ML20010J529
| ML20010J529 | |
| Person / Time | |
|---|---|
| Issue date: | 09/23/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19251A190 | List: |
| References | |
| REF-10CFR9.7 CLI-80-21, SECY-81-486, NUDOCS 8110050283 | |
| Download: ML20010J529 (50) | |
Text
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PUBLIC MEETING DISCUSSION OF SECY-81-486 -- PETITION FOR EXTENSION OF DEADLINE FOR ENVIRONMENTAL QUALIFICATION OF CLASS lE ELECTRICAL EQUIPMENT DATI: September 23, 1981 PAGzg:
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
DISCUSSION OF SECY-81-486 -- PETITION FOR EXTENSION OF g/
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DEADLINE FOR ENVIRONMENTAL QUALIFICATION OF CLASS 1E 4
ELECTRICAL EQUIPMENT 5
PUBLIC MEETING 6
1717 H Street, N.W.
Room 1130 7
Washington, D. C.
Wednesday, September 23, 1981 8
The Commission set, pursuant to notice, at 9:15 9
m.m.
10 BEFORE 11 NUNZIO PALLADINO, Chairman of the Commission
_12 PETER BR ADFORD, Commissioner JOHN AHEARNE, Commicsioner 13 VICTOR GILINSKY, Cc amissioner 14 ALSO PRESENT :
15 L. BICKWIT S. TRUBATCH 16 MB, REMICK R. VOLLMER i
17 W. DIRCKS H. DENTON 18 B. MURRAY-P. DI BENEDETTO 13 Z. ROSCTOCZY 20 21 22 23
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=2 CHAIRMAN PALLADINO:
The meeting will please come 3 to order.
Again, I apologize for the delay.
We have been
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4 vaiting for Commissionet Bradford, who is expected 5 momentarily.
But I think we can get underway since this is 6 primarily discussion.
7 The topic for today is discussion of SECY 81-486, 8 petition for extension of deadline for environmental 9 qualification of Class 1E electrical equipment.
And I 10 gather the staff is prepared to lead the discussion for us, 11 so I will turn the meeting over to Mr. Dircks.
12 HR. DIRCKS:
I want to put it somewhat in 13 context.
This is the meeting for *.he petition for the 14 extension of the June 30, '82 date.
I want to mention we 15 are on separate tracks but connected, working on a rule for 18 the qualification of electrical equipment.
17 We have a program plan that is now before the 18 Commission and we do have another group working on 19 mechanical equipment.
So I just wanted to make sure that we 20 had three or four different threads moving across the 21 fabric.
And I wanted then to indicate today's discussion 22 will be 23 COMMISSIONER AHEARNE:
Did you say where the
('.
24 electrical equipment rule is?
25 MR. DIRCKS:
I could say very briefly that it is l
ALDERSON REPORTING COMPANY,INC, 400 VIAGIN!A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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1 right here (indicating).
2
( La ug h te r. )
3 MR. DIRCKS:
I am reviewing it now with Harold and
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4 Research and their staffs to make sure that we can -- that 5 whatever we do today and whatever we do in the next few days 6 will be reflected -- any last-minute changes we can put in.
7 COMMISSIONER AHEARNE:
So it is at the stage of 8 review by ED0?
9 HR. DIRCKS:
Yes.
Harold Denton is here and Dick 10 Vollmer will make the presentation on the extension of the 11 date petition, although I might mention it was in the 12 General Counsel's paper.
But, Len, I guess you would just 13 as soon that Dick would pick up the lead?
k 14 MR. BICKWIT:
That is my position, yes.
15 MR. VOLLMER:
All right.
Thank you.
If we could 16 have the fi:st slide, what I would like to do briefly is go 17 over a li'.tle of the history and give you the current status.
~
(Slide.)
18 19 As you are a ware, CLI-80-21 was issued May 30, 20 1980, and the staff in response issued orders on October 24, 21 1980, modifying technical specification ~of the licensees of 22 all operating plants to incorporate the June 30, 1982, 23 deadline for environmental qualification of safety-related 24 equipment.
25 This was preceeded a little bit by regional ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
f4
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1 meetings where we went out to licensees and contractors and 2 gave them a presentation and discussion of what our 3 requirements were, environmental qualifications, and what we 4 saw as a good program for their meeting the June 30,
'82, 5 deadline.
6 The licensees were required to submit information 7 packages showing the status of the environmental 8 qualification of their equipment by November 1, 1980, and we
. 9 did receive licensee rnh;aittals, I think, in all cases by 10 that date.
11 Th.s staff technical review, th en, proceeded and we 12 did our comp ate technical review.
13 COMMISSIONER BR ADFORD:
In retrospect, when you
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14 say you received licensees' submittals by N ovember 1,
- 1980, 15 in view of the fact of the later budgetary response I guess 16 rou would have to say that they were inadequate to the 17 purpose.
18 HR. VOLLMER Well, they in many cases pointed out 19 the deficiencies they found in qualification, but in some 20 cases they listed items as qualified which the staff did not 21-f eel had justification for qualification based upon test 22 data or analysis.
In some cases they pointed out equipment 23 they deemed necessary to replace or relocate to meet safety
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24 goals.
They did so in most cases the staff agreed with tha t.
25 I think in a few instances we pointed out ALDERSON REPoF ?!NG COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINuTON, D.C. 20024 (202) 554 2345
i' o
5 1 additional immediate action that needed to be taken, but the 2 November 1 submittal was just a giant potpourri of what 3 inf ormation they had for those specific electrical equipment 4 pieces that they had in their plants and an ind.
tion of 5 what justification they had for qualification.
6 And in r.ost cases they, too, concluded thas 7 perhaps there van not enough documented, full justification 8 that all of the test envelope requirements indicated by the 9 guidelines had been met.
In many cases they had engineering to justifications as to why they felt the equipment would 11 indeed f unction in the event of an accident or in a harsh 12 environment, but the staff felt, as it will get to later, 13 that a certain fraction of this equipment was indeed k
14 dem onstrated to be qualified.
15 Another fraction was not demonstrated to be 10 qualified, part of that being, we felt, there were 17 documentation or analysis deficiencies, and part of it 18 COMMISSIONER BRADFORD:
In terms of the timing of 19 the deadline we are now coming up against, at least by 20 November 1 the licensee should have been aware, on the basis 21 of their own responses, that there was a certain amount of zz equipment that would have to be replaced.
23 MR. VOLLMER:
Tha t is correct.
That is correct.
(
24 The staff did its review.
The Commission had 25 asked it be done by February 1, 1981.
We didn't complete l
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE.,5.W., WASHINGTON, D.C. 20024 (202) 554-2345
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1 our technical review for the 70 operating plants -- 70 or so 2 -- until a period spanning February through April of
'81.
3 We sent these staff evaluation reports, we called 4 them at that time, to licensees requesting that since we had 5 come up with different findings than they had come up with 6 in their November submittals that they take another look at 7 the safety of continued operation and notif y us within ten
~8 days.
9 They did so.
And on our review of the 10 inf ormation, the last bit of information provided by the 11 Licensees, the staf f issued its final SERs over the period 12 of May to early June of 1981.
We met with about 450 or so 13 licensee and contractor participants in mid-July of this
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14 year to give them the results of our findings in more detail 15 on our environmental qualification review.
16 We tried to give them as much guiaance as we 17 could, what we felt was indeed required to achieve final 18 compliance with the. Commission 's requirements and also to 19 get a good understanding of what the problems were as best 20 we could in meeting the Commission-proposed dates, and.also 21 to get as good an undc. standing as we could as to how much 22 industry was respondirq -- in other words, how much of best 23 efforts were being put forth to meet the June 30,
'82, dato.
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24 The staff review to this point, we believe, that 25 is a summary statement of our review process, that ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
7 1 approximately twenty percent or so of the equipment we feel 2 meets our qualification on the DOR guidelines.
We feel that 3 the order of fif teen to forty percent of the equipment would i
4 need to ae replaced or relocated because the equipment, as 5 such, would not likely meet the environmental qualifica tion 6 guidelines which leaves forty to 65 percent that we believe 7 is likely qualified upon further demonstration and paper 8 analysis and looking with closer scrutiny at the test data 9 that could be shown to be qualified without perhaps 10 replacement or relocation of equipment.
11 COMMISSIONER BRADFORD:
Let me see if I have 12 understood tha t correctly.
13 What you are saying is that as to eighty percent k
14 of the equipment now in place you either do not think it is 15 qualified or at present adequate documentation is not 16 available.
17 MR. YOLLMER:
Eighty percent of the equipment we 18 don 't feel would me.et the full guidelines as laid out by, 19 say, the DOR guidelines for qualification of electrical 20 equipmen t.
21 COMMISSIONER BRADFORD:
Some forty percent of 22 that, forty percent within the eighty percent, you think the 23 problem is primarily documentary?
24 MR. VOLLMER:
Forty or more percent.
We think
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25 tha t equipment can be shown to be qualified either by ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $54-2345
8 1 further documentation or testing or analysis with similar 2 equipment.
And forty percent or less would likely have to 3 be replaced with qualified equipment or relocated or 4 protected.
5 COMMISSIONER BRADFORD Of the part that has to be 6 replaced, is it possible to pin dowr. the primary areas of 7 deficiency? MR. VOLLMER:
We have done that in a little bit 9 later slide, yes, sir.
10 COMMISSIONER BRADFORD:
All right.
11 MR. VOLLMER:
Okay.
52 Based on our review of the licensees' reports and 13 other meetings we had we looked at some alternatives or 14 different options for them tc proceed.
As far as the 15 licensees are concerned we see their particular alternatives 18 as follows.
17 One, replace a piece of equipment if a qualified 18 piece is available.
Secondly, well, the problem with this 1gis that some pieces of equipment that are in the 20 qualification testing process are not even expected to be 21 qualified until, say, mid
'82.
Transmitters are perhaps an 22 example of that.
23 So if a qualified piece of equipment is available 24 in mid '82 and the industry finds that here is an example of 25 a piece of equipment which will pass all of our tests and ALDERSON REPoRDNG COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9 1 it's a good thing to put in place, then you have the 2 procurement time, with the licensees wanting to buy the 3 equipment and then installation time for the equipment.
In 4 some cases it might require a plant shutdown.
In some cases 5 it might not.
6 COMMISSIONER AHEARNE:
Dick, r.re you saying there 7 there are some types of equipment for which currently there
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8 is n'o qualified piece?
9 MR. VOLLMER:
There are some pieces of equipment 10 that we do not have a demonstrated qualification test, for a 11 piece of equipment.
That's right.
12 COMMISSIONER AHEARNE:
From any manufacturer?
13 MR. VOLLMERs Phil, do you want to give me an k
14 example of that?
What would you give as examples of major 15 general pieces of equipment that we haven't got full 18 qualification for?
17 MR. DI BENEDETTOt Depending upon the criteria --
18 my came is Phil DiBenedetto, Equipment Qualification --
19 depending upon the equipment type, such as transmitters, 20 they haven't all been qualified to the highest level of 21 qualification.
The DOR guideline plans had at some time a 22 level of qualification.
But pre-1971, 323 criteria, they 23 were qualified to some extent.
They haven ' t been qualified
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24 to the full extent of the DOR guidelines.
