're about the 19 right economics for the two systems.

20 COMMITTEE MEMBER KERR: I don't pretend to know 21 which is better and maybe it's impossible to decide. I 22 have not seen a serious effort on the part of anybody to 23 decide. It would seem to me it would be worth pursuing, 24 but I'm not sure whose responsibility this is.  !

25 MR. PUSHECK: Well, let me comment on that for a PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SulTE 240 SACRAMENTO CAUFORNIA 95827 l TELEPHONE (916) 362 2345

q-u 182 1 minube. Move' to the PWR Containment and show a partial 2- cutoff there on the right' screen and let me say that there 3 'has been a fairly significant - effort in the area of 4 evaluating PWR containments. Most recently the power 5 . company commissioned',' under.their DOE contract,-to develop 6 design comparisons and constructibility. comparisons and 7 several' workshops were held'in'1987 and.1988 to review the

~

i 8 results of' those designs', participated 'with most of the 9 . major AE. vendors.

10 Andsthen EPRI used the results of that to come 11- to our determination of what we woul'd put- in -the 12 requirements document, which was put in front of the study.

13! . committee and endorsed by them. .

From an economic O:-

14  ? standpoint- the spread was something like reinforced 15 concrete, containment, allLin largeIdry containment first.

16 .of all, all with similar internal volumes or. essentially.

17- the' . same internal volumes, all the same internal area.

18 Reinforced concrete came out to be lowest construction 19 cost, followed by prestressed concrete, followed by steel 20 ' containment ~ vessel with a secondary concrete shield j

21 building, followed by spherical containment. That was l 22 considering the overnight construction costs and the 23 special considerations, the cost for interest during 24 construction. Other factors considered. Considerations 25 'for a severe accident situation, containment cooling for O

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1 example, sealed containment'got'a big plus in that area.

2-So ' the bottom line ended up the evaluation:

l 3 concluded that' the free-standing steel containt.ent, 4

secondary concrete building Lwas the recommended design 5 basis l..for the requirements' document.

6 What I'm saying.here is thatLyes, there was an

'7' extensive-industry review, in which EPRI. participated, and 8

~

took the benefits ~of quite an extensive design analysis and-9 schedule work khat~was done under Duke Power Company:by:a 10 major'AE. ' '

1 11. So'we ended up with 150 foot inside diameter 12 . steel vessel, reinforced concrete surrounding: building.

13 What's not shown there is the hemispherical-top head and

  • 'O. 14 the concrete building surrounding it.

15~ COMMITTEE MEMBER CARROLL:- Have you got your fan 16 coolers up off the main operating floor? To calibrate 17- median as to whether 150 diameter is okay?

18 MR. PUSHECK: Can't remember. Most of the past 19 . containments have been in the area of 120 foot inside 20 diameter for 800 to 900 megawatt range up to 140 foot 21 diameter for some of the larger 1250 megawatts. And one of 22 the major considerations was adequately space at the. ,

1

23. operating. tech level and more efficiency. (

24 COMMITTEE MEMBER CARROLL: Right, and whether you 25 have the fan coolers there or not is very important whether O l PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD, SUITE 240 SAORAMENTO. CAUFORNIA 95827 TELEPHONE (916) 362-2345

q Y i  ; 184 1 that's' adequate.

2 ,

. MR .' PUSHECK: Yes. -I cannot' recall from my

-3 memorycwhether they are.-

l 4 Access. Large equipment' hatch, plant grade, size

-5 - reactor. coolant pump, removal to. vertical position. And-6 provisions forf steam generatioi removal and replacement. As 7 I/said wei have'a goal of 120 days outage for that.

i 8 COMMITTEE MEMBER' CARROLL:

~

And that doesn't come l

9 ~ out through the" equipment hatch?:

10 MR. PUSHECK: Well,,there's a lot of debate'of

'11 this.f!A~ lot of consideration ~to put the large hatch at the 12 operating deck' level. Maintenancewise and constructionwise

-13 ~ there was" tremendous advantage'to put the large hatch at

~

14 grade level to enable trucks to come in there and movement

'15 of personnel at grade level, and lower part of the o i

'16 containment. As a matter of fact there was a major  !

17 workshop-held.with the people wh'o are studying this issue, 18 our consultants, our staff, and the utility representatives 19 and this'is what the conclusion came up.

20 Now we haven't excluded putting a large hatch at 21 the upper deck for removal of the steam generators. We 22 only say we want that big maintenance hatch at grade level 23 which happens to be down about two levels --

24 COMMITTEE MEMBER CARROLL: Right.

25 MR. PUSHECK: But because of the steel shell, O

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.1 /theres~no reason that you can't cut.'a hole in that steel 2' shell' very nicely and . bring the generators 'i'n from the

. 3- operating' deck level. We have not precluded that. This is v 4' .one of the.other benefits --

~

p 5. COMMITTEE MEMBER CARROLL: Okay.. And .two I:

L 6' personnel' locks.

7 MR.:PUSHECK: You bet,'and I want to emphasize--

8- COMMITTEE MEMBER CARROLL: Good for you.

! >< 9 MR. PUSHECK: --that one of those is not an 10 emergency lock that a guy has to crawl on'his belly. These

, 11 'are full-sized' doors. Some people don't have . a full

.12 Appreciation for.that. Obviously:.you do.

13 A couple of points on - the arrangements. I

.O. '

14 apologize in.~ advance for what these look'like,.made them

.15 very hastily. But they give an impression of a couple of 16 1 things I wanted to convey, 17 As you can see this is a PWR showing the steel 18- containment. It's surrounded in plan by the auxiliary 19 building here and by the fuel building and at this site and 20 -between the turbine building and the auxiliary building by 21- the control building.

22- One thing ~that's fairly interesting here is the 23 four quadrants of the auxiliary building contain the

'24 safeguard pumps. Provide ideal separation. Think of this 25 as a separation of divisions down the centerline, with the O:

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A on one side, B on the other side. The quadrants provide 2 both separation of divisions and separation of safety 3 trains. Very desirable.

4 CHAIRMAN WYLIE: You say four, are you talking, -

5 - four safety divisions?

6 MR. PUSHECK: No, not four divisions, but two 7- divisions, and then there are different trains within the 8- divisions.

9 CHAIRMAN WYLIE: Four trains.

10 MR. PUSHECK: Essentially that's correct.

11 Okay, component cooling water heat exchangers are 12 at the lowest' level of the control buildings, right here.

13 Capability to bring those up to grade through hatches and O 14 out.

15 There was a comment about the open equipment 16 hatch on BWR and first of all, in providing the, we have a 17 requirement that the hatch be closed within six hours and 18 a requirement that the hatch be operated from overhead and 19 come down.

20 On the PWR we also have a requirement that 21 doesn't reflect in this plan, but outside the equipment 22 hatch and I'm going to indicate the location of the 1.

23 maintenance hatch is right here, at the grade level, and 24 outside of that is another structure in this area which 25 provides a truck bay and there's a requirement for rollup O

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1 doors on the truck bay and the capability to maintain that 2 area of the truck bay outside containment, negative 3

pressure, while you have.the equipment -- we think that's 4 a very important feature.

5 COMMITTEE MEMBER CARROLL: However, for some of 6

the middle loop accidents one can postulate, you are going 7 - to have a' fair steam generation rate. I'm not sure whether 8 you'd overwhelm the negative pressure feature.

9 MR. PUSHECK: It would also make it a little 10 difficult.to get'in there and close the equipment hatch, I 11 suspect.

12 COMMITTEE MEMBER CARROLL: Yes.

13 MR '. PUSHECK: I'm sure that when we put in the O 14 criteria for the hatch it wasn't with the idea that we had 15 steam conditions --

16 COMMITTEE MEMBER CARROLL: Well, the notion the 17 staff presently has for those kind of accidents is if it's 18 pressure closing it just needs four bolts in place just to 19 hold it up there because you don't need really tight 20 closure for that sort of a situation. You're not talking i

21 about design basis accident pressure, but a few pounds.

22 MR. PUSHECK: The requirement speaks to the 23 closure testing--

24 COMMITTEE MEMBER CARROLL: Yes.

25 MR. PUSHECK: --go beyond.

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COMMITTEE MEMBER CARROLL: Yes.

2 MR. PUSHECK: Also are the diesel generator 3 locations which are approximately in this area on either l 4 side of the control structure, north and south direction of 5 plan there, correspond to the divisions. i 6 Again, not very good --

7 COMMITTEE MEMBER CARROLL: I didn't see it on the 8 picture, just one of my things I'm always interested in is 9 are you putting the MSRs on the turbine deck or on the i

10 mezzanine?

11 'MR. PUSHECK: --on the turbine deck.  ;

12 COMMITTEE MEMBER CARROLL: You're better off

.t

.p 13 putting them on the mezzanine if you're going to make 87 d 14 percent availability. They get in the way.

15 MR. PUSHECK: Okay, this is the BWR arrangement.

16 Just going over that real quickly for orientation. Turbine 17 building control. structure, reactor building surrounding  ;

18 the containment. Now in the reactor building three 1

1 19 quadrants are located the diesel generators and they remove 20 strictly at grade from those quadrants, and the component 21 cooling water heat exchanger, again pursuant to the PWR, is 22 the lowest elevation of the control structure. And has 23 hatchway provision for lifting vertically and removal at 24 grade.

25 COMMITTEE MEMBER CARROLL: Do the generators O

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1 communicate with the' refueling building?

2 MR. PUSHECK: No, they're isolated totally from 3-the standpoint they're not in the same fire area, they are 4

structurally in the same building and the reactor building 5 and the fueling building is also within that.  :

6 COMMITTEE MEMBER CARROLL: I see something that 7

looks like a door up there but probably isn't then, huh? ,

8 MR. PUSHECK: Again, there is not very much  !

9 detail- on the ' drawings currently in the chapter because 10 they do not reflect requirements and we were hoping by the i 11 next stage to put more' detail, part of the process --

12 'MR. VINE: The chapter six drawings, themselves,

~

13 in the document are much better quality but are larger than d -

'14 you can put onto a Vugraph and so if you have access to 15 that chapter six you .can get' a much better view of the 16 laydown.

'17 MR. PUSHECK: I'll come back for just a minute 18 to the PWR -- interest of why we got that in containment 19 refueling water storage tank and we think it's a good move  !

20 in the right direction.

21 Principal function of this tank is to provide 22 water for the safety systems, but an even larger capacity 23 requirement is to fill the refueling pool for an outage )

24 condition. So that establishes the sizing and is 25 approximately 550 gallons.

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So safety. injection, RHR and containment spray 2

all take suction off this pool, as well as providing water 3 capability to the reactor cavity.

4 We think there's an advantage because it puts the 5 water source of the tank atmosphere pressure, so for all 6 the safety functions this is a big advantage.

7- As you recall from the other figure I showed the 8 safety pumps in outside containment; this provides for a

~

9 very close coupling between those pumps that feed directly 10 into the pump rooms. Big advantage, we think. And because 11 of the pumps being in the four quadrants we get a lot of 12 symmetry which should aid in the design and 13 cone':ructibility.

V 14 One of the' things I think was asked about 15 flooding and in relation to the -- isolation valve, are we 16 providing flood protection against the H load -- and the 17 answer is yes, as~a matter of fact -- stairways that come 18 ou( of the lower elevations, so there is a lot--

19 Let me touch just briefly on this. For a severe 20 accident flooding situation there's a normal operation or 21 containment operation, there's a whole volume on the floor 22 and that's illustrated by that kind of shaded area above 23 the IRWST in this figure. This shaded area here. The 24' objective is to not allow water to get back into the IRWST 25 in the event of an inadvertent containment spray actuation i

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-becauseLof potential for water, oily' substances to mix and 2

get back~tn the IRWST. .So there'is about a 60,000' gallon

'3 capability, then water returns to the IRWST and ' would 4; - recirculate.

5 Under a seve.re accident situation then we have to 6 admit water, or we'have a scheme to admit water using a set 7 of. lines'and valves' connected directly to the IRWST which 8 will fl'ood this.

9

-Now that water being admitted is substantially

'10- less than the full volume in the IRWST' so that the RHR 11- containment' spray system would still function, . and ' also

~12 that volume is limited because'we don't want to. initially 13 wet that reactor vessel nor floodLthe cavity _with borated

.O 14- water.

? .15 .The idea.here is to. provide something-which is a 16 safety capability and that ' the operator would ..not be

'17- concerne'd in case he operated that value, that he's going 18 to have a clean up situation;-in other words there should 19 riot be something laid ~~on the operator where he would be 20 -hesitant to operate that valve.

21 That wraps up everything we really wanted to

._ 22 summarize to you on chapter six.

23 I.did not hear chapter seven on your list of 24 things . that you wanted to talk about, but I do have a 25 couple slides here that I can address, if you don't mind O

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and we'll just -- we have not presented this to the staff, 2 specifically, although a copy of chapter seven was 3 transmitted to them.

4 This chapter deals principally with requiring 5 utility requirements for fueling and refueling systems and

}

1 f~ 6 deals with fuel receipt and storage and spent fuel 7 handling. It establishes the functional requirements for 8

support systems, the pool temperatures, the spent fuel 9

storage pool, HVAC systems, temperature and humidity for 10 those systems, and also for overhead cranes and service

11. ' cranes.

12 COMMITTEE MEMBER KERR: The reference to HVAC

, 13 systems has to do only with its influence on refueling?

V 14 MR. PUSHECK: Yes. In this chapter we establish

.15 certain requirements,- principally in the area of spent fuel 16 to keep the operator comfort; quite a bit concerned about 17 the heat coming off the spent fuel pool, particularly with 18 our criteria of essentially it's ten years of operation 19 plus a. full core is the sizing basis and that amounts to 20 'about three full cores plus another, in other words four 21 cores.

22 MR. RUBENSTEIN: Is that normal density or is 23 that collapsed?

24 MR. PUSHECK: We do not --

we consider high 25 density-- fuel consolidation -- Did I answer your question O  !

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on HVAC?. .

2 COMMITTEE MEMBER KERR: Yes.

3.

- MR. SHUM: Is HVAC decided---

4 .MR. PUSHECK: Yes.

5- MR. SHUM: And yet the total --

6 MR. PUSHECK: .I.can't answer that question.

7 COMMITTEE MEMBER KERR: I-didn't understand the 8 question?

9 MR. . l PUSHECK: He ' asked the question if:we're 10 going to have charcoal' filters.

11 ~ COMMITTEE' MEMBER.KERR:- Okay.-

12 COMMITTEE MEMBER CARROLL: ' ~But' if we're-13 traditionalist we'll have them, right?

14 MR. SHUM: -- fuel handling - charcoal filters.

15 COMMITTEE MEMBER KERR: I don't understand that 16 statement.

17 -MR. SHUM: The fuel handling, while ~you're 18- handling this spe't n fuel,,-if you drop those fuel and then 19 you create'an. accident, plus the spill, be partial release 20 of the fuel, ~ it's normal', traditionally, --

charcoal 21 filters would--

22 COMMITTEE MEMBER KERR: Wouldn't your filter 23 system'be designed on the basis of what you assume about 24 the fission products when they come out of the fuel?

-25 MR. SHUM: That's a question I've been asking O

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I because EPRI, in the very very beginning, they say no 2

charcoal filtern.

3 COMMITTEE MEMBER KERR: I'm not talking about 4

EPRI, I'm talking about the design of a system to handle a 5 fuel-handling accident. Shouldn't it take.into account 6

that chemical and physical form of the fission products 7 that might be released?

8 MR. SHUM: It should, --

when deciding a 9 filtration system.

