ML19332D376
| ML19332D376 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1989 |
| From: | NRC |
| To: | |
| References | |
| FRN-55FR29043 AD04-1-019, AD4-1, AD4-1-19, NUDOCS 8912010096 | |
| Download: ML19332D376 (61) | |
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. Nuclear Regulatory. Commission' Public Workship on Technical.and.' Policy 7jdg'.
Considerations for Nucfe'ar' Power. Plant License Renewal:1 Overview of: Conceptual
-Approach =and-Regulatory Framework ~
Docket No.:-
CONCURRENT SESSION.'S p
IOCATION:
Reston, Virginia L
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' Monday, November 13,.1989 PAGES: 1 - 59.
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i 5-PUBLIC WORKSHOP ON' s
6' TECHNICAL AND POLICY CONSIDERATIONS "7-FOR
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8 NUCLEAR POWER PLANT LICENSE RENEWAL l'
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11 CONCURRENT SESSION 5 12 OVERVIEW OF CONCEPTUAL APPROACH lt f l
l ~ 's 13 AND REGULATORY FRAMEWORK-i 14' 15 f
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16 Sheraton Resort Hotel l
17 Conference Room 5 L
18 11810 Sunrise Valley Drive l
l 19 Reston, Virgiaia l
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20 21-Monday, November 13, 1989 22 1:15 p.m.
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- 1 NRC~ PARTICIPANTS:.
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'2 Frank Gillespie 3
Lawrence Chandler I
4 Robert Bosnak 5-Cecil Thomas F
.6 7
INDUSTRY PARTICIPANTS:
8 Sol Burstein,-ASME 9
Jay Silberg, Shaw, Pittman, Potts lE Trowbridge 4
10 Joseph Gallo,-Hopkins & Sutter 11-Don Edwards,. Yankee Atomic Electric Company Er'g 1;2 Pat Ward, Grove Engineering k,/:
13 Bob Weiseman, Westinghouse t
14 Bart Cowan, Ekert, Siemans 15-John DeVincentis, Yankee Atomic Electric Company 16 Tim Bailey, Northern States Power Company L
- 17; Ed Griffihg, NUMARC t
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1<8 Frank Bell, Baltimore Gas & Electric l.
L 19 l
20 NRC AUDIENCE PARTICIPANTS:
21 Leon Rider q.
22 Guy Arlotto L
23 James Sniezek 24 25
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PROCEEDINGS j
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(1:15 p.m.]
3 MR. GILLESPIE:
Let me ask a' couple of questions 4
before I' turn it over to this panel.
I'm left over from this-r 5.
morning, so I, don't get a little name thing.
I have to stand.
'I 6.
That's my punishment, I'm told, for not being argumentative 7
enough this morning.
Et Let me'ask a couple of things that would really help 9
us out.
We hashed a couple of questions over-at lunch, and I 10 want to make sure I understand what you understand so I can 11 understand it.
i L/"'g 12 The last three speakers in this morning's session D'
13 spoke to the current licensing basis, and let me separate the l
14 current licensing basis into two pieces.
One is the paper 15 basis, the list, the bookshelf full of paper that says here is
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16 the current 1icensing basis.
No one really wants to xerox that 17 bookcase full of stuff and send it in.
'18 Well, in issuing a renewed license, it was generally 19 our belief that we would have to somehow reference or to make 20 valid or to bring it up to date all of the old requirements, 21 and that was kind of the genesis for wanting the wording of the 1
22-rule the way it is, so that in the renewed license, there would 23 be a definite reference.
I think we can take under 24 consideration the need for analysis of that, but we definitely 25 felt that we needed the reference in there to reference it back
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as a starting point.
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.Yes.
3 MR. BURSTEIN:
I am concerned with your reference to 4
a new license.
I would like you to tell us why you think this 5
is not an amendment to the existing license, in which all of 6
.that garbage does not have to be revalidated.
l 7
MR. GILLESPIE:
I didn't say rovalidated.
I said 8
listed, but let me try to answer you.
t 9
Larry, do you want to -- I can take a shot at it.
10 (Laughter.)
11 MR. GILLESPIE:
Let me take a shot.
I'll take a shot 12 at it, and I don't feel bad, because only OGC can i
+ ret.
I 13 MR. BURSTEIN:
You issued all that stuff.
'ly.
14 You should have it all.
15 MR. GILLESPIE:
It's a matter of whether we make up 16 the list and give it to you or you make up the list and give to 17 us for referenceability, but in any event, we feel we have to 18 reference it.
Let me take one step back and say the Atomic l
19 Energy Act itself uses the term " renewed license".
It doesn't l
20 say amendment.
It doesn't say new.
It says " renewed".
l 21 So, we call this a " renewed license".
Now, to a 1
l 22 degree, that's calling it " George" to eliminate the pitfalls of L
23 either one, bitt we'll try to be fairly consistent in that, and
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24 I believe, in the Atomic Energy Act, there is a limit on the 25 length of time a license can be issued for.
A license can only 1
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be issued for 40 years.
2-MR. BURSTEIN:
The initial license.
3 MR. GILLESPIE:
The initial license can only be 4
issued for 40 years.- What's the exact wording, Gary?
It just 5
says "a license".
6 It then goes on and talks about "a renewed license".
7 So, we feel we're in renewed license space, and I'm probably 8
splitting hairs.
I don't know if that's a whole lot different
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9 from a new license.
It's something in the middle.
10 MR. BURSTEIN:
You are equally justified in assuming.
11 it's an amendment to an existing license or a continuation-of 12; that existing license.
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13 MR. GILLESPIE:
No.
14 MR. BURSTEIN:
Why not?
Tell me why not.
t 15 MR. CHANDLER:
It would not be a continuing license, 16 because the Act puts a 40-year limit on that license.
- You, 17' arguably,.could talk in terms of amendment.
I think, based on 18
'our review of the legislative history of the Act, though, we 19 fairly well satisfied ourselves that a renewed license is 20
.probably a better way of looking at it and, even more 21 specifically, looking at virtually as a new license.
It is not 22 simply an amendment, in conventional terms, of a license.
23 Now, I think one of the things that we would like to O)
(s-24 elicit from you-all is any help that you have on that that may 25 persuade us otherwise.
You know, if there is some argument to
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be made for treating this as a somewhat routine license i
2' amendment or somewhat more than a routine license amendment, we i
3 certainly would be interested in knowing what the basis for 4
that view would be, but right now, we're satisfied that the j
5 better way of viewing it, given the constraints of the Atomic l
6 Energy Act, are to treat it as a new license, a renewed
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7 license.
8 MR. BURSTEIN:
What's the basis
- 'r saying it's a new F
9 license, as opposed to a renewed license?
i 10 MR. GILLESPIE:
Could we have, the gentleman in the t
11 back, your name and organization, just so we have it on record?
I 12 MR. BURSTEIN:
My name is Sol Burstein, and I am l
13 representing here ASME.
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14 MR. SILBERG8 I'm Jay Silberg from Shaw, Pittman, t
15 Can you tell us what's the basis far saying that this should be 16 treated as a new license?
I Is MR. CRANDLERt I am not sure I can distinguish -- let 18 me back up..
I am not sure I know what a " renewed" license is.
19 There is no help that we were able to find in any of our 20 research that suggasts that there is an initial license or a 21 different ocense that's called a " renewed license" that is i
22 issued sometime down the road, after 40 years, which would have 23 any different limitations or have any different standards for 24 its issuance than an operating license.
25 MR. GILLESPIEt I guess, more importantly, despite
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what we call it, it wouldn't make any difference, would it?
2 MR. BURSTEIN:
It may, yes.
3 MR. CHANDLER:
Well, as a practical matter, we did i
4 not see it, and as I suggest, if you-all have a thought on 5
where there would be a distinction, if it were viewed as a
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6 renewed license, it would be helpful for us to know what that 7
would be.
8 MR. GILLESPIE Generally, an amendment can go to 9
hearing, also.
So, once you notice it, it didn't seem to 10 really matter a whole lot what we called it.
i 11 MR. SILBERGt It's the findings that carry over or
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12 don't carry over.
If you treat it as a new license, something 13 that's fresh, something clean, then you ought to.have a new 14 document and everything has to be resubmitted all over again.
15 If it's a license amendment for a renawed license, 16 something that isn't a whold new document, then it seems to me 17 you're entitled to take credit for all those things that you've 18 put on the document over 40 years and you don't have to refile, 19 you don't have to submit a new list.
20 The Commission ought to have the list of all the t
21 things that are on the docket.
I don't know why anything more 22 would be necessary.
You ought to be able to take credit for 23 the findings that the commission has made, provided that those 24 findings are not undermined by age-degradation.
25 MR. CIIANDLER:
I'm not sure, Jay, that treating it as
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a new license changes the ability to rely on matters of record.
2 In other words, I'm not sure that, even though the 3-staff would be looking for a current licensing basis, that 4
certain credit can't be taken for that which is already a e
5 matter of record.
Again, if you've got a better way of 6
skinning a cat, let us know.
I'm not sure, practically, it 7
makes much of a difference, though.
8 MR. GALIA:
Joe Gallo, Hopkins and Sutter.
Do you 9
see a problem with simply extending the term of the particular 10 operating license from expiration date to whatever it is, to a 11 20-year period?