25 They are lacking documentation.
They are lacking ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE, S.W, WA'
.3 TON, D.C. 20024 (202) 554-2345
l 10 1 perhaps the test to accomplish this.
There is a lot of 2 equipment of that type.
3 COMMISSIONER AHEARNE:
Let me try again.
My 4 question is, is there a type of equipment -- take a 5 transmitter -- that there is no manufacturer's piece of 6 equipment that has been qualified to the extent that the NBC 7 would now say yes, you have met the qualifications?
8 It sounded like, Dick, you were saying that if a 9 plant wanted to replace a piece of equipment right at the 10 moment there's no place they could go to buy one which is 11 currently qualified.
12 MR. DI BENEDETTOs That's correct.
The memorandum 13 and order the Commission put out stipulated that replacement 14 parts should be done in accordance with the Category I 15 criteria.
16 COMMISSIONER AHEARNE:
Right.
17 MR. DI BENEDETTOs To date there are none
~
18 qualified to that level.
There are quite a few pieces of 19 equipment engaged in that type of testing which may produce 20 qualification within the next six months to a year.
21 COMMISSIONER AHEARNE:
Fine.
22 CHAIRMAN PALLADIN04 You used the word "none" are 23 available.
Do you mean there are none available within a 24 certain group?
You d 'n 't mean to say none are available in 25 any category, is that right?
ALDER 3oN PEPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, O C. 20024 (202) 554-2345
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MR. DI BENEDETTO:
Within the operating plants, 2 the NTOLs, there are not very many pieces of equipment 3 qualified to the '74 standard.
We are engaged in testing, 4 not to qualify to that extent, and the first plant that has 5 to meet this is the Comanche Peak-type plant, where they 6 have to have f ull compliance with the '74 standard.
Others 7 are in a testing program, not to try to achieve that level 8 'of qualification.
9-Personally I don't know of any piece of equipment 10 qualified to the '74 standard as of that date.
11 CHAIRMAN PALLADINO:
I see. It is that extensive.
12 ER. YOLLMER:
Which is required for the 13 replacement of parts.
I But addressing again, Phil, a specific item, like 14 15 transmitters, are there transmitters that are qualified to 16 the DOR guidelines currently in operating plants?
17 MR. DI BENEDETTOs Yes, there are.
All equipmen t 18 out there has some. level of qualification.
It may not all 19 meet our level of criteria at this time.
20 MR. VOLLMER:
It is a matter of meeting the whole l
l 21 nine yards, more than being grossly deficie nt, I think.
It 22 is an oversimplification of what I said, but I'm trying to 23 characterize it the best I can.
l i
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24 COMMISSIONER BRADFORD:
When you say some level of 25 qualification you mean th a t some of it dates back to the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
o 12 1 time when the standard was simply high industrial quality or 2 some standard of that sort with very little specificity?
3 MR. VOLLMERs In sor.a cases that's true.
But most i
4 of that that was high industrial standard, cables for 5 example, many of these things have been showed to meet the 6 qualification.
7 COMMISSIONER BRADFORD Yes, but it was connectors 8 which originally met that standard, which flunked the test 9 that began. this whole process.
10 MR. VOLLMER:
Those things needed to be replaced 11 and they were done separately.
Many of the :hings we are 12 now finding not meeting the full qualification, again, for 13 replacement, we are requiring them to meet the full 14 standard, the '74 standard.
15 COMMISSIONER BRADFORD:
The only point I want to 16 make, Dick, is that things which met those early standards 17 and would f all within the terminology of still meeting some 18 standard have been shown as a practical matter not to be 19 adequate to meet what we contemplate as accident conditions.
20 MR. VOLLMERs That's right.
21 COMMISSIONER BRADFORD So it is not in all cases 22 just taking that equipment and making sure it comes up to 23 snuf f.
Some of it won't.
24 MR. DENTON:
But the converse of that is also s
1 25 true.
Just because they don't meet the umb rella total ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
13 1
1 standard does not mean they will not perform their function 2 adequately f or the time duration they have to work.
So it 3 does go both ways.
4 COMMISSIONER BRADFORD:
That's right, within the 5 spectrum.
But within th a t eighty percent some will work and 6 some will not.
And the' problem is to make sure we get to 7 where all of it will.
~
8 MR. DENTON:
And pieces which are identified where 9 the staff has a real doubt that it will do its jobs under 10 the condition it has to do it in even though it doesn't meet 11 the umbrella does lead to direct, immediate action.
So i
12 those items have been acted on as the staff finds them.
13 MR. VOLLMER:
Those ha, all been acted on.
(
14 MR. CENTONa But when they find it is not fully 15 qualified they look to see where is it loca ted, what 16 f unction does it have to serve, how long does it need to 17 remain f unctional and this sort of question.
18 COMMISSIONE'R BRADFORD:
But if I understood the 19 beginning of the presentation, up to forty percent of all of 20 the equipment is still in the staff's judgment likely to 21 have to be replaced.
22 MR. VOLLMER:
Replaced or relocated to meet the 23 full qualification.
That's right.
(
24 COMMISSIONER AHEARNE:
Since that point has been 25 reiterated several times you might be getting to it, but ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
P' 14 1 could you briefly summarize, is your judgment on it having 2 to be replaced or relocated based upon ti doubt of whether 3 any of the equipment will be qualified in time or that you 4 doubt whether the equipment will be able to be made to meet 5 the specifications?
6 MR. VOLLMER:
I think the majority of that would 7 f all in the category that it is a piece of equipment that 8 aar be semi-unique in an operating plant.
It is not being 9 manuf actured.
It would be more costly and time-consuming to 10 try to qualify that piece of equipment than it would be to 11 buy a good, qualified piece and replace it.
And it is just, 12 going back there, is such a large amount of different pieces 13 of equipment of different manuf acturers, and so on.
14 COMMISSIONER AHEARNE:
So are you saying it is not 15 because, and that you know that a piece of equipment is 16 inadequa te.
It is that you do not believe, loccing at how 17 auch it will cost to prove that it 's.adequa te, that that's 18 going to be done and the economic solution is to replace it?
19 MR. VOLLMER:
I think that's a large part of it.
20 Is Zoltan here to comment on that?
21 MR. ROSCTOCZY:
Yes.
The fifteen to forty percent 22 is basically coming from the November submittals of 23 licensees when they looked at al' of their equipment.
They
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24 decided that some of them will '.a replaced, will be 25 replaced.
It doesn't necessarily mean that it needs to be
)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 70024 (202) 554-2345
15 1 replaced.
For example, some licensees, the ones which fall 2 into the forty percent area, they look at the work, what it 3 might require to come up with some kind of a documentation 4 of the old equipment, and they decided that that might cost 5 them more money than to buy a new piece and put it in.
6 And they voluntarily replaced forty percent.
So 7 the fif teen to forty percent is a replacement they are kind 8 of con 2itted to, based upon the November 1 submittals. - The 9 rest of that, up to eighty percent, what remains, those are 10 items when they have not yet made up their mind, meaning 11 when the November 1 submittal came in they hadn 't made up 12 their mind yet.
They were outstanding at the time.
13 But we expect in the 90-day submittal, which we 14 are receiving now, we expect to hear from them to tell us 15 what are they proposing to do with the rest.
Our review 16.will either accept what they have proposed or suggest some 17 alternatives in some cases, if we think the proposal is not 18 suf ficient.
19 CHAIRMAN PALLADIN0s Dick, can I clarify a point?
20 MR. VOLLMEas Sure.
21 CHAIRMAN PALLADINO:
Earlier I thought you said 22 twenty percent of the equipment meets the umbrella 23 guiletines.
24 MR. VOLLMER:
(Nods affirmatively.)
05 CHAIRMAN PALLADIN0s And then later I thought I ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
16 1 heard that none of it meets.
2 MR. VOLLMER:
We are saying twenty percent as a 3 ballpark figure we find acceptable.
4 CHAIRMAN PALLADINO:
I was trying to get the 5 difference between twenty percent and none.
That's why when 6 Phil said none I was a little concerned.
It is 7 cont radictory to what you have.
-- 8 MR. VOLLMER Phil, do you want to clarify - the 9"none"?
10 M3. DI BENEDETTO Excuse me.
I apelogize if I 11 created a confusion.
What I meant by "none" is none met the 12 1974 323 criteria, which is the highest level of 13 qualification.
The minimum level of qualification is at 141 east the FSA commitment.
The DOE quidelinos are a bit of 15 an escalation above that.
Category 2 requirements are a bit 16 of an escalation above that, Category 1 being the top 17 guidelines.
18 The DOR guideline plans -- there's quite a bit of 10 equipment out there meeting the DOR guidelines.
There are 20 some that need additional analysis and/or testing to achieve 21 that level of compliance.
22 CHAIRMAN PALLADIN04 Are you saying they don't all
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23 have to meet the Category 1 guidelines?
24 MR. DI BENEDETTC4 That's correct, except for 25 replacement parts.
ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
l 17 1
MR. VOLLMER4 Let me summarize the whole thing 2 because I don't think you were involved in some of this in 3 the beginning.
4 CHAIRMAN PALLADINO:
No, I wasn't.
5 MR. VOLLMERs For the operating reactors, the 6 Commission memos and order said they needed equipment 7 qualified to the DDR guidelines.
The DOR guidelines are a 8 set' of requirements basically meeting IEEE 1971 objectives. -
9 And they are, let us say, if you vare to categorize them, 10 they would be the easiest qualt '.utions to make because 11 they did not have large margin requirements.
Aging and 12 radiation :ould be done by analysis and they didn 't
- require, 13 say, sequential testing for each component.
14 Going up the level now, in the NUREG Category 2 15 requirements, which are to be applied to all plants getting 16 their OL licenses -- the near-term OL licenses -- up to a CP 17 SER of July 1, 197b,whichput in perspective -- is up to 18 theCod%'an~chePeakPlant.
The guidelines would requice or 19 allow partial testing plus some analysis, but it would ask 20 for a sequential evaluation, meaning -- sequential 21 evaluation meaning that you have to consider the equipment z;is first aged.
Then it goes through seismic testing, then 23 radiation testing and then a LOCA and then containment spray.
24 In other words, the whole sequence of events which i
25 could be happening to the equipment at the end of plant ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
18 i
1 life.
We would require sequential testing.
They would 2 require aging and radiation testing and they would require 3 margins over and above the specific parameters you expect 4 just for conservatism in the testing.
5 The highest category is NUREG Category 1.
That is 6 based upon IEEE 323, 1974, standards and that would require 7 that the qualification be done completely by testing and the
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8 testing be sequential and the sequence that I-indicated, 9 that aging be done completely by testing, radiation would be 10 done by testing, and they would address any known 11 synergistic effects.
So that would be the ultimate 12 qualification.
13 Now the Commission memo and order CLI-80-21 k
14 specified that any replacement parts needed to be qualified 15 to the highest standard.
So we have come into a Catch-22 in 16 some cases, where we recognize some equipment needs to be 17 replaced, but we are requiring a high degree of standards to 18 do that replacement..
19 CHAIRMAN PALLADINO:
Doesn't Category 2 require 20 testing sequentially?
21 MR. VOLLMER:
Yes, it asks for sequential testing, 22 but it does allow for analysis in lieu of testing. -
23 CHAIRMAN PALLADINO:
I see.
