ML19332D407
| ML19332D407 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1989 |
| From: | NRC |
| To: | |
| References | |
| FRN-55FR29043 AD04-1-020, AD4-1, AD4-1-20, NUDOCS 8912010155 | |
| Download: ML19332D407 (55) | |
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OFFICIALTRANSCRIPT OF PROCEEDINGS
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Nuclear Regulatory Commission Public Workshop on Technical and
Title:
Policy Considerations;for Nuclear Power Plant License Renewal i
Docket No.
SUMMARY
OF CONCURRENT. SESSIONS 7y
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l-LOCATION:'
Reston, Virginia l
DATE:
Tuesday, November'14, 1989 PAGES:
1 - 53 1
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ANN RILEY & ASSOCIATES, D.
1612 K St. N.W, Suite 300 Whington, D.C. 20006 (202) 293-3950 g
8912010155 891114 PDP MISC i
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UNITED STATES OF AMERICA j
N_J-2 NUCLEAR REGULATORY COMMISSION i
3 4
5 PUBLIC WORKSHOP
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6 ON I
7 TECHNICAL AND POLICY CONSIDERATIONS i
8 FOR 9
NUCLEAR POWER PLANT LICENSE RENEWAL i
10 11 t
12 Summary of Concurrent Sessions i
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-14 15 Sheraton Resort Hotel 16 Conference Rooms A, B and C L
17 11810 Sunrise Valley Drive 1.
18 Reston,. Virginia i
19 20 21 Tuesday, November 14, 1989 l=
22 1:18 o' clock p.m.
23 24 s
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2 1
SESSION LEADER:
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Themis P. Speis, Office of Research, Deputy Director 3
for Generic Issues 4
PARTICIPANTS:
5 Robert Hosnak, NRC 6
Frank Gillespie, NRC 7
Don Cleary, NRC 8
Larry Shao, NRC r
9 Milt Vagins, NRC 1
10 Ashok Thadani, NRC l
11 James Richardson, NRC i
12 John Haseltine, Yankee Atomic Electric Co.
13 Terry Pickens, Northern States Power 14 Bill Rasin, NUMARC 15 16 17 18 19 20
.21 22 23 24 O
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PROCEEDINGS
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2 MR. SPEIS: I think we are ready to start.
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3 Ladies and gentlemen, my name is Themis Speis.
I am q
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from the Office of Research, Nuclear Regulatory Commission.
Of 5
course, this is the last session of the workshop, and it's l
6 called Summary of Concurrent Session.
The workshops we had 7
yesterday and today, we will summarize this afternoon.
t 8
What we would like to do is call upon the chairmen of 9
the concurrent sessions to provide a summary of most of the 10 important issues or some of the key issues or questions that l
11 were' raised during these workshops, and in addition to our 12 people who do it for the seven concurrent sessions, the (n
13 industry representatives will also provide their summary of 14 what happened the last day and a half here.
15 The next step on our side is to inform our commission l
16 of what took place here the last two days or so.
They have i
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asked us specific questions that we have to provide answers to, 17 I
18 and of course, the other thing that is more important is to 19 take the questions and the insights and the comments that were 20 provided by you and start finalizing the proposed rule.
21 As was indicated the last two days, the schedule for 22 the proposed rule is next spring, and the final rule is 1992.
23 of course, you have provided very strong comments that you 24 would like to see the rule done a year earlier, to make sure q
25 that the rule is available when the lead plant applications l.
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come in, and this.is something that we will have to consider g) 2 very carefully.
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As you know, the key issue that has led us to choose 4
1992 is the issue of the GEIS, the Generic Environmental Impact-
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S Statement, so these are things that we have to think very 6
carefully on, and we will do the best we can.
7 We don't have in mind to provide any positions todef 8
based on what we heard, it's premature.
We understand also 9
that it; addition to what we heard, and the viewgraphs, intustry 10 will provide detailed responses to the issues that have been 11 raised, as well as the answers to the specific questions that 12 we have been able to put together.
/T 13 So we are looking forward to those answers before we b
14 finalize our positions on these important issues.
15 I think, speaking for the Staff, that this workshop 16 accomplished the objectives that we have set forth, We want to i
17 make sure that you people understand our approach, and 18 understand the details of implementing this approach.
19 As most of you have said, there seems to be general 20 agreement or general philosophy on the general approach, but 21 there are differences, different views on the details of 22 implementation.
And, of course, our position has been a draft 23 one, and this workshop is part of the process of going forward i
24 and putting the rule together.
i 25 So, without losing any more time, I would like to 1
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call upon the chairmen now to summarize the issues.
I hope
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2 that they can keep their presentations to no more than 10 3
minates, so we can have some time for the three industry 4
representatives, as well as maybe open the floor later on for 5
some additional questions or comments.- And I am sure that all 6
of you are looking forward to rushing to-the airports or 7
wherever to go back to where you came from.
8 So, with that, again I thought that this was a very 9
constructive workshop, because I had the honor or dishonor of 10 chairing the IPE seminar back in Texas the earlier part of the 11 year, and it was full of fire, and I thought that Zeus was 12 coming down from the mountain.
13 (Laughter.)
14 MR. SPEIS:
So, with that, I will call upon Bob 15 Bosnak to provide his summary of Sessions 1 and 5, 16 MR. BOSNAK:
Yes, thank you, Themis.
17 What I tried to do here first, and we may have left 18 some important ones out, but we tried our best to include all 19 the issues, and the first slide indicates how we grouped these 20 things.
21 A are issues on which there was general agreement.
22 There were five of those.
23 B are the ones that are more difficult to fix.
24 C are the ones that perhaps are easier to fix, and 25 things that were put into categories B or C -- there was not 1
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'l general agreement.
I didn't have a chance to talk with
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industry or the staff, so there may be disagreements on what's 3
easy and what's difficult.
There's a total of 19, as you see
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4 here.
5 Let's just go quickly through'some of them to give 6
you an idea of where there-is general agreement.
7 The current licensing basis provides adequate safety 8
level and, of course, the license renewal should focus on i
9 aging.
10 Next, it is important, we think, because we want to 11 know what is necessary in the area of regulatory guidance, and 12 we did hear some comments that format and content and
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13 screening, there was some guidance needed.
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l 14 Now as far as the lead plants and their influence on 15 this whole process, we would wait for the reviews of the lead 16 plants to see if there is anything else that is needed.
17 The last bullet that you see, specifics and details 18 on Reg Guide versus the detailed rule, I thought I heard that P
19 people preferred to have those in the Reg Guide.
If there's 20 disagreement on those, perhaps in the written statements, you 21 can clarify that.
22 Next.
23 Now we get into the ones that are a little more 24 difficult.
The current licensing basis should not be O
25.
documented, and you only want aging-related portions and time-
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1 dependent exemptions, and we will get into those a little j
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later, because there may be again disagreements as to what the 3
staff feels are important time-dependent areas and aging-1 i
4 related areas, and what the industry as a whole thinks of 5
those.
6 Certification of compliance is unnecessary, and
'7 there's no need to define the current licensing basis in the 8
rule.
Obviously the utilities felt they have a complete 9
knowledge of current licensing basis and they should make this
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10 available.
11 Next.
12 Another one of the more difficult ones is with 13 respect to the conceptual approach is inconsistent with the
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14 basic philosophy.
The requirements with respect to components, 15 systems and structures does not give enough credit to existing 16 programs for managing aging.
These were the points that were 6
17 made.
And it is not necessary to reanalyze design of aging as 18 adequately addressed initially.
It may be difficult to prove, 19 but again that was a point that was made, i
20 You wanted the options, you did not want to have it 21 included in the rule to specifically identify evaluated trend i
22 degradation mechanisms.
You felt that this was excessive, 23 particularly if you looked at all the numbers of components.
24 There are many thousands in a given plant, and you felt that t
25-this was too prescriptive for the license renewal rule.
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Tech specs are not a suitable instrument for
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2 controlling aging management was a point that was made.
3 Backfit.
This is a difficult one.