12 MR. CHANDLER:
By amendment?
Yes.
13 MR, GALID:
What is that problem?
j 14 MR. CHANDLER:
The 40-year limitation that's imposed 15 in the statute.
l 16 MR. GALLO:
Why?
Because that would create a 60-year f
17 license?
18 MR. CHANDLER:
Yes, something that wasn't 19 contemplated when the Act was passed, recognizing that that 20 period wasn't necessarily imposed for health and safety 21 reasons.
l 22 Don?
23 MR. EDWARDS:
Don Edwards, Yankee Atomic.
24 Suffice it to say that we have an unusual creature 25 here.
It's not necessarily amendment and it certainly isn't a l.
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1 new license.
We've been looking at this for quits a while, to l
i 2
come up with a way to treat it.
We want to carry information i
3 forward.
We want to recognize that the plan exists, it is 4
running, it has records, it has established itself.
It is not 5
an uncertain question about the facility.
l 6
So, all of that informati~,
s readily available.
We 7
ought not to have to reconstitute it and resubmit it at this f
8 point.
9 What you are really concerned about is the hardware 10 degradation that you can segregate out if you analyze it 11 carefully and systematically and make sure that that's l
12 mitigated.
That is really where our focus has been in the 13 development of the methodology of that whole approach.
I guess
-14 what we have read doesn't seem to go in that direction.
15 MR. GILLESPIE:
I think it was our intent to submit a l
16 list for referenceability that was a' defined quantity that 17 would carry forward.
18 Go ahead, Larry.
19 MR. CHANDLER:
Let as just add, it's more than simply l
20 so that matters can be referenced down the road but today, if 21 you look at an operating plant and one of our inspectors ic out 22 there, there's a defined bace against which one can inspect and 23 one can establish compliance against a given set of 24 requirements and designs and procedures.
25 It's necessary to carry that base forward.
Now I l
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1 don't disagree with what Jay was suggesting before.
Those 2
things ought to continue forward and we're proposing, 3
suppose, one way of carrying it forward and if there are 4
others, fine.
5 MR. SILBERG:
Why do you need to have anything?
I 6
Lean in the year 39, you don't need a new list.
Why in the 7
year 41 all of a sudden do you need a new list to carry out the 8
same inspections that you were doing yesterday without the 9
list?
10 MR. CHANDLER:
It's not a new list.
11 MR. SILBERG:
A list that didn't exist before.
12 You're asking us to submit something new.
l 13 MR. CHANDLER:
No, I think Frank said what it is.
We 14 can do the list or you can do the list.
Our proposal says you 15 do the list.
Why do you need a list at all?
You 17 don't have a list today.
You don't have a list in year 39 and 18 everyone recognizes that you can inspect a site.
We have 1
19 commitments and we abide by those commitments.
Why in the year 20 41 do you --
i 21 MR. BOSNAK There are things in the current 22 licensing basis, particularly in the initial design that expire 23 at year 40.
They were designed for 40 years and what happens 24 to those when you go beyond the 40 years?
Somebody has to take 25 a look to see if the initial design basis is adequate for 50, i
i 11
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1 60, perhaps more, but until you do that there is this 2
uncertainty.
3 MR. SILBERG That is the analysis which would be 4
done, degradation time, dependency --
l 5
MR. BOSNAK Right.
Exactly.-
6 MR. SILBERG:
And that's the list that we get I
7 submitted, not the list of everything.
i 8
MR. BOSNAK I think we recognize that.
That is the
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9 list that we all want to see.
l 10 MR. SILBERG You won't find it, j
11 MR. GILLESPIE:
I think we're not going to probably f
12 argue it out here.
The comment is good.
We could put a Oi 13 comment in the rules rather than a list.
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14 One alternative would be to reference everything on j
15 the docket since CP submission as being applicable and then no 16 one needs a list.
You just say everything submitted under 17' docket umpty ump remains 100 percent in effect.
But then t
18 someone has to give us a list of superseded things or we'll 19 develop the list of superseded things, but we generally right 20 now feel and the reason it's in there was referenceability and 21 completeness.
22 Gary, do you want to add anything to that?
You're 23 the one we were working with -- or Larry?
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24 MR. CHANDLER:
I would hope, and this even ties to 25 the question of certification, that the industry and the
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1 individual utilities have as good and likely better knowledge 2
of their facilities than does the staff and I think that's
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-3 where it becomes particularly important to have the most l
4 current -- I'll use the word " licensing basis"
-- but not as l
5 used in the straw man regulation.
That's why it becomes 6
important to have that compilation, irrespective of what you 7
call it and that's why in a sense the industry is in the best 8
position to provide it.
9 MR. GILLESPIE:
Let me go on to the next thing and i
10 see if this can be -- at least evoke some questions.
11 The last three speakers this morning raised the 12 second part of the issue with the licensing basis.
That's the 13 paperwork side of the licensing basis.
Who writes the list.
14 Do we need a list?
15 I'm not sure that I was hearing him correctly because 16 it kind of drifted through my mind at lunch and I tended to I
i 17 lose it and I talked to a couple of other people -- I won't 18
' mention their names but they lost it too.
I 19 If a component is in fact already covered by a 20 program we say we're not now going to review and ISI is one of l
21 those programs, the intention of the wording and the conceptual 22 rule we have written would be that that component still has to l
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23 be looked at for its material characteristics, the environment 1
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24 it sees and the judgment made as to which degradation 25 mechanisms are in play and if those mechanisms are made up for i
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1 or accounted for by the test already being performed then 4
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2 thats okay.
You don't have to do anything more with that.
If 3
it's not, then you have to either increase the frequency of the 4
test or do another test.
j 5
Now what I thought I heard and I might have misheard t
6 it.
I might have not had it come across right, was if a t
7 component was currently covered by a current program, it 8
shouldn't have to be looked at again at all. 'Now, that's what 9
I thought I heard.
Would anyone like to -- is that what I 10 heard?
Is that what everyone else in the room heard or is that i
11 what you meant?
.i 12 (No response.)
l 13 MR. GILLESPIE:
It's not what you meant?
14 I was groping for the exactness of what I heard.
15 MR. BURSTEIN:
Let me say it again if nobody else 16 will.
I hope that's what you heard because that does indeed i
17 represent what we do periodic inspections and tests for.
Why 18
'else do we do them?
We know that things begin to age from day 19 one and the whole period of doing these inspections and 20 revalidations of ability to perform during the initial 21 licensing period is to take care of those things.
Unless you 22 define because we haven't been able to, a new mechanism that 23 begins to show itself in year 40, then the existing ISI's and O
24 tests and all the other things we do to validate equipment and 25 apparatus performance should continue to apply beyond the
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1 initial licensing period.
2 MR. GILLESPIE:
Okay, and be satisfactory.
j 3
MR. BURSTEIN:
Unless there is some new phenomenon 4
that so far as I know has not been elicited from either side of l
l 5
'these items, if that's the case, I think you= heard it
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6
' correctly.
7 MR. BOSNAK I would just like to make one comment on 8
that.
Both ISI and IST programs and other programs continually i
9 change.
So if we're talking about keeping up with a program 10 that doec change and for instance, with respect to the 11 containment ISI, now it's just looking at wells but there are 12 things coming forward which would require that the base 13 material be examined to look for things like gross corrosion.
14 So there are things that are going on in existing programs and 15 I would expect that those would be included.
16 MR. BURSTEIN:
I think to make this a dialogue, would 17 that not apply to existing licenses?
18 MR. CHANDLER:
Exactly.
19 MR. BURSTEIN:
So what's the difference?
You're 20 reinforcing my argument.
21 MR. GILLESPIE:
We're not disagreeing with it. I just 22 wanted to make sure because that's not the way our conceptual 23 rule is written and I wanted to make sure I understood the 24 exact context of the comment, because there are other programs 25 and components which are now included in various maintenance
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1 programs from anything from just looking at it and doing an 2
observation to tearing a valve down and I don't know that right 3
now-I'd have to look to Bob to say we feel comfortable that 4
those requirements and those commitments were put in place 5
necessarily to cover the spectrum of degradations that are 6
listed in the conceptual rule.
7 We have to go back and think about that a little 8
more.
In the conceptual rule, it was asking for a match up of 9
those components with degradation mechanisms before you say the 10 test is still all right, but in keeping with the philosophy we
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11 had, if it's a problem with today's rules, then today's rules j
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12 would be changed and they consistently would apply.
13 So it's a good comment and I've got to think about it l
14 a little more because it's just not as straightforward as stuff l
15 that's covered by codes.
16 Don?
17 MR. SILBERG:
Let me take an extreme example of the 18 way I think the rule was written which says that you have to 19 list only the design conditions and assumptions, only 20 environmental conditions and so forth and then you decide 21 whether or not --
I don't disagree with that.
A 23 specific comment this morning was on components that get 24 changed out and I think the implication was it was changed out 12 5 at a relatively high frequency compared to 40 years.
l 1
16
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i1 I can't argue with that at all.
I agree totally with (d
2 that.
That's a matter of needing to put more. detail or 3
criteria possibly within the rule itself to fit some classes --
4 some instances where there's classes like that that says, j
j 5
something like "any component changed out at a frequency 6
betvaan umpty ump and umpty ump or significantly less than the 7
life of the license, you don't have to do anything further 8
with" and that's a good comment.