24 MR. V LLMER4 And the final category does not
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25 allow the analysis in lieu of the testing.
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
19 1
COMMISSIONER GILINSKYa Where's the Catch-22?
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2 MR. VOLLMER I shouldn't have called it that.
3 It's a Catch-22, the utility could perhaps buy a somewhat
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4 better piece of equipment and replace now in the interim 5 until he finds a piece of equipment that meets the Category 61 criteria, the full guidelines, 7
But what we have said and what CLI 80-21 says is
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8 that any replacement part should meet the Category 1 9 requirements.
10 COMMISSIONER GILINSKYs That's no t a Catch-22.
11 It's just a more demanding standard.
12 MR. VOLLMERt I apologize.. Eighteen licensees 13 petitioned f or a thirteen-month extension to requirements to 14 the deadline of June 30, 19S2.
Other licensees have 15 requested hearings on staff orders based cpon timing as well 16 as sor,a technical issues.
17 Ihese requests for hearings are pending resolution 18 of the deadline issue and the staf f is working with the 19 industry to clarify the technical issues to see if they have 20 really a valid hearing issue remaining.
I think we will be 21 able to resolve these.
22 (Slide.)
23 Going on to the next slide --
(
24 CHAIRMAN PALLADIN0s You had something here.
25 Licensee 90-day response.
What does that mean?
I
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ALDERSON REDORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554<345
20 1
MR. VOLLMER:
The licensee's 90-day response was a 2 request to the licensee to provide us, af ter his receiving f
't 3 our safety evaluation report which we issued in May through 4 June of this year, to tell us more precisely what his full 5 program was to qualify all the things the staff found 6 deficient and to provide a detailed justification for 7 continued operation in light of the staff findings.
8 We have received 42 or 43 of these out of 70 or 9 so.
And at this point most licensees have been fairly 10 timely on it.
The timeliness has not run out yet.
11 CHAIRMAN PALLADINO:
But it will soon run out.
12 MR. VOLLMER:
Yes.
When you consider time for 13 them to receive it.
14 COMMISSIONER AHEARNEs Is the ninety days based 15 upon when the SER came out?
16 MR. VOLtdER:
Yes.
i 17 COMMISSIONER AHEARNE:
Then they all should run 18 out.
19 MR. VOLLMERs We give them ten days or two weeks 20 mailing both wa ys.
21 MR. MURRAYs Five days each way.
22 COMMISSIONER AHEARNEs So it's all run out.
23 MR. VOLLMER:
It's pretty well run out.
(
24 COMMISSIONER AHERRNE:
No, it's all run out.
25 MR. DENTONs We have a survey.
Apparently because ALDERSoN REPORTING CO*.I?tNY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
21 1 of the way we count days we give them more than five.
We 2 give them ten days on each end -- ten days for it to get to 3 tt-and ten days for it to get to us.
It's more like 110 4 days and it depends on when we actually mailed it.
But 5 they ' re all now expiring.
6 COMMISSIONER BRADFORD4 What do you intend to do 7 about those t:., have not responded?
~ ~ ~
~
~~
MR. DENTON:
If they haven't requested any 8
9 exemptions and haven't indicated any response at all to us to we will take appropriate action.
In this case some of them 11 have requested exemption in writing and provided the bases 12 and in that case they will be consideced, case-by-case.
13 We are right at the point now of getting all of I
14 them, again, and I don 't have a complete survey yet of who 15 has responded and what type of response they have given.
We 16 vill follow up if it's approptiate.
17 MR. VOLLMER:
That is from the licensee's 18 viewpoint.
From the technical staff's viewpoint we are 19 taking a look at them on a quick basis to see if indeed ther 20 are responsive.
I don't know if we'll have any cases 22 like the Siren case, where we didn't hear a t all, or not.
23 COMMISSIONER BR ADFORD:
Dick, what sre you 24 finding?
Are they all responsive?
g5 MR. VOLLMER:
We have had some which we have ALDERSoN RdPoRTING COMPANY,INC, 4
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-?345
22 1 looked at that have been very responsive and have provided 2 very detailed justification and analysis for equipment which 3 has not been deemed acceptable.
4 We have also had at least one that I was informed 5 of this morning which didn't provide much of an evaluation 8 and we are going to have to take a look at that in more 7 detail and see if he hasn 't provided adequate justification, 8 then work with the licenseeing people to get an adequate 9 response or take an action.
10 COMMISSIONER BRADFORD:
I perso.. ally feel it's 11 time to take a pretty hard line with those whose responses 12 are not giving you the information you need.
This is our 13 third, fourth or fif th effort to get a f ull inventory.
14 MR. VOLLMER:
Yes, and what we are really looking 15 for, as I said, is a technically solid justification for 16 continued operation in light of the deficiencies noted.
And 17 this is what we feel is important e.t this point in time.
18 Later in the presentation we are viewing 19 extensions beyond '82 or even June
'82.
We need assurance 20 that saf ety is not com promise d in the interim.
21 On the next slide we have looked at a number of 22 options, based on our own internal discussions and 23 discussions with industry, to various paths to getting the 24 job done right as f ast and efficiently as possible.
There 25 are a lot of options that we could come down on, but I think ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
23 1 this represents a reasonable population of the options.
2 These are discussed in the staff paper.
3 The first option being maintaining the 6/30/82 4 deadline, as indica ted in CLI 80-21.
We feel that based 5 upon what we know now we do not believe that any licensee 6 can fully comply with that particular date without 7 requesting some sort of an exemption.
We also feel that if 8 the date is kept we have a likelihood of hearings staring us 9 in the f ace and perhaps a stat.1 re so urce-in tensive 10 Commitment, if we do get into the hearing process, to meet 11 that.
12
_I might_ indicate up until now the staff resources 13 have been over thirty manyears put into this particular
(
14 program.
That doe's include our contractor manpower, so we 15 have put a lot of effort into it.
We have put about as much 16 as we can in light of the scarcity of people who are 17 actually experienced in this particular area.
We have just 18 about used all we could find available.
19 COMMISSIONER BRADFORDa Let me understand that.
I 20 take it that you have people who are still reviewing the 21 same issue with regard to f orthcoming licenses as well.
22 MR. VOLLMER:
That's correct.
23 COMMISSIONER BRADFORDa So you are saying you have 24 put as many people into this area as you could with mee ting
(
25 all the licensing schedules that we have to provide to the l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2340
l' f
2u 1 Congress.
2 MR. VOLLMER:
The major staff effort was 3 concentrating on the operating reactors.
We had Franklin 4 working on that with a staff.
We got our reports out and we 5 are getting 90-day responses in.
But we are not diverting a 6 great deal of --
7 COMMISSIONER BRADFORD4 I am not suggesting you 8 haven't been going at it as hard as you can.
But if, in 9 f act, the Commission had said our highest priority is 10 getting this situation fixed up in the operating plants and 11 then we will worry about processing new licenses there would 12 have been additional manhours available to you.
13 MR. VOLLMER:
We could divert more manpower from 14 that, that's right.
ka b o Z fa, bhYnn COMMISSIONER 9ILINSKY:jy(Inau v
15
&4ue.u, s;ct<aSsy hacs<J a~l w k th 16 MR. DENION:
We have two contractors now.
We have 17 tended to give Franklin all the operating reactor reviews 18 and we intend to give EGEG more of the reviews.
19 MR. VOLLMER:
Franklin now has ten people working 20 fulltime on it.
21 MR. DENION:
Staf f oversees these two ef forts.
j 22 COMMISSIONER GILINSKY:
Is it a shortage of 23 overseers or a shortage of contractor employees or a 24 shortage of funds?
25 MR. YOLLMER:
I think a shortage of people who are ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
~
25 1 qualified.
2 COMMISSIONER GILINSKY:
For Franklin or within the 3 NBC?
4 3R. ROSCTOCZY:
Recently we had discussions with 5 Franklin in terms of the re view of the 90-day submittals.
6 We have given them the first, what we have received.
So 7 they had a chance to look at at least a few of them.
Then 8 ve sat down to see what could be done and how fast they' s could be reviewed.
And then we explored with them all of 10 the possibilities of how this could be accelerated.
11 So this is basically the operating draf t program.
12 We have about ten people who have been working for us in 13 terms of the November reviews and then some followup on this 14 and ther proposed a list to continue with the ten people.
i 15 Doing it with ten people their present estimate is ther 16 could complete the review by September of next year.
So it 17 would be approxima tely a 12 -mon th revie w.
18 And we asked them about the possibility, and we 19 discussed the possibility, of accelerating it.
Maybe ten 20 people would be working in two groups of five in each group.
21 to accelerate it to include more people.
And the response 22 was that they really don't have trained _ people.
They would 23 have to train them during the process and the value, what 24 would come back f rom it, would not be proportional with the 25 number of manhours that would have to be put into it.
So ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
26 A
1 their recommendation is.to go at this speed, but if there 2 were more trained people svailable it could be done faster.
3 Another possibility is to.iaybe handle the review i
4 differently -- don't review every submittal but instead 5 maybe have a meeting with each of the licensees and let them 6present to us all the information they have and based on 7 that meeting make a judgment of whether it is acceptable or 8 not, the program they have going on, which could accelerate 9 the process somewha t.
10 In terms of the near term those are being handled 11 by the staff, by my branch, with help from Idaho.
And they 12 are rather busy keeping u9 with that load.
But we feel we 13 can confidently handle that load continuously, so there will 14 be no delay because of the availability of staff in terms of 15 the licensing proposals.
16 MR. YOLLMER:
So clearly the revie; on the 17 operating plants could be shortened by dumping all the 18 resources we have currently, trained people, to the 19 operating reactors.
20 COMMISSIONER GILINSKY:
I'm still surprised that 21 Franklin can't expand the number of people involved.
I 22 sean, there must be people who are acquainted with these 23 problems outside of Franklin.
24 MR. VOLLMER:
One thing that I know has occurred s
25 from our own personal experience, the industry is hiring ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
27 e"
1 people away.
I 'magine Franklin ha the same problem 2 finding qualified people as we do.
We have lost people in 3 this area and I erpect we will continue to.
4 The industry is aggressively trying to marshall 5their own resources to meet the problem.
6 MR. DENTON:
Part of it comes, too, from our way 7 of setting dates, where all of the information comes in from
~~
8 sev'enty licensees on the same date.
It makes a short-term 9 intensive program.
If we could find a way to space out work 10 so that a given group of people could work longer -- we tend 11 to create these peaks and valleys in our work load and that 12 gives the contractors problems with hiring up.
13 COMMISSIONER GILINSKY:
We've spaced this one out
(
14 pretty well.
15 MR. DENTON:
There are a lot of peaks and valleys 16 and it still -
17 CHAIRMAN PALLADINO:
If this were the only one 18 that might be work,.but we have others as well.
19 MR. VOLLMER:
Keeping the dates the same would put 20 maximum pressure on the industry to complete this job.
We 21 believe, obviously, this would be most resource-intensive 22 from both points, and it's questienable.
It is a matter of 23 dudgment whether or not there are really enough qualified 24 people out there to get the job done adequately.
25 One thing I would mention is, in the case of the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (20.') 554 2345
28 1 testing laboratories, they are not the holdup to this whole 2 situation.
The tasting labcritories, when I talked to them 3 in July, indicates that they were running at thirty or forty 4 percent of capacity.