10 COMMITTEE MEMBER KERR: Okay, then the source 11 term is what you assume to be the quantity and the physical 12 and chemical form of the fission products released from the 13 fuel, I would think.

C/ 14 MR. ARCHIZEL: That's what he's asking, a 15 different source term for fuel handling.

16 MR. SHUM: I don't A. tow, that's not my area, so 17 I don't know.

18 COMMITTEE MEMBER KERR: Okay, if it's not your 19 area then I will disregard your statement.

20 MR. PUSHECK: . Okay, focusing back on the chapter 21 seven policy statements, one of the major objectives of the 22 . chapter is to improve the component reliability arrangement 23 features so that we're able to achieve a maximum 17-day 24 outage at least for the 1300 megawatt size, assuming that 25 there will be a 24-month operating cycle. '

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h 195 V 1 COMMITTEE MEMBER CARROLL: What's driving the 17 2 days, is that the critical path through refueling?

3 l'R . PUSHECK: As it turns out it may not be the 4 critical path, particularly when there are a lot of other 5 maintenance functions, but what we asked the designers to 6 do is to make a detailed scheduled evaluation analysis of 7 all the critical path events that are involved in every 8 refueling outage and where assigned functions performed or 9 maintenance functions are performed, they in fact may add 10 to that.

11 But from this chapter standpoint, got to pay 12 attention to those things that are really directly in line g 13 with --

U 14 COMMITTEE MEMBER CARROLL: So the 17 days, 15 forgetting what else is going on out in the plant, that's 16 the --

17 MR. YEDIDIA: It's 25 days of outage, 17 for 18 fueling. This is the objective.

19 MR. PUSHECK: The 17 days is essentially breaker 20 to breaker, in other words, open the breakers, all the 21 activities involved, --

22 COMMITTEE MEMBER CARROLL: Wait a minute, you're 23 saying 17 days, he just said 25.

24 MR. YEDIDIA: I'm saying 25.

25 MR. PUSHECK: I think we're saying something

?

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D. 1 diffarent.

2*5-2' COMMITTEE MEMBER CARROLL: I think you are, too.

3~ (Laughter.)

4 'MR. PUSHECK: He's .sayj ng within:the 25 days that L 5 there are other maintenance activities that might occur 6 that.are not included in the 17-day schedule. I'm saying 7 that the '17-day schedulo for fueling outage involves 8 activities starting from a come off line, cool down vessel, 9 open'up vessel, begin to refuel and transfer fuel assembly, 10 to start.it back.up. The difference between 17.and 25 is 11 to allow for other activities of maintenance requirements 12 which we don't' define'specifically'in the chapter.

13- .

MR.- YEDIDIA: But they're still 'within -the O 14 schedule- activities. You see we have 87 percent 15 . availability requirement _and that accounts for about 48 16 . days.per year.that the plant is not going to be;on line, 17 of which some of which are allocated'to a one in ten year 18 shutdown which is 18 days, so that leaves you with about 30

'19 days of which five are for unscheduled events, and 25 are 20 for. scheduled main'tenance and'that'can be of. course apart 21 from the 17'can be'something outside the time of refueling 22 but usually it's assumed to be at the same period of time, 23 25. days.

24 COMMITTEE MEMBER CARROLL: So what you're telling 25 me is once every two years you're planning a 25-day outage O l PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SulTE 240 SACRAMENTO, CALIFORNIA 96827 TELEPHONE (916) 362-2345

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breaker to b'reaker.for refueling and other maintenance.

2 MR. STRAWSON: But the refueling operation is l 3 part of that itself.

4 MR. VINE: We've got to keep them very separate 5 because the chapter seven focus on refueling alone is

'6 setting a functional requirement on how long it takes for 7 refueling and'the relationship between that' number which is l- 8: .only every two years'and the overall calculation to meet i 9 our. 87 percent availability criteria are really pretty 10 . separate. Obviously that fits into one of the outages but-11 it's not; necessarily true that we (are saying that 12 refueling outage is 25 days breaker to breaker; it might be 13 17, it might be 30, depending on' whether ~ we have other

,O 14 things to do. That's just an average'. Whereas this one we -

15 expect, if there's nothing else to do, that -- or nothing 16 that's controlling, critical path, we'd be able 'to go 17' breaker to breaker in 17 days.

18 COMMITTEE MEMBER CARROLL: Does that envision in 19 the PWR case full-core off load?

20 MR. PUSHECK: Yes, in both PWR and BWR the 21 capability of full core off load.

22 Some utilities feel they would, some would not.

23 We're not requiring it.

24 COMMITTEE MEMBER CARROLL: Until we get rid of 25 fuel -- you'd better think of doing the full core off load.

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MR. VINE: The requirement right now is we went l 2 )

so far I think in the final language to almost say that the j 3

3 17 days applies to both methods, so we clearl1 called for 4

the designer to look at his ability to meet the 17 days by 5 - using either of the two methods and I suppose the baseline 6 for the calculation is the fuel shuffle method, but full 7 core off load is discussed explicitly in the requirement.

8 MR. PUSHECK: Yes, af ter a little arm-twisting we 9 did come out with the requirement to make the full core off 10 load.

11 MR. ARCHIZEL: I had a question on the type B, 24 12 months and the type C and you did not include it; on the 13 type B did you envision asking 24 months, do ycu envision

[,]

' 14 doing type B test on line?

15 MR. VINE: That's not part of this chapter, 16 number one, because this is all on fueling and refueling 17 and more the equipment and design features for that. Both 18 type C and type B containment testing would be discussed in 19 chapters five and six, and I think we can probably try to 20 get an answer to that for you along with the other issues 21 related Lo this in chapter five.

22 MR. ARCHIZEL: You haven't asked for anything on 23 type B.

24 MR. VINE: I understand that and I'm not sure we 25 have an explicit answer to that at this point, but we will O

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consider that and try to get'that one worked out along with 2 these other containment grade testing issues.

3 MR. MILLER: You've been coming up with that same 4 thing -- was there any analysis done, did you represent any 5 analysis concerning any optimal strategies for being able 6 to shuffle the fuel in order to be able to achieve time 7 period. I know that's been the subject of studies for many 8 years.

9 MR. PUSHECK: Okay, within the chapter we have 10 for both . BWR and PWR, a logic schedule line of time of 11 about four or-five pages because it wouldn't swing out all i 12 in one and it delineates all the activities and provides  !

13 the durations and this was developed by our consultants, 14 our staff specifically, but it was reviewed by both 15 General Electric and Westinghouse' to make sure that in 16 terms of shuffling the number of fuel assemblies that we 17 had reasonable allowance in terms of handling the number 18 simply and the duration is achievable.

19 Matter of fact, they seem to be quite comfortable 20 with it.

21 COMMITTEE MEMBER CARROLL: Does the PWR have two 22 transfer tubes and--

23 MR. PUSHECK: No, it does not. l 24 MR. VINE: Again, we studied that one very 25 closely and looked at all the pros and cons to see whether i

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or not it was needed to meet the requirements and felt that 2 we could--

3 MR. PUSHECK: There was a lot of consideration 4 given to that -- committee who decided not to include it, 5 to make it practical, in other words, the issue is what 6 happens if one of your tilt or transfer mechanisms is 7 during the outage not available. The only way the other 8- transfer tube is effective is if you have it installed, 9 devices on both ends, transfer two at the same time. So a 10 capital commitment has to be made to the whole ball of wax, 11 everything.

12 And they felt there were enough things being  !

,- .3 13 required in terms of proving the reliability of the i

i' 14 components, that it was not worth the capita) investment.

15 COMMITTEE MEMBER CARROLL: Well, you can do a 16 heck of a lot better than the historic design of that 17 equipment, too, in terms of making it reliable.

18 MR. PUSHECK: That's what they relied on.

19 COMMITTEE MEMBER CARROLL: One other question.

20 My old friend, Tom Christopher over at Westinghouse, the 21 last time I talked to him two years ago, was absolutely 22 convinced that you weren't going to get maximum capacity 23 factor with a 24-month operating cycle. Has he changed his 24 mind? I tried to change it for him.

25 Does Westinghouse believe in the 24-month cycle O

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1 today, I guess is the question.

2 MR. PUSHECK: Dave, do you have any input --

3 MR. STRAWSON: I don't really, I think they're 4

going in long cycle requirements set, but I don't know -;

I 5 really. )

6 COMMITTEE MEMBER CARROLL: From a fuel point of 7 view, Christopher's point is that you're going to take a 8 e' quote" mini-outage of 12 months to sustain a 24-month j 9 refueling cycle and probably the optimum is about 18 months I i

10- without the mini-outage in between. Because the mini- l 11' outage turns out to be a mega-outage.

12 MR. PUSHECK: Couple other points, simplification 13 in equipment design to improve reliability is extremely 14 important. In the PWR for example we specified that the 15 same spent fuel handling machine be used outside of the 16 containment as the fuel transfer machine inside containment 17 so that the operators can f amiliarize ' themselves with 18 controls and equipment and operating capability and not

.19 have to learn it new and fresh once they go back into 20 containment.

21 Also that the electronic components be removable 22 easily to take outside containment-- affected by the 23 atmosphere.

24 COMMITTEE MEMBER KERR: What's the significance J

25 of the statement that you're trying to reduce radiation i O l,

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exposure of ope:ators, compared to what?

2 MR. PUSHECK: We don't have any specific goal in 3 there, there are a lot of statements in terms of how to 4

achieve this, for example, adding additional shielding on 5- the PWR, let's see --

put a channel in before for 6 transferring fuel, I don't recall all the specifics right f 7 now. Specific areas where we've identified additional 8 shielding considered by the designer to reduce the 9 radiation exposure to the operators during the fuel 10 transfer process.

11 COMMITTEE MEMBER KERR: Do you know what it is 12 now and what you'd like it to be?

13 MR. PUSHECK: I don't know.

O 14 COMMITTEE MEMBER KERR: Doesn't seem to me it's 15 very meaningful unless you did.

16 MR. VINE: Well, we have an overall goal of 100 17 man-REM target for both BWR and PWR man-REM exposure and 18 we'd made a number of design changes throughout the design 19 to help achieve that. We think we've made sufficient to 20 achieve it. One of the rollup items that we intend to 21 undertake is a design review to more closely pin down 22 whether or not we have achieved that goal, but we have not 23 yet broken it down by function as to whether or not, how 24 much of that hundred is in refueling and how much of it is 25 in other maintenance and so forth.

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COMMITTEE MEMBERiCARROLL: 'My. impression is that q

2 the operators get a trivial amount of exposure . in the i 3- -course of refueling either' kind. But that's not true of 4- maintenance people, 5 MR. PUSHECK: This next to last bullet, protect' 6 against draining the refueling pool is'a very important 7

~

thing. Instead of using inflatable seals and we have a 8

requirement for' designing a permanent seal between the-9 reactor vessel and the fuel pool.

10 Cask loading, traditionally considerations have 11 been put in for large cask.. We require that. We also have 12 . a requirement ' that' the designers . continue to follow the 13 development of the technology for fuel transfer device 7

g. 14 using kind of a shuttle cask which could handle one to four 15 fuel assemblies, transfer them dry, a technique.that has 16 been used successfully in some of the Navy applications.

17 This is about the extent of-what we've talked 18 about.

19 Going to skip chapter eight and talk about 20 . chapter nine. This deals with site support systems. Is 21 there a. question about --

22 MR. VINE:

Do you want to take a break? I think 23 we can probably take it best, you're going to be on this 24 one probably ten minutes or so?

25 MR. PUSHECK: Right.

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MR. VINEi;. Fifteen,.or whatever.

2 '

CHAIRMAN WYLIE: -No,.we'll-just wait, i

3 MR. VINE: All right, then we'll go ahead.

4. MR. PUSHECK: Site support systems, these. are the 5 principal areas that are dealt with in this chapter. It's 6 sort of a catch-all in terms of some of the systems, fire 7 protection, environmental monitoring, -site security, 8 -compressed air gas, HVAC and the decontamination. I'm 9- - only going to speak to fire protection, security, 10 compressed air gas and HVAC.

11 COMMITTEE MEMBER CARROLL': . Environmental 12 monitoring means< environmental; radiological monitoring?

-13 MR. PUSHECK: Right.

O 14 COMMITTEE MEMBER CARROLL: Okay. j 15 .MR. PUSHECK: Fire protection, objectives.

16 . Basically it's to put the plant in safe shutdown condition, 17 - protect the. public in the event of a fire. And just as

~

18 important as protecting the public is protection of plant 19 investment. l t

20 So the design basis.is to assure all divisions of 21 safe shutdown equipment cannot be disabled by a fire. And 22 to accomplish this the objective is that all divisions, 23 safety divisions be in separate fire areas; in the PWR the 24 two divisions separated and in the BWR all three divisions

-25 . separated.

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We require a fire hazard analysis be performed, 2 safety, all nonsafety systems within the safety area.

3 COMMITTEE MEMBER KERR: Does the first bullet of 4 the design imply that if you could achieve that that there 5 could be zero contribution to core melt from a fire?

6 I'm just trying to understand what assure means.

7 Assure that it can't be disabled.

8 MR. VINE: Let me take a stab at that. I think 9 the assurance there is that we intend to achieve sufficient 10 separation so that a fire in one division is not going to 11 affect another division.

12 COMMITTEE MEMBER KERR: I'm trying to understand  !

, 13 what the applications of this are as far as contribution 14 to core melt, 15 MR. VINE: The applications are that there is a 16 significant reduction in the contribution to core damage 17 frequency from the fire. It's not zero because you still 18 have other scenarios possibly where you've got a failure of 19 one division, independent for some other reason, and a fire 20 here, multiple failures, failures in the control room and i 21 the like, so there are plausible but very low probability 22 scenarios could accompany a fire, seismic event or whatever 23- that could add some small amount of core damage frequency 24 overall.

l 25 MR. PUSHECK: The last area of protection safety l O

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equipment ~ within a fire area, the main objective. is to 2 provide separation by 3R fire barriers. Inside 3 containment, .of - course, there" is not explicit 3R fire 4 , barrier. separation facilities nor in the control . room.

5 These ' are the ' couple areas . that ' the capability is not 6 provided.

7~

Even within the divisions, there's an attempt to-8 provide separation of components by.3R fire barriers, for 9 example emergency feedwater pumps on in PWR, separate --

10 along with the safeguard pumps in' quadrants. .

11 We do have,~we still have a provision in there of 12 capability to provide separation by 20-foot distance again 13 within a fire area.

O '14 . Fire system, water. system is essentially J

15 dedicated fire water supply. Two large capacity pumps i 16 which are diverse design and illustration to the right is 17 out of the chapter illustrating'the type pumps.

18 COMMITTEE MEMBER KERR: Do you~now. feel that you 19 have in hand a method in which you have confidence that 20

~

enables you to predict ~the risk due to fire?

21 MR.-PUSHECK: I can't answer that one, I'm not 22 sure.

23 MR. VINE: You're talking about the fire hazards I 24 analysis type analysis or are you talking about a Pila 25- analysis of fire?

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-1 COMMITTEE MEMBER KERR:: I'm talking: about 2 something: that_ would give 'you an estimate 'of the 3' contribution to core melt frequency, either absolutely or

4. other things-that.contrib'ute to core melt frequency. I'm 5 .trying to understand .how you decide ' effective by the 6 methods that'you propose to use.

i 7- MR. VINE: Well, as~you know,-there have been 0

8 . full fire PRAs done on probably a, half dozen plants'in.the f

9 country and that number is growing and'one of the things 10 that. is part'.of the severe accident resolution for  ;

11 operating plans is the idea . that one would need to do 12 'something like that on every plant in the country. We 13 clearly will be doing a fire hazards analysis and be 0 . 14 .looking'at the fire risk in our PRAs for the ALWR.