The rationale for 4
the backfit rule, I think the point was made that it's valid in 5
zelationship to license renewal issues, including aging 6
concernst that if an aging concern is valid, you should go P
7 through the benefit and cost relationships to show that that is 8
a valid point, and the backfit rule again has the built-in 9
procedures that if you were talking about a minimum level, lo adequate protection, it's already included.
11 There was an additional point about ambiguity in the 12 backfit rule and the conceptual approach, and that should be 13 corrected.
14 Maintenance requirements, you felt that they should 15 not serve to replace a maintenance rule, and any requirements 16 put in the license renewal area should relegate itself to aging 17 degradation.
We should accept current practices, supplemented 18 as needed for aging management, to support the license renewal, 19 and aging management methods should not be prescribed in l
20 detail.
Those were the points, again, and they are important i
21 because maintenance is a vital thing with respect to managing 22 aging.
1 23 Now we are getting into the last category, and some 24 people may disagree with respect to easy to solve or hard to c
25 solve, but one of the points that you made on severe accident
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closure was that there is an existing generic letter out, and l
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2 it should take care of the severe accident area, and since L
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severe accidents are not a consequence of aging -- although 4
some people might want to debate that -- tne current licensing 5
bsais should be defined as including treatment of severe 6
accidents.
That was a point that I think was made by Joe i
7 Gallo.
And the accident management programs are being 8
addressed.
The NUMARC working group has guidelines for l
9 evaluating accident management capabilities.
10 The rulemaking schedule, I think, was one of the last 11 things that I wanted'to mention, and you have heard about that 12 again with resfact to mid '91 for the lead plants, but if we 13 are going to couple environmental and technical issues, it may
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go as far as April 1992.
14 15 Now into an area just very quickly of definitions, 16 and there is a group from NRC and EPRI that are working on the 17 time-dependent processes.
The issues that are important to 18 safety, I think the point was made that there is an existing 19 definition of important to safety.
Even though the one that is I
20 in the current rule is clearly stated, there could be some I
21 problems if people don't understand what important to safety 22 really means.
23 And finally, the last thing, the current licensing 24 basis, what we are trying to say here, that there are important l [
25 things that go into age-related degradation mechanisms.
If we l-
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i don't agree on what they are, and that's the last bullet on the
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2 slide, we have indicated nine identified mechanisms -- if we x_
3 don't agree on what they are, then we're going to have problems 4
in trying to decide what to do with respect to the current
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5 licensing basis.
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And the properties and parameters that change with 7
time, we ought to agree on what vital properties and parameters l
8 change with time.
So there is work going on with that.
It was i
9-an area that was perhaps not discussed in the general sessions 10 as much as in the specific technical sessions.
11 Thank you.
12 MR. GILLESPIE:
I want to add two things to what Bob y
13 said, because I think in two different sessions, we went round t
14 and round ar.d round the horn on this.
I try to say this 15 without getting into-toc much trouble.
I've been advised by 16 legal counsel not to do it but I'm going to give it a try 17 anyway.
16 one of the links -- in the wording of the rule, we 19 may have to go back and we'll take a look at it -- but one of l
20 the links between the existing license and this thing, this 21 renewed license, I won't call it anything else than renewed 22 license, it's that ill-defined, is a listing of what the l
23 current obligaticas are.
As those obligations get carried i
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24 fcrward, so do the original findings and it's an important link 25 to make.
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l-1 If you look in the standards, in the conceptual rule l p)
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2 right now, you'll find in the standards that we're not remaking 3
the original findings.
So one reason for having and I'll call 4
it a list, a list of what it is as a minimum, is to make that t
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5 vital link to also carry forward we hope, the findings.
6 Now, that's what we're trying to do.
That's our 7
intent.
I don't know if we'll be fully successful or not but i
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that's the intent of making the link.
So, I was-asked to at 9
least clarify that and that night be helpful.
10 The other thing was in the screening -- in the rule 11
-- our rule has been described as not like a funnel like people 12 would like to see it but more like a trough or a toilet --
13 (Laughter.)
14 MR. GILLESPIE:
-- where everything gets flushed down 15 or nothing gets flushed down.
One of the things that I think 16 we would at least be receptive to some comments on is how to 17 integrate some screening classes, I'll call them, the classes 18 which are very, very well defined into the rule itself, 19 realizing that it never can be all inclusive but it's a middle 20 ground between a prescriptive and a broad rule we currently 21 have now which causes certain analyses and information to be 22 collected and decisions made on every component.
23 The example which came out in one session which is 24 one of the easier cases is, if a component has a fixed life and I
25 we basically have fixed that life because we know everything or
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think we know everything that's going to happen to it over that
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2 time, then why should we have to do an analysis of that piece?
3 Well, that's one class which we'd have to think about it more I
4 but it's a good comment.
It's not currently in the rule and if
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5 there's other classes of things like that which are very 6
definitive, very deterministic in nature, I think we'd be happy 7
to entertain those kind of comments as far as coming to a 8
middle ground in the screening process in the rule.
9 Those were and/or slots.
I want to get Don off the l
10 hook because Level III PRA came up in several sessions and I 11 guess it came up most in the environmental sessions.
I'm going 12 to let Don address it there.
The general concepts of, should
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13 the rule mandate a PRA, as Bob said his slide came across as i
14 no, it shouldn't mandate it.
15 For other reasons not on the technical portion of the 16 rule but on the environmental portion, Don has to deal with the 17 question of off-site doses and some people relate a Level III 18 PRA one for one with off-site doses and I think where Don's 19 going to be coming from is maybe that isn't a one for one 20 relationship.
You maybe can address off-site doses without 21 necessarily going through all the steps of a Level III PRA.
22 For the technical portion, we did not anticipate at 23 this time in the conceptual part, of requiring a PRA.
24 MR. SPEIS:
The next speaker is Don Clearly who will 25 discuss the environmental issue.
That is the issue that
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received considerable discussion, dialogue, views, and cased on
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2 what we heard, at least wishing that you do understand our 3'
position because as I said earlier, one of the objectives of 4
the workshop is to make sure you understand where we're coming 5
from.
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So, Don, we thought, let's go into that issue and
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7 then.we'll proceed to the technical issues after Don is through 8
with his presentation.
9 MR. CLEARY:
We heard a number of points being made i
16 addressing the questions that had been put out in the 11 environmental area.
Our impression was that there seemed to be f
12 pretty much of a consensus.
We didn't hear differing opinions.
13 We heard'that a new age had begun for the license renewal rule,
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14 that the schedule for that rule should be accelerated so that 15 the final rule is published in May of 1991 and this is tied to 16 the lead plant applications.
17 We heard that a generic NEPA study is either okay or 18 there are some merits to it.
We didn't hear any negative 19 comments on it.
That generic study however should be decoupled 20 from the Part 50 rulemaking.
We heard the encouragement that 21 in developing a generic NEPA study that the staff should be 22 very careful to build on existing policies and documents that 23 have been generated over a number of years within NRC, for 24 example, in the waste confidence area.
O 25 We heard relative to the question of Level III PP.A,
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1 an acknowledgement that off-site consequences of severe 2'
accidents have a legitimate place in the NEPA analysis and that 3
these off-site consequence analyses are tied or can be tied to 4
Level III methodologically in that they address the same thing 5
and that many of the tools are the name, or several of the 6
major tools are the same.
7 However, we did not see support for the feedback from 8
these off-site consequence analyses to the decision process on 9
the safety side.
We also heard an offer from NUMARC to work 10 with the staff in developing information that would go into a 11 generic study and we look forward to hearing more hopefully in 12 the responses in the next two weeks as to areas where NUMARC f
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l L,l 14 This is as we develop our work plan for the GEIS i
15 assuming that we get the go ahead from the Commission.
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16 certainly will open this prospect up for further discussion 17 with NUMARC and with any other source of information.
18 Relative to the question on sources, both 19 environmental effects, this wasn't addressed in any detail but 20 we did hear several individuals make the statement that there l
I 21 shouldn't be any significant effects, that whatever effects 22 there might be have been pretty much bounded by experience 23 already.
24 Relative to alternatives, we did hear the advice that
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i definition of exactly what the Federal action is that the NEPA g
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2 analysis is supporting.