So they are not the ones who are 5 holding it up.
6 I think it is the reluctance for industry to put 7 stuff into the testing laboratories.
It is two-fold.
- One, 8 they are looking for our last word of guidance before they 9 commit money and resources into the te sting programs, which 10 I don 't think is entirely appropriate -- in some cases yes, 11 in some cases no.
12 I think also they are concerned about testing old
- 13. equipment in their plant because they either can't find a i
14 similar piece of equipment to test and they can't take it 15 out of their plant to do so.
It just does not appear to be la a viable way of testing.
So they would rather wait until a 17 piece of equipment is qualified and replace on that basis.
18 The second option is extend the deadline for the 19 Year and allow the licensees to request exemptian beyond 20 that time for good cause shown.
21 COMMISSIONER GILINSKY.
Beyond 6/83?
22 MR. VOLLMER:
Beyond 6/83.
The reason -- there's 23 nothing magical about that date, of course, except that we 24 estimate that eighty or so percent of the equipment could be 25 shown to be qualified by that date, which would leave a ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
29 1 limited number of specific items that could be addressed and 2 focused on by the staff and industry to achieve full 3 complianca.
4 We think between now and June of '83 much of the 5 equipment could be shown to be qualified by verification or 8by similarity or previous testing or relocated, and much of 7 that work could probably be done without incurring a
~ 8 specific plant shutdown.
9 CHAIRMAN PALLADINO:
Why did you pick the 6/30/83
'10 d at e ?
That wasn't the one they petitioned, was it?
11 ER. VOLLMER:
It was sort of close.
There is no 12 real good reason for that.
It was just a one-year 13 extension.
I would characterize it as being nothing more 14 tha n that.
15 CHAIRMAN PALLADINO:
Do we have evidence that with e
16that year's extension we could actually accommodate?
17 HR. VOLLMER:
We think a lot could be accomplished 18 within the year.
We think within the year the staff could 19 better f ocus on the remaining pieces of equipment that need 20 to be identified.
We could allow the industry to use the 21 results of our SERs to achieve qua'ification by analysis, by 22 retesting, relocation or replacement of a large fraction of 23 the equipment -- around eighty percent.
And I don't think 24 that could be done between now and June of
'82.
\\.-
25 I think we would need enough time f or them to A1.DERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
i 30 1 digest and for us to digest their reports and to go back and 2 communicate with them as to what we see as the best solution 3 to some of their problems.
We know that the testing in 4 progress in some cases cannot be complete until then.
5 CHAIRMAN PALLADINO:
If some of the testing can't 6 he complete until that time then how can they comply?
7 MR. VOLLMER:
Some testing is ongoing.
Som:
8 equipment is currently being replaced and so on.
It is 9 true, as I. indicated before, that some testing of equipment 10 is not expected to be done until mid ' 82.
And, clearly, 11 that if 'the plants were to use that equipment, that ther 12 would have to ask for an exemption or something to allow 13 continued operation, because we are going to have
(
14 procurement lead times and things like that.
There would be 15 a real rush on equipment.
16 MR. DENTON:
The more I have looked at dates the 17 more attractive I find some sort of staging of dates, with a 18 docket number or some other characteristic of the plant, so 1g that they don 't all come due on the same day.
Tha t creates 20 a very big work load for the staff and industry to meet an 21 artificial date like June 30 or January 1, and it would be 22 easier to schedule it after a given date.
23 So that would give sort of an even spacing so we 24 would have a more continuous work flow.
To pick a given s
25 date applying to all plants in the country creates a 4
ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W,. WASHINGTON, D.C. 20024 (202) 554-2345
n 31 1 tremendous impact.
2 COMMISSIONER AHEARNE:
Do you expect a majority of 3 this insula tion is going to require the kind of outage that
.4 comes with refueling?
Or will some large f raction be able 5 to replace short-term?
6 MR. VOLLMERa We estimate more than one, but not 7 acre than two ref ueling outages typically would be capable
' 8 of accommoda ting.
~
~'
9 COMMISSIONER AHEARNE:
I'm sure it would be 10 capab10 of it.
That wasn't my question.
It would be 11 required to.
That?s a long period, two refueling outages.
12 3R. VOLLMER:
The time of two ref uelins outages, I 13 am saying, would be sufficient, to the best v3 can tell.
14 Phil ma y want to comment on it more.
It would very 15 difficult or impossible to do it in strict time sequence.
16 MR. DENTON:
The answer is, it's very likely to 17 cause an outage if it's as extensive as we are talking 18 about.
We wouldn't want it done during operation.
It gets 19 to be too complicated. It depends upon the extent of change.
20 My guess would be it would require an outage to 21 accomplish the kinds of changes we foresee.
22 COMMISSIONER AHEARNE:
But there are a lot of 23 outages tha t occur between a refueling outage.
If you say 24 You will take two refueling outages, that seems to be a long
(
25 time.
I ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASH:NGToN, D.C. 20024 (202) 554 2345
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32 1
MR. VOLLMER:
What we were thinking of is the type 2 of tooling we did on Appendix R, which, after the staff 3 approval of cpecific items, they would be given a certain
'4 amount.of time and then the next ref ueling outage.
There 5 were also provisions in there for interim outages that might 6 occur.
7 MR. ROSCTOCZYa Mr. Ahearne, we would expect that 8 the time needed for actual accomplishment would be very 9 strongly plant-dependent, in some cases.
For example, if a to certain cable type is unacceptable and has to be replaced it 11 could require a lot of time and it shows up as a single 12 equipment type on our list.
So it's a very low percentage, 13 but nevertheless it could require a lot of time.
14 Overall, the opinion we received was that the 15 expectation, those who are replacing a fair amount, their 16 expectation is that one ref ueling outage, if it goes full 17 speed, the refueling outage would probably not be enough to 18 do the job.
19 At the same time we expect that there are other 20 plants where just because of the type of equipment that 21 needs to be replaced it probably can be done in one.
There 22 is also the time delay which was mentioned earlier, that 23 some equipment is still not available in the fully qualified 24 manner.
In the first refueling outage, for example, next 25 year, not all the equipment will be available and, ALDERSoN REPORTING COMPANY,INC.
j 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) $54 2345
33 1 therefore, part of it would have to be done at a later date 2 either by a special outage or two to accomplish this.
3 CHAIRMAN PALLADIN0s When there changes have been 4 made will this have satisfied the equipment qualification 5 once and for all, or is this an interim measure?
Have you 6 set forth what you finally want?
7 MR. VOLLMER:
This would qualify them for the
~~'
8 operating plants.
Their replacement parts would have to 9 aeet the full nine yards of qualification.
10 CHAIRMAN PALLADINO:
If they have to replace any 11 parts.
12 NB. VOLLMER:
That's right.
But hopefully by tha t 13 time one would be able to have an inventory of parts that 14 were qua'ified.
Industry is working on data banks to make 15 sure that they do have general replacement equipment that is 16 qualified.
17 CHAIRMAN PALLADINO:
The reason I ask is I have 18 seen several letters f rom utilities complaining about our 19 use of. uterim requirements where they have to spend quite a 20 bit of r.oney and then final requirements come out which may 21 be differen t.
22 I am just wondering to what extent that complaint 23 applied to this problem.
24 MR. VOLLHER:
The problem there, I think, more 25 specifically is in the IEEE standards as well as the NRC ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554 2345
-34 i
1 requirements.
The subject of seismic qualification of 2 equipment is part of the overall qualification.
We would 3 hope that when we get around to addressing the seismic f
4 qualification of the electrical equipment that we are 5 currently addressing in the environmental sense that we 6 would not get into another go-around of necessary 7 requalification.
~
We would hope it would be very l'imited..
~
8 9
CHAIRMAN PALLADINO:
In other words, we are not 10 addressing the seismic cr.alifications?.
11 MR. YOLLMER:
No, this is electrical equipment in 12 harsh _ accident environments.
13 MR. DIRCKS:
There is some discussion about the 14 seismic qualification of electrical equipment.
I think that 15 is something we vill have to address before the rule comes 16 down.
17 CHAIRMAN PILLi.DINO:
I'm also a bit concerned.
18 Every time you go into the plant and start to fiddle around 19 with connections and cables you may introduce flaws that you 20 don 't identify right away and that could give us as much 21 problem as some other things that could take place in a 22 plant.
23 I'm sorry.
24 COMMISSIONER BRADFORD:
If the extension were 25 granted is there any possibility of including the seismic ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) 554-2345
35 1 qualification standard as part of the replacement 2 requirements?
3 MR. DENTON:
I guess I see seismic as a bigger 4 potential issue.
Some people see -- it depends on how it is 5 done, what standard do we require.
Some people think the 6 main problem in seismic for equipment is the support of that 7 equipment, being sure it is properly tied down.
That could 8 be reviewed one way.
9 If, in fact, the equipment has to be demonstrated 10 by analysis of test, most of the same equipment has never 11 been subjected to the kind of three access analysis we would 12 require today.
n COMMISSIONER AHEARNE:
Much less test.
14 MR. DENTON:
Or test.
Tha t's right.
15 MR. VOLLMERs Again, as Harold is saying, it 18 depends on the type of analysis.
Much of the similar 17 equipment has operated through major earthquakes and power 18 plants, not necessarily nuclear plants, and so an analysis 19 DY similarity plus certain testing could demonstrate, 20 likely, that a lot of it is adequa tely qualified, 21 particularly if it is tied down.
22 So the staff would look toward a mechanism getting 23 into seismic qualification to not redo the whole job over i
24 again.
(
25 MR. DENTON:
There are examples of power plants in ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554-2345
36 1 Managua which went right back on line very quickly very 2 close to faults and the equipment had no special 3 qualification.
And I guess the industry's view is, in 4 looking at this, that equipment tends to fail because of 5 lack of suppsrt.
We don't yet have a position on what we 6 would accept on old equipacnt.
7 And if you push all of the way back to analysis 8 and testing, again, there is very little equipment out there 9 today which has been shown analytically to survive, although 10 that is in conflict with observation, where a great deal of 11 it survives.
12 The main concerns which have been identified are 13 ceramics, which are very prone to failure,. and things like i
14 battery racks where it's very important tha t they be 15 properly supported and tied down.
16 How to approach equipment in genera-1 for old 17 plants?
We have an approach for new plants, but we haven't 18 quite come to agree. on how to approach equipment in plants 19 which have been there for twenty years.
20 MR. VOLLMER4 But to again address the question 21 more specifically, if we were to include seismic as a part 22 of this package I think we would have to step back and take 23 a look at the staff criteria, develop staff criteria, and 14 probably go out with a rule for public comment and take a 25 broader look at the whole picture before we would come down ALCERSON REPORTING COMPANY,INC, 400 VIRCINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 i
l
37 1 on data.
2 I don't think that we could say that extending 3 this a year we could fold in the seismic qualification too.
4 I couldn 't answer that right now.
5 MR. DENTON:
The SEP plants have agreed to make a 6 proposal in the - next couple of weeks as to how they would 7 approach this in their plants.
~
~
C::AI? MAN PALLADINO:
Which plants?
8 9
MR. DEllr0N :
The eleven oldest plants are looking to at this as an owners' group and are due to'make a proposal 111n this area.
12 CHAIRMAN PALLADINO:
Are there,any other issues?