9 That's a class that's not quite as generic as the r
10 other one.
11 I'm just saying, we've got to think about it a little 12 and digest that.
We had a reason we put the other way in but O
t 13 we kind of have got to go back and we'll take a look at it.
14 MR. EDWARDS:
That principle applies, although there 15 are problem.
If you are concerned about pressure boundaries 16 and integrity, and monitoring pressure bondaries, then you have 17 a program that takes care of the item of concern.
18 If you have an operation, you may need to augment.
19 That is the difference.
20 MR. GILLESPIE But as components age, they will have 21 less and less margin in them.
I think the general thought was 22 that you may actually have to look at testing even more and 23 more and it was the words -- you know, I see him throwing his 24 hands in the air.
If the code changes; that would do it.
25 But the code won't change by February, and we're
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1 probably going to have the words of the rule down to submit it 2
through, you know, our chain.
That is why I have to go back i
f 3
and think about that.
4 when you look at pipe wall thinning rates, when you 5
look at the technology that is coming out of the research 6
program, I am not sure, standing here, that the current rates 7
of testing, the current types of tests, aren't types.of tests t
8 done.
t 9
MR. EDWARDS:
Excuse ma again.
t 10 Take the pipe wall and'you have a minimum thinning.
i 11 If you are going to catch that in that period, then you have a problem. The margin is at minimum thickness.
What else was O
12 13 left there, or to throw it away is operations.
It is a 14 problem.
15 MR. GILLESPIE:
I am saying that I have to go back 16 and think about it.
I'm not going to promise anything, 17 standing here, because a lot of hashing around went around 18
' exactly on that topic.
I have to go back and revisit with all 19 of the experts who were revisiting with at the time as to what 20 way we go.
21 But it's -- I accept the comment and I agree totally 22 with the one on replacement.
If you are replacing with that 23 frequency, it's crazy to have to do a lot of analysis on it.
24 As we work through the other classes, I have to think about it
-25 more.
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18
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1 So, I now have a clear understanding.
I had the 2
right understanding of what was said, and that he?ps me out a 3
lot.
4 4
One other comment on -- this came out after the first 5
sessions in the hall, and I'll throw it out -- and that was on 6
doing all this analysis on components that are even already 7
covered.
This is somewhat analogous to reconstituting or a 8
piece of reconstituting the design of the plant.
9 If we're not happy with the current constitution of 10
. designs of plants, or if we are, why couldn't we continue to be i
11 happy with that.
I was told that I ought to at least mention 12 the view that SSFIs have been finding on the ability of some l
13 utilities to know the reason their plants were designed the way l
.14 they were.
l.
15 The part of that was part of the thought that went 16 into requiring all that analysis.
Right now, as a here-and-now 17 problem, we are working on design reconstitution guidance in 18 NRR and that may become a here and now problem and I have to l
19 think about the phasing of that also.
We might have been 20 fixing a current problem with a future rule.
21 I've got to give that some thought because the rule 22 may be out before the guidance is, in which case I'm not sure 23 which fixes the problem.
I thought I would mention that, and 24 we will give that some consideration also, because that goes 25 into the mix of the same database we'd be asking for.
19
}
With that, that clears up my problem.
Does anyone i
1 2
else have something left over from the morning?
3 MR. WARD:
I have one followup question which you 4
just talked about, referring to the docket as a means of 5
getting at the Current Licensing Basis.
If one were to do i
6 that, would that preclude the need for any type of i
7 certification?
5 8
MR. GILLESPIE:
Larry, do you want to --
l 9
MR. WARD:
Since the cumulative effect of all the 10 corporate officer signatures along the way --
11 MR. GILLESPIE:
Is the equivalent of certification.
12 MR. WARD:
What would it gain you to certify it in 13 bulk?
14 MR GILLESPIE:
I think Larry already agreed that 15 we'd go back and look at that this morning.
Do you want to add I
16 anything?
17 MR. CHANDLER:
I think we will look at certification 18 again, but I go back to the comment I made a few moments ago, 19 and that is, I guess I don't fully appreciate the reluctance of 20 the industry to sign off on what their plant is all about.
I 21 recognize these are very major and conplex creatures out there, 22 but they've been operated for many years now and they will have 23 been operated for many more years as we get down the road and
()
24 closer to actual renewals.
25 I would think that corporate officials ought to have
w 20
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1 sufficient confidence in their plant that they -- you know, 2
after due review, be willing to sign on the bottom line, so to 3
speak.
4 MR. WEISEMAN:
With regard'to that last remark, this 5
is Bob Weiseman, Westinghouse.
There is a board decision and 6
the calloway proceeding that says the NRC regulations do not-7 require inspection.
In the building of a plant there are going 8
to be a lot of things that don't come out exactly the way they 9
should.
10 If you have an adequate QA program, you will find the 11 most important; maybe not right away, but later on.
I think 12 every utility will have no problem if it's certifying a plant
(
)
13 designed and built in accordance with Part 50, Appendix B.
But 14 it becomes another matter to certify that everything in the 15 plant satisfies the regulatory requirements, because Part 50, 16 Appendix B did not require you to provide that kind of 17 assurance.
18 I can speak for one who has been involved in trying 19 to help utilities provide certification in other areas.
I will 20 tell you that it requires practically a one hundred percent 21 -
check, rather than a Part 50, Appendix B check which is very 22 expe.7sive and on the basis of the kinds of thing that we found, 23.
no one could ever justify the expense based on the nature of O
24 the discrepancies that were found and the potential effect they 25 might have on safety.
w
i 21 1
k 1
MR. CHANDLER:
I don't disagree.
i 2
MR. WEISEMANs I can't speak for the utilities.
But 3
from my own view that is why people are reluctant to certify I
4 that something is a hundred percent all right.
)
5 MR. CHANDLER:
Sure, I understand that.
j 1
h 6
MR. WEISEMAN There is no basis on which to base i
7 that certification.
L 8
MR. CHANDLER:
Recent history suggests that one ought
-l 9
to be most careful about certifications and assertions of 10 compliance.
I-think it may be a question of what the I
11 certification calls for; in other words, what is required by 12 that certification.
13 In other words, are you going to require
~
14 certification that every nut, bolt, and color of paint is just 15 as billed, or is there some lesser standard?
As I also 16 mentioned early this morning, there is 50.9 which is one of the i
17 requirements in our regulations now, which deals with 18 completeness and accuracy of information.
19 If you put that together with the oath or affirmation
'20-that presumably will be required for the submission of an 21 application that was suggested a moment ago, it's something 22 that's worth considering.
23' MR. GILLESPIE:
Jim?
(
24 MR. SNIEZEK:
Jim Sniezek, NRC; I think one of the 25 philosophical underpinnings of our thought in this is an
22 1
1 appropriate assumption of the current licensing basis with l
2 sufficient and adequate assurance of public health and safety.
l 3
That's an underlying premise flowing into this program.
That 4
is our underlying premise.
5 If you're going to use that as an underlying premise, j
i 6
I believe it's very important that the utility and the NRC have 7
a mutual understanding of what constitutes that Current 8
Licensing Basis.
That's the premise we're going in under.
We 9
should be in a agreement on what constitutes license basis.
I 10 Secondly, we hold utility first, as responsible for 11 the safety of their plants.
That's why we've asked for a
~s 12 certification that, in fact,-the plant does meet the Current
[
13 Licensing Basis.
There is nothing more to it than that.
That 14 is the rational why we wrote what we wrote.
15 MR. BURSTEIN:
May I ask why that is necessarily the 16 year 41 and not in year 397 l
17 The same questions come back about our treating this
[
18
'as a different license, as a new license.
You don't need it 19 for anything sooner than the expiration of the current license l
20 term.
Why is it necessary beyond that?
l 21 MR. SNIEZEK:
Well, I'd say it's because that that 22 wete treating this as a super-session type license.
23 MR. BURSTEIN:
Again it comes back to your definition i
24 of what the license is and I think that's the rub.
25 Please revisit that, gentlemen.
1 1'
i Y
23
-(
1 MR. GILLESPIE:
Okay, one other question came up in i
l
~
2 the hall.
That was the disincentive that may be built into 3
this rule.
Let me throw this out.
4 We have got to figure out how to put an incentive in 5
because both we and you want to get this over with as soon as l
t 6
possible -- not the meeting necessarily but getting the rule on 7
the street and getting some applications in so we can both do j
i 8
some orderly planning.
I 9
The disincentive that was pointed out was that if l
10 someone comes in at year 20 and we issue a new license, he's l
11 probably going to have identified many, many components which 12 will be folded in into his maintenance program or which he is O
ig going to do trend analysis on or take some kind of measurements 14 where if he waits until three years before his license expires 15 he gets away with not knowing that information for 17 more 16 years and therefore not paying for that to be done, j
17 The question was, well, how can you allow that?
No 18 one will ever come in early, given that they are going to have 19 to go through all that extra expense for all that 10 or 15 20 years.
21 I have to admit we hadn't thought about that.
22 We'll figure some suitable punishment out.
23 (Laughter.)
24 MR. GILLESPIE:
So --
25 MR. BURSTEIN:
Again, there must be some naivete that
l 24
)
1 exists out in the halls.