15 Now whether or not the methods are rigorous and 16- mature and so forth is I think your question,.and as I said 17 earlier when we first talked.about fire, I think'that the

18 technology exists for doing a reasonable and accurate fire 19 PRA study. The problem has been that it's been done.Very 20 -conservatively in the past with'some very very conservative 21 assumptions about performance of systems and operator 22 actions and the like, and so I'm just suggesting by that l.

23 that if one takes a better estimate approach to the

24 analysis combined with the tools that are available I think 25 we have in hand a reasonable methodology to give a pretty O l PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO. CALIFORNIA 95827 TELEPHONE (916) 362 2345

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good' prediction; of ifire risk, an'd that it villibe much 2 lower-than:whatyou'veseenknthepast.

3' COMMITTEE-MEMBER KERR:- That's an answer to part

-4

. of my question but I also was' wondering how you decide, you '

'5- clearly .are doing some thingsL. differently than might bc 6- found in existing plants. lHow'do;you decide which of the

. methods you use are.most effective or how do you decide 7.

8- - when.you've.made.a change it is making things better and 9 how much. You apparently are not using PRA'to.make that 10! kind of decision.

11 MR. VINE: Well, ..we ' have been, as Bill'Sugnet 12 explained .this morning, we've done 'some scoping PRA 13 analyses up through the first five chapters to ' decide where O .14 the. improvements have really paid off, where the residual 15- risks still remain. . That study did not get into details on 16 fire analysis.

17. .our next iteration on this will clearly include

.18 that and I don't think we are planning on doing sensitivity 19 studi'es on every conceivable issue but certainly the ones 20 'that are crucial in terms of resolving outstanding issues J 21 or sensitivity studies to address areas that appear to be 22 significant contributors will get studied sufficiently to 23' answer those kinds of questions.

I' 24 MR. RUBENSTEIN: Bruce, if I may, could we go 25 back to your last Vugraph, the previous Vugraph.

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A 209 V I On the last two bullets at the bottom, obviously 2

we like the separation of redundant trains by a PRA 3

barrier, and the last two bullets, how do you select where 4

you want to apply this? What we're saying to you is 5 basically the staff position is separation by redundant 6 trains by a three-hour barrier, and we would then entertain 7

the last two, in our case when we look at the application, 8 the last two bullets would.say in the containment or in the 9 control room, and if you don't envision further 10 application, then we're probably converged on your 11 requirements scenarios, but if you have other specific 12 subcompartments or areas you see, then we may diverge.

13 g But I would leave it with that.

V 14 MR. PUSHECK: Well, our objective is to achieve 15 separation, mechanical equipment and electrical equipment 16 by a three-hour fire barrier. We intend to look at this 17 one more carefully and strengthen that requirement. The 18 exceptions would be obviously in the containment, in the 19 control room and we're going to try to come very close to 20 that.

21 MR. RUBENSTEIN: If those two bullets are an 22 escape clause for those two areas then we're probably very 23 close to agreement. If they're an escape clause for 24 something we haven't articulated, then we can probably 25 diverge.

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.MR. PUSHECK: Well, you mentioned this' morning  !

.2- the'out that you' thought people were looking for for late

~

l 3

backfits as the result of modifications or changes in 4

. construction'. We don't see that as an acceptable basis for

5. making th'ese- -

..6 MR. RUBENSTEIN: I was ' presumptuous about 7 assessing .. motives ' on 'some of the designers, I probably

'8- should not have'done.it.

9 MR. PUSHECK: Okay, that wasn't something they 10 told you then, it was just --

11 MR.-RUBENSTEIN: 'Well, not formally.

12 MR. VINE: It's important-in that last set of 13 bullets to recognize that the heading there says. protection O 14 of' safety equipment within a fire area.

15' MR. RUBENSTEIN: Right.

l 16 MR. VINE: And each division is in a separate 17 fire area, so there's this mechanical redundancy within the 18- divisions.

19 MR. RUBENSTEIN: I saw a great deal of nervous 20 shuf fling - on your part this morning, although I didn't 21 really'think we were that far apart.

22 MR. VINE: Well, I hope we're not. It's just 23- that there's a lot more that we need to understand about-l 24- the position and how it's to be interpreted and . single l 25 . failures and things like that that we need to better O J PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO. CALIFORNIA 95827 TELEPHONE (916) 362 2345

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2

.MR.? PUSHECK: I think we're about finiv.ted with 3 'this other one, .too, as I said, we showed you that 4' schematic of the. fire' system, large capacity pumps, with 5 100 percent-_ capacity available even with loss of;off-site p.

6 power and starting automatically,on' low pressure.

7 -Use = of.halon and carbon dioxide system limited to 8- areas"where you'vetgot'to provide some kind of capability 9 to where water would-damage sensitive electronics.

10~ , COMMITTEE ' MEMBER KERR: Must be my Kentucky 11 background,.but firewater always makes me think of alcohol

~

12 for some.. reason.

13 (Laughter.)

O. 14 MR. PUSHECK: Security systems, the concept to 15 identify all'the vital equipment has to be protected. We 16- have a requirement in the document to do that, have.the 17 designer do that, install the components, piping --

18 evaluation of those things that are necessary to separate.

19 Locate all the vital equipment and separate vital areas by 20 division.

21 Basically this kind of goes hand in hand with I

]

22 architecture.

23 COMMITTEE MEMBER KERR: You probably haven't 24 gotten into this detail yet and you may not get into it, 25 but if you have, is it your view that probably this will O

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h 212 V 1' take care of itself when'you have looked at: fire protection 2 and protection against flooding and so on, or will the look 3

at this point perhaps produce design requirements that 4

might otherwise not exist had you not looked specifically 5 at sabotage? I'm asking, purely for information.

r I don't

' .6 ' pretend to know the answer to the question.

~

' .7 Do you understand what I'm asking?

8' MR. PUSHECK: -Yes; I understand wh'a t .you're 9- saying and.I think prudent design from protection against 10 flooding a n'd ' f i r e . p r o t e c t i o n .. i s going to provide this 11, capability'largely. 1 There are some things.that you have to 12- consciously.look at, for example the alarm and security

'13 barrier box system has to be preplanned well in advance of 14 the construction activities.to make sure that things are 15 hidden well, and so forth. But that really is kind of a 16 detail--

17- COMMITTEE- MEMBER KERR: I guess I'm sort of

-18 asking whether you're going to have someone who.really has 19 thought in_some detail about sabotage, participate at some 20- stage of this. Because unless--

21 MR. PUSHECK: There is not a requirement 22 currently to have--

23 COMMITTEE MEMBER KERR: Unless you do, I don't 24.- think you're' going to do much other than design for fire 25 and floods and so on and then you'll reach a conclusion PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD, SUITE 240 SACRAMENTO, CALIFORNIA 95827 TELEPHONE (916) 362 2345

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p 4 213 1-well,- this is ? pretty well takenl ' care ~ of. Maybe that's

2 enough. I don't pretend to be an expert on sabotage, but 3

I've heard a few people talk on occasions who.are and they 4 think of . things that certainly would not occur to the

,1 5 casual observer. i 6 MR.'FIDRYCH: In chapter nine we do specifically

7. call for a sabotage analysis; it's going to be= examined 8 from the point --'and it calls for examination to 73.35 is l

~

9 it, and. specifically asks' for a sabotage analysis ' to be 10 performed,. so that would . infer , that someone would know 11 something about.the subject, doing the analysis.

12 MR. PUSHECK:. But as you say, the grouping of the 13' confluence will actually take a'd v a n t a g e " o f- t h i s hazard 14 protection ~ because that seems to be the sensible thing, 15 whether .' there are certain details within that framework '

16 which come out in that analysis, I can't say.

17 COMMITTEE MEMBER KERR: What - I was saying, 18 special vulnerabilities, for example, that may not-have to 19 do with' physical' protection, it may have to do with systems 20 interactions that a casual observer would miss. I don't 21 pretend to know the answer to this, but if you're convinced 22 that your wording implies that there'will be somebody who

.23 looks for this sort of thing--

24 MR. VINE: Dr. Kerr, let me give you one example, ,

25 I'm sorry -- go ahead.

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J 214 I MR. RUBENSTEIN: I was only going to say that 2 we've- asked that same question specifically to the 3 designers and are pushing that way. For example, I might 4 ask Bruce, the controlroom location, isn't that driven 5 mostly by sabotage considerations, located within the body 6 of the plant above grade level?

7 MR. PUSHECK: Well, no is the answer. It 8 happened to fall out of some other considerations. We had 9 it at one time, on the site of the reactor building, on the 10 site of the auxiliary building because of constructibility l l

I 11 and safety system separation. We decided we could get a I 12 lot better separation of redundant division by splitting

.13 it down the middle of the control room, being an axis O 14 between the containment and the turbine building. That put f 15 it kind of in the center of the control building and as it 16 happened, we had space on the outside, so it's not on the 17 outside of the building. It happened to come out one level 18- above grade which seems to be fortuitous because a lot of 19 people think that's a good location. I'd like to say we 20 preplanned it that way, but we didn't, 21 MR. VINE: I was just going to mention as we 22 moved through chapter ten development on man-machine 23 interface systems, there's a lot of questions that come up

24. about preventing human error, making it less likely that an 25 operator would bump a switch and do some things that would O.

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( 215 l l' initiate a plant -- and the like. A lot of those kinds of 2 considerations will have some benefit in this area, too.

3 MR. PUSHECK: The last bullet, access control 4 syst'em and vital areas, on the drawings and provides for 5 monitoring the control of access.

6 COMMITTEE MEMBER CARROLL: If Hal Lewis from the 7 Committee was here he would - ask you if you have any 8- computer systems in the plant that some. clever hacker might

~

9 get into and do the things adverse from a security point of 10 view.

11 MR. VINE: Good question.

12 MR.'PUSHECK: Within the site support systems we 13 deal-with' compressed air and gas systems. The system is 0 14 ~ designed to eliminate the --grade with exception of certain 15 areas.. There.are certain air lines going to accumulators 16 which operate safety related valves and the isolation 17 valves on those air lines are safe related. And then the 18 check valve upstream of the accumulator and then to the air 19 operated valve actuator.

20 COMMITTEE MEMBER KERR: I assume your objective 21 here is to make this system more reliable and less 22 expensive than if it were safety grade.

23 (Laughter.)

24 COMMITTEE MEMBER KERR: I hope that's the 25 objective.

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1 j MR. PUSHECK: The objection is to make it 2 adequately safe and simple and easy to operate and we think i

3 that can be done without sacrificing or categorizing as a j

.I 4 nonsafety system.

~

I 5 COMMITTEE MEMBER KERR: No, I think- that l

6 objective could well be achieved. I hope that's the a 7 objective rather than making it less reliable than if it 8 were safety grade.

9 MR. PUSHECK: It certainly was not an objective j 10 to make it less reliable.

11 COMMITTEE MEMBER CARROLL: There's been a lot of 12 horror stories lately about check valves and air supplies s 13 to accumulators. Have you given that any thought in terms  !

h 14 of making them more test-able, making them more reliable?

15 MR. PUSHECK: A lot of thought given to that, I'm 16 not sure if they're related to the incidents you're talking 17 about.

18 MR. ARCHIZEL: Is that a manual connection, when 19 you use off-site power, do you have to make an operator 20 action, -- go off off-site power?

21 MR. VINE: I will cover that in chapter 11.

22 COMMITTEE MEMBER CARROLL: That's your gas 23 turbine, um-hum. l 24 MR. PUSHECK: Okay, the last one I want to cover 25 in chapter nine is the HVAC.

(~

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Define certain temperature ranges for personnel 2

comfort, classifies them based upon whether they're control 3 room, or similar occupancy areas, shops, or inaccessible 4 areas. It also establishes environmental equipment 5 qualification ' requirements for HVAC. It establishes system 6 segregation for plant fire areas, in other words capability 7 to isolate both the plans and the capability to isolate at 8 a fire barrier with fire damage.

9 Meets security requirements, and provide barriers 10 at appropriate interfaces with different conditions.

11 COMMITTEE MEMBER KERR: What's the availability 12 requirement on your HVAC system, especially your air 13 conditioning part of it?

O 14 MR. PUSHECK: I don't --

15 COMMITTEE MEMBER KERR: It's been my observation 16 American technology has been successful in a great many l 17 things but builds lousy heating, ventilating and air 18 conditioning systems. Probably nuclear power plant systems ,

19 are an exception to that, but in many offices I've had to 20 sit over the years, I've been disappointed in American 21 technology.

22 Seriously, I think you ought to focus something 23 about an availability requirement because in a power plant 24 especially where there is solid state instrumentation or 25 other kinds of instrumentation, this would contribute.

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\h' I MR. PUSHECK: Important design bases, circulating I 2

systems it's where the outside air temperature is to zero 3 exceedance, --

4 COMMITTEE MEMBER KERR: I don't know what that 5

~

bullet means. Outside air temperature to zero exceedance.

6 MR. PUSHECK: Right, it's that in other we 7s --

7 MR. YEDIDIA: We have a site envelope that 8

defines the temperature conditions on our envelope site, 9 standard site; that's the idea here is it should be l 10 designed to a zero percent exceedance of that maximum level 11 that is shown on that envelope.

12 COMMITTEE MEMBER CARROLL: Okay, so it should say 13 maximum temperature.

V 14 MR. YEDIDIA: Maximum, yes. Sometimes we say we 1* allow 1 percent exceedance of the maximum. In other words 16 it's slightly below maximum, then that maximum.

17 COMMITTEE MEMBER CARROLL: Because I don't want 18 you '.'o exceed minus 10 degrees on the cold side.

19 MR. YEDIDIA: Oh, that's I think temperature for 20 the high side.

21 MR. VINE: But it's not even the hottest day of 22 the year.

23 COMMITTEE MEMBER CARROLL: Right.

24 MR. PUSHECK: The HVAC systems are separated 25 according to --

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1 COMMITTEE MEMBER CARROLL: That may be getting 2

fairly marginal in some locales in terms of at least my l 3 experience of what calid state equipment is good for if 4

you're talking about outside air temperatures of 120 5 degrees or something like that. Particularly stuff that's 6 in racks where only the bulk air temperature coming out of 7 the HVAC may be something, inside rack temperature may be 8 tan or 20 degrees higher.

9 MR. FIDRYCH: Excuse me, I think -- this is the 10 design basis for the HVAC system. Of course you probably 11 have to use chillers for most of these rooms to provide the 12 ambient that you would have to have for that equipment for

, 13 the maximum ambient temperature.

\' ,/

14 MR. PUSHECK: .Okay, the system operates on a 15 safety actuation signal and/or is interlocked with a system 16 that -- mechanical system.

17 I think we already touched on the next slide.

18 That was for the fire isolation.

19 COMMITTEE MEMBER KERR: So you will insure that 20 the reliability of the HVAC system is at least as good as 21 the equipment being serviced?

22 MR. PUSHECK: It doesn't have to be.

23 COMMITTEE MEMBER KERR: Doesn't have to be, but 24 I think it should be.

25 MR. PUSHECK: The last area on HVAC was control o

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220 I room envelope where the requirement is to maintain a 2 positive' pressure in the control room and transfer to a 3

recirculation mode, airborne radioactivity, gas detection, 4 external expulsion. And to accommodate that it has 200 5 percent redundant divisions. -An air handler, smoke purge 6 fan and emergency f.ilter units. And redundant detection 7 for -- pretty much standard practice --

8 COMMITTEE MEMBER CARROLL: Smoke purge fans is an 9 addition which is a good idea, I think.

10 MR. PUSHECK: So that concludes chapter nine, 11 unless there --

12 COMMITTEE MEMBER CARROLL: Let's say there's been 13 a bunch of problems with water chillers here lately,

.g V 14 haven't there, Charlie, where people. don't understand that 15 the big air compressors need to keep their oil hot, is that 16 the issue, and I can't remember which plant it is;'it's one 17 down in the south where it had run for some time and they 18 discovered that the H&D' guys didn't understand how their 19 own equipment worked, they had these heaters plugged into 20 a wall socket, whereas this whole device is emergency 21 pc,wered and all that stuf f, and on one occasion when they 22 lost the normal a/c the oil had cooled down and tore up the 23 air conditioning compressor.