I think those are the important points 3
that we got out of the discussion in Section 8.
4 MR. SPEIS:
Thank you, Don.
5 Now we're going to get into the detailed technical 6
issues and the next speaker will be Larry Shao who will discuss 7
the primary boundary.
r 8.
MR. SHAO:
We had very discussion yesterday in 9
Session 2.
Reactor pressure boundary.
It was agreed that the 10 reactor pressure boundary must have very high reliability for 11 the operating life of the nuclear power plants.
The key t
12 components in the reactor pressure boundaries are reactor r"%
13 vessel, steam generators, pipings, pumps, and valves.
b 14 The key aging mechanisms for these components are 15 radiation, fatigue, erosion, corrosion, wear, and 16 embrittlement.
The seven prepared questions we-discussed in 17 great details.
It was concluded that seven code groups such as l
18 ASME, ASTM, are looking at issues of reactor vessel safety 19 programs and currently ISI and IC programs for license renewal.
l 20 For aging of cast stainless steel, it was felt that 21 there were no sufficient data and more work needed to be done l
22 in this area.
However, the experience of cast stainless steel l:
l 23 can be evaluated from our service components.
Mechanical L
24 analysis can be used to resolve this issue, t
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25 In the ASME code -- need to be considered.
These
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1 curves are being developed by ASME and PVRC.
The use of
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2 exotransients in lieu of these X-rays is likely to reduce the j
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fatigue usage factor.
-- in the area of cancellations will 4
also reduce fatigue usage factors.
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For wear overlay repair, it was recommended that I
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improved techniques should be developed and the repair pipings I
7 should be properly analyzed for the effects of wear overlay.
8 It is agreed that a new criteria could be developed.
It is 9
very important that the full experience should be utilized as
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10 much as possible.
11 There was also interesting discussion as to how to 1
12 tackle the issue related to areas that have no detailed fatigue 13 analysis.
There were three options.
The first option is to 14 perform reanalysis.
The second is use analysis and inspection 15 results for similar plants and the last one is use fatigue 16 monitoring.
17 In addition to NRC staff, several presentations were 18 made by the industry groups.
The industry groups have prepared
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19 generic technical reports for PWR and BWR reactor vessels and 20 primary pressure boundaries.
These reports were addressed all 21 age-related degradations.
Each licensee has to show how these 22 generic reports are applicable to his plant.
For areas of the 23 plant that are not properly covered by these reports, plant-L 24 specific analyses had to be performed for these areas.
.O-25 MR. SPEIS:
Thank you, Larry.
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The next speaker is Milt Vagins who will address the V
2-section on fluid and mechanical systems.
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Milt.
4 MR. VAGINS:
Of course, part of our session in i
5 reality was covered oy boundary components.
You can't have j
6.
fluid mechanical systems that don't include boundary components 7
but we stuck more or less to things like pumps and valves and 8
things not generally thought of as the primary boundary.
9 We start off by -- we had seven questions but the way 10 the answers came in, tha way the comments came in, didn't 11 generally follow those questions.
However, one thing that 12 became very clear is that clarification, at least in our area
'13 was necessary to assure that the philosophy of the rule was y
-14 kept into or was involved in the details.
I think you've heard 15 this before and you'll probably hear it again.
The purpose of 16 the proposed rule is to maintain safety of current licensing 17 basis, in other words, assured continued safety -- not to 18 enhance safety.
19 This is what we've been saying all day long.
One of 20 the questions raised was should we require hot functional 21 testing, benchmarking, et cetera, for license renewal and the 22 comment again was that most components are tested, inspected, 4
23 repaired, refurbished, or replaced under NRC programs that are 24 effective now and will continue to be effective during extended O
25 operating term.
Additional requirements are not needed for
p 18 l
Understood, of course, that involved here f
2 were the words, that items not affected or not showing aging 3-degradation.
In other words, this is true, but there are areas j
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-4 where aging degradation which is not or may not be a principal 5
concern now could very well be a principal concern in the 6
license renewal period.
i 7
Of course, pressure boundary degradation needs to be 8
assessed and that was covered by Mr. Shao, so we'll continue on I
9 the next one.
10 What equipment should be included for license renewal 11 review?
Here we have some very succinct statements.
The only 12 components important to safety with unresolved aging 13 degradation issues as stated in philosophy.
The kicker there 14 was definitions of importance to safety and it's obvious we're 15 going to have to do some more work to be sure that we have the 16 definition well pinned down and well-defined and consistent l
17 throughout the rule.
18 Section XX-9 is inconsistent with philosophy because 19, it requires detailed information for all equipment important to 20 safety.
The philosophy again states that we are really only 21 concerned with those equipment which show aging degradation 22 which are not handled by present licensing basis.
The third 23 item was that screening is essential to allow focusing 24 resources on important issues.
O 25 I think of course, there's general concurrence on
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1 that.
That's exactly what we want screening for.
We don't i
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2 want you to waste time on issues that are not important.
There 1
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becomes a basis -- a point -- to agree or disagree as the case 4
may be on what are important issues.
l 5.
The inclusion of balance playing components should 6
. follow same criteria as screening rule.
The issue was brought 7
up about initiators and it was brought up in several of my 8
sessions and I'm sure in other sessions, too.
Again, it's 9
something that's going to have to be examined very clearly.
We 3
10 certainly don't want to be looking at all initiators of balance 11 of plant but we certainly do want to be looking at balance of l
12 plant components that may prevent or mitigate safety systems 13 from operating if they fail.
14 We certainly don't want the old assistance to be 15 challenged more than they are now.
So again, some further 16 points of analysis is required.
There was a definite 17 disagreement on inclusion of components that increased 18 frequency of accident initiators.
This is the point I was talk l
19 I was talking about.
The initiators -- some people felt that 20 initiators -- looking at these subclasses of initiators were i
21 extremely important and the general feeling of the audience was 22 that initiators fall outside the bounds of present day 23 licensing basis and really shouldn't be involved beceuse that's i
24 what the safety systems are for, the backup systems, et cetera, 25 to take care of the initiators.
. -.. - -. - - a
me 20 1
h-lE Then we moved.on to the next one.
of course, the-2
' question alises, do we need augmented inspection and/or 3
analyses for aging pumps and valves and this really became.
,4 involved with today-tomorrow' problems.
We all know that there 5
are weaknesses in the ISC program but we're: working on it.
So 6
comments said that augmented needs will be developed as part of 7
an evaluation procedures for selected components.
The lead 8
plants are working specifically on that.
They did feel.that a 9'
good part of the inspections will.be handled by the IFC's and-10 that the OEM committees on ASME, the NRC, various groups, are 11-working on improving IFC's and those are today's problems.
12 The issue of trending came up in the same area and 13 most comments were, use trending only where absolutely L
14 necessary and where they're effective.
The-issue was brought 15 up that if you have something that is due to replacement or 16 refur; tweent at a periodic period and that period 1c period was 17 shown to be effective, in other words, no increased failure 18
. rate, then you don't need trending.
It's hard to take issue 9
19 with that.
l 20 The next question was should functional or proof 21~
tests be required as a prerequisite.
This is a point I raised-L L
22 before and it goes back to the general clarification and again p
. 23 it says, current in-service testing is sufficient.
If we have 24 problems with in-service assessing, let's settle them today --
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25 let's handle them now.
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The question of what requirements be for including
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. operating-history, water, environment, and higher temperatures-3 of fatigue, evaluation, you've heard that addressed in the t
4 boundary components sections and the same goes here.
Very 5-briefly, ASME is working on it. NRC is working on it.
Other 6
people are working on it and again, I don't see that as 7
tomorrow's problem.
- 8 The next question is tomorrow's problem and that is,-
9 how should the life of ASME Class II and III components be 9
10 determined?
The general comments there were that the two and 11 three components do not normally experience severe thermal 12 cycles and the load cycles are not severe and therefore, the r~}
original acceptability criteria using ASME directions were 13 U
14-sufficient.
However, we brought up that in cases where a water 15 hammer has been identified and water hammer has been an issue, 16 then special analysis has to be attributed to-that.
