ML20045C135
| ML20045C135 | |
| Person / Time | |
|---|---|
| Issue date: | 06/10/1993 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9306220119 | |
| Download: ML20045C135 (87) | |
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.D 6l BRIEFING BY EPRI ON POLICY, TECHNICAL AND LICENSING ISSUES PERTAINING TO EVOLUTIONARY AND ADVANCED LIGHT-WATER REACTOR (ALWR) DESIGN bOC3(bO3l ROCKVILLE, MARYLAND D3I6l-JUNE 10, 1993 Pag 6Sl 75 PAGES NEALR.GROSSANDC0.,INC.
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l DhSCLAIMER
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This is an unofficial transcript of a meeting of the United States Nuclear Regulatory commission held on June 10, 1993, in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general I
informational purposes.
As provided by 10 CFR 9.103, it is t
not part of the formal or informal record of - decision of the matters discussed.
Expressions of opinion -in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the commission in any proceeding 'as the renuit of, or addressed to, any statement or argument contained. herein, except as the commission may authorize.
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o NEAL R. GROS $
Count htpotitti AND TRAN$CRittti 1313 RHoot ISLAND AYtHUG. M.W.
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BRIEFING BY EPRI ON POLICY, TECHNICAL AND LICENSING ISSUES PERTAINING TO EVOLUTIONARY AND ADVANCED LIGHT-WATER REACTOR (ALWR) DESIGN PUBLIC MEETING Nuclear Regulatory Commission One White Flint North Rockville, Maryland Thursday, June 10, 1993 The Commission met in open session, pursuant to notice, at 11:00 a.m.,
Ivan
- Selin, Chairman, presiding.
COMMISSIONERS PRESENT:
IVAN SELIN, Chairman of the Commission KENNETH C.
ROGERS, Commissioner FORREST J. REMICK, Commissioner E.
GAIL de PLANQUE, Commissioner 9
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3 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
SAMUEL J.
CHILK, Secretary MARTIN MALSCH, Office of the General Counsel R.
PATRICK MCDONALD, Vice Chairman, ALWR Utility Steering Committee, EPRI JOHN TAYLOR, Vice President Nuclear, EPRI JOSEPH SANTUCCI, Manager, Advanced Reactor Development Department, EPRI JOHN DeVINE, JR., ALWR Program Manager, EPRI
}
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P-R-0-C-E-E-D-I-N-G-S 2
11:00 a.m.
3 CHAIRMAN SELIN: Good morning, ladies and i
4 gentlemen.
5 The Commission is very pleased to welcome 6
representatives of the Electric Power Research 7
Institute to present their views on the policy, 8
technical and licensing issues pertaining to - the 9
evolutionary advanced light-water reactor designs.
10 They'll also brief the Commission on the status of the 11 advanced light-water reactor program.
12 The staff briefed the Commission on the 13 policy and technical issues associated with both.the 14 evolutionary and the advanced designs on May 14th of 15 this year.
I'd like to stress EPRI is a very 16 important organization.
_Its focus is somewhat 17 different from the vendors.
EPRI more or less 18 represents the customer as the features that the 19 eventual people that operate the power plants would
~
20 like to see in their reactors.
So, continuing to get 21 views from EPRI as well as from the vendors, from 22 NUMARC, from the general public is of great benefit to 23 the Commission to make sure that we understand all 24 aspects or as many aspects as possible of.the 25 interests of the different parties as these important t
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projects go forward.
2 I understand that the EPRI's presentation 3
slides are available at the entrance to this room.
4 Commissioners, do you have anything?
5 Mr. Mcdonald, we welcome you.
6 MR. MCDONALD: Thank you. Thank you very 7
much.
I'm looking for my slides.
8 CHAIRMAN SELIN:
All the screens are the 9
same.
10 MR.
MCDONALD:
- Well, we're here to 11 present you with some information and make some 12 requests from you.
Our presentation will have about 13 five different parts in it and I will lead off and 14 then others will follow me.
15 Our objectives today in this session are 16 about three-fold, tailored to the material we want to 17 cover.
One, we have an objective of trying to assure 18 their regulatory stability.
- Second, we want to 19 assure -- as you indicated, our representation is the 20 utility.
So, we're trying to assure that the users 21 are getting in these designs what they think they need 22 to for them to be viable.
The third is a simple 23 requirement put in for design.
The devil is in 24 details, as so many of your people remind us, and we 25 are going to talk about some details, technical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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i details today which I think are very important because 2
some of the details, when we put them in things like 3
bids and we're going to build plants forward and 4
design and build can have long-range implications for 5
safety as well as cost.
So, those are the objectives 6
that we're going to be talking about today.
7 We have been having a very active ongoing 8
discussions with the staff and I must say we've had 9
some very productive discussions.
So, it's a sense of 10 working together with the staff and the Commission to 11 fully inform you of what our needs are.
i 12 Now, along that same line, sort of our 13 platform for discussing these things and our 14 understandings of how we're proceeding, we believe 15 that by our past discussions and submittals and so 16 forth that we are completely aligned about where we're 17 trying to go.
We're both interested in safer plants 18 and better plants, and so we think we have a common 19 ground with you.
We are pursuing the process that's 20 been agreed upon and that is the utilities set the 21 requirements in the so-called URD, the utilities 22 requirement
- document, NRC reviews and then as 23 appropriate approves and endorses them'via a safety 24 evaluation report. On that basis, we can proceed with 25 the certifications with a high confidence that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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requirements that are codified are the appropriate 2
ones for both what we need and what is needed to be i
3 proper regulation.