J 2
[ Laughter.)
3 MR. BURSTEIN:
Let me just point out the reality of l
l 4
what the utilities face.
If it gets to continue to operate its 5
existing nuclear plant, it does not have to seek to build a 6
replacement generating facility.
If it doesn't get such a l
7 license amendment or extension, then it certLinly has to-go out l
l 8
and construct, pre-license, design, finance, get all the j
9 regulatory state and Federal permits necessary to do that,
- 10 which unless it's a combustion turbine type thing will probably f
11 take six to ten years.
12 There is no way that anybody can wait until three 13 years before the present nuclear plant license expires to find 14 out whether it is going to be able to continue to operate that 15 plant or not.
16 MR. GILLESPIE:
Well, that's what I said, but it's l
17 funny because we'd still have, you know -- the effects would i
18 still be of a timely renewal so the plant would not be shut i
19 down.
20 MR. BURSTEIN:
I submit to you it'll probably be a b
21 lot earlier rather than later.
i 22 MR. GILLESPIE:
Well, that was the question. I felt 23 that the certainty of knowing 10 or 15 years in advance that a plant would operate would more than offset the added cost of 24 25 coming in early and folding all these extra components and
. ~... -
I 25 U]
[
1 trend analysis in.
2 If this was an industry person who asked me had I l
3 thought about it and it was in the vain of if someone's coming 4
in and therefore at the end of their 40 year license they've l
5 been under the renewal program for 10 or 15 years and have 6
developed a lot of trending information on corrosion, on wear, j
7 on thinning, what would there be to induce someone to know that r
8 that same quantity and type of information for that same type 9
of time frame should be available for the plant that comes in 10 at the last minute, and I just wasn't to answer the question i
11 and I thought I'd ask it here to get it on the record since I 12 was asked in the hall.
O 13 I would hope the economics would say the earlier, the l
14 better but it was a question that was asked.
l 15 Would anyone like to comment on that?
Anyone else?
16 or is there general agreement that the view is the economics r
17 would cause the utility to want to get that certainty in their 18 license?
19 (No response.)
l 20 MR. GILLESPIE:
All right.
With that lack of l
21 response --
22 (Laughter.)
l 23 MR. GILLESPIE:
Maintenance does become a key to this 24 whole thing, our second principle was that the plant is 25 maintained in a condition commensurate with the first 40 years.
- ~. -
26 1
-Cecil Thomas is from our Division that is dealing in 2
NRR with the maintenance policy statement and its interfaces.
l 3
He does have a list of questions that we published.
i 4
Bob Bosnak I think is going to be interested in how 5
this is going to be done, what types of tests will be committed 6
to, so let me turn it over to them to get into the more 7
detailed and maybe technical areas in question on maintenance i
8 and how the plants will be maintained.
l t
9 Cecil?
10 MR THOMAS: Thank you, Frank.
This morning we heard l
11 that our proposed regulatory approach to license renewal is 12 founded on two key principles.
13 The first one is the current licensing basis provides f
i 14 an adequate level of safety for operation during the renewal 15 period, and secondly that that level of safety will not degrade during the renewal period.
16 17 We believe that the licensee's programs for 18 maintenance, surveillance and record-keeping are going to play 19 very important roles in assuring that the level of safety will 20 not degrade during the renewal period.
21 To stimulate discussion, we have proposed a list of 22 13 questions which you all received and we encourage you as you l
23 make your statements and go through the discussion period this
()
24 afternoon you'll focus on them, we really want to hear your 25 views on those questions.
L i
27 i
1 With that, let me turn it over to Bob.
)
2 MR. BOSNAKt This might be a good time for those 3
1 3
persons that have indicated that they'd like to make a 4
statement for the session and we have listed apparently the i
5 same individuals that spoke this morning.
6 I'd like to ask the first gentleman who spoke for 7
NUMARC if John DeVincentis is here he'd like to make a further 8
statement in this area for Session 5.
9 MR. DeV1NCENTIS:
I'm here and I don't have a 10 prepared statement.
i 11 MR. BOSNAKt Okay.
Is there anybody else, because we 12 also have Northern States Power, Terry Pickens.
13 Any of the other individuals?
EPRI?
John Carey?
14 Joe Gallo for Hopkins, Sutter?
Again we have Yankee Atomic and 15 Pennsylvania Power & Light?
Douglas Walters?
I 16 Are there any of those individuals or any other 17 individuals that would like to make a statement in this area of 18 maintenance or trending recordkeeping?
19 Obviously it is very important that there be programs 20 and that thern be programs obviously for the existing 40 years 21 but to identify the degradation mechanisms that we have listed 22 in the rule and to be able to know what's going on with respect 1
1 23 to trending information is to me quite important.
1 ()
24 One of the things that we talked about and I have --
25 at the risk of putting it up on the screen I'll still do so is i
, -., ~
. _ ~
4
)
25 1
the difference between short-lived and long-lived components.
2-It's an-important aspect.
i 3
Let me illustrate what I mean.
4
[ Slide.)
l 5
MR. BOSNAKt This has a lot of things associated with i
I 6
it..And first of-all,,I'm talking about the long life of the 7
component design.
And we showed it going all the way into 40 l
8 years.
But you could go just before or could go just 9-afterwards.
10 If-you trend what is going on with respect to the 11 component, you will know exactly what you have to dt,with age-12 related degradation.
The short-lived components, as you can 13 see, are being replaced periodically.
And those are the ones 14 that I think we can both agree on, if they are done with sose 15 sense of perhaps reliability in mind, there are no problems 16 with respect to license renewals.
It is the long-lived 17 components I think that we are all concerned about.
}
18 And by the way, some of the terms that we have on 19 there are perhaps not the best choice of words.
" Fragility 20 level" means to me a point at which the component, system or 21 structure will fail.
The " safety margin" that you see, and it 22 is a variable term, the horizontal term, the constant licensing 23 basis, can be higher or lower depending on the plant that you 24 are talking about.
It is a variable for plants.
But again, 25 for all the plants, wherever you are, it is safe operation for
I 1
29 i
()
1 the first 40 years and beyond.
2 So what we are trying to get at here in the 3
maintenance area is how do we decide what is adequate for the f
i 4
short-lived components?
And I think perhaps that is much 5
easier to do.
But what do we do for the long-lived components, 6
those that have a life perhaps greater than 40 years, 50 or 60?
7 Some of the vessels that are out there, depending on how they j
8 are operated, can go much longer than the 40 years.
But unless 9
you have the information available, unless you are doing your 10 surveillance testing, trending, you won't know where you stand.
i 11 And that is the purpose of showing you this.
12 Does that generate any comments, any discussion?
O 13 (No response.)
14 MR. BOSNAK:
There is a lack of response.
15 MR. THOMAS:
You better respond, or Frank will get 16 back and give some hall talk.
17 What should be required in a rule for maintenance?
18 Anything?
What about trending?
How are you going to provide 19 the assurance that we need that things won't degrade during the 20 renewal period?
Any views?
You don't care?
21 (No response.)
22 MR. THOMAS:
I warned you.
23 MR. GILLESPIE:
I know he was kidding.
But I am 24 going to ask Guy Arlotto -- Would you care to say anything, 25 Guy?
30 1
MR. ARI4TTO:
I would like to ask Bob just one simple 2
question.
Where would you place steam generating recirculating i
3-piping for BWRs on that curve?
Long-term component, or short 4
ters?
5 MR. BOSNAK:
They are somewhere in between, Guy, I 6
believe.
7 (Laughter.)
I I
8 MR. GILLESPIE:
Let me throw one last item out --
l 9
okay.
10 MR. COWAN:
Bart Cowan.
Did I read that slide 11 correctly, that you assume that the safety margins are set for i
12 the long-term components at 40 years?
j 13 MR. BOSNAK:
Some of the safety margins, if they are i
1 c
14 defined in a code, are standard.
This was similar to the u
15 question that we had this morning.
Fatigue.
You have a usage i
16 factor of 1.
And that is defined.
But as you use up your 17 fatigue life, you are going to be somewhere between the zero
[
~
18 and one.
The one is the requirements that the design standard 19 has.
And obviously, you are not going to fail if you reach the 20 level of one.
So that is the, if you will, the safety margin, 21 for that particular parameter.
If you are talking about some i
22 other parameter or some other inherent property, again you have l
l 23 a variable safety margin.
But it is very difficult to try to 24 cartoon here in one diagram things that can vary for different 25 component systems and structures.
~_
31 1
NR. GILLESPIEt Let me raise a question about backfit
]
f) l 2
again.
]
3 There are problems and limitations on the backfit j
4 rule.
And if I understand what I heard on the comments this 5
morning, counter to the way it would stand right now, the 6
comment was that the backfit rule should apply to this rule.
l 7
It should apply to anything extra -- I will call it extra for 8
now -~ above and beyond what is currently in place as part of a l
l 9
license application.
10 And the Staff would have several options for putting i
11 that extra on.
One would be to call it, under 5109 there is a l
12 paragraph under " Adequate Protection," to say this is necessary 13 for adequate.
People understand when we say something is 14 necessary for adequate, there's no exemptions, hence, into the 15 future on it.
16 That means if you don't meet that particular criteria I
17 for adequate, you shut down.