24 So you've got to look at those things very 25 carefully.

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'MR. LONG: The staff, with the assistance of 2

Argon Laboratories, has done quite a few surveys of control 3 . room habitability at various plants and that has been a 4

very significant problem, operators understanding their 5 systems.

6 MR.' VINE: Can we make the break rather short 7 because we are really kind of far behind here?

8 CHAIRMAN WYLIE: Well, okay, a.five-minute break.

9 (Brief recess.)

10 MR. VINE: To start off chapter 11 I want to make 11 it clear you'll see this as we move through this and you've 12 probably already seen it as we've talked about chapters 13 six, seven and nine, but we hava set forth some pretty high O 14 standards for safety and availability, simplicity for this 15 design, in particular chapter five talks a lot about how 16 we're achieving safety and of course, as you know, Bill 17 Sugnet is going to go over that safety philosophy and 18 safety approach tomorrow morning again. But we didn't stop 19 with chapter five to achieve those objectives. There are 20 a lot of things in the last half of the requirements j 21 documents in these last seven chapters which significantly 22 contribute to improved safety and design and I think the 23 chapter 11 is one of the chapters that has a really 24 significant impact on safety and I think you'll see that as 25 we move through it.

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O 1 By the way the drawings that you saw Bruce put up 2

earlier, the . drawings that I'm going to show here were 3

inadvertently left out of the package that you received and 4

we're going to have some copies of those drawings over here 5 in'a few minutes.

6 The scope of chapter 11 are all a/c and d/c 7 systems within the plant, auxiliary service, safety systems 8 and so forth. The chapter was completed this month and is 9 currently being mailed out to the ALWR program participants 10 and the NRC Staff, mailed from the NRC yesterday. We have 11 a few extra copies here now.

12 A more detailed look at the scope of this chapter 13 shown in this drawing, beyond general requirements we go O 14 through all the off-site power system requirements and this 15 goes out to the main step-up transformer and does add some 16 requirements to the switchyard to improve the reliability 17 out there.

18 The next section goes over the medium voltage a/c 19 distribution system, either the 4160 or 6.9 kV or 13.8 kV 20 system on site and we go through the on-site standby a/c 21 power supply system which includes both safety and 22 nonsafety on-site sources. The low voltage a/c 23 distribution system, th'is is the 480 volt system. The d/c 24 and low voltage systems, this is the instrumentation and 25 other low voltage a/c, vital a/c systems as well as entire O

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l d/c system, go through normal emergency lighting and 2 electrical systems including grounding and so forth.

l l 3 As an overview we have placed very high priority 4~

on this chapter and making significant improvement in a/c 5 distribution. We think that these improvements will result 6 in significant safety availability and overall

~7 simplification in electric power systems, will help assure 8 our ability to meet requirements.

9 Chapter 11's broad and comprehensive and we think 10 it will lead to significantly increased standardization in 11 the industry on electric distribution and get away from 12 what we see now which is a lot of site-specific and design 13 specific electric distribution.

O 14 Some policy statements that governed our approach 15 to this chapter, first of all, as I said before, we were 16 comprehensive in the requirements so we have set forth 17 specific requirements. These requirements are based on 18 historical data, reviewing the operating experience, the 19 PRA and the like.and finally decide what improvements were 20 necessary to obtain the goals that we had. But it is based 21 on proven technology and careful review of the operating 22 expense.

23 We put a great deal of emphasis on increased 24 reliability and e. availability of these systems in helping 25 to achieve our safety and availability codes.

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n 224 Q) 1 Organization of plant systems according to 2

functional characteristics of loads. De separated safety 3

and nonsafety systems, separated the divisions of safety 4

systems, we tried to pair off the functional requirements 5

of load groups and the reliability needs of that group and 6

power sources that will be providing power to that group.

7 Additional policy statements, specific emphasis 8

placed on station blackout and on-site a/c and d/c power 9 supplies to reduce the contribution of station blackout to 10 core damage frequency.

11 Improved availability received a great deal of 12 emphasis particularly when either due to regulatory r

13 requirements such as LCOs and the like, or failed

)

(

14 equipment. We have seen in the past electric system 15 failures contributed to --

these specific areas seen in 16 these areas with design fixes to improve that availability.

17 And finally we tried to focus as best we can en 18 reduction of potential for operational errors, simplified 19 procedures for plant startup and shutdown and minimizing 20 cross connects and the like, looking at the electric l

21 distribution system from the operator's point of view.

22 Quickly I'll review the safety availability and l

23 simplicity features that we have touched on in this 24 chapter. On the safety side again we're looking at loss of 25 off site power, station blackout and loss of d/c power as e

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seen in - the PRAs and taken specific. design features to 2 address those ares.

3 'First of all, we've reduced the ' potential for 4 loss of . normal power supply. The normal off-site power 5 supply. Three things we've done there. We've eliminated-6 the need for load transfer on shut down. We have 7 . recognized as did the ACRS in their 1987 letter to us and 8 the rest of the staff, the fact that the normal power 9 supply, the most reliable power source on site is the low 10 side of the main step-up transformer. We're using that as 11 the normal power supply for all on-site loads, both safety 12 and nonsafety and what that gives you is the ability to 13 continuously power all on-site- loads unswitched, from 14 startup'through operation, back down from shutdown without 15 any fast transfers or changes in lineup and we think that 16' 'has some significant safety as well as operational 17 simplicity benefits.

18 We've improved switchyard redundancy and 19 configuration in the switchyard to again improve the 20 capability of -- improve our frequency of loss of normal 21 power supply.

22 We now have an independent low exposure reserve 23 off-site power circuit dedicated to essential safety and 24 nonsafety systems. The operating experience has taught us 25 that if you have a reserve transformer, reserve circuit O

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that is independent of the switchyard'that it's likely to 2

remain available in a typical loss of off-site power event.

3 We found that to be true and feel if we have that

.4 independent circuit that we can exploit'that independence 5 in keeping done the frequency of'a total loss of off-site 6 power.

7 COMMITTEE MEMBER CARROLL: What would the source 8 be, another power plant in the vicinity?

9 MR. VINE: Not necessary; I'll get- to the 10 requirements a little bit later, but basically it's likely 11 to be at a' lower voltage, down a substation or two, more 12 protected from the environment than the main switchyard.

13 For example is in the Northeast there are a number of O 14 plants that have had some significant loss of off-site 15 power events of long duration and they've been oftentimes 16 caused by storms. Many of those plants have a reserve 17 circuit that is going to a substation well inland that does 18 .not face those same salt problems and the like and those 19 reserve circuits normally remain available through such an 25 event. And we envision the same type of source for the 21 reserve circuit.

22 COMMITTEE MEMBER CARROLL: In the case of a 23 coastal plant, though, insulators on reserve line, would 24 the line normally be energized?

25 MR. VINE: Yes.

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COMMITTEE MEMBER CARROLL:- Okay.

'2 COMMITTEE MEMBER KERR: You've accomplished this 3- '

what you've said~with generator circuit --

4' MR. VINE: Yes, > v s'll' show ~ you the generator 5 circuit breaker here in a second. You can't do it--

6 Had a lot of encouragement from a number = of 7 utilities'in.this' country and believe it is the best way.

8 Reduced potential for-loss of the on" site power.

9-wer ve .added ' on-site alternate a/c source for blackout 10- coping capability; set higher reliability targets and some 11 specific design requirements that will appear with higher

12. reli~ ability.with all these on-site sources of safety and 13 nonsafety. We've improved the reliability and testability O 14 .oh d/c- supply systems' and I think achieved some 15 simplification in the range and operations of the systems.

16 How we're accomplishing that simplification is as 17 follows: First of all, these a r e' some of the 18 considerations that we looked at', simplification. . In-the

19. configuration area we've distinguished between loads and 20 set those loads up into three basic load groups. The first 21 load group is nonsafety loads required for unit of 22 operation; second group are fairly nor. safety loads; third 23 group are,the safety' loads.

24~ The permanent nonsafety loads are the loads that 25 you need to' operate 100 percent power and if you're not at 0

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-(m 228 b 1 100 percent pow- you don't need them. These are the 2 nonsafety loads s site which you'd like to maintain power

.3 .to at all' times during the shutdown, during the loss of 4' off-site power.

p 5 Redundancy in types of power sources are based 6 on the types of loads, in other words within these types of 7 loads and load groups we have targeted specifically the l

8 reliability needs and so fcrth and set up the redundancy 9 and diversity,of power soarces, importance of those load 10 groups.

11 Complete separation between safety and nonsafety 12 which will help us eliminate isolation problems. Complete 13 separation between safety divisions, single, medium voltage O 14 level, which-I'll discuss later we think we can achieve a 15 single medium voltage level and thereby simplify the 16 configuration for all plants with the possible exception of 17 a'very large TWR at the high end of the range where you may 18 need to go to a 13.8 and 6.9 combination, but even if that 10 happens we will have simplified the configuration by 20 eliminating some of the transformers able to do that.

21 And finally the bus range reflects this load 22 arrangement.

23 Other areas of simplification in operation and 24 equipment. We've eliminated the transfer requirements for 25 startup and shutdown through the use of a generator breaker A

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J 229 1- tand the low side -- step-up transformers-our normal power 2 source. Capability for selective operation ofLindependent 3 systems. -

We're going to use the.on-site.nonsafety' source, ]

l 4 lthe power for important nonsafety loads'during loss of off-

5. site- power. Doesn't' come on just during a station p 6 blackout, but anytime you need it to power nonsafety loads.

7 T.nd elimination of load shedding requirements and manual 8 restarting- of loads . comes along with the separation of 9 safety'and nonsafety.

- 10 Simplification of equipment. Eliminated startup 11 transformers and tie lines as a result , of the generator 12 breaker and the arrangement we have for the normal on-site 13 power source,- the normal power source, elimination of O 14 isolation devices between safety and nonsafety, between 15 safety loads and safety buses as a result of the separation 16 of safety and nonsafety loads. The lower operating medium 17 voltage, we're looking at' probably 6.9, but that's not 18 .specified in the requirement, but we think we can get to a 19 single and probably lower operating voltage and elimination 20 of bus type transformers which goes along with this 21 achieving a single mid voltage.

22 MR. ARCHIZEL: Can I ask a Tuestion on the 23 nonsafety loads, is that then connected to that turbine?

24 MR. VINE: Yes.

25 MR. ARCHIZEL: Is it connectable, that's

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2 I'll explain that.

MR. VINE: And finally the 3- availability, we've looked very carefully at all the forced 4~

ottages and deratings that have driven the availability 5 figures and found some significant contributors to 6 ur. availability from electrical systems. Step up 7 . transforms, low voltage, power supplies and inverte.rc, the 8 diesels, themselves. Many times we'll find a forced outage 9 driven by the failure, oftentimes a minor failure, but 10 significant enough to force an outage in one of tnese 11 categories.

12 In the d/c area, for example, any failure puts 13 you into a two-hour LCO which gives you very little 14 . flexibility for doing maintenance on line, we specifically 15 address that.

.16 Same thing with 1E switch out of commission or 17 even short maintenance requirements force a plant shutdown.

18 We've installed a stair step-up transformer and 19 also a' stair up zone transformer to facilitata quicker 20 changeouts, transformers --

21 CHAIRMAN WYLIE: Let me back up here, the stair 22 step-up is that a three phase?

23 MR. VINE: Three. I believe so.

24 CHAIRMAN WYLIE: Single three phase of a stair, 25 is that it or --

1 1

l O

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., MR. VINE:~ Single. I'm sorry, I misunderstood

.2 your question. 'We have a single step-up transformer. It's '!

3 not the Duke arrangement. We have one step-up transformer,

. -4 one generator breaker.

5t CHAIRMAN WYLIE: Well, it must be single phase, 6 with a stair, single phase.

7 MR. VINE: Yes.

8- CHAIRMAN WYLIE: I assume that's what- it is 9 because.you can't get a single three phase that' size.

10 MR. VINE: I think that's correct'. I'm going to-11 have to check.

l 12 ' Operation of single failure of inverter battery 13 or battery charger. 'By this we mean the continued plant

h. 14 operation is not jeopardized by ' any of these single 15 failures.

'16 Nonsafety standby a/c power source already 17 discussed and redundant adds to low voltage safety system 18 loads within.

19' COMMITTEE MEMBER CARROLL: Is that identifying 20 better converters than the ones we've historically been 21 using?

22 MR. VINE: I think so. The arrangement of the 23 a/c electrical systems. Our main objectives again were to 24 max the reliability and redundancy of these various power 25 sources to the functional characteristics of the loads and f}

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4 <g,e h-232 to' insure separation of safety and ' nonsafety loads. to 1

2 ' eliminate requirements- for.; isolation devices 'and load 3~ ' shedding. And we- provided and organized a flexible 4

arrangement ^with clear ~ system demarcation-'and. integration

.5 of independent systems _ in the same load group. and redunciant 6 systems are being fed through an independent system. These 7 all- really are the implementation of those: design 8 objectives.

9 I mentioned we had three functional categories 10 of loads. Again, to review, the nonsafety loads required 11 for unit ' operation are those loads t h a t '. a r e needed to 12 operate.at 100 percent power and when.you're not operating 13 at full' power you don't need them. Reactor coolant pumps,-

0 14 feedwater. pumps, circ water pumps and so forth.

15 Permanent nonsafety loads are 'the nonsafety loads 16 that should remain operational at all times, including when 17 .the' plant is shut down or as I said'before, during a loss 18 of off-site power. This includes just a few examples, but 19 the list is much longer. Charging pumps, fire pumps, 20 nonsafety lighting, nonsafety HVAC and so forth..

21 And of course the class 1 safety loads as we all i 22 know them are unchanged.

23 One of the goals here was to try to minimize the 24 loading on the diesels and to minimize the number of loads 1 25 that are placed on the safety buses. We've attempted to PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD, SulTE P40 SACRAMENTO. CALIFORNIA 95827 TELEPHONE (916) 362 2345

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l 233 1

insure that there are no nonsafety lo' ads, unnecessary loads 2

-that.are puton the' safety. buses that can't be put up here 3 on ~ the permanent nonsafety bus; to be powered from a 4 different source. This ~is part of the objective of 5 separating safety and nonsafety loads.

6 put this drawing over here; this is the PWR 7 drawing; the BWR' drawing is very similar.

8 Try to explain how-all these features work out 9 in real life here.

10 Again, this is our main step-up transformer with 11 an installed stair, single generator circuit breaker, two 12 auxiliary- transformers with an installed auxiliary 13 transformer stair. The auxiliary transformers feed all on-l 0 14 site loads through a set of breakers that feed four buses 15 up here, or five buses and again I guess I should point out l

l 16 that we have a' note there that says this drawing is not 17 . intended to specify exact details of the requirements but 18 simply as an example of a drawing that meets all the 19 functional requirements. There are other conceivable ways l 20 that you would be able to meet the requirements, with a 21 little bit of flexibility on this particular drawing.