13 This is environmental qualification and you get seismic 14 qualifications.
Will there be others?
15 MR. DENTON:
Dynamics will go for low-down loads 16 and things like that.
17 MR. VOLLMER:
The same thing for mechanical 18 equipment -- seismic, environmental and dynamic.
19 CHAIRMAN PALLADINO:
This is just electrical?
20 MR. VOLLMER:
Tha t's right.
21 COMMISSIONER AHEARNE:
You predicate your one-year 22 extension on the conclusion that eighty percent of the 23 equipmen t will then end up being qualified.
This is i
24 qualilled to the Category 1 criteria?
25 MR. VOLLMER:
No, qualified to whatever that plant ALDERSON REPORTINJ COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
38 1 requires.
2 COMMISSIONER AHEARNE:
In th a t eighty percent is 3 there an assumption that some of that will have to be 4 qualified to Category 1?
In other words, are you assuming 51n a year you will aave some --
6 MR. VOLLM?,Es Yes, because we estimate in some 7 cases they will replace a fair fraction.
They are already 8 committed to do that.
9 COMMISSIONER AHEARNE:
From what we have earlier 10 heard there is so f ar no equipment qualified in Cateogry 1.
11 M8. VOLLMER:
I don't believe so.
12 MR. ROSCTOCZY Let me try to clarify th a t.
The 13 question Phil was answering was specifically. the 14 transmitters.
So that's one type of equipment out of maybe 15 100 types.
And the transmitters were given as an example 16 th a t there were no transmitters qualified to the new 17 standards at th'e present time in the marketplace.
18 CHAIRMAN PALLADINO:
I didn't understand it that 19 var.
That's why I came back to ask the question again.
20 MR. ROSCTOCZY:
That's why I am trying to clarity 21 1t.
That answer was relating to transmitters.
There are no 22 equipnent qualified for the Category 1 requirement on the 23 market list today, but there are other equipment types.
24 Most of the equipment types do have equipment available 25 today on the market.
ALDERSON REPORTING COMPANY. INC.
400 VIRGINlA AVE., S.W., WASHINGTON o.C. 20024 (202) 554-2345
39 1
COMMISSIONER AHEARNEs Qualified to Category 1?
2 MR. ROSCTOCZYa Qualified to Category 1.
3 HR. VOLLMER:
That's why the replacement program 4 vill achieve something by June of
'83.
5 CHAIRMAN PALLADINO:
I would like to trace that a 611ttle bit more -- true or f alse?
7 (Laughter.)
8 CHAIRMAN PALLADIN0s I am just not clear nov 9 because I have heard several answers.
One, true or false, 10 th'ere are items of electrical equipment which have been 11 qualified to Category 1?
12 MR. VOLLMER4 That's true.
13 MR. ROSCTOCZYs That's true.
~
14 MR. DI BENEDETTO:
Yes, that is true.
We have 15 specific examples.
There are switches and solenoid valves 16 that have been qualified to the Category 1 criteria.
17 When I spoke last we were talking transmitters.
18 There are quite a few involved in testing but none qualified 19 to Categry 1 at this time.
20 MR. VOLLMER:
Conversely, there are equipment 21 types in which we don't see any types from any manufacturer 22 which are qualified, and I think that is what we thought we 23 were answering before.
24 CHAIRMAN PALLADINO:
Could I ask another 25 question ?
Suppose no matter what date you pick a plant ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
l 40 1 meets the requirement and then a couple of days later 2 somethina goes wrong and they have to replace an item?
They 3 do have to replace it with a Category 1, is that correct?
4 Presumably the one that failed was not Category 1.
5 MB. VOLLMER:
That's correct.
6 MR. ROSCTOCZY There is a modification af ter that 7 sentence, which is taken directly from the Commission order, 8 which says unless there is some good reason to the 9 contrary.
So normally we would expect them to replace it 10 with something qualified to Category 1,
but if they've a 11 good reason not to do that they are permitted not to do it.
12 They have to document it and keep the documentation in their 13 file.
14 CHAIRMAN PALLADINO:
What I was leading to is 15 almost any date we picked would require that every component 16 have a Category 1 qualification available.
17 COMMISSIONER AHEARNE:
(Nods in the negative.)
18 CHAIREAN PALLADIN0s No.
I say if you don't have 19 tha t escape clause.
20 MR. VOLLMER:
Oh, yes, yes.
21 CHAIRMAN PALLADINO Because --
22 COMMISSIONER AHEARNE:
Unless you could prove.
23 MR. VOLLMER:
You see, the operating class can 24 sho w --
25 CHAIRMAN PALLADINO:
No.
I am going on the basis ALDERSoN REPORTING COMPANY. INC.
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41 1 they get to a point, and there undoubtedly will be some 2 f ailure of equipment and you need a replacement and the only 3 thing you can replace it with is a Category 1.
4 MR. VOLLMER:
If it's available.
5 CHAIRMAN PALLADINO:
That says the Category 1 0 items better all be available at about that time.
7 HR. DIRCKS:
Except if a transmitter failed today 8 I gather you would not.
9 CHAIRMAN PALLADINO:
Yes.
10 MR. VOLLMER:
0,n the extension of the date we 11 would expect, then, that the licensee by June of ' 8 3 wo uld 12 be able to come in with specific exemptions.for specific 13 pieces of equipment, showing in reasonable detail what his 14 program is to achieve compliance.
And we would expect to 15 look at that and expect to look at his program for 16 installation -- what outages he would use and so on -- and 17 do a staff evaluation and finding that in our judgment this 18 is the most expeditious vay that he can find to meet our 19 requirements.
20 And then and only then would we grant an exemption.
21 CHAIRMAN PALLADINO:
So the 6/30 date is really 22 not an absolutely firm date.
23 MR. VOLLMER:
It vould require an exemption, 24 depending on how the thing was characterired by rule or 25 order.
But in any event it would require some sort of ALDERSoN REPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554 2345
42 1 licensee request and a staff action to extend beyond that 2 date.
3 One sort of alternate to that would be the third 4 option, extending to the second refueling outage after 5 January 1,
'82.
This would spread out the deadline.
If you 6 go a year-and-a-half af ter that it vould spread out the 7 deadline something between mid '82 or mid'83 as being the 8 earliest completion date and, well, at the end-of '84 being 9 the latest completion date.
10 CHAIRMAN PALLADINO:
Do any of these plants have 11 any of their so-called first refueling between 1/1/82 and 12 6/3b/82?
13 MB. VOLLMER:
I'm sure there will be.
i 14 CHAIRMAN PALLADINO Do you think they would have 15 an opportunity to use that for some of the changeovers 16 needed?
17 HR. VOLLMER:
I would think so, yes.
And I would 18 hope in the programs we are getting -- the 90-day submittals 19 -- they will be pointing out to us that they will be 20 replacing in the next ref ueling outages wha tever equipment 21 is indeed qualified.
That's part of what we have asked for 22 in the 90-day responses and I would hope if the licensee is 23 doing his job in the period between now and '83 he wi.
take 24 advantage of his refueling outages to replace or relocate 25 deficient equipmen t.
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COMMISSIONER BRADFORD:
How long are you assuming 2 that a refueling outage takes when you say it would take two 3 outages foc most plants?
4 MR. YOLLMER:
I think we are working to 45 to 5 sixty days.
6 MR. ROSCTOCZY Forty-five days to two months.
7 And considering that during the refueling outage not 8 necessarily the whole plant is freely available for the
~
9 people who would be working on this.
10 COMMISSIONER BRADFORD:
It sounds more like two 11 outages has to do with having two separate periods of time 12 than it does with two months being an insufficient period of 13 time to do all of the work.
14 MR. VOLLMER:
Some of both.
It's spreading out 15 th e tim e.
16 COMMISSIONER BRADFORD:
Didn't your filing with us 17 say it v uld typically take about a two-month period of time 18 to compli this?
ROSCTOCZY Yes.
There is certainly a little 19 20 bit of both '.here.
It is almost certain that those who 21 would be ref ling early would not have all of the equipment 22 available.
i 7se who would be on the end of the schedule 23 mig h t ge t a ist closer to it.
And then, depending on what 24 type of equipment has to be replaced in a plant, the time 25 might or might not be enough.
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i 44 1
CHAIRMAN PALLADINO:
Also, each outage may have 2 other things that might need to be done.
3 MR. ROSCTOCZYs Yes.
4 MR. VOLLMER:
What this would do, assuming that 5 some plants had their first refueling outage, if you vent 6 this way, early in '82 and their second one typically would 7 be mid ' 83.
So those plants would f ortunately or 8 unfortunately fall at the time when we know or strongly feel 9 that equipment won't be fully qualified anyway.
So they 10 would have to apply for exemptions.
11 So in any event this option would also require, 12 lik ely, the request for exemption.
Both this and option 13 number two, we feel, are, if I cCuld characterize them as 14 moderate staf f resources.
In other words, we think with the 15 resources we have now and the licensing tasks and other 16 areas we are involving ourselves with in the program plan 17 and so on that we would have the resources to handle this 18 type of scanario.
19 CHAIRMAN PALLADINO:
There's a certain 20 attractiveness to this from the standpoint of NRC resources, 21 that you spread it over a period of time, the amount of 22 effort you need.
It certainly doesn't give any plant any 23 more problem than another. I'm wondering what's wrong with 24 it.
There must be something wrong with it.
25 MR. VOLLMER:
I will give my answer and then I ALDERSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE S/N., WASHINGTON. O C. 20024 (202) 554 2345
45 1 think Harold is ready to give his, and it may be different.
2 My view is that we have carried the procedure 3 along up to this point, meeting with the licensees in large 4 seatings trying to address the problems as they come up and 5 so on.
I think I would like s: try to keep the momentum 6 going, keep the date which we apply to be a fixed end date.
7 It seems to me it would give more incentive to get the job 8 done es early as possible.
9 You can make arguments both wais, but that is how 10 I look a t it.
11 CHAIRMAN PALLADINO:
The attractiveness also comes 12 about from the fact that no matter what date you pick the 13 applicant or the licensee has to have some shutdown in order k
14 to accomplish it.
So why isn't it right to talk in terms of 15 a shutdown?
You won't get them all to do it on the 30th of 16 June.
17 HR. VOLLMER:
No, but I think when they ask for an 18 exemption to a specific date picked that would be a part of Ig the request, that it meets an appropriate shutdown.
20 CHAIRMAN PALLADINO:
'4 h a t you are really saying 21 when you picked the 6/30/83 date is that you have to get it 22 done in a shutdown coming before 6/30/83.
23 MR. VOLLMER:
For those items requiring shutdown 24 we would sort of use the appendix to our approach.
CHAIRMAN PALLADINO:
Are there some items which 25 ALDERSON REPORTING COMPANY,INC.
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46 1 don't require shutdown?
2 MR. VOLLMER:
Yes.
3 CHAIRMAN PALLADIN04 Like what?
4 MR. VOLLMER:
It depends.
I mean, there are 5 pieces of equipment which can be replaced in containment, 6 which are accessible in containment.
7 CHAIRMAN PALLADIN0s Do you mean.you would make 8 the changes while the plant is operating? -
9 MR. VOLLMER In some cases it could be done and 10 in some cases it could not.
Really it depends upon the 11 piace of equipment.