17-I'm not quite sure what that analysis will be but 18 certainly sonething will be necessary in that area.
19 Final question, I believe, right, is additional 20 guidance needed?
Do the utilities have all the guidance they 21 need to do a good job in license renewal right now?
The 22 general comment was no, no new regulatory guides are needed but 23 after issued, they should take advantage of the NUMARC NUPLEX 24 the industry technical reports and absolutely should not delay
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25
-- there should not be a reason for delaying evaluation and
22-
'l license renewal for the lead plants.
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Again, I'm not quite sure we totally agree with the 3
-fact.that guidance is needed but those were the comments that 4
were made.- Thank you.
5 MR. SPEIS:
Thank you, Milt.
6 Ashok Thadani from the office of Nuclear Reactor
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7 Regulations will discuss the screening methodology for systems, 8
structures and components, and you'might as well stay here.to 9
discuss the electrical systems.
10 MR.fTHADANI:
Actually I think Milt has covered 11 everything,.but since I made these notes, I might as well go 12 through these.
13 The screening methodology session was a fairly lively J('N '
14 session, not quite close to the IPE workshop, but it was 15 somewhat lively..
16 There were three formal presentations.
NUMARC and 17 Yankee Atomic made presentations on the proposed screening 18 methodology.
They indicated that there is a basic 19 inconsistency between NRC staff philosophy and the explicit l
20 requirements of the proposed rule and gave several examples.
L
~21 Bill Vesley of SAI described his work on the use of 22 PRA methods to quantify the impact of aging on component
-23 failure rates, the effect of multiple aging mechanisms, and the 24 effect of maintenance and surveillance programs on failure 25 rates.
o i
~. -
?
23:
1
.These three formal presentations led-to a fair-amount
??';i
{
(,)
2 of discussion, and let me give you a sense of some of the
~
3 issues that people raised.
4 First,.the industry consensus seems to be that the 5
information requirements in 9(c) are in fact excessive.
Milt 6'
also touched on that.
They believe that the required 7L information should be related to the results of the screening i
8 process, and on different aging management strategies that are-9 chosen.
10 They also indicated that the focus of the screening 1
1 11 process should be on structures, systems.and components, which 12 are important to safety as defined in the licensing basis.
13 This initial scope of the systems, structures and f"')T
(_
14.
components should then be reduced, based on existing progranc.
t 15-and those not subject to significant age-related degradation.
16 only the remaining components which have unresolved 17 age-related degradation issues should be required for further 18
. evaluation.
I 19.
.There was a fair amount of discussion on the t
l 20 inclusion of balance of power equipment that could lead to 21 transients.
There seemed to be consensus that it's okay to i
22 include balance of plant equipment if it's utilized to mitigate 23 transients, but not necessarily as the initiating equipment.
24 There seemed to be a general sense that the utility
[~
5 25 that embarks on license renewal activity should have a pretty
q y
s 24 1-good handle on design basis information.
]
2 There was concern that not enough credit, at least 3
the= language in the conceptual-rule doesn't give enough to the i
4 established programs to mitigate aging-related degradation.
5 Bill Vesley raised some questions about whether the'
.6 methodology proposed by NUMARC is able to deal with multiple 7
component failures due to aging and the impact on that_ failure 8
rate.
9 PRAs can be used to evaluate aging effects-and-10 effectiveness of maintenance programs and controlling coremelt
.11 frequency, and are useful in priorization.
The key word there-I 12 is priorization.
13 The NUMARC methodology-is based on a deterministic 1
v 14 approach with PRA used to augment and provide additional-15
. insights, but the sense was that PRA should not be mandatory.
16 Those are some of the highlights of Session 4.
17 Now let me go to Session Seven, which is the 18 electrical systems.
19.
Again there were three formal presentations during l
20 this session.
NUMARC discussed the approach to life extension
'21 of electrical components, with specific smphasis on cables and 22 containment.
23 Yankee Atomic commented on the appropriateness and 24-scope of Section 9 again, and that kept coming up again and L
L 25 again, and I think in all the sessicns.
1
_.,. ~... _ _
=
t J:
25-3 1
Bob McCoy of-Yankee Atomic-also addressed the A
Li
)
2 benefits of existing programs.that apparently are not 3;
recognized,-and indicated that Section 9 should incorporate a
.il 4
screening" process and only look at equipment not in the 5
existing programs, and only equipment subject to'significant 6
aging degradation, one morpe time.
-7 Mr. J.B. Gardner, consultant, gave some comments on c
8 the rule and some of the other issues he was concerned about, 9
and then let me give you again the flavor of the type of 10 comments that were made.-
11 There is, one more time, inconsistency between the 12 proposed rule and the staff philosophy, and there was a
(~}
question in terms of what should.be included under important to 13
'.wJ 14 safety.
A discussion on how credit will be given for existing 15 programs; how much description of these programs should be 16 provided in submittals.
17 There was a fair amount of discussion, but not real 18 answers, I would say, to what are considered the ncW issues, 19 and let me clarify what that means.
Some people in the 20 audience said that we know of a number of problems with 21 electrical systems, and how ate these problems going to be 22 treated in the license renewal process?
And questions came up, 23 are those problems that should be dealt with right now, because 24 they are problems today, and what is the significance of these
,O
\\/
25 problems for license renewal activity?
Lots of discussion; no
e...-.,-
~
~*
~
t a
26.
e t
i
't. _.
1" answers.
'I N_- f 2
Some people, of course, feel that today's problems 3'
should be dealt with today, and should have nothing to do with
- 4'
'the license renewal process, 5
Generally the industry feels that no additional 6
requirements should be imposed on systems that are covered by-l 7
the EQ rule.
8 There also seemed to be a common view that the 9
effectiveness of the EQ program for older plants may need a 10 further look, if one were to go through the license renewal 11-process for those older plants.
12 Redundancy.
There was a fair ametnt of discussion.
-[^\\
13.
What does one mean by.important to safety?' Redundancy is there s).~
14 to provide defense-in-depth, and the general sense was that
~
~15 even failure of a single crane, if caused by aging, should be 16 given close attention.
17 There was a fair amount of discussion, one more time, l
18 on whether the equipment that could lead to transients should-19 be included in the scope or not, just as it was discussed in 20 the screening session.
L
'21 Gardner raised some questions.
He said, you know, 22 this research shows good and research shows bad, and he said if L
23 we~ utilize research, things are actually better than we thought l
'24 they might be and take credit for that, then we should also p;
25 recognize that research is showing that there may be problems
p:
I 27 1
'whereLwe didnft realize there were problems, and we ought to b'e
[
JN/-
=2 focusing attention on that.- I think he was looking for some 3:
balance infthe way we look at the issues as we go through_this T
4 process.
S '-
There was some discussion of what is meant by 6
trending and what needs to be trended, but-a comment was made 7
that was sort-of interesting that -- again it was Gardner,_I 8-think, who said he had looked at some data and found that the 9
root cause analysis was not very good, and he says this root 10 cause analysis is not very good, and what are you trending?
11.
Good question, I think.
12 Also another comment in the area of electrical 13 systems, we focused a lot of attention on cables.
The point 14 was made that we should be careful when we talk about cables, 15 we should really be talking about cable systems.
This includes 16 connectors and so on, the whole thing, and not just cables.
~
L 17 Again the session was quite effective in surfacing 18 some of.the major issues, I think.
19 Thank you.
.20 MR. SPEIS:
Richardson will now give the last l.
21 technical presentation from the staff side on the session on 22 containments.
23 MR. RICHARDSON:
Session 6 dealt with containments.
24 We also had three formal presentations by industry.
e-N_)y j
25 The first presentation, by Bob Nichol, representing
t 28' NUMARC,-noted that there are three industry reports coming l'
.,m.
k_,f 2
'forth in the area of containments and structures -- one on PWR 3
containments, one on BWR containments,'and the third on Class I 4
structures, and he also noted that these industry-reports will, 5~
in general, make generic conclusions, and then it will be up to 6
-each of the licensees to.show that those conclusions are,-in l
7 fact, applicable to their individuals plants, but it was Bob's 8
conclusion that containments, in general, continue to provide 9
the structural and leak integrity necessary and that there is 10 no real concern about corrosion of tendons, or reduction in 11 tendon pre-stress, that cannot be detected over the course of' 12 time, and that fatigue of expansion bellows, which is of
' ('
. concern to people, should be able to be handled by normal 14-fatigue analysis.