22 These are all the loads required for unit 23 operation on t.nese buses here. There's also a feed 24 directly down to the two permanent nonsafety buses from the 25 auxiliary transformer.

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p. 234 V 1 This feed directly from the auxiliary transformer 2 feeds into the permanent nonsafety bus on both sides and 3 the permanent nonsafety bus contains on it all the loads 4 that we say are required continuously but are nonsafety.

5 Now these permanent nonsafety loads are 6 significant. There are, within this group anything that 7 you might conceivably need for any related safety purpose 8 of any kind, anything that relates to accident management.

9 Anything that would contribute to plant investment 10 protection. We have all the air conditioning on site, all 11 the air compressors that are not safety related. We have 12 nonessential cervice water pumps, pressurized repeaters, 13 fire pumps, cooling pumps, a number of loads shown here at

\d 14 the mid-voltage level, load out of course at the low 15 voltage level there are a number of other loads that are 16 related to investment protection. Anything being used for 17 service loads for the turbine generator coming off the 18 permanent nonsafety bus.

19 Refueling equipment would be off the permanent 20 nonsafety bus. I think you get the impression if you need 21 it when the plant is shut down, and you don't need it full l 22 power operation, it's going to be down in this permanent I

23 nonsafety bus.

24 Now it gets power from the auxiliary transformers 25 from the gas turbine and from the reserve transformer; this I

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1 is the reserve transformer coming in powering both the 2' permanent nonsafety buses.

3 Coming down from the. permanent nonsafety bus you 4

have power to ' your l safety divisions. Those are the lE 5 buses ' with their own diesel generators. We've also 6 provided as a backup capability a direct connection from 7 the off-site reserve transformer directly to the safety 8 buses but this is intended right now to be a locked-open 9 breaker or a racked-out breaker and not normally the normal 10 path for getting power to the safety bus in case of the 11 loss of off-site power.

12 So in operation power is coming from the low side 13 of the main step-up transformer and the main generator O 14 through the auxiliary transformer to all on-site loads. If 15 you lose off-site power with PWR and full load rejection, 16 continue to power all on-site loads from the nain generator 17 uninterrupted and unswitched.

18 If you lose both the main generator and the 19 switchyard, which would require some ' independent failure of 20 both, you have power coming immediately available to all 21 your permanent nonsafety loads and all your safety loads 22 from the reserve transformer, you've not even started the 23 diesel yet.

24 If this source of power is also lost, then all 1 25 three on-site machines start up, carry the safety O

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provisions, the . gas I turbines carries both permanent and  !

2

. . ^f n'nsafety, o provisions. . The gas. turbine ic sized to be able ~l 3

to handle'both this bus and this bus. If one of the diesels 4

fails to start, the gas' turbine equivalently could handle

.'5 one of the permanent nonsafety buses as well as one of the 6 safety bus'es. So it'is a large' size gas turbine.

7 We envision from some preliminary load studies, 8 probably in the neighborhood of eight to ten megawatts.

9 MR. LONG: Does ' the gas turbine receive an 10 emergency start signal along with the -diesels 11 automatically?

12 MR. VINE: It will receive a start signal 13 automatically in loss of off-site power. It does not start O -

14 on an ECCS signal because an ECCS signal alone,.not a loss 15 of off-site power of course, would not mean on-site back'up 16 power for these buses because you have not-lost,off-site 17 power,- so these would continue from your auxiliary 18 transformers.

19 If it also-involved the loss of off-site power, 20 then the gas turbine would start and' pick up these loads.

j. 21 MR. MILLER: You said this morning I believe the 22 gas turbine would have the capability of being able to 23 start and pick up loads in two minutes?

~

24 MR. VINE: Yes, the station back-up calls for I' 25 ten; we've looked at the technology and it looks like these O

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, machines can be started in about 45 seconds to a minute and 2- specified two minutes in the requirement.

[ That would be l

t- 3 that the gas turbine starts automatically in loss of off-4 site power and is ready to accept the . load in a couple 5 minutes. That 'doesn't mean that all these loads are 6 automatically sequenced on. The committee felt very 7 strongly that'they wanted'the starting of these loads to l 8 be primarily a' manual action, so there could be some of 9 them for selected reasons that might be sequenced on the 10 gas turbine; certainly the machine is capable of that, but

-11 for purposes of how this thing is physically used and 12 operated,- we felt that most of the loads could be 13 controlled by the operator.

e i 14 COMMITTEE MEMBER CARROLL: On the ECCS, unlike 15 present thought, you do not start the diesels and transfer 16 the load to the diesels?

17 MR.-VINE: Nothing has changed in that area. If 18 you have an ECCS signal, the diesels still have to start.

19 I'm trying to remember whether we automatically switch; I 20 don't think there's a requirement to do that so you still 21 have power through the normal source of these unless 22 there's an interruption, but the diesels start 23 automatically, I think that's required.

24 MR. LONG: Unless you have a loss of voltage on 25 the safety buss, the diesels won't move. ,

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MR. ~ VINE: I said we. grouped.the loads by load.

.2~ group and: set up power supplies to' match . the L functional L 3 needs of. that group. You notice for category 'l- the 4 permanent nonsafety ' loads I;really only have two sources, c 5 the - normal -off-site - source, the ' switchyard . and the main 6- generator break'er. So as long as either of those two are 7 providing' power,:I:have no interruption of power to those 8 loads.

9 The next category, the. permanent nonsafety has 10 those two sources-plus the reserve off-site power source, 11 plus the on-sitie nonsafeth power source, the gas turbine.'

12 And then for the safety loads you have everything 13 that these'two categories have plus the diesels, so you now

_O' '14'

. have the normal .off-site source,- the main generator, the-15 reserve -transformer, the safety, provision diesel 16 generators, and the nonsafety on-site. source, plus you have

17. this; independent feed coming off the reserve circuit --

18 safety buses which would be manually used if-everything 19 else failed. So the capability of getting power by widely 20 diverse means to the safety buses from all these different 21 -sources is greatly improved and very flexible.

22 MR. YEDIDIA: We just received here, in fact, a 23 set of all these' records with figures--

24 MR. VINE: -- all the package?

25 MR. YEDIDIA: The whole package --

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MR. VINE: Oh, I was hoping they'd just give us-2^ a--

3 MR.'YEDIDIA: That's'what,they did, so everybody

,4' wants to, replace the present, I'll give it to you.

$5 MR.iVINE: The BWR drawing we show is virtually 6' the same'in the chapter with the. exception that it pulls in 7 the third division here, but the configuration is basically.

8 the same.'

9 (COMMITTEE MEMBER CARROLL: How big are the 10' auxiliary transformers with the reactor feed pumps? They

11. must' be' pretty. good size.

12 MR.-VINE: These are large auxiliary transformers 13 but they're not:100 percent capacity; in other words, this

.O 14 ' auxiliary transformer'can basically handle these loads and 15' this-one can handle these loads.

16' 'One other point I should make is they have dual

17. secondary windups'which means thattif this plant were to be 18' a ' large PWR that needed to have the top . tier at 13.8 kV 19 then this second'ary winding would be 13.8 and this 20 secondary winding of this one would be at either 6.9 or 21 4.16. But that is the capability that we don't expect

- 22 would be used very often except in very large plants.

23 Standby system, again I said this system consists p 24 .of one. safety source per safety division diesel generators l'

25 plus one on-site nonsafety source, specified to be a large O

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1 gas turbine.

2 There is some flexibility in that, but very 3 little. It virtually has to be a gas turbine by the 1 4 requirements, very little flexibility.

l 5 The safety diesels, very quickly these are very l 6 similar to what current requirements are today, dedicated 7 to the class 20 loads and starts up automatically on either 8 loss of off-site power or LOCA and we discussed startup 9 time. You eliminate the cold start requirements with class 10 1 prelube and prewarming system.

11 The nonsafety source is large capacity, power to 12 important nonsafety loads, plus one safety division if 13 necessary, in case of loss of diesel or station blackout.

V 14 It's automatic startup, two minutes startup time and will 15 meet all design related requirements for an a/c from the 16 Red Guide table in there that specifies the requirements 17 for that on-site nonsafety source.

18 MR. LONG: If you have a loss of off-site power 19 are you put into a natural circulation condition for going 20 all the way to shutdown for the PWR, or would you be able 21 to run say one pump and treat it as a -- shutdown, a forced 22 circulation condition?

23 MR. VINE: If you lost the switchyard and the 24 main generator, both, these pumps are on this top tier and 25 so you would not have power to them. You would have a loss O

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.of forced circulation and so you would be in that 2: circulation mode until such time as you restored power to 3 the switchyard.

4 MR. LONG: I can see, you know, you did have a 5 way to back these up here, but I don't see -- if you wanted 6 to run a pump I just don't know if you have the capacity.

7 MR. VINE: Talking about the reserve circuit or 8 the gas turbine backup to this point. That puts you goir.g 9 back to the unit transformer like this and I've been told 10 that's. difficult to do and high inefficient, so I'm not 11 sure that that'would be attempted.

12 You really would have to get the switchyard back 13 to be able to have'a forced cooldown.

14 If you look at the benefits that we hope to gain 15 from having an on-site a/c power source, this lists them 16 all. It provides us for the first time the opportunity of 17 segregating on-site a/c safety and nonsafety loads. We 18 didn't really have the luxury of being able to take the 19 nonsafety loads we wanted to be able to power during a loss 20 of off-site power and get power to them without the penalty 21 of having to load them onto the emergency diesel l

22 generators. Now we have the ability to get the power to 23 them without having to load them on the diesels. It's a 24 large capacity on-site power supply capable of powering 25 permanent nonsafety loads.

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.\J 1 Here is some of the loads it will power that used 2

to be.on the diesels that we'd like to get off the diesels, 3

the point here is that there are a lot of other nonsafety 4

loads on site that we would like to get power to and 5 haven't been able to because of diesel loading problems and 6 so we will now be able to provide power to them with this 7 gas turbine.

8 This enables us to keep the diesels' rating down 9 and it reduces-the impact of the diesel cutage on the plant 10 safety and availability. The point here is we believe that 11 the nonsafety source gives us an additional flexibility in 12 the area of loss of diesel or for maintenance.

13 Reduce core damage frequency, obviously the on b 14 ' sit'e'a/c nonsafety diesel source!will have a significant 15 impact on core damage frequency in that

  • t will drastically 16 reduce the station blackout contribution to core damage i 1

17 frequency. It certainly conforms to everything we've seen l l

18 in the NRC and probably goes beyond that, especially in l

19 capacity and it does provide the opportunity for 20 significant peaking power.

21 And of course the path there would be to energize 22 the permanent nonsafety bus from the gas turbine and then 23 probably either feed on-site loads, or feed back out to the 24 reserve transformer which would be the normal test mode for 25 the gas turbine.

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'b 1 Now to achieve these benefits we looked at 2

whether or not this is kind of .a machine we would only 3 start and use during a station blackout event or one that 4

we would start after loss of off-site power and if we 5 restricted its use to only station blackouts it would 6 really only provide us benefits four through seven, those 7 last four. And what's more, given the improvements we've 8 made in our off-site, normal sources of power, reserve r

9 circuit and 'so forth, the frequency of the station blackout 10 is already.so low that the investment into a gas turbine to 11 handle the very low station blackout frequency would hardly 12 make it pay'for itself, whereas if you started it up for j 13 loss of off-site power, there's a much better chance that i

V 14 we can be able to recoup the investment and deal with the 15 cost benefit. If,we start it after every loss of off-site 16 power, it provides all those benefits and that's why we 17 took the second approach.

18 MR. LONG: Extracting this commitment from 19 vendors did you promise them any kind of expect relief on 20 LCOs with respect to diesels being out of service.

21 MR. VINE: Well, we're certainly not in the mode 22 of promising things like that, no. We're hoping that you 23 will look at that very very seriously.

24 MR. LONG: Are you going to make recommendations 25' with respect to --

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244 I MR._ VINE: That's really in the vendors' area of 2 . responsibility. We, I think, set the stage in the document 3 for some-things.like that and to the degree we're involved 4' in those discussions we certainly have 'some ideas and 5 certainly have some input from utilities, by the'way, on 6 where they would like to see some.

7 So, it's certainly open for discussion and 8 clearly one of the hopes is that we'll be able to use the 9 gas turbine as a backup to the emergency diesel if the 10- diesel is out of commission.

11 MR. LONG: The staff has been discussing a 12 requirement of installed spare diesel and in view of the l 13 start time on the gas turbine relative to that of the O 14 diesel, there will be some impact on the technical 15 specifications, in the event of an inoperable diesel. This 16 remains to be worked out in the future. We certainly do 17 consider an alternate turbine as an equivalent if not 18 -better than installed spare diesel.

19 COMMITTEE MEMBER CARROLL: Why do you say that?

20 Diversity?

21 MR. LONG: Yes.

22 COMMITTEE MEMBER CARROLL: What are the 23 comparative merits of a diesel versus a gas turbine from a 24 seismic point of view? Is one markedly better than the 25 other?

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/~y ' 245 C/ I MR. LONG: Certainly the more diverse they are 2

the better they would be from a seismic point of view.

3 COMMITTEE MEMBER CARROLL: Yes, but does one or 4 the other stand shaking better?

5 MR. LONG: I don't know, but in this case the gas 6 turbine would not be seismically qualified.

7 COMMITTEE MEMBER CARROLL: I understand, but --

8 MR. VINE: It's not required to seismically 9 qualify the --

10 COMMITTEE MEMBER CARROLL: I understand.

11 MR. VINE: They come from the manufacturer with 12 that pedigree already, but they're not required, station 13 blackout doesn't. require them.

O 14 We took a close look at the comparative benefits 15 of both a gas turbine and diesel and found that gas 16 turbine, especially the modern technology are superior to 17 the diesel in many respects, equivalent in a few, and only 18 clearly deficient in one area, and that's starting time.

19 We don't think we can get down to 20 seconds starting time 20 or the technology is going to be achieving that in the near 21 future. So that's the per alty, but it's not a big one in 22 terms of the difference hore. We're talking about getting 23 up to 40 seconds for the diesel in terms of final loading 24 and the gas turbine is likely to start within 45, so the 25 time difference here is pretty marginal.

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( 1 COMMITTEE MEMBER CARROLL: So your answer to my 1 2 question is that the . gas turbine is superior from the 3 seismic point of view?

4 MR. VINE: I don't have an answer to thet 5 question.

6' . COMMITTEE MEMBER CARROLL: Okay. It would be 7 interesting to know what sorts of acceleration these things 8 see on aircraft when they take some of these landings that 9 we experience on occasion.

10 MR. VINE: They certainly handle that. I think 11 it's important to point out, though, that the types of 12 machines that we looked at to compare to the diesel are not 13 strictly the aircraft derivative. They are ones that are

_f 14 a little more rugged, made more for application on land for 15 .the backup emergency power supplies and so forth, so they 16 have greater reliability, a little bit heavier than the 17 aircraft derivative.

18 I mentioned that the PWR will have a full load 19 projection capability which configures to further reduction 20 in the likelihood of the loss of a normal power source, and 21 this is the key by roughly of 50 percent determined bypass 22 capability plus the fast partial rod insertion such as 23 what's installed and has proven itself many times at Palo 24 Verde already.

25 We looked at the PWR and felt that a full load O

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projection capability was not cost effective and so we 2 retained the 40 percent capability previously specified.

3 We've done, as Bill Sugnet explained earlier, a very 4 preliminary risk analyses of the first five chapters and 5 we've done some extractions from that point to try to do 6 some sensitivity studies and so forth. And we conclude 7 that there's probably rough equivalency in terms of PRA 8 results for BWR with three divisions and a PWR with only 9 two diesels but with a full load projection in terms of 10 overall impact on the bottom line, 11 COMMITTEE MEMBER KERR: How can you concur with 12 full load rejection isn't cost effective with BWRs on every 13 possible system. I don't think this is really an issue of O 14 the utility's operating philosophy as much as anything.