18 I don't know that you really want that.
I don't know 19 that we really want that.
Because when we think of adequate, 20 we think of an integral set of requirements.
And if we have to 21 start looking at every single individual requirement and 22 labeling it, it can present, I will call them bureaucratic 23 problems later, where you work yourself into a hole.
So it is
(
24 very important to think about how you are saying the staff 25 should use the word " adequate."
We are very careful of how we
_ _. ~. _
i i
32 I
)
1 use it any more.
We have lots of fights about how to use it.
2 When some parts of the Staff want to call something " adequate" j
3 on the regulatory side we try to protect our flexibility 4
because we can't tell in the future where we will need to grant 5
an exemption.
So, very difficult.
It is a concept to grasp.
6 And I would ask that wh6a you are preparing some comments on l
1 7
this, think about that, that if the Staff says'this is a
necessary for adequate, be it for welds, pipe thinning or 9
components, there is no exemption from it, from the time it is 10 issued.
11 The other part is we would end up doing some kind of 12 FRIST effectiveness or cost-benefit analysis on other changes.
13 We are hoping, although it is maybe a tiger getting unleashed, 14 that the NRC has developed enough discipline within its own i
15 ranks that it is not our intention to go forth and unmercifully 16 ratchet.
But I will say that, from the way the rule reads, in 17 the perspective of the people reading this morning, it does 18
~ give the impression of the option being there, although it is 19 not our intent.
20 So let me leave those two thoughts there on backfit 21 and please ask you to think about those as you are submitting 22 comments.
e 23 Does anyone else have a comment they would like to
()
l 24 make on backfit?
It evoked some emotion this morning.
25 MR. COWAN:
Bart Cowan.
Let me make a preliminary l
l
.~
1 1
33 j
i
[}
1 comment on one of your questions.
2 Reasonable assurance, or adequate protection, are 3
statutory standards.
From a time concept, what is reasonable 4
assurance at one point in time may not be reasonable assurance l
5 ten or 20 years later.
And what is reasonable assurance at one j
6 point in time may not be reasonable assurance if you are going 7
to extend the life of the plant for 20 years.
So that you can l
8 have requirements that are necessary for adequate protection in
{
9 the context of plant life extension and not shut current plants i
10 down.
In fact, some current regulations, when they were put in 11 as requirements recognized that time concept because they 12 phased in instead of having to have this done by a certain O'
13 date, or so much of this done by a certain date.
+
14 So it is not a cliff, you will.
15 MR. GILLESPIE No, it is not a cliff.
But when it-i 16 becomes effective, then it is effective.
r i
17 MR. COWAN:
That is right.
But it depends on how the 18 rule is written as to those things that are needed, if you are l
I 19 raising the level of what is needed for adequate protection, in i
20 that category.
l.
21 MR. GILLESPIE It applies to both the rule and the i.
22 individual licensing submittals themselves, on the individual l
l 23 backfit basis.
()
24 That's all I have.
No one else talk to me in the 25 halls.
I mean, that consumed my lunchtime.
I-
V
);
s' 34 A
1 John?
2 MR. DeVINCENTIS:
John DeVincentis.
And I am wearing
.n 3
my Yankee Atomic Electric hat.
4.
I feel a little guilty that we didn't go into r
5 discussion a little further with Bob onLthe maintenance and 6
what we are really, how we see maintenance changes being j
'l 7
required.
j
~!
8 And-part of this is, we have a session going on now-l 9
on screening.
And where this really impacts the process is, 10 the screening process itself identifies those issues that 11 require some sort of action to be taken, some sort of 12 evaluation c.r further analysis.
/
13 And until you have participated in the screening 14-
. process itself,-and have done that binning and funneling to 15 identify those components that require something in addition L
16 to what they have, you don't have a good enough understanding 17' of what you are really trying to accomplish.
~
L H
18 I said this morning that what we were looking for 19 from NUMARC with maintenance was anything that had to be 20 addressed we would address with our existing programs.
And we 1
L 21 ourselves on our screening process ><aluated some 600 1:
22 maintenance procedures.
And we bumped up the pr-ticular i
23.
components that were covered by the maintenance program by the l (9 24 adequacy of those procedures.
And if the procedure needed a q) 25 little enhancement like, and since I didn't participate I can't l-
.. ~.
.~
i w
35 i
11 describe what the enhancements were.
2 But say, for example, it was a sticky issue, and we i
~
3.
looked'at'it with our PRA, and'it. looked a little uncertain.
j 4
We might change the frequency of testing it from semiannually 5
to quarterly.
Now, we can handle that in our existing 1 procedures.
7 And subsequent discussion with Frank was, how do we
-8 make sure we are not going to change that again?
Then we've 9
decided we'd flag those procedures.
10 So we are not talking a whole new system, we are 11 working within the current guidelines and practices that we.
11 2 have currently.
And to date we haven't really run up against O
\\- /
13 anything substantial that would have us even consider a new 14 program or changing our philosophy with respect to maintenance.
I am not sure if that is adequate H
L 16 for discussion.
Maybe this afternoon.
Maybe if our people in i
i 17 the bottom end of our screening process free up, they might l~
(
18 give you more concrete examples.
19 MR. BOSNAK:
I think we recognize that the screening 20 session on this one had some overlap, but it was one of the 21 questions that we had here.
I think it's number 13 on the 22 list.
l 23 In reviewing the NUMARC screening document, one of 24 the big problems was those components that are routinely
.( )
25 maintained.
How do we define that?
Is that set by some basic l
l
.l l
36
]
1 tY 1-reliability goals?
What is routine maintenance?
'%-)
)
2 On the slide we had up here, we talked about the L
3 short-lived components.
Guy has something about,it, things r
i 4
-that are somewhere in between, like steam generators and other 5
components.
How do you decide whether or not age-related l
6 degradation is important and may give you a surprise if your 7
routine maintenance'is not adequate and doesn't trend, for 8
instance, and tell you what you should be concerned with or i
9 what you don't have to worry about?
10 So, it was that kind of aspect that we were trying to 11 get at with question 13.
12 MR. DeVINCENTIS:
Well, I think we would be looking 13 at the functional capability of that piece of equipment, and i.f L
14 that equipment function would be diminished in the renewal 15 period, then we'd take some sort of action.
If the pressure 16 boundary was going to be maintained and we could predict it 17 would be maintained for an additional 40 years, then it would 18 be continued to be covered under our existing program.
19 MR. BOSNAK:
But that is based on trending and 20 prediction, what you say.
In other words, say we had a 21 particular plant which had not been doing any work in the 22 trending area and now decided it wanted to come in for license 23 renewal, and I think we had a question like that in one of the j )
24 other sessions -- it was probably 2 or 3, but should you not 25 have any idea of a long-life component -- could be the vessel,
-~
.,~----_
i
-37
[
((~h 1
=could be something else,.but you had no idea of where you were
- ~
- ~ /
t 2
in time, what do you do for; license renewal?
l 5
MR. DeVINCENTIS:
Well, you either do further 4
analysis or change out the piece of equipment.
We're not 5
advocating shirking our responsibility.
I think that our 6
position is we'll do an evaluation, and.if.it isn't clear-fron-7 the evaluation what the corrective action is, then we'll either i
8 change it out or refurbish it or redesign it.
9 I think thers are many options available other than 10 trending'every parameter in the plant, and whether you've been 11 trending it for 40 years or trending it because now you know 12
-you've got to trend it, I think the engineers are capable of 7-.
13-identifying uhere you go forward with the trending and how far l
/
14 back you can responsibly take credit for, but I think the 15 analysis will be very comprehensive.
If I'm going to sign 16 under oath and affirmation,.then I'll be sure as hell that we-17 can stand behind the analysis-that was provided.
18 MR. GILLESPIE:
I think, John, since you've got your 19 Yankee hat on, I'll talk to you like you're a Yankee person and 20 not a NUMARC person.
21 You just describe exactly the situation which gives L
22 me hesitancy earlier in answering the question on if it's L
23 covered by a current program, because I've been to Yankee a
()
24 couple of times, because you were almost to the point of 25 sending in some submittals, some initial work, and in fact, in l'
r
L
-l 38 ta r
/"'
1-those' cases where you had things that were already being V) 2 maintained,-you did-look at them and say is this procedure good-3 3
enough?
Do we have to do anything more to fix it?
{
MR..DeVINCENTIS:
Yes, we did.
4 S '.
MR. GILLESPIE:
We' definitely are not telling anyone 6
to initiats a new program.
Our general expectation is that we.
?
7.
fold it under what exists now, but that's exactly what we saw 8'
.being done there.
It looked like a good job being done, which i
9 gives me hesitancy to say if it's already in a maintenance 10 program, you don't have to do anymore, because there were some 11
~ tweaks that you were making on it.-
12 MR. DeVINCENTIS:
We were.
We are, in fact.
o
-s
(--
13 MR. GILLESPIE:
And there's maintenance and.there's 14 maintenance.
So, I can't view with broad generalities quite 15 yet until I go back and talk to people, because there's certain-16 components that you might walk by and do just a visual-17 surveillance on, or there's certain components that you're 18
' going to strip down, but you're going to add a step into a L
19 procedure that makes sure that the guy checks off or initials l'
'20 off that he's observed that the seat doesn't have any cuts in 21 it.