12 MR. DENION:
I am concerned about making too many 13 changes while the plant is operating because then you have k
14 problems with operator training.
15 CHAIRMAN PALLADIN0s I would be worried to do tc0 16 many.
17 MR. DENTON4 We have asked some plants recently to 18 look at all of the changes we have required as package and 19 tell us which ones they would propose to do during certain 20 outages rather than looking just in isolation on an isolated 21 date to try to get all of this work together.
22 CHAIRMAN PALLADINO:
I am concerned.
If we don't 23 schedule it, relate the timetable to outages, you are going 24 to be constantly in a position of having to examine 25 petitions to got it into an outage.
If tha t 's the posture ALDERSoN REPORTING CCMPANY,INC.
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47 1 ve're going to be in why "en't we just accept something 2 based on that.
3 MR. DENTON:
I prefer the outages.
The only 4 drawback is it extends the date for some applicants longer 5 than a hard and f ast date.
6 CHAIRMAN PALLADINO:
But my argument is that is 7 probably what would ensue anyhow.
8 MR. VOLLMER, Do we know what f raction-would 9 require shutdowns in all likelihood?
I know it's to plant-specific, but could you give us an estimate?
l 11 HR. DI BENEDETTO:
Depending upon the equipment 12 the majority. of the equipment you put in would require a l
13 shutdown simply because when you install a piece of
(
14 equipment you have to functionally test it in particular 15 transmitters.
It may be perfectly viable to install a 1
16 transmitter while the plant is operating.
However, to 17 ensure f unctionality and operability you must shut down the 18 plant to do the calibration testing and the. winding up.
j 19 So a majority of the equipment would require some p !
l#
20 type of a shutdown, the extent of which is up to the utility l
21 to determine.
There are some pieces of equipment, such as 22 solenoids and switches, which can be installed and can l
23 probably be checked without interrupting the operation of l
j4 the plant.
25 COMMISSIONER GILINSKYs But it's a rare plant that ALCERSON REPCRTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
j' C,.
48 1 doesn't have any. outages except for ref ueling.
2 MR. DI BENEDETTOs That's correct.
There are 3 always times when they are down where a piece of equipment 4 could be done.
5 CHAIRMAN PALLADINO:
But then you have to be
' 6 Drepared.
In other words, just because an outage occurs t
7 d,oe sn ' t mean --
1 8
MR. DI BENEDETTO:
And that'.S extremely dependent 9 upon the availability of the equipment.
10 CHAIRMAN PALLADINO:
And your crew's ready to go, 11 the procedure is ready, and you would be prepared to take 12 the time necessary for checkout.
13 MR. DI BENEDETTO:
Yes, sir.
14 CHAIRMAN PALLADINO:
So it doesn't necessarily 15 follow you could take adve atage of every shutdown.
16 MR. VOLLMER.
Ok'f.
If I may, finally, the fourth 17 option we did consida-y4a -o qualify most equipment by June 18 o f
'83.
This is sort o f a.,
industry proposal with complete s
19 qualification by November 30, 'es, Licensees would commit 20 to demonstrate that most of the equipment was qualified by 21 ' 8 3 by su6mittal.
And they would provide a program for 22' items no t meeting these qualifications.
23 Inis would eat up the least resources as far,as we 24 are concerned.
The problem we have with it is it would 25 really -- the industry would be defining the basis for ALDERSoN REPORT NG CCMPANY, INC, 400 VIRGINIA AVE., S.W., W ASHINGTCN. D.C. 20024 (202) 554 2345
49 1 extensions beyond whatever the fixed deadline, say June of 2 ' 83, was.
The staff would have no input as to whether or 3 not there was a good cause for those extensions.
4 CHAIRMAN PALLADINO:
Do they identify what most 5 are?
6 HR. YOLLMER:
Their petitions said "most" was in 7 the order of eighty percent also.
So we are thinking along 8the same lines.
Wu view the eighty percent as a reasonable 9 number by S/83.
10 CHAIRMAN PALLADINO:
Would this be plant-specific, 111n other words, eighty percent in each plant?
12 MR. YOLLME5s I think it would be plant-specific.
13 At some plants there would be a higher level of compliance 14 because of availability of a certain piece of equipment.
15 COMMISSIONER GILINSKYa How does that differ from 16 the first proposal?
17 MR. VOLLMER4 The first one was maintaining the 18 June 30, '82 leadlines.
19 COMMISSIONER GILINSKYa I'm sorry, the second one.
20 MR. VOLLMER:
It's really different from the 21 second one in that the licensees would be required to come 22 in and ask fer exemptions or extensions based upon good 23 cause.
We consider good cause as being a showing of a good 24 program toward meeting the final objectives.
25 COMMISSIONER GILINSKY:
What is it they propose to ALDERSoN REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554 2345
50 a
1do by 6/30/83, then?
2 MR. VOLLMER What they propose to do by 6/30/83 3 is you will get everything to generally say they have j
4 qualified most of their equipment but only tell us what th e y 5 vill be doing to achieve qualifications by the date of 6 November '85, and staff would not have the opportunity by 7 this particular option, if fulfilled, of saying that we
~
~ 8 don't think this is adequate.
9 COMMISSIONER GILINSKYs It really means waiting 10 until
'85.
11 MR. VOLLMER:
That's right.
I am assuming in most 12 cases good licensees program will -- there shouldn't be any 13 dif ference in the sense, you could say, if everyone was 14 applying the maximum efforts.
There wouldn 't be any 15 difference except for the formality of the staff seeing.the 16 exemption requests and reviewing them.
17 CHAIRMAN PALLADINO:
I understand Commissioner 18 Bradford has a slightly different version.
Will you discuss 19 that?
20 COMMISSIONER BRADFORD:
It's in the slide.
But 21 before we go on to tha t can we talk a little bit about the 22 techniques of extension besides why the staff is comfortable 23 going beyond June 30 of '82?
I just say that I read through 24 the list of items in the UCS petition that were affected at
[
25 TMI Unit 1 -- emergency core cooling, core flood, l
l i
i ALDERSoN REPORTING CCMPANY. INC, I
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53 E'
1 containment spray, containment isolation and others.
2 If there is doubt that those types of things might l
3 function in an accident condition it seens to me we need 4 pretty specific and well reasoned justifica tion to tolerate 5 it at all.
6 MR. YO113ER:
We have done -- the review process 7 has been two-stage.
The first stage was for identification 8 of the equipment and identification of specific pieces of 9 equipment that would call for immediate action because you 10 would see f ailure of that equipment would threaten the safe 11 reactor shutdown.
Tha t part, I think, has been f ulfilled by 12 our initial staff review and the licensees' review.
13 We have now identified all of the things where the 14 qualification is not complete and we have asked the 15 licensee, an I said, for a detailed justification in all 16 cases why f ailure of a given piece of equipment sill not 17 threaten the reactor.
18 We feel we are supposed to be getting these in the 19 90-day responses, the detailed justification.
We have 20 reviewed some of the submittals and indeed the licensee has 21 gone and picked a piece of equipment which is not qualified 22 and taken a look at how does it fail, how could it affect 23 oth er equipmen t, and this is why either it is not needed to 24 function in the environment, in the timeliness of the 25 environment it sees, or there is something else that is ALDERSoN REPORTING CCMPANY,INC, 400 VIRGlNIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
52 1 qualified tha t can meet the needs of that equipment.
And 2 then he would have to procedurally instruct his operators 3 that if such-and-such happens and if this equipment does 4 f ail you would have to use an alternate route.
5 So we feel we snould have, at this point in time, 6 a detailed evaluation of safe operation.
If we don 't have 7 it I think we need immediate action and replacement or 8 relocation of equipment identified that precludes that.
9 COMMISSIONER BRADf0RD:
But aren't you in a 10 position of recommending a set of deadline options 11 conceptually without having had a chance to review the 12 justifications for many of the plants that would underlie 13 them?
14 In fact, let me just ask one other part of that 15 question.
The 90-day responses, I take it, were geared to 16 the June 30, '82 date.
17 MR. VOLLMER:
Tha t 's right.
18 COMMISSIONER BRADFORD:
So that in any case they 19 don 't address the introduction of an extra year into the 20 pro cess.
21 MR. VOLLMER:
That's right.
COMMISSIONER AHEARNE:
Unless they were in the 22 23 answers, as Harold said.
Some of them may have already 24 requested a waiver.
25 COMMISSIONER BRADFORD:
I take it the staff can ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE
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53 1 review it in that additional year.
2 HR. VOLLMER:
Tw'o things.
One is it is true, the 3 staff has not done an independent analysis of if a given 4 piece of equipment fails what happens.
So from that 5 standpoint, to the extent that the staff has reviewed these 6 plans and in some cases, particularly in near-term OLs, some 7 of which ware built a fairly long time ago, we have done 8 detailed reviews in f ailure mode and effects. analysis and so 9 on and have satisfied ourselves that indeed failure of that 10 equipment which is not qualified does not threaten the 11 saf ety of the plant and plant shutdown.
12 But it is certainly true that if the staff were 13 obligated to go through each of these reviews.ourselves, 14 which the licensee is supposed to put on, we really aren't 15 there yet.
16 HR. DENTON:
I think it goes to the level of 17 confidence licensees will be asserting in these replies of 18 90 days tha t the plant is safe to operate for these various 19 reasons, even though they don' t need the umbrella standard.
20 We were going to audit that process but not look behind each 21 and every one.
22 Really there would be less change of the equipment 23 failing if it were all qualified to the umbrella than if you 24 look at it on the detailed piece-by-piece basis.
But next 25 spring we will have reviewed and our contractors will have ALDERSON REPORTING COMPANY. INC.
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g#
e.
1 reviewed all of these 90-day responses and if there are any 2 areas we don't think that situation still holds and the 3 plant is safe to operate we would require changes.
4 So in a sense the time after that period is the f
5 time required to acquire a fully-qualified piece of I
6 equipmen t.
7 MR. VOLLMER:
It certainly seems like a long time l
8.getting there and it is.
But there's an awf ul lot of 9 equipment.
10 CHAIRMAN PALLADIN04 It all cones down to the 11 question of conflicts, because you may have equipment there l
12 that will eventually become Category 1.
So this gives you a 13 conflict, but that doesn't mean items in 2 won't v.ithst and 14 the action.
So it's always a question of conflicts.
15 MR. DENION:
That's right.
16 COMMISSIONER BRADFORD4 Yes, except I take it we 17 have said our confidence will be up once they have been
- 18. reached.
19 CHAIRMAN PALLADINO:
Yes.
20 COMMISSIONER BRADFORD4 The point you just made 21 may be a f airly good lead-in to the suggestion I have made 22 that even if some deferrals are in order we ought to at 23 least, by June of next year, have taken the uncertainty out 24 of the process of just what it is that's going to be 25 replaced and what it is that can remain.
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55 I
x 1
MR. DENTON:
We have that as the last slide.
2 MR. VOLLMER:
I think we can get there quickly.
3 (Slide.)
4 The naxt slide, which we have altesdy discussed, 5 is the staff recommendation and I want to focus only on the 6 conditions for extensions that we felt were important, that 7 it be timely filed, that they really show good faith for
' 8' qualification.
In other words, th ey have a testing program
~
9 and they are doing something.
10 The implementation, then, of any possible e extension, which we haven't touched on yet and maybe that 12 should go later, whether it be by rule or order, is 13 something that probably needs resolving.