15 MR. VINE: We did a cost benefit study that 16 really looked on the benefit side primarily at 17 availability, down time frequency of events and so forth 18 and we came to the conclusion that the cost of a full 100 19 percent driven bypass is somewhere in the neighborhood of 20 $6 to $7 million and that the benefits from a full load i

21 rejection capability is somewhere in the neighborhood of $2 22 to $3 million. And so if you're achieving your full load 23 rejection all by turbine bypass it doesn't pay off from an 24 availability standpoint, however if you look at being able 25 to achieve it with partial rod insertion, it's already part I

O ,

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1 of the design, it is clearly. cost effective for the PWR.

l 2 COMMITTEE MEMBER KERR: Yes, but I think the way 3- a utility ought to look at it is from a' system reliability 4 point of view, not from an availability of an individual  !

5 unit. If we learned one thing out of the Northeast j l

6 blackout it was that you want your good units. If l 7 something bad happens you want them to trip but to protect 8 'themselves, but to be sitting spinning ready to be 9 paralleled when you get ready to put the system back 10 together..

11 MR. VINE: We looked hard at the BWR case and the 12 two points that helped keep us at the 40 percent are one, 13 any kind of a fast rod insertion on the BWR is impractical O 14 as a means of achieving,~so you're really locked into 100 15 percent turbine bypass, and the experience throughout this 16 country as well as the world on 100 percent turbine bypass 17 after all the effort that goes into the design has been i 18 sometimes they work, sometimes they don't, but not with 19 sufficient reliability that you think you're going to get 20 all the payoff that you hoped for.

21 MR. LONG: Gary, doesn't the ABWR have a 22 recirculation pump trip instrumentation system that trips 23 seven out of ten pumps and causes a sudden runback like 24 that that would readily permit this capability?

25 MR. VINE: I don't think so; I think it can run O

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l O 'l back from mid power levels, but not from 100 percent power 2 to be able to do this.

3 COMMITTEE MEMBER CARROLL: I thought I read just-4 exactly whatyou were saying someplace in here.

'5 MR. VINE: Chuck, can you help me on this?

6 MR. JOHNSON: You could trip the pumps and run

-7 power back but that would not save you from -- what happens 8- with the- PWR is you get a mismatch in the steam --

9 generated steam leaving the pot when the generator ejects 10 loads and that squeezes the bubbles in the core and you get 11 a' reactivity surge, you get a flux going. It's so quick 12 and it's so -- 100 percent bypass and it's.got to be a very 13 good 100 percent bypass, but you get that litti.e mismatch O 14 and you're --

15 COMMITTEE MEMBER CARROLL: I know all about that, 16 but it can still be done.

17 MR. VINE: We were hoping to be done by 4:30 and

18. we have two.more chapters to cover. We can cover those 19 rather quickly, but even if we do, I think we're going to 20 have to look at the agenda and decide how you want to 21 approach this.

22 Do you want us to quit and pick up your other 23 items, otherwise I'll keep on going?

24 CHAIRMAN WYLIE: Well, you keep going.

'25 MR. VINE: Okay, then I'll keep moving here as O

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,m 250 L) 1 quickly as possible.

2 I On the d/c -- a/c systems we again were looking 3 very hard at the problems we were f acing in maintenance and 4 in compromise of systems relation as evidenced by risk 5 analyses and also that the forced outage and frank trips 6 caused by the local, by the a/c and d/c systems.

7 Our approach in this area in general, this is 8 kind of the top level approach, was first of all to 9 increase d/c source redundancy or at least backup 10 capability to insure normal system operation, continuous i

11 operation with a single failure. As I said before, we want 12 to be able to operate without having to shut down if we i 13 lose a single battery charger or single inverter.

/ 14 We want to insure capability of the full task of 15 maintaining the system on line. He want to be able to do 16 charges, test the charges, equalizers, all this kind of 17 stuff on line without having a shutdown. We want to 18 eliminate all cross-ties within safety divisions and want 19 to separate the safety and nonsafety d/c loads.

20 COMMITTEE MEMBER KERR: Is that decision to 21 eliminate cross-ties based on satisfying some sort of 22 general design criteria or criterion or is it based on a 23 risk analysis?

24 MR. VINE: Both. There are regulatory 25 requirements, there are IEEE requirements for that O

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separation. Clearly _ a strong position taken by our own 2

steering committee that they wanted absolute complete 3

separation mechanically and electrically of the safety 4

divisions on both mechanical and electrical and on the 5

electrical both on the a/c side and the d/c side.

6 So you'll see, for example, in --

l 7 COMMITTEE MEMBER KERR: I haven't heard anything 8 about risk analysis yet.

9 MR. VINE: Risk analyses will support this 10 because one of the contributors to specifically the - one 11 of the main reasons why d/c power is a contributor to core 12 damage frequency or why d/c power shows up so often as an 13 element in the significant risk sequences is some failure 14 of separation, some case where the two batteries were tied 15 together, where one failure in one battery somehow affected 16 the other division. So we've clearly separated one 17 division from the other.

18 However, you'll see that we do have the ability 19 to cross-connect various sources and have some flexibility 20 within the safety division and I'll show you that in a 21 minute. But not from one division to the next. l 22 The main functional requirements, again failure 23 or unavailability of single battery, battery charger, i 24 inverter cause a plant trip or forced outage. We have l 25 provisions to test, maintain and replace those items on

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line without having to affect plant operation. Capability 1

2 to allow operation of our station blackout coping loads for 3 at least eight hours; the regulatory requirement is four.

4 And capability for offline charging.

5 The design concept is to place total plant value 6 capacity -- I'm sorry, the total plant value capacity is 7 set by both our coping requirements, ER requirements, and 8 our requirements for backup capability to achieve these .

9 availability goals and our approach then is to take that i i

10 necessary capacity established by both coping and backup l 11 requirements, distribute it among several batteries rather 12 than among fewer larger batteries.

13 This is the PWR drawing; the BWR drawing is o

V 14 similar.

15 Quickly, what we have here, again total 1

16 separation of this division's d/c, and vital a/c systems i 17 from this division's vital d/c and a/c systems. Within l 18 each division we have a full division battery, division one l

19 battery, division two battery powered by its own battery 7

20 charger and all the reactor protection channels and l l

21 divisional loads come off separate invertors.

22 We also have a requirement for a separate source i 23 of a battery charger and a small battery, dedicated j l

24 normally, in the normal lineup to these reactor protection i

25 channels on both sides. So each reactor protector channel O

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1 has its own' dedicated source, division loads on that side 2 .have their own dedicated source.

3 You then have basically three sources within a 4 division and the ability to . cross-connect those sources .

5 within that division.

6 The demands of the.RPS channels are such that 7 these sources don't have to be as large as the full 8 divisional battery; however, because of our requirement 9 that says we want to . be able to operate continuously 10 without a forced outage, if we have a single failure, if we 11 have a failure of a divisional battery or the divisional 12 battery charger, then we would not be able to meet our 13 coping requirements, our eight-hour coping requirement and U 14 still stay on line. So one of these two channel batteries 15 would have to be upsized and essentially be equivalent in l 16 size to a full divisional battery to meet that availability l

17 of requirement.

18 So in essence for the PWR you would have four 19 full sized divisional batteries, two on either side; and 20 then the last RPS channel battery in each of those 21 divisions would not have to be full size.

22 In the BWR drawings, you can see in your handout, t 23 is similar I

24 COMMITTEE MEMBER KERR: No, we can't, because we 25 didn't get the drawings.

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) 1 MR. VINE: The drawing is still not in there?

2- MR. PUSHECK: Nonsafety is but the safety is not.

3 MR. VINE: Did the a/c drawings get in?  ;

4 COMMITTEE MEMBER KERR: No.

5 MR. VINE: We'll get more copies tomorrow. This 6 is the BWR drawing and it's too difficult to explain in the 7 short amount of time we have, but in this case, with some 8 language we have in there to resolve some problems with 9 forced outages, this would be a single battery and in both 10 cases the channel batteries would.not have to be full size.

11 So this would have three large divisional batteries and the

12. channel batteries would be smaller.

13 And you see in your drawing the nonsafety 14 batteries, the 250 volt system and a 125 volt system.

15 COMMITTEE MEMBER CARROLL: When the asked the PRA 16 fraternity to tell us about all these insights you're 17 getting out of NUREG 1150, the common example is, well, 18 everybody needs a gasoline driven battery charger that they 19 can have available and bring on and hook it in for these 20 kind of vulnerabilities.

21 You might want to look at whether you really need 22 one of those or not. But that seems to be a popular thing 23 to do nowadays.

24 MR. VINE: I don't think with the design we've i 25 got that we need to provide those kinds of additional -~

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n 255 b 1 the benefits we see from this chapter, Bill Sugnet 2 mentioned this morning that a large percentage of the 3 residual risk after the first first chapters was in 4 electric power supp. ties. We think we've addressed that 5 head-on and in the area of the reliability of the normal 6 source alone, and the reserve source alone, before we even 7 get to the question of the gas turbines you see a 8 significant improvement in~ reliability and reduction in the 9 loss of off-site power frequency with DWR and PWR. This is 10 before we look at the gas turbine, and the difference here 11 of course is because of the full load rejection.

12 We further will improve the reliability of our 13 on-site sources and reduce the station blackout frequency

' 14 by roughly a factor of 100 from the addition of the a/c and 1

15 the improvements in the d/c sources. The improvements in 16 the d/c sources feed back directly to starting capabilities 17 on the diesels and so forth.

18 So we think it really addresses the station 19 blackout. The station blackout core damage frequency is 20 going to be probably indiscernible in the PRA, overall 21 results, at least for the internal sequences we think will 22 be -- 6 for the design.

i 23 Other benefits from improvements in this chapter 24 are in simplicity and flexibility. We have looked at these 25 improvements and feel that they are practical and cost O

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256 0 1 effective and. will have an overall favorable impact on- 1 2 operations ~and maintenance. We think we've exceeded all 3 the regulatory requirements to meet the NRC's expectations 4 in terms of the generator circuit breaker, alternate power 5 supply, redundant safety and nonsafety values and so forth, 6 and we believe all this is based on proven technology.

7 And I'd like to quickly turn it over to, unless 8 there are any questions,' turn it over to Joe and try to get 9 through three' chapters here in a short' period of time.

10 CHAIRMAN WYLIE: --short circuit voltage study on 11 your auxiliary' system?

12 MR. VINE: No.

13 CHAIRMAN WYLIE: Looks like awfully large 14 transformers in there. I would guess around 60 mVa 15 auxiliary, just looking at it. Might want to do'that.

16 MR. RUBENSTEIN: Before you fly through this, you 17 know, between two and three tomorrow, you've essentially p

18 covered most of the issues, fire protection. I think 19 you've certainly covered the electric system design, fire 20 protection -- for a break -- physical security or -- well, 21 not OBE I guess.

22 MR. VINE: Our hope for tomorrow afternoon's {

23 agenda in response to the issues listed in SECY 8913 would i

24 be to focus as much attention as possible on the last two l l

25 For both items, hydrogen generation and source terms. )

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L q 257 V 1 source term and hydrogen we prepared a significant 1

2 presentation for that three-hour block and would like to 3 spend'the majority of time on those two issues. The other 4 ones we think we've already addressed in today's chapter 5 presentations 'with maybe a couple minor exceptions or j 6 questions from the ACRS would like to cut those down quite 7 a bit.

8 . CHAIRMAN WYL;.E: Yes, I would agree.

9 MR. RUBENSTEIN: .I can't imagine what more you 10 have to say about the electrical system.

11 MR. VINE: We hope that there's nothing more to 1 i

12 be said. If you have any questions we can cover it.

13 COMMITTEE MEMBER KERR: Is - the implication of G

14 what you're saying is you've heard enough for one day?

15 (Laughter.)

16 MR. RUBENSTEIN: I was trying -- he was saying to 17 Joe that he's got to fly through this in a few minutes.

18 MR. VINE: There are some important things in 19 these chapters and if we want to continue tomorrow and find 20 some time to finish off the last couple, we could probably 21 do that, but I don't want to shortchange hydrogen and 22 source terms because we have prepared quite a presentation 23 for you in that area.

24 MR. YEDIDIA: Okay, chapter eight is plant 25 cooling water systems and has these subsections in it. The O

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e) 1 component cooling water system which--in the turbine 2 building, service water systems which are essential and 3 nonessential, used to cool the energy first come from 4 cooling system and the other for the turbine building.

5 Chilled water systems which are safety and nonsafety types.

6 Circulating water system to cool the condenser and the heat )

1 7 sink, the normal heat sink and the alternate heat sink. l 8 And fuel pool cooling and cleanup.

9 My discussion will revolve around the component 10 cooling, the service water, the heat sinks and the fuel 11 pool cooling and cleanup.

12 First some key requirements that are listed, one 13 of the key requirements is that the safety functions will 14 be performed by the service water system, the component 15 cooling water system and the chilled water system. And the 16 requirements of the chapter, the engineer safety functions 17 of chapter five, the HVAC cooling toads in chapter nine, 18 and the fuel pool cool.ing load of this chapter, itself.

19 Many of the features of the design are described 20 in this chapter; we had separated under division which are 21 parallel with those that we have in chapter five, in other 22 words where we have in chapter five two divisions for the 23 PWR, we have parallel systems in chapter eight that would 24 support those systems. Original separation carried through 25 all systems including a/c and d/c power supplies as O

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1 described before.

2 So basically what we see here is we'll see during 3 discussion that the BWR case we have three parallel 4 divisions providing the safety loads and in the PWR we have 5 two of them.

6 Now, cross-connection of the two divisions are 7 restricted. We are not showing them, basically in a 8 requirement that I'll discuss later, requiring that they 9 will be used only in very selective situations where it can 10 be shown that actually providing, adding to the safety of 11 the plant, but basically the principle of few requirements 12 is to restrict the number of cross-connections.

13 The discussion of cross-connections among 14 electrical reflects the same here.

15 Allow some safety loads primarily from the NSSS 16 to systems that are safety load. I'll explain why we 17 decided to go that way in the case of the component cooling 18 system.

19 This is actually a drawing of a component cooling 20 system for the PWR and it's also for the BWR because the 21 differences in the two, the drawing that is showing for 22 BWR, PWR are too small to worry about them in this 23 juncture.

24 What we have in each one of these divisions let's 25 say for the PWR is two component cooling changes, essential PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD SUITE 240 SACRAMENTO. CALIFORNIA 95827 TE LE PHONE 1916) 362 2345

260 0 1 service water and each -- and two pumps, each one of which 2 is capable of carrying 100 percent of the load of that 3 division. In other words, basically an installed spare to 4 the other one which does the job of supplying component 5 cooling water.

6 Now this system operates throughout the operation 7 of the plant and also of course during shutdown or during 8 an accident condition and we have here some notes on valves 9 which close on systems with signals or valves which open on 10 high temperature, which is in this case', an indication for 11 the opening of the containment spray heat exchanger.

12 The reactor coolant pump is cooling as you see 13 here by a component cooling load which can be isolated if 14 desired, but usually it stays open during any event 15 including loss of off-site power.

16 I might want to leave that drawing here, it'll 17 explain the issue of whether or not we should use a 18 combined system, in other words a system that ccn supply 19 ccoling to either generators and essential chillers and so 20 on wnich are safety 1oads and also supply cooling to 21 nonsafety loads in this was an issue that was debated quite 22 a lot before we reached a decision that we would go with 23 that kind of approach rather than segregating completely 24 between nonsafety loads and safety loads in that system.