Now, you'd say, well, a good mechanic is going to see 1
1 22 that, and if he sees a cut, he's going to bring it up, but 23 we'll add the step in just to make sure he knows he's supposed f\\
24 to look down at that seat and make sure there isn't.
g l-25 Those are the kinds of things, in many cases, we 1
.~
a.
1 e
i 39 l
/s 11 expect are going to take care of the concerns that come up.
(_-}
l 2
We're not advocating a massive new program, but also,'on the 3
other hand,;I can't use a vague generality and say everything q
-. 4 -
that's already.having something done to it is good enough.
5 So, I'm groping for a middle ground, and that's why I 6
couldn'tcrespond earlier.
It's exactly some -- what look like 4
7 successful application at a pilot plant -- and that's what 8
pilot plants are for, to demonstrate how to do things -- that 9
gives me pause in reacting to that, and when Don brought up 10 about the short-lived components, I totally agree.
I've got no L
11 problem with that, and as a class, I can cope with that, and L
12 there's probably some other classes I can cope with in'the
, p Ams'.
'13 rule, but I don't know that I can put it all togetner in one 14 class.
That's what I've got to go back and talk to che 15:
engineering guys and -- we have to beat it around a little-16 more.
17 MR. DeVINCENTIS:
Well, maybe after we submit the 18-pilot studies, the pilot system screening results, we'll be in 19 a better position to come up with some suitable appropriate 20' wording that we can understand and can find acceptable.
21 MR. GILLESPIE:
The only problem I have with that is 22 that we're trying to get a rule out by April and you told me 23 your report was coming in in April.
24 MR. DeVINCENTIS:
Our report is coming out --
()
25 MR. GILLESPIE:
The screening report was coming in
,7-40
/-il l'
this month, I thought.
)
t
~
2 MR. DeVINCENTIS:
This month, right.
4 3
.MR. GILLESPIE:
Yes,-but the actual list of systems.
4
-was sometime in the spring.
5 MR.-DeVINCENTIS:
The pilot report is all the system 6
level' screenings.
'7 MR. GILLESPIE:
Okay.
8 MR. DeVINCENTIS:
The component screening for a fluid 9
system and electrical, structural, and INC.
-10 '
MR. GILLESPIE:
We'll see what kind of insight s we 11 can get from it, but --
lL2 MR. DeVINCENTIS:
No, no.
Maybe we can take the lead
.i~
. (
13 14 MR. GILLESPIE:
Okay.
l 15 MR. DeVINCENTIS:
-- and follow it up with some 16 insights from our side.
17 MR. GILLESPIE:
If you could suggest some wording, 1-18 how-would you cut these things into classes?
We're open to
.19 suggestions.
I'm not disagreeing with the concept.
I just, L
20 right now, don't have the words.
So, if there's classes and
.21 you can suggest some wording, I'm more than happy to take it 22 and give it real serious consideration.
23 MR. DeVINCENTIS:
Okay.
24 MR. BAILEY:
Tim Bailey, Northern States Power.
)
25 I think one of the things that's going through the s
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I I
F 41 1
f(#').
1 maintenance area is that we are taking a look at the different
'\\_J r
safety functions of a component, and what we may find is that
. 2 3
it may take more than one effective program, such as an IST 4
program, and to appropriately cover all of the safety 5
functions.
So, I would like to submit to you that maybe this 6
the reason, but it's not possible just to say that since we have a Section 11 IST program on this valve that we have all 8
the necessary programs.
9
'MR. GILLESPIE:
It would cover the functionality of 10 it.
That's why the rule -- the concept we put in there is the 11 way it's there, but for short-term replacement, again, that's 12 an easy class to deal with, maybe that class.
Is there other
,~s O
13 classes you could come up with?
We'd be very receptive to tho' 14 help in-that.
15 I think Northern' States also found that they have put 16' in place a lot of trend programs'to start collecting data to 17' build.the case for why you don't have to do more, and as I 18 recall, you said you were putting them in place at other than
.19 Monticello, or considering it anyway, to design the programs to 20 ensure there was enough-information available to make the case 21 on what you had to or not have to do.
22 MR. BAILEY:
The point I'd like to make about 23 trending is that trending is just one aging-management option
()
24 for those components that have been determined to have 25 potentially-significant degradation, and therefore, I'm not
t 42 I )
1
'sure that it makes a lot of sense to have very post-scripted
'2
' rules"on trending, where I think it basically upLto the utility
'3
.to determine where trending is to be the best option for a 4-managing agent.
5.
MR. GILLESPIE:
We've got to two extremes.
I'll go 1
6 with something Joe Gallo said this morning.
A very general 7
rule is open to.very general interpretation; a very specific
[
L 8
rule is very specific; and somewhere in the middle is what we 9
are shooting for.
10 Right now, in the maintenance and trending area,.we 11~
have something that's very general.
Is there anything any 12 better.we can do?
Is there a topical report kind of something yr-)
'G/
13 that can be written on classes of plants, types of degradations 14 for given environments, or classes of components which could 15 then be referenced, which is kind of a middle ground, and the p
16 staff goes on record with an SER saying we agree with this?
L 17 You know, maybe it's an extension of what NUMARC is 1
L 18 already doing in the component area, and the component report I
s 19 we got on containments was,-in our first looking at it, very 20 good.
We might not have agreed with all the articulation that l1 21 was in there, but the topics covered were the right topics, and 1
22 we felt we wanted to change some "shoulds" to "shalls", but in 23 general, it was a very good report.
It was pretty 24 comprehensive, and that kind of good work, extended into l
25 generic maintenance practices, would be a big help for us,
=
t E.
' 43
' jeK 1
reference-ability-wise, and maybe helpful to you.
U"..
2 Right now, it's left plant to plant.
We have a vague 3
. generality in there that says you're going to do maintenance
- 4 and recordkeeping.
J.x 5
MR. GILLESPIE:
How much is enough?
We are hoping to 6
get information today on how much is enough.
Otherwise, you
' 7.
are-kind of leaving it to us to determine how much is enough.
8 Does anyone have any other questions?
9 (No response.)
10 MR. GILLESPIE:
The priority session is in the room 11 we all started in this morning, but it's got a door halfway 12 across that closed off. - So if people would like to catch the
.13 tail and of-the screening process, it is in that same room,
1 14.
with maintenance as the two key. elements of the rules.
15 Any.other questions?
L
- 16 MR. GRIFFING:-
Ed Griffing from NUMARC.
' 17-I would just like to say that our intentions were to 18 respond to your questions after we had a chance to at least 19
. deliver them our working group.
20 MR. GILLESPIE:
Okay.
21 MR. GRIFFING:
That is one of the drawbacks that we 22 had in preparing this workshop.
So it is not that we don't 23 want to answer.
But we are going to at least attempt to get
()
24 them before the working group to develop our normal consensus 25 approach.
We are not trying to avoid you.
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2 MR. GRIFFING:
We are looking at maybe one week away.
3 MR. GILLESPIEt That's fine.
We are operating on a.
4 pretty tight schedule.
The important part for us to get out of.
5 today was any feedback we can get, but for you to be able to 6
ask us what did we intend by a particular set of words, so that 7
we are talking in the same context?
8 Inevitably we start talking past each other, because
-9 we are not: articulating very well what our intention was.
10
.With all the questions that we listed out in 11 maintenance, I think it was 13 to 14, I think where we are 12 coming from is reasonably plain.
Yes.
f-s
.is' 13 MR. WEISEMAN:. Bob Weiseman from Westinghouse.. I'm 14 not involved directly in the maintenance.
However,-I see part-
'15 of this problem as being moot of what has been talked about is 16 surveillance, where we establish certain requirements-that 17 safety equipment has to meet in order to be able to perform a l
18 safety function, and then you do surveillance to determine when I
19 you must take some action to correct the situation.
And that 20 could be a lot of different actions.
But I don't view that as L
21 being maintenance.
But I see you people are looking at that as 22 maintenance.
I see that as a thing that we have always had in l
1 23 the licensing process, a set of surveillance requirements, so
)
24 that there will be, so we would know that the equipment was in 25 the operating mode that it needs to be for the plant to be
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safe.
And then there was some kind of an action that would be 2
taken.if we found-that.it wasn't, there would be time for some 3
action to be taken before it.would be necessary to alter the
-4 mode of operation of the plant.
'j
-5 But it seems to me from what I have listened to here 6
that the concern seems to have to do with implications that the 7
NRC is going to require certain kinds of. actions to be taken 8
once you have identified the need to do something.
There is 9-not so much a disagreement as the need.to make sure that in the 10' surveillance requirements you have taken-into account -- I 11 think the comment was made that you might have to do 12 surveillance more frequently involving certain items, for some
' \\ss/
13
-age-related effect.
14-If you go back to experience on steam generators, 15 steam generator surveillance requirements were established 16-taking into account the rate at which degradations occur in 17 steam generators.
18 Limits were placed on the, acceptance limits place 19 on the ability to demonstrate that the equipment was able to 20 withstand accident forces, in a loss-of-coolant accident or 21 steam-break accident.
22 So I think it may be helpful if we were to 23 differentiate between that or talk about it as surveillance and
()
24 not talk about it as maintenance.