We have the 14 Commission's CLI 80-21 which directs the staff to do 15 something.
We then issued orders to the licensees to make 16 these da tes ef fective.
17 We feel at this point in time a rule would be 18 helpful because of this petition and a number cf hearings 19 which are f acing us to put into the regulation whatever the 20 Commission believes is the appropriate end date or series of 21 eni dates, or the appropria te way to complete this process.
22 (Slide.)
23 The next slide --
24 CHAIRMAN PALLADINO:
If someona did not come in 25 with a timely filing and their only need for extension was, ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554 2345
56 1 vell, we just haven't gotten around to fixing it up, what do 2 you do?
Shut it down and tell them to fix it up?
3 MR. VOLLMER:
I guess we could issue a show-cause.
4 MR. DENTON:
The difference between the rule and 5 the order that we see is that we could always order them 6 into compliance and then we would have to have an 7 opportunity for hearing as to whether that was in order or
~
~
'A rule would foreclose that.
' ~
^
8 not.
9 MR. VOLLMER:
The next slide, as I have just 10 indicated, includes the items we believe will indeed be
- 1 qualified by 6/83 and the types of things we feel we will 12 have a difficult time qualifying.
13 There are test programs under way.
We have had
('
14 some failures and we believe that the general lead time once 15 something is demonstra ted to be qualified'will stretch 16 beyond 6/83.
17 COMMISSIONER AHEARNE:
Do you mean in the second 18 set that you don't believe the items will be qualified, or 19 you don 't believe the qualified items will be installed by 20 6/83?
MR. VOLLMER:
The types of it*ms which will not be m
22 able to be installed and meet a planned date of 6/83.
I 23 think some of these will indeed be qualified by tha t time.
24 COMMISSIONER AHEARNE:
Do you have knowledge that 25 any large set, say transmitters, for example, that currently i
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) $54-2345
57
(^
1 on a technical basis you do not believe are going to be able 2 to meet the qualification standards?
3 MR. VOLLMER:
I will ask Zoltan that.
4 MR. ROSCTOCZY:
The transmitters are presently 5 under testing and one of the prograt s we are following, one 6of our side programs is to follow the industry qualification 7 programs and it relates to one of those.
8 For example, there they tested six.specimins --
i 9 six transmitters -- and they had problems with three of them 10 in this t3st program Test conditions were set up in such a 11 way t ha't the transmitters could be used in a large group of 12 plants, so it was not exactly the condition calculated for a 13 given plant.
It was what I think Mr. Denton called an 14 ':L5rella type of approach.
15 It would have established the qualification of 16 this transaitter for a large number of plants. But they had 17 problems with :nroe out of six.
They are working on this 18 and trying to resolve it.
Our expectation is that finally 19 they will come out with an acceptable transmitter from the 20 program.
It may have some component in it different than 21 the present.
22 COMMISSIONER AHEAR.NE:
But, Zoltan, is there any 23 set of items that currently you believe will not be able to 24 be qualifiad ?
25 MR. ROSCTOCZY I cannot give you a yes or no ALDERSON REPORTING COMPANY,INC.
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4 58
^'
1 answer.
My expectation is that with some modifications they 2 will be qualified.
3 COMMISSIONER AHEARNE:
So your answer is you de 4 not see any?
5 MR. ROSCTOCZY:
In that sense, yes.
But I do see 6 some modifications needed to accomplish it.
7 MR. VOLLMER:
In in the next slide Mr. Bradford aihad proposed early identification of the qualifications',
9 timely filings of schedules.
10 (Slida.)
11 The staff would certainly not have any problem
.12 with such a proposal except it wasn't clear what we would 13 spacifically do with the information that we received.
(
14 If from the information received we had to tell a 15 licensee that wasn 't good enough we would have to evaluate 16 how much staff resources would have to be used by that.
17 COMMISSIONER BRADF0ED:
At the moment you tre 18 still in that situation, are you not?
19 MB. VOLLMER:
We are in a situation of looking at 20 w ha t he is proposing on the 90-day submittals, but not 21 exemprion Layond a specific date.
22 COMMISSIONER BRADFORD:
What I am trying to i
23 achieve is a clear-cut decision as to what does and wha t 24 does not have to be replaced, still consistent with the June 25 ' 82 deadline.
And the premise there is tha t tha t work --
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W.. WASHINGTON 0.C. 20024 (202) 554-2345
59 1 the testing and the staff review -- can be accomplished.
^
2 And the only basis for going beyond it would be the lack of i
3 availability of equipment.
4 So the point would be to get the testing and the j
5 staff review done on a schedule that would, by June of
'82, 6at least permit us to have a clear knowledge of what the 7 problem areas were and, therefore, a relatively clear-cut
- 8 set of justifications for centinued operation.
And we 9 really would know at that point what equipment would have to 10 be taken out.
l 11 At the moment there is still a good deal of 12 fuzziness and, consequently, the justifications f or 13 continued operation rest in part en assumptions about what 14 will and will not pass tests that are now proposed to be 15 strr', out over a couple of years.
16 COMMISSIONER AHEARNE:
Can I ask a couple of 17 questions on your proposal?
18 You say schedules for testing or replacement shall tgbe filed by June '82 and shall include vendors and testing 20 laboratories.
Would that include acceptance of a licensee's 21 statement that here is a piece of equipment which I know 22 will not meet the current guidelines so I have gone out to 23 the vendors to find a piece of equipment?
There is none 24 currently a vailable.
However, these three vendors are 25 currently testing equipment.
Have these kinds of testing Al.DERSON REPORTING CCMANY, iNC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $54 2345
60 1 schedules been laj ' out.
The licensee couldn't commit to a 2 particular replace ont because they have not yet gone 3 through the testing to meet the requirement.
4 COMMISSIONER BRADFORD:
That would, of course, 5 have to be acceptable, provided that we were comfortable 6 with having the plant still in operation.
7 COMMISSIONER AHEARNE:
That's a separate
~
8 question.
I am just trying to find out whe ther you' would
~
gthink that would seet your statement.
10 Another interpretation of your statement would be 11 the licensee must commit to buy item X and item X will 12 complete its testing program by such-and-such a date.
~
13 COMMISSIONER BRADFORD:
I am sorry.
You have lost i
14 me as to the difference.
Okay.
I see what you are saying.
1s COMMISSIONER AHEARNE:
Cut ently let's take a 16 particular plant and it's looking for let's take, a 17 transmitter.
And there are five transmitters currently 18 being tested or going into a test program and it doesn't 19 know which will succeed and which will f ail.
20 COMMISSIONER BRADFORD:
I see what you are saying 21 now, John, and I think you can't separate as neatly as one 22 would like the justification for continued operation f rom a 23 decision abottt what we might accept.
24 I mull expect anything reasonable a t the time the 1
25 matter was before us.
If it seemed this item was of very l
ALDERSoN REPCRTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, O.C. 20024 (202) 554 234S
61 1 low safety significance I would be more willing to accept 2 the open-ended proposition you put first.
If it turned out 3 we felt that it was not of such importance that you had to 1
4 shut down or modif y operation but was still of consequence 5 one might insist that it be done by a date uttain.
6 It is hard to deal with it in the abstract.
7 COMMISSIONER AHEARNF-Except that if we were to 8 accept this we wou.( he saying you have to explain to the 9 licensee what it is that we mean and given, as long as we 10 are not really clear, then I think that the staff and the 11 licensee will have to assume that we are at the bounda y and 12 the boundary would be independent of whethe r the test 13 programs have started and independent of how rany
(_
14 manuf acturers there are.
15 The licensee has to commit to buy a component from 16 this manuf acturer and hr r, to make a commitment that the test 17 program will be completed by such-and-such a date.
18 CHAIRMAN PALLADINO:
I was hoping if you went thi s 19way the schedule wot only be for information, because I 20 think we are getting in an area there --
21 COMMISSIONER GILINSKY:
In other words, you 22 wouldn 't review it?
CHAIRMAN PALLADINO:
I don 't know what we wanted 23 24 it for, but it seems it might be useful.
COMMISSIGNER GILINSKY It seens.
25 i
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ALDERScN REPoATING COMPANY,INC, 400 VIAGINIA AVE., S.W WASHINGTcN. D.C. 20024 (202) 554 2345
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CHAIRMAN PALLADINO:
I think we are getting into 2 an area where we dcn't know when things are going to be 3 tested, what the results are going to be or when you can buy 4 it.
And then we ask for schedules.
Those are good 5 reference points around which to develop some other 8 thinking, but I would hope the schedule would not be 7 something that is so mandatory that.we are going to say, 8' a h'- h a h, you didn't mee t tha t date.
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9 COMMISSIONER GILINSKY:
I wouldn't thi:.6 you would 10 review thos a, certainly not in detail.
But it would seem to 11 me it would be a factor subsequently if there were a request 12 for an exemption.
You could look back and say --
13 CHAIRMAN PALL 5DINO:
Suppose you said I am going 14 to buy an item by a certain date and it turns out the tests 15 weren 't completed?
16 COMMISSIONER GILINSKY Well, if it couldn't be 17 done, it couldn't be done.
18 CHAIRMAN PALLADINO:
So that's why it might be a 19 ref erence point.
But I would hope these are not schedules 20 we would try to follow.
21 COMMISSIONER GILINSKY:
Somehow keeping them to a 22 schadule whicit might turn out to be unrealistic.
23 CHAIRMAN PALLADINO:
I think the very process of 24 schedcling is unrealistic.
25 MR. DENTON:
The key would be what do you expect j
i I
ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE S.W., WASHINGTCN, D.C. 20024 (202) 6$4 2345
63 1 the staff to do with this information?
How do we handle it 2 in view of these oncertainties?
3 CHAIRMAN PALLADINO:
He does have one good point.
4 It would indicate what the targets were and you could use it 5 as a measure to determine good f aith.
6 MR. DIRCKSa Could you use it as an exception, a 7 mid-course correction, if there is a true signal that there 8 is a realy hazard, that something won't be: highligh ted as 9 opposed to just a general plan?
10 CHAIRMAN PALLADINO:
I don 't like using it for 11 those kinds of purposes.
12
. COMMISSIONER B2ADFORD:
Let me try to be more 13 specific than that, if I can, and by all means help me out.
14 COMMISSIONER GIIINSKY:
Do you want me to 15 interpret your proposal?
16 COMMISSIONER BRADFORD:
Maybe I should have let 17 you do that first.
18 (Laughter.)
19 COMMISSIONER BRADFORDs This whole program has a 20 hirtory of surprises.
Equipment that we thought would 1
21 perform up to certain standards didn' perform up to those 22 standards or we weren't satisfied upon review that it 23 would.
Plan ts tha t were no t supposed to ha ve had particular 24 items in them did have then in places where we didn't think 25 they were.
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTCN, D.C. 20024 (202) 554 2345
64 1
I am trying to drive what is left of the 2 uncertainty in that process out at the earliest possible 3 stage such that if there are further problems of the sort 4 which have plagued this effort all along those will be 5 identified.
And if they propose any kind of a threat to 6 continued operation that issue will be resolved at some 7 point between now and the time the proposed extensions of 8 the deadline would take us out to, 9
It is one thing to say we now have a clear picture 10 of what it is that has to be tested and wha t it is that has 11 to be replaced.