25 So we had option of combined circulating these O

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261 0 1 two systems and we finally decided to select a combined 2 system basically for the following reasons. It 3 significantly improved the reliability for cooling of the 4 PWR active coolant pump seal. The reason for that is with s

5 this approach we have cooling for the pump seals from the 6 diesel generator source, in other words, from a source 7 protected by diesel generator source and from a source 8 protected by the gas turbine. So these are two completely 9 redundant and diverse ways of cooling the reactor coolant i

10 pump seal, which is very important for the PWR.

11 By the way, this issue was an issue only strongly 12 debated with regard to the PWR.

13 In addition to that, of course, there is a 0 14 relative simplicity of the design due to the fact that we 15 have less -- changes required in order to put together a 16 system like that, rather than a system which has also 17 additional pumps and heat exchangers for nonsafety loads.

18 And also in our calculations of the diesel 19 generator loads, we determined that having this kind of an 20 approach will in some casec show a reduction in diesel 21 generator loads due to the fact that we don't have to use 22 the diesel generators to protect against the loss of the 23 a/c which would be the carrier of the loads of the 24 nonsafety related pumps.

25 COMMITTEE MEMBER KERR: You mentioned there was O

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262-1 a lot of debate before this decision was reached. Who were 2 the. participants in the debate?

3 MR. YEDIDIA: First of all, there were debates 4 among the' people who prepared the chapter, and then there 5 were some debates along steering' committee members; 6 eventually we settled on this decision.

7 COMMITTEE MEMBER KERR: Who won,.the good guys or 8 the bad guys?

9 MR. YEDIDIA:- I believe it's the good guys.

10 What do you think?

11 COMMITTEE MEMBER KERR: I don't know.

12 MR. LONG: I'd like to comment; something that 13 really jumps at me is could you put that slide back up? I n

14 think the customary practice for RHR heat exchangers and

15. diesel generators is to use the-river water for cooling, 16 then it's introduced in intermediate system, and I wonder 17 what's going to happen when you have 95 degrae rivera and 18 you're trying to maintain a cool a suppression pool say 19 down to 95 degrees?

20 MR. VINE: That was again studied carefully; 21 Joe's got some slides that I think will deal with that 22 issue pretty well. We realizo the efficiency penalty that 23 we've got for achieving a 60-year life. The long-term 24 problems of using raw water to cool components was probably 25 would be much more beneficial to go with an in between PETERS SHORTHAND REPORTING CORPORATION 3336 BRt.DSHAW ROAD. suite 240 SACRAMENTO CAUFORNIA 95827 TELEPHONE (916) 362 2345

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\) 1 system and that's what we've done.

i

]

2 l MR. YEDIDIA: That is -- 1 3 COMMITTEE MEMBER CARROLL: In all the things 4 you're talki., about here, safety related, does the 5 isolation of nonsafety related components on a safegusrd 6 system give the utilities any problem from an investment 7 protection point of view? One thing that comes to mind is 8 chopping the cooling water off to say the turbine lube oil 9 coolers; doesn't sound like too swift an idea to me.

10 MR. VINE: Well, first of all, there is a 11 separate, a completely separate cooling water system for 12 all the turbine loads. There's a nonsafety--I'm sorry, go 13 ahead Joe.

(Q

\> 14 MR. YEDIDIA: That's right, the component cooling 15 system from the turbina building is a completely separate 16 system. This is only for the NSSS.

17 COMMITTEE MEMBER CARROLL: What's, the box -- left 18 then, nonsafety related components.

19 MR. YEDIDIA: Nonsafety related components that 20 aren't NSSS; for example, chillers and the nonsafety 21 related chillers in the section of the building that is in l

22 the NSSS or other loads such as that.

23 Or a cooler f or a motor on the charging-- for  !

24 example, would be part of that system, or any other -~ or 25 a little heat exchanger in the CDCS, or sealer water heat O

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i 264 1 exchanger for the CDCS. All those loads which are CDCS, as 2 you know, is a nonsafety related system.

3 COMMITTEE MEMBER CARROLL: Sort of.

4 MR. ARCHIZEL: Before you had that turbine 5 available for backup, now you don't have any cooling water j 6 for'the charging pump, so you really don't have a charging 7 pump in that situation anymore.

8 MR. YEDIDIA: The charging pump is available only 9 in case you have the a/c. You have the turbine--

10 MR. VINE: My recollection is'that the intent is 11 to make all the auxiliary systems that support the charging 12 system also nonsafety. So what you have then really is a 13 case where your reactor coolant pump seal cooling is really

,r5 k> 14 provided by two independent and diverse means. One is the 15 charging seal injection powered by the gas turbine and 16 supported by nonsafety systems and you have the component 17 cooling water heat exchanger or the pump seal heat 18 exchanger cooled by a safety system. So they're really 19 independent and diverse. A loss of the component cooling 20 water system does not take out the charging system.

21 MF. YEDIDIA: We wculd just not put it on this 22 line, we'd put it on one of those.

23 This issue of cross-ties I discussed before. The 24 basic reason for not recommending the use of cross-ties is 25 that the systems as they are have sufficient redundancy O

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1 already and cross-ties cannot pro'cect against a common load  !

2 failure and if we leave the cross-tie, between divisions, 3 we can wipe out two divisions, so basically what we are 4 saying is if any cross-ties are used, they should be only 5 if they are shown to be needed for safety, availability, 6 utilized under strict administrative controls and that a 7 single failure is going to be tolerable and basically this 8 is the reason for not recommending the use of cross-ties.

9 I know that this may be a little bit in conflict 10 of the recent SECY that was put out by the NRC where cross-11 ties have been suggested, but there I think it is mostly 12 with regard to the idea of using cross-ties between plants 13 and not between divisions within the plant.

( 14 That could be a compromise but not permanently 15 installed cross-ties which could be more detrimental than 16 helpful.

17 With regard to essential service water system, 18 here I tried to concentrate on the issues that were listed 19 in GSI to 51 and 130 and if you read those you'll see that 20 they talk about problems with fouling, corrosion, icing 21 also concern about leakage within the plant. Our 22 resolution of these issues is basically by providing these 23 improvements in the plant.

24 First of all we do not intend to use any direct 25 raw water cooling to any components in the plant. That, by PETERS SHORTHAND REPORTING CORPORATION 3336 BRADEMAW ROAD. SU'TE P40 SACRAMENTO CAllFOHNIA 95827 TEL EPHONE (916) 362 2345

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( 1 itself, reduces the problems of fouling and corrosion to 2 very limited areas where we can provide control of the 3

situation and that is basically the main component cooling 4

packages; then additional of course are the ones that you 5 would think about, silt remover, material selection which 6 is in agreement with the type of the raw water that you're 7 using, water treatment, particularly against 8 microorganisms, velocities which are limited on the upside 9 to reduce corrosion and the downside to reduce the 10 accumulation of microorganism or other type of fouling.

11 Cold weather design requirements which are 12 basically circulation of hot water in through the area as 13 well, icing could be expected, and of course, adequate U 14 redundancy of pumps and interchanges. As I said in the 15 case of the PWR we have two divisions, each of which has 16 two pumps and two heat exchangers, each with 100 percent 17 capacity and prevention of service water leakage into the 18 rad waste system by reducing the area or taking service 19 water completely out of the area where the rad waste system 20 could be collecting any leakages that could come out of 21 that system.

22 So basically what we have here is there is an 23 error in the drawing, we have two systems for the PWR and 24 three of these systems for the BWR, taking water from heat 25 sinks, essential service water, taking water from the other O

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267 l 1

heat sink through strainer and compound cooling exchanger 2 only to these two and back to that.

3 A similar system for the nonessential service 4 water takes the water from the cooling towers which are the 5 normal heat sink.

6 COMMITTEE MEMBER CARROLL: Has anybody looked at 7 that configuration with the vulnerable single line between 8 the strainers and the heat exchangers?

9 MR. YEDIDIA: This is really only schematic; 10 could definitely be this way. What you see here, that 11 single line, of course, one of two or one of three that you 12 have and this goes all the way from the intake to the l 13 building, so this is really the longest line. But if it G

V 14 happens to be a short line then you could go with two. But 15 this line is the line that is buried in the ground between 16 the intake and the auxiliary building, but close in a ditch 17 that you can have access to the line. This is all in the 18 requirements, having capability of reviewing the status, 19 this line.

20 MR. LONG: The general design criteria for single 21 failure would be met by the other system.

22 COMMITTEE MEMBER CARROLL: I understand.

23 MR. LONG: Okay, I thought that was your 24 question.

25 COMMITTEE MEMBER CARROLL: But my question is the l

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'1 way'I -- I mean my sense of reliability making this system L 2 as reliable.as possible would be to use a cross-tie and 3 have a line from the pump through a heat exchanger, through 4 a heat exchanger, pump, through a heat exchanger with a 5 cross-tie.

6 How about the single line out to the ultimate 7 heat sink. Those have becu known to be vulnerable because 8 of the elevated temperature things like in salt water tank, 9 mussels growing in them and --

10 MR. YEDIDIA: Again, the first line of defense 11 for that is to try to eliminate the growth of such mussels 12 or organisms by proper chemical addition. Then the seccnd 13 line of defense is the redundancy between systems. That 14 again would be a rather long line, so we have chosen to 15 show here a single line, inspectable, buried in a ditch 16 where you have access to review it, check the status of the 17 pipe and selection of the proper materials.

18 Since we are not spreading this system throughout 19 the plant but we're concentrating on going from the heat

.20 sink to the building and back we feel that it could be 21 justified to use stainless steel rather than carbon steel 22 for these particular lines, or -- we don't require that, 23 but we require that selection of the material be adequate 24 to meet the conditions of that particular site, as far as 25 quality of its water.

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269 1 COMMITTEE MEMBER CARROLL: The real world 2 problem, of course, is that your heat load at full load is 3 not as great as your heat load when you're trying to cool 4 down, RHR. And I've been involved in situations where you 5 run this system throttled and now open it up to full load, 6 normal operation, want to open it up to cool the plant down 7 and I find that I've got a load of mussels and stuff in 8 that tailpipe and I can't get the heat exchange I want.

9 MR. FIDRYCH: Incidentally, that was one of the 10 reasons why people argued for the combined system, it does 11 provide a larger load during normal time operations, but 12 you don't have some of the components, only running during 13 the shutdown case or having a very light load during normal 14 operations. This tends to overcome that problem.

15 Also looking at the components is another reason 16 why we put redundancy in active components with things like 17 the heat exchangers where you normally have a lot more 18 problem, but would have a higher velocity at times, so you 19 can cycle those to get the higher velocity through them 20 during operation.

21 COMMITTEE MEMBER CARROLL: Because two systems 22 don't give me much comfort if you want to postulate mussels 23 building up in the tailpipe, they don't know which system 24 they're in as long as the temperature is optimum for their 25 growth. Common failure situation.

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270 V: 1 COMMITTEE MEMBER KERR: Four' systems give you

~2 more--

3 COMMITTEE MEMBER CARROLL: No, mussels don't know 4 the difference. The temperature's right,1 they grow.

- 5 MR. YEDIDIA: You're right . that the growth of 6 mussels and all kind of organisms .is one of the major 7 problems that people encounter with service water systems, 8 but EPRI is working on that separate from what we are doing.

9 here. We're working on remedies to that and hopefully 10 there ' will be ways found to . do that , to overcome these 11 problems.- But.there's definitely a need to improve that

.12- concern.

13 MR. FIDRYCH: I think we've put into the 14 requirement document everything we can think of; if there 15 were any further suggestions --

16 MR. YEDIDIA: I'd like to talk a little bit about 17 .the ultimate heat sink which obviously is very much site 18 related and we couldn't really say what exactly would 19- happen in any particular site with regard to the ult.! mate

'20 heat sink, however, we chose for the reference plan to go 21 two ways. First of all, heat sink, select what we calle d 22 a passive pond without sprays as the basis for the ultimate L

23 heat sink and as you'll see later for the normal heat sink 24 for the normal operations of the plant, there is a cooling 25 tower.

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271 1 Now, we start with ultimate heat sink. It is a 2 single passive pond and we selected that -- spray pond for I 3 preferability, the spray ponds, even though they have been i 4 used in recent years, still are not been able to put 5 together a system with spray that are free of problems with 6 maintenance and operation, so we have determined that for 7 the size of the pond that we need for our service water, we 8 can in most cases, get an -- pond with an area that is nor 9 excessive, in other words, what we are talking about is 10 something of the order of no more than 50 acres of the pond 11 to cool a plant of this size, the reference size for the 12 ALWR.

13 And Reg Guide 1.27 permits the use of a single k) s 14 pond even though a little bit reluctantly, but it does not 15 disallow the use of a single pond, so if the designer can 16 show that he can design that pond to moet Reg Guide 1.27, 17 our requirement document permits it. in cases where it is 18 not possible to meet the 1.27 which has certain limitations 19 on the use of a single pond, then of course they might be 20 other alternatives such as a second pond cr a pond and the l 21 river or any other combination of heat sinks that are 22 permitted by 1.J.

l 23 Now the performance standard for the pond is l

l 24 based on 0 percent exceedance of the ALWR envelopes, in 25 other words the temperature that is required for cooling O

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1 272 1 safety loads has to be 95 degrees, under old conditions,

~2 however - the optimization between the size of the heat 3 exchanger in the plant and those of the' component cooling 1

4 which use surface- water .to ' cool the . plant, that's 5 optimization between these two sets of heat exchanger is up 6 to the designer.

7 Now for the normal heat sink, we selected 'a 8 single natural draft cooling tower as a reference, which 9 achieves desired' simplicity. The specific size conditions,

-10 other alternatives, requirement documents specify 11 requirements in case of the selection of the --

draft 12 cooling tower which would have -- and the standard plant 13 performance is based in this case on the 1 percent 14 exceedance, in other words temperatures slightly lower than 15 those for the ultimate heat sink, - and under 1 percent 16 conditions we should'be able to operate at full power in 17 case we reach 0 percent 'exceedance which is the highest 18 temperature, then'at least the requirement is that even 19 though you cannot generate full power with your turbine, 20 you still would have to be able to have the reactor 21 operated -- put down specific requirements for improvement 22 for reliability and maintainability and those relate <

23. specifically to the area of the fill, the replacement of 24 the fill, the maintenance of inside of the cooling tower 25 and there is a specific requirement in the document that O

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\ 1 requires that maintenance of the cooling tower should be 2 done within 25 days of the shutdown that I talked about 3 before.

4 If that is not shown to be possible, then the 5 option is given in the requirement document to go to two 6 cooling towers which would kind of overlap in the summer, 7 but most of the year would be able to carry the load by 8 themselves, so there would be something like 70 percent 9 cooling tower that two of them that would probably be easy 10 to carry hundred percent load throughout most of the year 11 except during the summer months.

12 So basically as I'm saying, the reference is a 13 single cooling tower, but we cannot meet other requirements 14 which are the requirements that concern maintainability; 15 other options can be sought. Including, of course, use of 16 forced draft cooling tower or even two natural draft 17 cooling towers.

18 And the last issue in this chapter is concern the 19 fuel pool cooling and cleanup system. Functions of that 20 system is to maintain the pool within specified water 21 temperature and water quality and also that system provides 22 cleanup and cooling of the -- cooling with RHR, --

23 MR. VINE: Cooling with RHR or containment 24 spread.

25 MR. YEDIDIA: Okay, so that combines cooling y,

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274 1 cleanup for the IRWST or the suppression cooling in the 2 case of the BWR.