'15 He also noted-that there is a need, however, to 16 manage degradation mechanisms in the area of acid attack, l
17 particularly associated with acidic soils and ground water, for 18 those structures that are below grade; also noted a concern 19 regarding floor liner, plates that are beneath the floor slab, 20 attacked by corrosion; and finally, a need to pay attention to l-21 interior coatings.
L
'22 Tim Bailey, from Northern States Power made a l-23 presentation representing the MARC I containment at Monticello, 24 and again, Tim concluded that the MARC I containment is 0
1 25 expected to continue to provide structural and leak integrity.
1
-c
, - -, - i
29 1
TheirLextensive examinations, to date, have shown no f},
' N_/
2-indications of any substantial degradation.
They have 3
estimated that their dry well is good for in excess of.100 4
years; the vent line and vent header good for at least 76 5'
years; and the bellows -- vent line bellows good for something:
6 on the order of 95 years; suppression chamber shell something.
7 in excess of 100 years.
8' Joe McCumber, frca Yankee Atomic, identified what
- 9 they felt were to be the significant issues in the containment 10 area, and that'is liner corrosion; coating degradation, again; 11 boric acid-induced degradation; and vibration-induced 12 structural damage.
. c}'
He pointed out the importance of walk-downs and the
(
13 14-valuable information that can be obtained from a. good walk-down 15'
.and that existing programs need only be augmented, as 16 necessary, when appropriate degradation mechanisms are 17 detected.
18 To repeat a song that has been sung in, I guess, all 19 of the sessions, Joe commented that XX9 goes beyond the basic 20.
philosophy.
One gets the idea that this may have been 21 orchestrated --
22
[ Laughter.)
23 MR. RICHARDSON:
-- and unnecessary.
24 We need to focus our resources on the real problems,
'O, 1
i 25 and the rule needs to better define the screening process.
It e
... ~.
Es i
[
30
[1-needs to be comprehensive, clear,-consistent, efficient, and
- 9d 2=
flexible.-- Sounds like the' Boy Scout oath.
3.
.The belief we heard was that,-in general, the
[
4 degradation mechanisms associated'with containment and 5
structures are pretty well understood.
6 In general, there was comments in response to some of 7
the NRC questions that the NRC itself needs to do a better job 8
and perhaps get'off its collective duff and endorse.IWE and 9
IWL; that they are, in fact, being modified and expanded to 1
10 include inspection of.the base material and that, in general, 11 these consensus standards will do a pretty good job in 12
. detecting aging mechanisms.
().
'13 We heard that we ought to pay attention, take note of L
14
'the testing process itself.
In some cases, it may be L
f15 challenging the containment to the point-of degrading it, and.
L L
16 it's sonething we need to pay attention to.
17 It was also noted that there are no real NRC requirements for inspecting Class I structures, and maybe that d'
18 l
19 needs to be remedied.
20-From time to time, people take core samples of 21 concrete.
Maybe we're not taking advantage of the information L
22 that those core samples may provide and that we ought to devise 23 some programs or methods for taking advantage of these concrete L
.-s 24 core samples when they're extracted, and again, as was pointed l
25 out, the industry reports that are forthcoming will address the l
1 31 s
i 11 need--forladditionallinspections and' tests.in the concrete and
]
y
.rm f(,f 2'
-stee1Lstructures,_and the bottom line is that the feeling we 1
3' heard was!that there is no real'need for rebaselining the.
4
. containment.
.5-MR. SPEIS:
Thank you, Jim.-
'j 1
6 I assume, Jim, that since NRC's Joe Scinto is not 7
here,.what you meant by Joe -- Joe Gallo?
When you said Joe 8.
said something.
9 MR. RICHARDSON:
No, it wasn't Joe.
10 MR. SPEIS:
Oh. VOICE:
Unfortunately, Scinto is here.
12=
MR. SPEIS:
Oh.
My apologies.
My apologies.
Oh did 13 I put my foot into.the --
14
'[ Laughter.]
15 MR. SPEIS:
-- into my pocket.
16' Joe Haseltine, of the Yankee Atomic, will give us a U
17 summary of his perspective of what happened here.
- 18 MR. NASELTINE:
It's with some intrepidation I get up-l 19 here, because I may repeat something somebody-might have said, 20 but I.would like to summarize, from Yankee's point of view,
[.-
21 what we consider the important points made during the last day l
22 and a half, starting with the current licensing basis.
23 As you have heard, we think it should be limited.
At 24 the most, we think we should provide a listing of the documents i
25 that are associated with the system structures and components.
l p
l
c --
t
~32-11 It should be analyzed only to the extent that you need-to for
~
7 c.
, ~ _
2
~ time dependency and for aging of the.SSCs.
c 3,
In-the screening area, we'believe you should only
~4 supply the design'information.that you need to~do your aging 5
evaluations and to do your screening.
6 A total list of' degradation-mechanisms, which a
'7 comprehensive list is probably not worthwhile to try and to'put 8
together, because somebody's always going to dreamLup a new 9
one, and it should be, really, on a component-by-component 10 basis.
11' In the maintenance area, we need flexibility so.that-C 12 when we go through the process, those components that~ don't f~)l 13 have any degradation or that are' covered by existing programs 14 can be put aside, and those that"need a detailed evaluation can 15 have a detailed evaluation.
We shouldn't have to treat them 16-all the same.
17 In the trending area, we obviously don't have to 18 trend every component.
Again, it should be on some type of 19 component-by-component basis.
20 Schedule -- we want to see the proposed rule issued 21-next May.
We want to see the final rule issued 1 year after 1
22 that.
In order to do that, obviously you've got to get into j
l 23 the environmental area, and we believe that you should perform
)
24 an environmental assessment to support the part 50 rulemaking, 25 consistent with the issuance of the final rule in 1991.
1 l
f 33 4
~
L1.
We also need an. administrative change to part 51.20-4 in the same.timeframe.
i I'%.
2 3
We'need a substantial change to part 51 before the 4
lead plant SERs areLissued in 1992.
5 So, it's a parallel path, and that's how'we believe 6
you can accomplish.all. objectives-here and get to 1992'with 7
everything in place.
8 As far as severe accidents, we don't believe there is 9
a place for it in the rule.
It is going to be part of our l
10 current licensing basis, and if you have to put it'anywhere, we 11 think.it should be in the statement of considerations.
12 PRA -- we do not believe that a PRA is needed for t
s j )
13 screening -- you can do it deterministically, but we do believe 14 there's a. lot of merit in using it= individual component 15 evaluations.
L 16 The Level III PRA, we don't believe is needed in the 17_
aging evaluations, since we're only interested in degradation 18 mechanisms.
19 The backfit rule should be applied to the development L
20 of the renewal rule and especially in the review of Yankee's 21 application.
22 (Laughter.)
23 MR. HASELTINE:
Earlier, in the first session, we 24 talked about those programs which should not be subject to a eg
.+ g 25 review, and I think it was Frank asked whether some other
PL,'
34 lL programs should-be omitted,'and we have a few-here.
j
, ~.
k_gb 2
We believe that the station blackout should be
)
31 omitted, as well-ATWS, hydrogen control, decommissioning, fire j
1 4
-protection,_-those general design criteria which~are not subject 5
to age-related degradation,-and those siting criteria which are 6
not subject to age degradation.
7 In summary, we think-the NRC has done.a lot of work, 8
has made aflot of progress, and you should-be-commended.
The 1
9 opportunities for interactions such as this workshop have been 10 very helpful and we think they should continue.
11 Thank you.
12 MR. SPEIS:
Thank you, Joe.
(
13 Now, Mr. Pickens, from Northern States Power, will
- s_ ) -
.14 provide his perspective through his summary.