And because of the schedules in the testing 12 labs or the availability of the equipment we can't get it 13 y et.
And so we are granting particular extensions based i
14 upon analyses that show us it's not significant to safety.
15 It's another thing to say we know there will be 16 massive problems with the testing so we are extending the 17 deadline in a general sense out to
'83.
And while we will 18 he reviewing these 90-day submittals on a schedule that by 19 sometime next spring we will have a complete and detailed 20 review of them, the processes that are going to go on after 21 those submittals will not really be called into account in 22 any meaningf ul way until, a t the earliest, 1903, or the 23 second refueling outage.
24
- 53. DENTON:
I think it would be useful if once 25 you settle on the main option as the date by which you want ALDERSON REPORTING CCMPAf4Y,INC.
400 VIRGINIA AVE., S.W., WASHINGTCN. Q.C. 20024 (202) 554-2345
65 1 these action completed, if sometime in advance of that date 2 they were to identify what you call " exceptions", which ones 3 should really be or do you axpect
.a have difficulty with, 4 and if that were done six months or one year in advance to 5 give the staff a chance to look into it.
6 I think where we have difficulty dealing with 7 exemptions is when they come in on the last day or the last 8 month and there is a big rush to try to look.behind the 9 basis for it.
So we do need a signal of difficulty some 10 time before the f ate tolls due.
11 CHAIRMAN PALLADINO:
But I'm not sure you are 12 going to get it by a schedule.
What I am concerned with is 13 micro-manageme nt.
That is what we are getting into and I
(.
14 don ' t think that is the province of a regulatory agency.
15 I think we should say what we want.
I don't mind 18 setting up a signal date so they can follow it.
But I hate 17 to see us getting into trying to look at the schedule in 18 great detail and say, you know, you could save three months 19 if you did this instead of tha t.
We are getting out of our 20 realm.
21 MR. DENTON:
That takes more staff to do it that 22 var.
23 COEMISSIONER GILINSKY:
I take this to be 24 something diff eren t, not for us looking into detail to hcw 25 the schedule should be done.
ALDERSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
66 1
CHAIBMAN PALLADINO:
I don't think we know how to 2 tell the utility how to run their business.
3 COMMISSIONER GILINSKY I think it is useful to 4 encourage the utility to plan these things early.
Some 5 utilities are very good at this and others are less good.
6 And I think they would benefit from some encouragement in 7 this area.
8 CHAIRMAN PALLADINO:
Let me ask you a' question.
9 '4h y did staff reject the outage proposal?
It seems to me to 10 have many attractive f eatures.
11 HR. DIRCKS I don 't think it was a question of 12 rejecting it.
It was a close call to begin with and I think 13 You could push either way very easily.
14 MB. DENTON:
I personally f avor the outage 15 question as one member of the staff because I focused on it 18 more and more sinre the paper came down.
The more I deal 17 with the number of actions we have out with licensees the 18 more I see that I would like to clump all of the actions we 19 are requiring into periods of outages rather than having 20 something fall through every week of the year that requires 21 staff to do.
22 But I think when we were putting the paper down we 23 wanted to give an option that assured competion as close to 24 the Commission's original date as possible, which was the 25 reason f or sticking with the one-year extension.
The outage ALDERSoN REPORTING CCA.9ANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
67 1 does let some plants get a few more months chan they would 2 under the ' 8 3.
3 CHAIRMAN PALLADINO:
We don't have to make a 4 decision today.
We have it scheduled for affirmation on 5 Thursday.
Can we explore for the minute what our options 6 are?
7 COMMISSIONER AHEARNE:
har I?
8 CHAIRMAN PALLADINO:
I-m sorry.
Go ahead.
9 COMMISSIONER AHEARNE:
Could you comment on the 10 dif f erences you see be tween the staff, some of the staff's 11 recommendations and Commissioner Bradford ',a proposal, 12 because the basic dates are the same in the sense that it 13 aust be done by June of '83.
It has the basic provision for f.
14 the Director to provide waivers.
The criteria for the 15 valvers seem to be the same -- timely' filed, good faith, 16 provide good cause.
17 MR. DIRCKS:
I may be misinterpreting.
I thought 18 that his msin point was this report, this mid-course report.
19 COMMISSIONER AHEARNE:
So it is a mid -cou cs e 20 report?
21 MR. DENTON:
I thought it was.
I may be wrong.
~
22 Is that it?
MR. V3LLMER:
I think that is it.
We would expect 23 24 to get in any filing f or exemption, if it is timely and we 25 are thinking of timely as being six months in advance, that 4
l ALDERSoN REPoATING COMPANY,!NC, 400 VIRGINIA AVE., S.W., WAShlNGTCN, D.C. 20024 (202) 554 2345
68 o
1 ve would get this information at that time anyway because 2 the licensee would have to tell us basically this 3 information to show good cause.
4 COMMISSIONER AHEA3NE:
And you are saying you 5 would see the basic difference being a six-month time period G between when you would get the same information?
7 MR. VOLLMER:
Yes.
And as far as the licensees
~~
8 are concerned I would judge they would have a problem Nith 9 this to the extent that they would like to get our review of 10 their 90-day responses under their belts before they commit 11 to any of these things.
So I think that is the problem they 12 would have with that.
13 MR. DENION:
And I guess it wasn't clear to me to 14 what extent we would be directing th em in -that proposal to 15 get into micro-management.
I just wasn't clear when we look 16 at a schedule.
Do I spend twenty mandays looking at it, or 17 one man hour?
18 COMMISSIONER GILINSKY:
At that point I took the 19 sense of it to be that we would like there to be a schedule 20 a t tha t point to encourage the utility to pinn the procese 21 and, at les st at that point, to have developed a schedule, 22 not that we will be examining the schedule in detail.
And 23 maybe the schedule doesn 't even have to be here.
24-MR. DIRCKS:
It wouldn't have to be submitted.
25 COMMISSIONER GILINSKY:
I may be modifying the ALCERSoN REPORTING CCMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
69 1 proposal.
2 MR. DENTON:
That is the thing I was not clear on, 3 to what extent we were supposed to examine that.
4 MR. DIRCKS:
I t.hink the difference is that when 5 something is submitted we feel compelled to review it.
6 COMMISSIGNER GIL'INSKY:
That is fed into our 7 nachinery.
~
'8-MR. DIRCKS:
Yes, it gets put into.the work load.
9 COMMISSIONER AHEARNE:
Being compelled to is 10 dif ferent than doing it.
11 MR. DIRCKS:
It gets at the end of the line, like 12 everything else.
13 MR.
OLLMER:
I would like to point out, getting i
14 back to the difference between option two and option three, 15 both of them would certainly require exemptions of some 16 sort.
Op'. ion three, if you use refueling outages, won't get 17 anyone off the hook.
I think that our option two, the 18 exemptions, would factor in refueling outages and that was 19 the thrust of it when we mentioned we would be using same 20 type provision we do in Appendix 2.
21 So I think the two are fairly close.
It is 22 perhaps a matter of how you characterize whether it is an 23 end date or a series of end dates.
24 CHAIRMAN PALLADINO:
I wonder if we could explore 25 for a moment what the pros and cons are of a rule versus an ALDERSoN REPORTING COMPANY,lNC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
70 1 order versus any other option we have.
Perhaps the General 2 Counsel could give us some guidance.
3 MR. BICKWIT If relaxation is done by rule there 4 will be a requirement for notice and comment on that rule.
5 But there would not be a hearing requirement on the 6 relaxation.
I think that is the major diff erence.
7 The possibility of a hearing is much greater if
' ~~
~8 wha't you are doing is relaxing by an amendment to the' '
911c ense, which is, I assume, what is meant by ocder in this 10 particular paper.
11 Further, if you --
12 CHAIRMAN PALlADINO:
You are saying an order would 13 automatically be an amendment to each license?
14 MR. BICKWITs I assume what is being called for is 15 relaxation by ordered amendment.
I don't think it would be 16 possible to simply order that it be done without amending 17 the license.
The requirement of the '82 date is now 18 included in the tech specs of the license.
19 Another difference is that if you go by rule then 20 further relaxation on a case-by-case basis, if it becomes 21 necessary, can be done by exemption.
If you go by amendment i
22 to the license then further rela xa tion on a ca se-by-case 23 basis would have to be done either by rule or by amendment 24 to the license.
25 That last observation assumes that you do not i
ALDERSON REPORTING COMPANY,INC.
400 VIRG1NIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
71 1 b'uild substantial flexibility into the rule that you adopt 2 or the amendment that you adopt.
If you have a firm rule or l
3 amendment, as the case may be, then that last observation is 4
4 correct.
5 MR. MURRAY:
I would just reemphasize that the key 6here is you have an opportunity for a full-blown 7 adjudicatory hearing when you are dealing with amendments or
- 8 ordered amendments, whereas you don't have.any opportunity 9 for an adjudicatory hearing.
You just have an opportunity 10 for comment and you get it all at one time when you deal 11 with a rule.
12 MR. BICKWIT:
My recommendation would be to go by 13 rule.
14 CHAIRMAN PF.LLADINO:
That means you have to send 15 it out f or comment.
16 H3. BICKWIT:
That's right.
17 CHAIRMAN PALLADIN04 Are there any other questions 18 or any other points we should hear on this?
19 (No response.)
20 CHAIEMAN PALLADINO:
I thank you all for coming 21 and we will stand adjourned.
22 (Whereupon, at 11:00 o' clock a.m.,
the meeting was Z3 adjourned. )
24 25 l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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NUCLEAR REGULATORY COMMISSION This is to certify that the attached proceedings before the COMMISSION MEETING in the matter of:
Public Meetina - Discussion of SECY-81-486 -- Petition for Extension of Deadline for Environmental Qualification of Class lE Electrical
- Date of Proceeding: __
snotember 23. 1981 Equip;. en t.
Docket Number:
~
Place of Proceeding:
Washincton, D.
C.
~
were held as herein appears, and that this is the original transcrip; thereof for the file of the Commission.,
Sharon Filipcer Official Reporter:(Typed)
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O The Public Docume
,Y oo DATE:
September 24, 1981 O
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e Attached are the PDR copies of a Commission meeting transcript /s/ and related meeting document /s/.
They are being forwarded for entry on the Daily Accession P
List and placement in the Public Document Room.
No P
other distribution is requested or required.
Existing h
DCS identification numbers are listed on the individual p
documents wherever possible.
Transcript of:
Discussion of SECY-81-486 - Petitiod for Extension of Deadline for Environmental Qualification of i
Class lE Electrical Equipment.
September 23, 1981 i
(1 copy) l Vugraphs presented at above meeting:
Current Status.
a.
(1 copy) b.
SECY-81-486 - RULEMAKING ISSUE paper dated m
Aug. 13. 81, Subj:
Petition for Extension of 5-8 Deadline for Environmental Qualification of Class h-1 lE Electrical Equipment.
(1 copy)
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P Off1'e of the Secretary 7
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- CONTENT IEORPATION LACKiiiG IN 11/1/80 SUBMITTAL
- JUSTIFICATION FOR INTERIM OPERATION
- ESOLUTION OF OLTSTANDING ITEMS
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EXTENSIONS TO CONSIER QUALIFICATION AND PROCUEENT SOEDllLES, EFLELING OlffAGES
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