25 MR. GILLESPIE:
We generally are not differentiating
i i
a1 l
46
()
1 when we use maintenance between maintenance and surveillance.
2
'It is all together.
3'
-MR. WEISEMAN:
'I think it is.two different things.
4
. Maintenance is what you'do to correct things and keep them.in 5-the condition you need.
Surveillance is what you do to 6
. determine when you need to do something.
7 100 GILLESPIE:
I am not disagreeing with that.
I am P
8 just, in our use of it I think generally we include maintenance p
L
~
9
.and surveillance as virtually the same category.
10 In fact, we are not going to-tell you how to fix a
- 11 valve, if you find it broke.
You are going to have an LCO on 12.
it, which is going to give you so much time to fix it and get 13 it back in'or shut the plant down.
14 So in fact, it does stem more on surveillance, or a 15 great deal on surveillance, rather than maintenance.
Because 16 if you can detect it and you know it is not right, then you can
-17 fix it.
18 So I just, I am agreeing with you.
19 Yes, Joe?
He's the man that knows where the 20 microphone is.
21 MR. GALLO:
Right.
My name is Joe Gallo from Hopkins 22
& Sutter.
23 One of the questions that was submitted, and you
)
raised it this morning, had to do with whether or not 24 25 additional programs should be added to the exclusion list.
And
l 4
47 1
I-took a look at them.
And as you know, NUMARC submitted a y
2 document that addressed that subject.
3 It struck me that there-are a number of regulations-.
4 that were addressed in the NUMARC document that are not on your 5-exclusion-list, that ought to be considered for inc?.uzion in 6-your exclusion list.
An example is hydrogen control.
7 As you know, 50.44 contains different measures for 8
dealing with hydrogen generating as a result of an accident.
'9 And the measures differ depending on the containment design.
10 I view those as performance requirements.
And an 11 expert, an engineering expert could well find that those 12 performance requirements, if met, are good enough for the 13' renewal period as they were for the original 40-year period, l
-14 and therefore you need not revisit that for license renewal.
l i
15 I think there are others on the NUMARC list that, if i
16 looked-at from that perspective, might also-make your exclusion 1
17 list.
.18 MR. GILLESPIE:
Okay.
We are in the process of 19 building our exclusion list.
And the difference between our 20 approach and the NUMARC document is, I call it one of research.
l-21 Going back and finding that the old statement is 22 considerations that the rule had in it, says for a license. It L
23 doesn't say what kind of license.
And we are needing to do a
'( )
24 whole lot more research than just saying, you know, this one --
25 I agree.
And what we are going to have to do is, we will be i
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going back and looking.at the exclusion list, looking at those
,:(
2 rules, going-into their statements of consideration, seeing is l
-3 there anything that can catch us in there,'that we have to 4:
counter.with this statement of considerations.
5 But clearly, if'something is dependent on a
'6 flammability limit, then the science isn't changing.
And if e
7 the' science.doesn't change, it sticks.
No. argument there.
8 If you want to help us, tell us what we missed.
4 9-We're-going to go back and do the comparison, anyway.
But the 10 kind of backup we need for it is more in the sense of 11 developing that legislative history to make sure that we-12 encounter it all.
And that level of detail was missing out of-13 what we got.
So we didn't just take that list and use it.
The-14 list we have there actually has that legislative history built 15 already and we have to report about, it must be about three 16 quarters of an inch, half or three quarters of an inch thick.
17 now, as we are building this thing, excluding different 18 sections.
It is not all-inclusive.
So we will go back and we 19 will be relooking at that.
l 20 MR. GALLO:
All right.
I know NUMARC intends to 21 address that question in more detail.
I just presented an 22 example.Yes 23 MR. GILLESPIE:
Yes.
()
24 MR. GALLO:
Let me just suggest to you that the 25 exercise has a byproduct result.
Not only do you enhance or
. _ ~.
~
-. _. _... ~. _ _
49 T2 x ol increase your exclusion list, but the exercise of determining--
2 whether or not a particular regulation should be on your, 3
exclusion list seems to me to represent _a judgment, if it does i
4 make your. exclusion list, that that regulation.is adequate for.
5 the renewal-period.
And that is part of your justification for 6
. relying on the current licensing basis.
7-MR. GILLESPIE:
No, I am not going to use the word 8
" adequate."
I'm going to say that the regulation does not need 9-any supplemental activity to go on with it.
I'm not geing to
'10 use-the word " adequate," just because I am the biggest advocate 11 of never using the word " adequate" in our office.
12 MR. GALlo:
Well,_" sufficient," or any one of the-13 other synonyms.
14 MR. GILLESPIE:
" Sufficient."
~ 15 MR. GALLO:
" Sufficient."
It does.
I agree.
l 17 Anything else?
Yes.
18 MR. COWAN:
Bart Cowan.
There seems to be an 19 underlying assumption on the maintenance, surveillance, and 20 recordkeeping questions, at least on some of them, that some 21 form of maintenance rule is needed as part of plant life 22 extension.
In view of the fact that the Commissioners recently 23 24 dropped the idea of having a maintenance rule and said in
()
25 various forms that it is not required for reasonable assurance,
,. h, '
L l
, +.
l 4
I 1
50-1 what is;the' basis forfnow suggesting that a' maintenance rule or
.2 a partial maintenance rule-be adopted as'part of plant life 1
3~
extension?
q l
4 MR.'GILLESPIE:
Okay.
It is not a maintenance rule,-
5 but it.is the partial piece.
And you can-definitely read that-6 into1the questions.
7 Part of extending the license, part of the basis for 8
that extension;is going to be a commitment of some kind'that we w
9 have-done this screening, these components came out the bottom,-
I:~
it needed this kind of augmentation on each of those 10 11 components, we are committing to doing that, and therefore we' 12 should now have a' license.
p
\\,,/
13 That commitment now becomes a requirement,-a 14 requirement somehow that needs to remain valid now through the.
[
I 15 additional term of the license.
And it is that increment that 16 we are dealing with.
What changes the requirement after your:
18
' reporting cut not required for plants that' don't go in for l
19
. plant life extension?
20 MR. GILLESPIE:
That the component was never analyzed 21 to go past 40 years, that we have evidence that there are 22 cracks showing up more rapidly than we thought in welds.
-23 MR. COWAN:
Once you have that analysis done, what 1
24 changes the requirement with respect to the maintenance rule,
'(\\
d 25 that it is different after your reporting than was present in
-~ _
~51 rs 1
year-35 when-you discovered that there were more cracks than t.
2 you hadithought?-
)
3 MR. GILLESPIE:
If we didn't have confidence that the 9
p 4
. comp? ment would make it from year 35 to year'40, nothing.- But 5
if we have reasonable belief that-it will make it to 40, and gp:I 6
then the plant is going to be-shut down, then it has everything l
7 to do with it.
Because that commitment to do that upgraded 8
' maintenance on that component becomes part of the basis upon 9
which we are~ renewing the license.
Another part is how do you maintain 11 the vitality of that commitment?
12 MR. COWAN:
Let's look at it in a different way.
How 13
-do you define the commitment today for a plant that's 30 years 14:
old with respect to maintenance?
f 15 MR. GILLESPIE:
What do you mean " define the 16 commitment?"
(t 17-MR. COWAN:
There has to be a commitment on present 18' plants.that they will be maintained in such a --
'9 How is that commitment any different than the 20 commitment with respect to plants that have a renewed life 21-because a plant---
22 MR. GILLESPIE:
In order to carry that out, right 23 now, certain components and systems are being maintained and 24 they're being surveilled.
So I'm not --
()
25 MR. COWAN:
That's without a maintenance list.
- aa 52 i
1 MR._GILLESPIE:
I didn't advocate a maintenance rule.
_ f( j/
2:
MR. COWAN:
Why_is the rule needed as part of'the 3
plant life' extension for an extension of the plants beyond 40 l
4 years, it's not required now.
5 MR. GILLESPIE:
It may and up not being there.
The-6-
current rule'-- the conceptual rule we have written doesn't
~7.
have a maintenance rule in it.
It's got a sentence.
So I'm-8 not -- you're trying to read it into the' questions.
Whether 4
9 you call it a rule or whether you do it independently at every 10 plant in the country -- we can try to do it either way so when 11 we ask the questions, the questions were to evoke, should this-12-be'in the rule?
Should it just.be in the rule or in fact, it 13 may be so plant-specific that you can't cope with it any other L
l 14 way than on a plant-specific basis.
Those questions are not 15 advocating or unadvocating a maintenance rule.
They were-16 questions to evoke discussion.
So far, no one has raised a hus l;
17 and cry that says we should put more maintenance requirements 18 into the rule we currently have written.
Jim?
19 MR. SNIEZEK:
Jim Sniezek, NRC.
Let me mention why 20 the words are-in that purported working group language.
About 21 three months ago, four months ago, we had a group of four or 22 five engineers from NRR, Research, along with OGC, sit down and 23 say, what can we exclude from the maintenance rule.
They 24 looked at all the programs, regulatory programs, industry 25 programs that were in place, formal programs.
53 1-They came up with many of the things that you see we 2'
can exclude from the rule.
They-ran into components that'had a 3
40-year design life.
They said, all right.
It's adequate for 4
40 years of-design life but:what's'in place beyond that?