15 MR. PICKENS:
Thank you, Themis.
16 Actually, I'm going to. play a dual role here.
Based 17 on some input that we received last. night -- or feedback --
-18 primarily from people who were in the Structure, System, and 19 Component Evaluation Section, we just wanted to very briefly 20 run through some of the key points that we made on each one of 21 the steps and that is to go into a little bit what it is as we 22 go through the screening that we intend to provide to 23 disposition components and structures and the type of 24 information that we think is necessary in the application.
~'
25 In the first step, Step 1-A, let me first go back.
l
P 35 1
It's'a two-level' evaluation.
There's a system level evaluation l'
L /T f(_):
2 and once we've gone through the system-level evaluation, we
-3
-take'the systems'that remain that have not be dispositioned and 4-we put them through a component-level evaluation.
I think it's l'
5-worth stressing that we feel we are actually doing evaluations 6
-- not just screening.
We're not just taking things out and-7 putting them out there and. kind of leaving them in never, never 8
land.
We are going to at each step of the process provide
-9 documentation as to why.it was appropriate and how we drew 10-those conclusions for the NRC's review in the application.
11 Step 1-A,.very quickly, just gets into taking all L
12 plant systems, putting them into 1-A and really looking: at E - ]
13 those that are relied upon to operate safely.
We believe that j/ ;
h L
14 the list'of systems that we've come up with, the way we've 4
15 defined'the criteria, comes very close to giving us that list 16 of systems that is important to safety and we didn't have a lot 17' of conflict or discussion on that point yesterday during that-i L
18
. session.
l 19 In Step 1-B, we are going through and we are 20 identifying the systems and structures that significantly 21 affect the radiological health and safety risk to the public.
22 To be dispositioned from further evaluation at this step, we 23 are going to document what the system function is and the 24 conclusion that it does not affect the radiological health and I
)-
25 safety risk to the public and the basis on which we've made
1 gg 36.
~
thaticonclusion.
Again, this1will be part of the application
~1)
.f}?
\\,. /
2 so thst the NRC can review the basis of our conclusion and how-3:
'we're dispositioning it at this point.
4 For those systems which are dispositioned at this 5
. point arid throughout all the steps as we go through, that's o-6 where Jee come from when we say we don't need to provide the 7
level of information that's called for in 9-C of the conceptual 8
outline.
SF Step 2-A, Step 2 is where we get down to the 10 component level evaluation.
This is where we're looking for T
11-those components in a system which do not contribute to 12
-performing a safety function or could prevent or preclude the
'l
)
13 system safety function from being performed.
To be 14 dispositioned, the industry will document that-a component is 15 not necessary for a system to perform the. safety, function and-16 conversely, that its failure also would not preclude the system 17 safety fur.ction from being performed.
18 At Step 2-B, we are going to be getting into 19 reviewing components that are subject to established effective 20 replacement, refurbishment, or inspection programs -- credit 21 for existing programs that we keep talking about.
To be 22 dispositioned from further evaluation at this step, the 23 industry approach would document that the components' safety 24 functions, the degradation mechanisms which could preclude tO 25 those-components from performing those safety functions and the
~
~
l 37 l'
programs which ensure the function is maintained.
>~;
t
(,)
2 So step by step component degradation mechanisms and
'3
-the programs and how they effectively deal with those safety 4
functions and the degradation mechanisms.
5
'At' step 2-c, we're going to identify.those components
'6 which are subject to significant age-related degradation, or, 7
to put it another way, we're going to look for existing, 8
established,' documented sources that have precluded that 9
there's significant age-related degradation that would affect a-10 component.
To be dispositioned from further avaluaticn at this.
11 step, we would reference the documents which previde the basis 12 for the conclusion that the component is not subject to jN 13-
-significant age-related degradation or with the risk criteria
~%l 1
L 14 that are' included,lwe would provide the risk assessment results L
15 which conclude that even if this component went'to failure, 16 that the risk increase would not be significant.
1 17 Finally, at Step 2-D, this is the components which l
18 have been identified, which are subject to potentially 19 significant age-related degradation and if were allowed to 20 occur unmanaged, could affect safety.
We've listed various l
l.
21 options, by no means all-inclusive in the document, as examples l
22 of different ways that we can address it.
Depending on the 23 option that you pick to address, the significant age-related l
l 24 degradation which might affect that component, there's varying 25 degrees of information under 9-C which would need to be
38 1-provided.
.There may-be some which you can just say, I know S(~jfkb 2
enough toisay'that this replacement interval is good.
You 3
provide the basis-for that.
Others where you may want to do a 4
~ complete technical evaluation to justify that the aging
-)
5 mechanism, that you understand it, that you don't want impact 6
at all over the life.
You need to put that forward.
In that-7-
case, you're going to need a lot more information -- design 8
basis, environmental conditions -- all that type of 9
information.
10 So it varies, but at each one of these, we would 11 submit and as part of our documentation for-the lead plant, 12 either reference in our application or supply it, the fr~}
13 information that would justify it through the screening L
~l J 14 process.
I guess that concludes the comments that I want to 15 make for the NUMARC screening methodology portion.
Now, I 16 don't need that anymore.
Now, I'll.go through the NSP L
l 17 comments.
1 1'
18 I guess first Northern States Power would like to 19 express its appreciation for the opportunity to participate in 20 this forum.- I think that it's a very important issue to talk 21 about license renewal.
It's something that Northern States 22 Power has been very interested and active in and I guess I'm 23 very happy to see the progress that we've made over the last 24 six months to a year.
ID 25 I think NSP's commitment in this area is evidenced by s-
v.
c 39 -
j 1
the participation both as a pilot study and now as a lead plant
. /3 I) 2
-to demonstrate the license renewal process and I think beyond
]
i 3
that, it's worth noting too that at Prairie Island,'we have I
)
4
'already initiated activities on plant 1;fe extension and
]
'S-license renewal.
I think there was a question earlier-about, 6
is there going to be some lull after the lead plants come in 7
and I think our response to that is no, we're already. planning 8-on Prairie Island, that shortly after we complete the 9
Monticello license renewal process, we'll be' coming in with our
-10 Prairie Island application.
11 By way of summary on the positions taken by NSP over 12 the last day and a half, we believe the NRC's philosophy stated
('"(
- 13 in the notice of this meeting is sound and that it provides a
%}
1A more than adequate basis to find that the already-existing 15 adequate level of safety will'be maintained during the renewal 16 period.
I~think the important part now is to take that 17 philosophy and the conceptual outline which we've commented on 18 and now take that and'to develop it into a regulation that 19 while it ensures consistency of application, as all utilities 20 go through this process, it also provides some amount of
'21 flexibility, recognizing that by the process that we've
'22 undergone as a way we are licensed, there are a lot of 23 differences between utilities that are out there now.
24 So we're going to need some flexibility in addressing 25 the aging phenomenon.
NSP believes that the approach is
p V
1
=
40 l
J 1
outlined by the industry through the NUMARC NUPLEX working
- (~)
A,._/'
2' group satisfies both of these principles.
It gives the NRC the 3
information that it needs.
It's going to provide consistency q
4 of application, yot it also provides a certain amount of j
5 flexibility for us to meet those requirements.
6 It provides a systematic approach in acsessing the 7
structures, systems, and components which ensures the ability 8
of the plant to operate safely.
In many areas, we-are' going 9
beyond those systems which were considered as part of the 10 original licensing basis into the balance of plant systems.
11-I've heard a number of comments abcut balance of-plant:
12 initiators, which ones are we looking at, which ones aren't.
)
13 We have tried to be careful through the approach that 14 we've gone through on the screening, to look at and be smart p
15 about which balance of plant systems need to be included and 16 indeed, in many cases, the major balance of plant systems which 17 can be initiators are also being picked up as important to 18 safety support systems which support safety-related systems.
19 For those systems which are just balance of plant 20-initiator, Northern States Power believes that it's more of an l-21 economic issue for utilities.
It's certainly not something i-22 that we're going to ignore.