3 Normal heat load is basically follows the lines 4 that were discussed before, chapter seven -- maximum size 5 exposure. This is the normal load. The maximum load would 6 be the same thing here, but full cool-off load, so that 7 would be much more new fuel coming into that pool than in 8 the normal case.

9 And the temperatures that are specified for these 10 cases, limits, are that during normal heat load we would 11 normally under 20 degrees; this is 120 degrees is the 12 temperature that we expect to achieve in most cases for 13 fueling, and for visibility, and during the normal

/

.ks' 14 operation. However, if there is single failure the system 15 should be able to run 140.

16 Here for the maximum heat load we have a similar 17 situation. We allow 140 for single -- here is 180 with 18 single limiting failure, but supplementary cooling and 140 19 would be with no limiting failure, but also with some 20 supplementary cooling, for example, from the heat removal 21 system.

22 Now with regard to the safety classification of 23 the system, right now it is the cooling function is a 24 safety related function and therefore cooling water has to 25 be supplied to the heat exchanger and the pumps have to be A

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able to operate, however what we're trying to achieve in 2- the case of the passive plant is a change in that 3

classification because passive plants will not have safety 4 related system that would be using pumps and for that .

s 5 reason we are working on changing the classification of the 6 system, for~ example, by providing makeup which is safety 7 related but not any pumping power for pumps to rtan tua 8 system, itself.

9 So this is still in the transition and I don't 10 know where we'll end up. But it's one of those 11 considerations that we have to take into account when we go 12 into the passive systems. We expect that eventually we 13 will change the clarification of that system.

q b> 14 COMMITTEE MEMBER CARROLL: The passive system 15 you're talking about don't use pumps, they use highly 16 reliable motor-operated valves, right?

17 MR. YEDIDIA: That is the intent. But for one 18 step of operation only. Only to initiate a defense of the 19 system. But not the full continuous, you know, modulating 20 of the -- now, this brings us to the end of chapter eight.

21 Do you want to go to chapter 12 and 13?

22 CHAIRMAN WYLIE: Well, ' 's see. Maybe we could 23 take these up in the morning? Let's do that.

24 MR. LONG: With respect to chapters seven and 25 eight, I haven't seen anything that's inconsistent with O

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\ - 1 current staff criteria.

2: MR. VINE: No, I don't think so. Joe and Bruce, 3 correct me' if I ' m ' wrong , I don't think we've got any 4 significant optimization issues in either of these two 5 chapters.

6 MR. YEDIDIA: In chapter eight we have only 7 generic--

8 MR. VINE: Yes, --

9 MR. YEDIDIA: And in chapter 12 we don't have 10 either.

11 MR. VINE: I think that's the point that Joe make i

12 at the end is an important one and it's interesting because j 13 we've never really faced the decision before on power I 14 supplies to some of these quasi-safety loads, and I say 15 quasi simply because they are, if you look closely at the 16 reg guides, they talk about the need for reliable power, l 17 the need for reliable on-site backup ability and so forth, 18 but they don't specifically say that the system needs to be I 19 1E, so it has become common practice to power a lot of 20 these loads, such as spent fuel pool cooling and 21 pressurized heaters and so off to diesels and treat them as 22 1E but the regulations don't specifically require it.

l 23 So we're now in a situation where we have the L 24 capability of putting some of these loads on a nonsafety 1

25 on-site source and meet all the function requirements  ;

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0 l

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277 O 1 intended by the reg guides, but because the reg guides were 2 written without a clear recognition of the option of having 3- nonsafety on-site power, they're just not clear.

4 COMMITTEE MEMBER KERR: What availability 5 requirement would you, yourself, put on them,.if you had 6 the complete freedom with no guidelines.from staff?

7 MR. VINE: Well, we would'like to see some of 8 these' loads,taken off IE because it's important for us,not 9 only in simplification here, but in terms of the 10 requirements that we expect to see on the passive plant.

11 . COMMITTEE MEMBER KERR: Suppose you could take 12 them off the 1E what availability requirements would you 13 set?

k> - 14 MR. VINE: Well, first of all the gas turbine is 15 specified to have a 98 percent reliability and we're 16 confident we can weet that.

17 COMMITTEE MEMBER KERR: Is that good enough in 18 your view for spent fuel pools?-

19 MR. VINE: Well, not only that, but you need to 20 look at the whole picture.

I 21 COMMITTEE MEMBER KERR: Okay, let's look at the l

22 whole picture.

23 MR. VINE: The whole picture says we've reduced 24 the frequency of the station--

25 COMMITTEE MEMBER KERR: Just tell me what O

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1 I i fm. _ 278 Q5_ 1 availability you'd want --

2 MR. YEDIDIA: You have'to remember that the spent 3 - fuel has a large capacity factor.

4 COMMITTEE MEMBER KERR: All I want to know is --

5 chosen an availability. Given that you have freedom, what 6 criteria would you use? All I'm hearing are qualitative 7 arguments which are good, but --

8 MR. YEDIDIA: There's no question that ultimately 9 you would have to be able to provide something to the --

10 and that has to be safety related. But beyond that I would 11 just allow'it to boil--

12 COMMITTEE MEMBER KERR: You really haven't 13 thought it clear yet, then?

q'/

vd 14 MR. VINE: Yes, we have. Let me try to answer, 15 first of all, there is a much lower probability with the 16 improved off-site source.

17 Second you have the ability if necessary to power 18' permanent nonsafety loads from a diesel if the gas turbine 19 doesn't start. You have that ability. So it's no less 20 reliable and in fact more reliable than--

21 COMMITTEE MEMBER KERR: I'm simply asking if you 22 have any criteria, or device criteria for the availability 23- of your cooling system?

24 MR. VINE: I think the criteria that we will be 25 using will be the PRA results and their acceptability.

O .

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1 We're trying.to avoid--

2' COMMITTEE MEMBER KERR:- PRA results tell you how 3

something operates that you have already designed, but they 4 don't ' tell you anything --

they don't somehow reveal a 5 wisdom that says these are the right criteria. You 6 yourself have got to decide how you want the : plant to 7 perform.

8 MR. ' VINE: - We have avoided setting specific 9 numeric criteria for' individual systems.and functions in 10 the plant because.that borders, in our mind, very close on 11 the idea of partitioning safety goals, which they're very 12 similar in the impact and in the final result and we don't 13 believe that that's an appropriate way to achieve safety.

14 COMMITTEE 14 EMBER KERR: What sort of criteria 15 would you set if they weren't numerical?

16- .MR. VINE: We have numerical criteria, we're just 17 not partitioning our numerical criteria for every system 18 in the plant.

19 COMMITTEE MEMBER KERR: You would have no 20 criteria for the performance of your cooling system for the 21 spent fuel pool? Is that what you're telling me?

22 MR. VINE: No specific criteria for that 23 particular function; however we have overall criteria which 24 we will meet for our core damage frequency and for our-25 offset release numbers which if this is in any way a O

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1 significant contribution to those numbers, it would have to 2 be reduced, and that's how it comes out. We achieve 3 exactly what you're looking for, but in an integrated way.

4 COMMITTEE MEMBER KERR: But you see now you have 5 to decide what is a significant contribution and that is 6 tantamount to some sort of criteria.

7 MR. VINE: Yes, but if you do it the other-way 8 and say arbitrarily my criteria is going to be "x" number, 9 you might find out when you do the PRA that that number was 10 way too high or low, so you're doing the same thing both 11 ways.

12 COMMITTEE MEMBER KERR: Your criterion might be 13 that you want "x" something, but it seems to me you have to

'?

.' 14 have something reasonable and quantitative, otherwise it 15 doesn't --

16 MR. VINE: We definitely do have something 17 quantitative.

18 Let's say we picked your number, we picked a 19 number for spent fuel pool cooling and we did the full PRA 20 and we found out that number was too high or too low, then

(

21 we'd adjust it again. So we're accomplishing the same 22 thing.

23 COMMITTEE MEMBER - KERR: So you're eventually 24 going to pick a number but you just haven't picked it yet?

l 25 MR. VINE: We're not going to have a specific l

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..n 281 g 1 afunctional numerical requirement for every system in the

2. .. plant.

3 ' COMMITTEE MEMBER KERR: I'm only talking about 4 the' spent fuel pool, it's not part of the reactor.

'5 MR. VINE: But.it'does contribute through your 6- safety calculations to-your off-site release number.

7 COMMITTEE 4 MEMBER KERR:. Yes, it does, but it 8 also--

9 MR.' VINE: If it didn't then we would have to set .

-10 'that kind of a criteria.

11 MR. FIDRYCH: My understanding is that we 12 'wouldn't raise ~this issue, wouldn't have the' passive plant 13 situation. The passive plant doesn't have a diesel that O' 14' is lE, just has a non IE and so under these circumstances 15 we just have to go into that direction of the nonsafety 16 related-pool and the solution to that-issue is a technical 17 _ solution such as providing -- trying to define a more or 18 less arbitrary objective of availability and reliability.

19 We just have to resolve the issue technically.

20 But what I'm saying is once we do that for the 21 passive plant, we can just as well do it for the --

22 COMMITTEE MEMBER KERR: Well, I guess T.'m not as 23 enthusias' tic about the pascive plant as some people. To me 24 passive does not necessarily mean reliable..I'm interested 25 in reliable plants.

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l 282 1- MR .~ LONG: Thisiis a philosophical issue which 2 we're struggling with, not only have they not put a number

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3 of the fuel' pool but they haven't put one on the 4 containment.- And we intend maybe to perhaps get into'this 5 a little bit tomorrow.

6 MR. .FIDRYCH: I think the- same thing -- core 7 . cooling system, we have not'specified'a specific number, 8 but,we have specified -- criteria --

9 COMMITTEE ' MEMBER KERR: Well, but . you see, a 10 single failure criterion was okay back in the days when 11 there had not been very much reliability studies done and 12 when it was better than nothing. But we.know a lot more 13 about reliability theory now and the single failure

.Or . 14 criterion does not- establish a uniform standard for

.15 reliability and what "we're trying to achieve is 16 reliability. 'You can say I want to achieve it for the 17 ~w hole system and that is a good idea, provided you know 18 'that there are systems about which there's not a lot of 19' uncertainty; just take a reactor shut down system as an 20 example. There's one in which _ you might require 21 unavailability be ten to the minus six, well, if you do, 22 you're going to have a lot of uncertainty and if you're a 23 good engineer you're going to worry about that uncertainty.

24 So I don't think you can avoid looking to some 25 extent at some.of the subsystems, particularly those that PETERS SHORTHAND REPORTING CORPORATION 3336 BRADSHAW ROAD. SUITE 240 SACRAMENTO, CAUFORNIA 95827 TELEPHONE (916) 362-2345

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will put you on requiring a lot. Maybe you don't look at l 2 the spent fuel pool that way. Maybe you think --

3 MR. VINE: Well, I hope I haven't given you a 4 false impression of our view here because we, in fact, do 5 look at the studies that have been done on the reliability 6 of existing systems and since this is an evolutionary 7 design, we have the luxury of being able to look at the 8 incremental improvements and be able to pretty well decide 9 whether we're going to be able to achieve a significant 10 improvement in reliability over an existing system that's 11 either already considered to be adequately reliable or is 12 viewed in general as needing improved reliability and so we 13 have a good handle on exactly what you're seeking. It's

\'h 14 just that for example the point was made earlier about the 15 midloop PRA and how it seems like every study of a 16 particular sub-issue ha.s a high contribution for that sub-17 issue and we find exactly the same thing when attempts are 18 made to apportion a safety goal, the safety goal happens to 19 be apportioned the way the person whose particular issue 20 is impacted by the way it's partitioned and we just firmly 21 believe in an integrated approach to design and an 1

22 integrated approach to safety and feel that the best way 23 to assure ourselves that we've met our goal with plenty of 24 margin is to do it in an integrated way and not to break 25 it out into little pieces.

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l But pragmatically we have the ability and in fact \

l 2 are looking at exactly what'you're wanting us to look at, 3 but I think we're going to steer clear of putting specific 4 numerical targets for each individual subsystem into the 5 requirements document to achieve that.

6 COMMITTEE MEMBER CARROLL: If I may raise one 7 other sort of off the wall issue. You mentioned limiting 8 off-site effluents in connection with spent fuel pool and 9 stuff, I ge^c the impression that people have not taken this 10 decision and proposed EPA standards, 10CFR part 61 very 11 seriously, but I guess we just got this the other day and 12 started looking at it. I guess what EPA is proposing is a 13 10 M-REM EDE per year from each site and in this thing it 14 has to include accidents in it. And I think this looks 15 like it's one of those things which I think we all feel we 16 probably need, at least normal operations, but proving it 17 may be a different matter and EPA's wisdom here is that all 18 you need to do is have better record keeping and monitoring 19 which looks very expensive to several of us who have looked 20 at this and most people think this is a health physicist 21 issue and I think it is also an issue for people that worry 22 about accident risks.

23 MR. YEDIDIA: --waste disposal--

24 COMMITTEE MEMBER CARROLL: Yes. I 25 COMMITTEE MEMBER KERR: Oh, Mr. Carroll reminds O I l

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' (p) 1 me of one question. Chapter one, I guess listing some of 2 the requirements, a statement is made that point 3G, 3 envelopes, I guess it is, all of the sites in the U.S.,  !

I 4 existing sites with the exception of the West Coast, does i 5 that take into account the USGS pronouncement that you 6 can't really tie down the Charleston earthquake to 7 Charleston?

8 MR. VINE: I think so, but I would rather have 9 Bill Sugnet answer that question for you tomorrow morning 10 if that's okay with you.

11 COMMITTEE MEMBER KERR: I was just curious as to 12 whether that would still hold if you found you couldn't--

13 MR. YEDIDIA: This is the one -- in chapter one, 14 the last -- actually -- of the available size or the, I 15 don't know, but that's basically what it says. It isn't 16 particularly related to the West Coast or Charleston, 85 17 percent --

18 COMMITTEE MEMBER KERR: I was just reading what 19 this says and I think the statement is all except West 20 Coast sites.

21 COMMITTEE MEMBER CARROLL: I think it was l 22 coastal, west coastal sites. Sites here in California, in

. 23 the Valley may be okay.

24 MR. VINE: So your question is what's the current 25 status of the implication of the 3G in terms of site Q

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selection in the US. We'll have an answer for you tomorrow 2 morning on that. l 3 COMMITTEE MEMBER KERR: If you. don't nail down 4 the Charleston earthquake to Charleston.

5 Well, the USGS has, within the last year or so, 6 they have no reasons to tie that earthquake to Charleston.

7 The philosophy used by the NRC for a number of years. In 8 arriving at the site -- for East Coast --

9 MR. VINE: We'll try to get something for you on 10 that in the morning.

11 CHAIRMAN WYLIE: Well, let's adjourn then until 12 8:30 in the morning.

13 (Thereupon, at 5:35 p.m., the workshop was 14 adjourned, to reconvene Wednesday, April 12, 1989 at 8:30 15 a.m.)

16 --ooo--

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() 2 1 CERTIFICATE l

3 This is to certify that the attached proceedings before the 4 United States. Nuclear Regulatory Commission in the matter f

5 of: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 Name: MEETING: IMPROVED LIGHT WATER REACTORS 7

~~~~

8 Docket Number:

9 Place: Palo Alto, CA 10 Date: April 11, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for tt- file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, p 14 thereafter reduced to typewriting by me or under the g

15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings.

18 /s/ Peters Reporting I

19 (Signature typed) :

20 Official Reporter 21 Heritage Reporting Corporation i

22 )

23 24 25 1 Heritage Raporting Corporation (202) 628-4888 l

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