They 5
came to the conclusion-that for some type of periodic 6
surveillance, predictive maintenance, trending, things of that 7
nature that we generically exclude things from the rule to hang 8
'our hat on, we coald exclude a lot more things from the rule.
9.
It didn't exist.
We couldn't hang our hat on it.
.10 That's why'that type of language basically is in the 11 rule'-- the proposed language.
It's as simple as that.
No 12 hidden agenda..
?
13 MR. GILLESPIE:
Anything else?
Okay.
14 MR. RIDER:
(Inaudible.]
15 MR. GILLESPIE:
Would anyone in the audience like to 16 respond?
1 (No response.]
18 MR. GILLESPIE:
I think what we've got and let me 19
_ reference -- I've read through the NUMARC screening criteria 20 that we're currently looking-at.
In the NUMARC screening 21 criteria, there's two types of screening mechanismc in there 22 which cover the same basic block diagram and same steps.
One 23 is somewhat deterministic and one is probabilistic.
()
24 I can cope with deterministic pretty easily.
We 25 probably have questions as I think anyone who goes to the
n i
54 r~~J 1
screening process meeting or looks'at the questions under-
' \\_ I 2
screening process.
There's a number of questions in there on 3
- the use of-the probabilistic.
4 It's not prohibited.
I'm just not sure right now how 1
5-we would cope with it in. regulatory space.
For example,fone of i
6 the criteria in there is -- and someone from NUMARC can corract 7
se on this if I' don't quote it right'-- if a particular 8
component does notfincrease the risk more than a factor of 9'
three or cause the core melt frequency to be greater than 10 to 1
10 the minus 4th, then the component is not safety significant.
11 Is anyone from NUMARC here?
Did I say that 12 correctly?
(l 13.
[No response.]
?
r
'14 MR. GILLESPIE:
It's pretty close.
Something like 15 that.
How do I. cope with a number that's not an engineering 16 number because the PRA now does not have a normalized human 17 being in it.
So now I've got every facility-in the country 18 being able to use a different operator model with different 19 recovery reactions and I don't have it baselined on the 20 operator end.
21 So I can now mask what's going on in the engineering 22 plant with the operator.
Also, it was not necessarily our 23 intent to review 110 PRAs as part of life extension.
Now could 24 they use the IPE one?
If it was done in sufficient detail and
()
25 they could answer some of the questions that are listed in I
1-
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s.
or-
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- 3--
i 55
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j-1 there'to everyone's satisfaction, we'd probably negotiate it or
),s 2
-discuss it but those are tough questions to answer.
a 3
The IPE is looking for outliers and when you start L
4
~ getting down into the refinement of which components or systems 5
are in or out and making regulatory. decisions on it, it's a 1^
L
'6 much tougher decision and there was a lot of concern this i
7 morning about dragging the current licensing basis into 8'
litigation.
9 Well, I think there would be just as much concern I 10 would think about dragging a PRA into litigation and litigating 11-the numbers because it seems like everyone's expert and says
[
12 something different with the same thing.
So we don't 13 anticipate right now the IPE necessarily being used but it's 14 not prohibited and NUMARC has takeh that as one of two ways of f
15 fulfilling their approach and we're going to review it and 11 6 comment back to them on it.
17 MR. WEISEMAN:
I'would just like to direct your 18 attention to what the Commission is doing with respect to 19 prioritizing. generic safety -- that nothing needs to be done.
L
.20 MR. GILLESPIE:
0933.
21 MR. WEISEMAN:
That's right.
I think that there is a-22 methodology that has been adopted, successfully, by the NRC --
23 whatever problems there are -- generic -- using a methodology 24 of that type to exclude things, basically excludes those things
()
25 that do not rise above a significant level of risk.
=
~.
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56 1
MR. GILLESPIE:
Well, I'm going'to fall back and the-t 2_
0933 document deals with things on a generic basis.- Similarly, 3
the safety goal deals with it.on a generic basis.
In making 4
that leap of faith from generic to plant specific, that's a
,5
. technological leap.
Someone may convince someone of it but no 6
one has. convinced me of it yet.
7 MR. WEISEMAN: -Do you talk about how you deal with
'8 numbers?
You do it all the time with express limits and so 9
.forth.
This is something that you do every day in licensing _
10 process.
You have a stress number.
How can you be sure that 11 all these different plants are going to come up with the right 12 number?.You have to review how they do the direct analysis.
-O7 13 MR. GILLESPIE:
Yes.
I don't think it's our position-14 right now to want to do that depth ~of review of every PRA.
15 MR. WEISEMAN:
I don't know that it necessarily 16 requires that but I think --
17 MR. GILLESPIE:
Well, okay.
That's a valid comment.
L
- 18~
MR WEISEMAN:
What's the alternative?
Include a lot 19
.of things that don't need to be included?
l 20 MR. GILLESPIE:
I am not all that convinced that the L
- 21
-- in seeing how the two methods might work, that the 22 deterministic approach includes that many extra items that the 23 probabilistic w. 21dn't.
24 MR. WEISEMAN:
I guess if you can't do it, you don't 25 know.
m j
.57 1
MR. GILLESPIE:
In the one application I did~see of 2
the probabilistic, it screened out core spray and the utility l
3 itself said, core spray, that's important.
You can't screen 4'
that out.
So they put it back in within their process because 5'
they had a review check at that point.
Defense and depth gets f
6 lost on a PRA because you've got multiple systems doing it and-7 it's.those. que'stions, it's that -- going from generic to plant 8
' specific is-a leap of faith that I don't know that we're quite 9
ready to make yet but we're looking at it.
10 If all the questions'we've asked could be'
-1 11 successfully answered, it's probably okay.
So we know we're 12 looking at apples and apples from' plant to plant.
.O_
"w-13 MR. WARD:
Pat Ward, Engineering.
I had talked about 14 the Final Safety Analysis Report, FSAR.
We talked about -- did l
15 you.mean that in the sense of a normal Final Safety Report, or.
16 a safety analysis report for renewal?
17 MR. GILLESPIE:
We picked that up-after we got it up.
18
' I'm surprised it took this long for somebody to come up with 19 it.
20 We've got to noodle the wording a little more.
The 21 intent really is an incremental FSAR, in other words, another 22 chapter on the end.
23 Because actually that's in conflict to what it says
()
24 in the beginning of the rule when it talks about 25 referenceability.
Clearly, referenceability is what we intend
'1 l
4 58
)
i L('T l'
and it's not to generate a whole new document for the sake of a J
L s?
-\\
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-2 new document.
So we would picture some addendum to:the current 3>
SFARs to cover it.
The minimal documentation that we could I
have and fituit in--- limited rewriting.
4 5
MR. BELL:
Frank Bell, Baltimore Gas and Electric 6
Company.
7 I just had a thought I'd like.to give you.all.
One 8f of my hobbies through the years is to track the issue of 9
important safety equipment.
I've noticed that in the t-10 beginning, it seemed like there wasn't a whole lot of
'11 agreement between the industry and the NRC on just what y
l_ O
.12 important safety meant.
l 13 Through the last several years,.until Admiral Zech i
14 recently left the word " safety" kind of took a low profile.
L I
15 You didn't see it a whole lot with the generic writers and L
16 stuff.
l 17 Now, it seems like the word " safety" has raised its 18 ugly head again in this proposed rule.
19 I also noticed that the definition provided in the 20-notice had a striking resemblance to the definition for 21 environraental qualification of electrical equipment, 50.49.
22 So it's not really a question.
It's just that I'm l
23 still not sure what "important safety equipment" means.
I'm
()
24 not sure rehashing the old 50.49 definition does anything for 25 me either, so I am still looking for a better definition of
. ~
- i 59 j-<,
1 what the safety equipment means in the context of license
- 2.
renewalLand why that has no effect on our current, day-to-day 3
'businese.
l t
4 MR. GILLESPIE:
Okay.
I very seldom come up short-5 for.something to say.
6 It, in fact, is not a coincidence that it mimics the 7
Q rule. 'That's virtually by design.
i 8
Our general feeling is that people had finally 9
figured out what that meant.
Therefore, it was probably a good.
10 thing to take on.
I'm not sure that I want to put more 11 definition in the rule or not.
12' If it still appears ambiguous, I think we have to go-13 back and do something to clear-it up, be it in the rule or 14 putting examples in a guide or having a typical example list 15 for a B and a P or something.
We will re-look at the lack of 16 clarity in the definition, though.
l 17' Any other questions?
f 18 (No response.)
19 MR. GILLESPIE:
Thank you very much.
20
[Whereupon, at 2:47 p.m.,
the workshop was concluded.)
21' l
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REPORTER'S C8RTIFICATE This is to certify that the attached proceed-i ings before.the United States Nuclear Regulatory Commission in the matter of:
1 NAME OF PROCEEDING: Public Workshop Concurrent Session-5 DOCKET NUMBER:
PLACE OF PROCEEDING:
Reston, VA-were held as herein appears, and that this is the original transcript thereof for the. file of-the United States Nuclear Regulatory Commission taken by me and thereafter reduced-to typewriting by me or under the direction of'the court report-
)
ing company, and that the transcript is a-true and accurate record of the foregoing proceedings, l'
V,m P -f 1-n $, hft.c l
Dean A.
Robinson Official Reporter Ann Riley & Associates. Ltd.
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