It's something that we are paying l'
23 attention to throughout our overall plant life extension 24 program and in addition to that, there are existing regulatory l
25 oversight mechanisms such as licensee event reports,
. ~
i t.
41
\\
3 1
performance indicators -
different things which cause us to g 1+,,-
[
2 down and look at root cause and as we identify those' types of i
3 things, we follow through on them and if we start seeing-things I
i 4-that come down to increased failure rates from age-related 5~
degradation causing an increase in BOP initiators, we're going
]
.l 6
to take a look at it and make sure it's taken care of.
1 7
Wo. don't think that it needs to be addressed in the 8
definition of Important to Safety BOP Initiators, that'is, 9
being a reason in and of itself to include it in for a_ license 10 renewal review.
j 11 The process allows for focusing of reviews where-12 necessary and it also provides for providing the current
' [ '/)
13 licensing basis-where, in support -- in the~ application wo need w
14 to support the analysis and the resulting conditions and that's-15 the extent to which we feel the current licensing basis should 16 need to be provided.
17 Again, we don't feel that it's necessary to submit 18' the current licensing basis nor confirm its accuracy and 19 completeness.
Current programs to track or to continue to make 1.
20 sure that we can identify the current licensing basis and keep 21 it implemented at the plant and don't undo something that we've j
22 told the NRC that we're going to do, are in place in our 23 current licensee's prograr.s for updating the FSAR, commitment 24 tracking, a number of things that we're doing, and the NRC has 7s
,_ h 25 access through its oversight programs to review these.
l l
u
_~
?-
42
!1 We think-that provides an adequate basis for the j
- continued operation in the renewal' period.
3 The backfit should be maintained during the 4
rulemaking process as well air during the review of our plant-5 specific application.
I think that moreso, we seek not to say 6
that changes shouldn't be made but that the backfit provides a 7
disciplined process which we can all look at and review and see 1
- 8.
if changes are warranted.
9 Severe accident resolution is proceeding.
It's 10 proceeding at Northern States Power.
We're well along on our 11-IPE evaluation and participating in the NUMARC efforts in that 12 area too and we do not think it needs to be linked to the
)
13-renewal-process.
I think that some'of the things I heard 14
'through the technical sessions and things is that there's a 15 tendency to want to get every issue that's open on the books 16 today, closed, and make that if we can part of the license 17 renewal process.'
18 I don't think that we want to say that there are no 19 "today" issues that shouldn't be put in there because there are.
20 some that are very important and will impact the renewal 1
21 period.
However, I think that we should be careful in
-22' including issues that are really "today" issues in trying to 23 put'them into the license renewal area.
It's going to be 24 difficult enough to get through the license renewal process
(>
25 without trying to solve all of the issues that we have on the
~
m
.y
'43 1
books ~today.
We should attempt to keep them-separate and let l :f%
-(_)
-2:
the normal-processes take their own course.
3 The three other quick points that I'd like to hit 4~
because I at times wanted to stand up and respond to questions 5
but I didn't, so I'll take my opportunity.now.
I think the 6
_ lead plants and it's Northern States Power's intention, is to 7 ;..
7 utilize the industry reports to their fullest extent by
'8 reference'and there was some question as to the Section 6 items 9
which are basically those items which could not be 10 dispositioned on a generic basis, those age-related degradation P
11 mechanisms and what the standing of those were.
12' We intend to address in our application those
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13 findings which could not -- those items of age-related-y b
14
-degradation which could not be resolved generically and we will 15 address them in our application on a plant-specific basis.when j
16 we get into those components.
i 17 Another item that I guess I'd like to address is the 18 current codes and what the current code activities are in 19 attempting to address license renewal.
As a NUMARC working I.
20 group member, I am also sitting on the Board of Nuclear Codes 21 and Standards Steering Committee on plant life extension.
I'm 22 aware of the activities that they've got going to try to direct L
23 the code-related activities and improving the codes for license 24 renewal and to provide information to those, that body, to s
25 guide their activities and what they need to go address, we
44-1 have=provided the follow on action item list from the pilot j
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2 study.and I know that as well as the inputs we're getting as we 3
learn things from-the industry reports is-going to that and I 4
think we should continue on with that process andLthat's a very 5'
important process and let the code groups address them as'they 6
see appropriate.
7-Finally, I'd like to address schedule.
I guess we 8
are in complete agreement with Yankee Atomic that we would like 9
to have the rulemaking issued in May of 1991-so that when we 10 submit our application, that it will actually be a 11
' demonstration of that rulemaking and that we agree that we'd 12 like to also have the generic environmental process completed'
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-in a time such that when we get our SER issued, that we can
.V:
L 14 close out some of those issues and I'd like to urge the staff 15 to work towards that schedule if it's at all possible.
L>
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16 That concludes my remarks.
l L
17 MR. SPEIS:
Thank you, Mr. Pickens.
I:
18 Bill Rasin of NUMARC now will give us his summary and 19-his impressions of what happened here.
[
20 MR. RASIN:
Thanks, Themis.
21 I'd like to make a few summary comments on behalf of L
22 NUMARC and the industry.
23 I think this has been a very good workshop.
I was 24 very happy to see the staff summary of the sessions, because it O
25 shows me that they really have listened and, I think, captured s.
- e.., - - -
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J 45
! 1'
.the comments that we had to bring here to this workshop.
. -.n.
2 I do want to make sure I have one opportunity here,
=3' just so that there's no doubt'in your mind that we think j
4
.there's some. inconsistency between the philosophy and the rule, 5-and I. wanted to make'sure we got that point across.
6i I will remind Frank, thought, that he'did ask that 7-question the-first day, and I don't think we'll be accused of
- 1 8-be nonresponsive to that question, anyway.
9 I'm not going to review all of the points and issued 10 that have been made.
I think the previous speakers just did a 11 pretty good; job of that.
I would like to hit a few high points 12 with a little bit of discussion as to what's behind our j )
-13 thinking in some of those points.
14 We had the question of consistency in the application 15 of the current licensing basis and what information should be 16 supplied to respond to the rule and demonstrate the applicable 17-age-related degradation has been taken into account for 18 continued plant operation.
19 There was the comment made that the current licensing 20 basic applicability could be dealt with by making a generic 21 finding in the statement of considerations with the rule, and I i[
22 believe that's one that merits some consideration and may be a j
p 23 way to resolve some of the difficulties and differences.
I 24 Our real dilemma here, I think, is that we need to 25 see the staff lay down the standards for the findings that need l
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46 1 1-to be made, and then we-need to make sure that the information 2
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- 2 provided is fully sufficient to make those findings.
To supply 3
less.in' formation than that'cartainly.is not in the interests =of 4
-the. industry.
To provide more information than'that, however, k
5 5
I think not.only wastes resources in the industry, but I think 6
will cause an inefficient use of resources in the staff,.and we 7-don't think either one.of us can really afford, in this day and
-8
. age, to.use our resources inefficiently.
9 We made some comments and you made some comments, and' 10 I think,.from.your responses, that you will do some thinking in 11 the staff when ycu go back, and I assure you,.we'll do some 12-more thinking in the industry over what you said and make sure
-13 that our position really is consistent and that we are looking i
14 to provide adequate information for you-to make your findings.
15 Let me say just a word about the environmental 16-effects area.
I have a lot of. sympathy with the staff over 17 coming to grips with this area, because, I'll tell you, it's 18 one that has driven us crazy.
Every time we think we L
19 understand it and have a handle on it, we get another opinion 20 that sends us around the loop again.
21 I believe that we have stated the best position that 22 we can bring to fore at the time, and that's that we believe 23 that the schedule for the rule to be put in place in 1991, 24 consistent with the needs of the lead plant, is a major I V(-w g
L 25 necessity.
To that end, an environmental assessment that
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47 i
~1L serves that rulemaking purpose should be done, and I think, as l )[ ~Y
.'2 acknowledged by the staff,-could be done on that timeframe.-
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~3-Now, the' generic environmental assessment to resolve j
4-generic issues, we think, also'iis a worthy goal.
It's one that J
5.
certainly will save the staff resources, but clearly can save j
62 the industry resources, as well.
i
'7 The staff indicated a schedule for 1992 based on the 8
work necessary for that endeavor.
We believe 1992 is probably 9-an acceptable date for that.
Even though it will be behind the 10 rulemaking of part 50, it should have the information available 11 before decisions have to be made on the lead plants and-12 certainly before any other decisions have to be made, f
- {
13 So,,that schedule, if the resources are available for 14-that one, we think probably they both could be accomplished 15 with about-the same resources by that difference in schedule, 16 and I will reiterate NUMARC's offer to the staff that, seeing 17 the' advantage in this process, we do stand ready to work with 18
.the staff.
The work is the staff's; the assessment is the 192 staff's.
However, it we can provide input from the industry in 20 the form of data or anelysis that can serve as input to the 21 staff's work, we will certainly consider doing so.
22 The backfit rule has been covered, and I think it b
23 comes down to the point that Terry Pickens brought up.
It's 24 simply discipline in the process.
X,.J 25 We know, from long history in this business, that all
I 48 I
1 of us have our favorite issues, and I don't mean this to be l
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2 criticism of the staff, because I will say that the industry, I
3 the utilities, our vendors, and certainly our consultants, are l
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just as guilty of finding the latest hot topic to latch on
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5 their favorite issue to.
6 We have worked very, very hard, in our process in the 7
industry in our NUPLEX effort, not to let that happen on our k
8 side, and we've had a lot of criticism and disagreement, but we
{
9 stuck fast to saying let's deal with this issue.
It's hard 10 enough, and the other issues will be dealt with in their proper 11
- forum, i
12 our concern with the backfit rule is simply that we 13 have that Samo disciplined approach on the part of the staff, 14 bee nse to do ctherwise will serve neither t.ne of us.
i 15 Now, with regard to severo accidents, again it's been 16 a conalst ut position we don't like that in the ru?,e.
I must 17 tell you, I'm a little b h tempted to sidy yes, go ahead and put 18 it in the rule, because I assume that would also hold you, NRC 19 staff, necessary to complete your reviews by that rule.
20 However, I'm not so bold -- not that I don't have confidence in 21 you, but I think that that adds an unnecessary degree of 22 difficulty and complication.
I will tell you that we are l
23 committed to resolving the severe accident issue and having the 24 industry respond fully to the Commission's policy statement, L
25 and we'll do cverything we can to do so.
j.
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49 l
./-
PRAs came up in Section 4.
There was a very lively
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2 discussion on the application of PRAs and some the very new 3
techniques on aging mechanisms.
In that discussion -- that was 4
one of the more exciting discussions I viewed in the workshop -
i 5
- there was a very interesting technical disagreement betwnen j
G three experts for whom I have a good bit of respect, but as 7
noon as I get disagreement between experts for whom I have a 1
8 great deal of respect, that tells me that technology is not 9
ready for application on a general basis.
1 10 I think that we should PRA as input where we have it 11 and for what it can tell us, but we are not ready to have PRA 12 be a requirement, and I don't think that the NRC is ready to l
13 use PRA to make formal. licensing decisions.
}
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L N-.
14 With regard to having PRAs in place only for purposes 15 of the environmental asoects, I would subnit that tha.t's an 16 awfully expencive way to do so'aething that we have done pretty f
17 successfully other wais in th9 past.
l 18 There was some concern, in Session 5, that discussion 19 of maintenance took place, and there was not an adequate 20 response from the industry on those issues, although in the l
21 slide that was put up on that, I think the right idea was 22 captured.
25 However, let me take about 30 seconds and answer the 24 first 9 questions, at least, on the maintenance, surveillance, f.
t 25 and testing.
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50 t-1 We in the industry and you in the staff are putting a
-( )
2 lot of effort into the maintenance question.
I do not think 3
that we have hidden our feelings too deeply that we in the 4
industry would rather not have a maintenance rule.
- However, 5
it's our burden right now to convince not you, the staff, but 6
the Commissioners that, in fact, we are doing enough in the
[
7 industry so that a rule is not necessary.
8 I don't there is any misunderstanding on the part of
[
9 the Commissioners or the staff that we hold that position 10 because we're against maintenance or don't realize 11 maintenance's fully importance to the safety of operation of 12 nuclear power plants, but let me say, again, that's its own j'~
13 issue.
It is receiving tremendous attention in the industry, i
14 and it should be solved on its own merits.
15 If it comes cut that the wisdom of the commirsion is i
14 that there should be a maintenance rule, it will hecome part of L
17 the current licensing basis, and I'm spro we'll t ake full l
18
, advantage of it for the purposes of licence renewal.
l 19 If, on the other hand, it's concluded by those 20 Commissioners that it is not necessary, then I think that 21 decision should stand and we should not try to use this other 22 process to put in place things that were not gained through 23 that very extensive dialoguing process.
24 To that regard, I think that is the answer for about 25 at least the first nine questions, I don't think they need to l
l
5 51 1
be answered one by one.
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2 Industry, through the NUMARC NUPLEX process, does 3
have in place, still, a significant amount of work.
We 4
promised the staff 10 industry reports.
These reports are 5
being sponsored by DOE and EPRI, and we are committed to 6
getting those reports out on schedule.
We have modified that 7
schedule with what we think is a schedule consistent with your 8
rulemaking schedule, and we'll do everything we can to make I
9 sure that those reports get out on time and are submitted to lo you, and we'll also look forward to your questions and comments 11 and will answer those as expeditiously as we can.
12 Finally, let me end up by saying that I, too, thought
/ T 13 this was an excellent workshop.
7 did have some comments from GJ 14 a few people, particularly some of the consultants and invyers, 15 that they nissed the entertainment of industry and staff 16 yelling at ona snother and calling one another incompetent, but 17.
I hava to tell ytu, I didn+t miss that.
I think th.ts was an 18 excellent exanple of a way that we can proceed forward, working 19 fully in public, but on a very professional level, to state our 20 views and trade our views and then act on them afterwards, i
21 S o,
.7, thank you very much for this opportunity, and I 22 hope this is more indicative of the way we do business in the 23 IPU workshop in the future.
i 24 Thank you, t
25 MR. SPEIS:
Thank you, Bill.
l l
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52 i
i 1
Well, according to the schedule, we're right on time.
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2 So, I would like to offer you some options.
3 There is coffee available, but possibly, the coffee i
4 can wait, unless you think this discussion can go on much l
5 longer.
Maybe we can go on for the next 5 or 10 minutes and 6
see if there are any questions or some things that have been 7
somehow missed from the presentations or some thoughts that 8
were generated as the speakers went through their summaries and i
9 see how we go from here.
f 10 So, let me open the floor to any questions or any
?
11 comments.
i 12 (No response.)
(
13 MR. SPEIS:
No takers, huh?
-(.
14 Well, I guess we have done our work.
i 15 MR. GILLESPIEt We need to leave on a lighter notet 16 1 would like to apologi.ze for using tha word 17
" initiator" in the first session.
I will never do that again.
18 MR. SPEIS:
Well, if there are no questions and if 19
-there are no comments, that means that we have done our work 20 properly and and efficiently and effectively, and I would like 21 to take this opportunity to thank all of you for participating 22 in this very effective and educational seminar workshop.
23 Especially, I would like to thank the lead plant participants -
24
- Yankee and Northern States Power and NUMARC.
r 25 I would like, also, to thank Donna Matson for
i 53 1
organizing this workshop and doing it so effectively and having rx(,)
2 coffee on time and water in front of the speakers and so and so 3-forth.
4 I wish you good trips back home, and hopefully, we 5
won't have to see you before the proposed rule.
6 Thank you.
i 7
[ A, clause.)
8 (Whereupon, at 2:50 p.m.,
the meeting was adjourned.)
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REPORTER'S CERTIFICATE
(
This is to certify that the attached proceed-ings before the United States Nuclear Regulatory Commission in the matter oft I
NAME OF PROCEEDING:
Summary of Concurrent Sessions Public Workshop 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.
,3
/s f.f /.
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(O) q2,9 7. hys yt
,t Kevin Mahoney
official Reportar Ann Riley & Associates, Ltd.
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