4 One other point that we're looking at 5
now, and I'm sure you are too, is that in this process 6
of going down certification by Part 52 is that no new 3
7 regulatory requirements are needed as part of this 8
process because of the way it's designed.
Our utility 9
requirement documents requires plants to exceed 10 current regulations and safety goals by a wide margin.
11 We want these to be not just as good as present plan, 12 but we want to try to make them as good as technology 13 can allow us to make them at the present time.
l l
14 So, we would note that in the subject 15 document today, that that document would treat these 16
- margins, and some in many cases, as regulatory 17 requirements.
18 CHAIRMAN SELIN:
I'd like to stop you at 19 this point.
Before you leave today, I'd like you to 20 go into this point a little bit further because the 21 Commission would be uncomfortable being put in the 22 position that says, "We're relying on a utility 23 requirement document to meet some regulatory 24 purposes."
So, before you leave, we'd like you to i
25 discuss, or at least I'd like you to discuss --
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1 MR. MCDONALD:
Let me just comment.-
I 2
perhaps did not express that correctly.
What we are 3
doing is we're putting forth the needs for the design 4
for our purposes and in doing that we're attempting to 5
make those robust enough that they will incorporate 6
what you require for regulation.
It's not that we're 7
trying to design regulations or anything like that, 8
it's that we're trying to encompass what you require 9
in the way of safety in present plants or what have 10 you.
Does that respond to it?
11 CHA1RMAN SELIN:
It starts, but if we I'm not in favor of more regulation 12 incorporate 13 than we need, but if a feature or a margin is 14 something that we agree is important for safety and we 15 incorporate it'in the regulation, would that -- how 16 would that affect either the utilities or the vendors 17 adversely?
18 MR. MCDONALD:
Well --
19 CHAIRMAN SELIN: If they're going to meet 20 the requirement anyway by putting it in a regulation, 21 what does that force them to do that they wouldn't 22 otherwise do?
23 MR. MCDONALD:
All right.
That's a very 24 good point.
You can always put another thing on that 25 is sensed to some way increase safety.
As you hang on i
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these extra requirements, and the way you hang them on 2
can make a plant more complex, and we're going to talk 3
a little bit about that today, make them more complex 4
and in the total they don't become more safe bccause S
they get too complex.
6 CHAIRMAN SELIN:
I don't want to argue 7
philosophy, but when you get to the details there are 8
three possibilities.
One is the design is going to i
9 meet the requirement anyway.
Putting it in the 10 requirement really is institutionalizing something 11 that at least currently people agree to.
12 MR. MCDONALD:
Right.
13 CHAIRMAN SELIN:
A design could meet the requirement, but you're afraid that the requirement' is 14 15 going to be too prescriptive.
So, it's not only going 16 to say you need a certain margin, but you need to meet 17 it in a certain way.
Well, the third thing is your 18 statement isn't strictly correct that the safety 19 margins -- that by putting something in a requirement 20 we would effectively ask for even a greater safety 21 margin than you would propose.
22 MR. MCDONALD:
All right.
We'11 try to 23 point something out like that.
24 CHAIRMAN SELIN:
Because these are key 25 questions about how far we go in these --
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MR. MCDONALD:
Yes.
Well, let us come 2
back to that and be very straightforward about it.
3 CHAIRMAN SELIN:
Thank you.
4 MR. MCDONALD:
As we look at that basis 5
and continue on, on the SECY-93-087 we think that 6
that's been a very valuable and is a very valuable 7
paper.
We've worked with the staff extensively on it 8
and I think that paper contains all the major policy 9
issues.
It's a summary of the issues that have been 10 resolved and outlines the work that remains.
11
- Also, I would like to highlight the 12 recent actions that's ongoing to define the matter of 13 the regulatory treatment of non-safety systems and the i
14 source terms.
That's been very encouraging.
The i
15 regulatory treatment of non-safety system gets down to 16 the heart a little bit of what you were asking right 17 now, but that's another aspect of it.
18 CHAIRMAN SELIN:
But there you are 19 pleased with the --
20 MR. MCDONALD:
Yes, very pleased.
Very 21 pleased.
What we have done -- and thanks to the 22 staff.
What we have done is we have been able to 23 think about t~nis matter of safety-related and non-24-safety-related to the sense that allows us to simplify 25 some things.
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the process.
2 Now, the positions described today that 3
we have are, in fact, very close to those of the staff 4
recommendations in almost all cases.
The closure and 5
implementation details are important to achieving this 6
design and I think we all agree upon that.
We're 7
going to talk about some details today.
We're going 8
to talk about three issues, but we're also going to 9
talk about some details.
10 Following on will be Joe Santucci who is 11 going to talk a
little-bit about our history 12 involvement with the SECY process on these policy 13 issues.
14 Go ahead, Joe.
15 MR. SANTUCCI:
Thank you, Pat.
16 The purpose of the next couple of slides, 17 really just two minutes, is to provide historical 18 perspective as to how we come about to be here today.
19 There's been a suggestion that some of 20 the issues that we are raising are, in fact, the new 21 issues and we wanted to clarify that this is not the The ALWR Program, EPRI identified optimization 22 case.
23 issues very early in the program.
In fact, as far 24 back as 1986 or 1987.
These were basically areas 25 where the design solution could simplify the licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON. D.C. 20005 (202) 234-4433
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process and really ' provide a way to affect tho 2
simplification or relief in.
the regulatory j
3 requirements.
One example of this is the elimination 4
of the OBE that we've come to agreement with the staff 5
on.
6 In early 1990 the staff prepared SECY t 7
- 016, which listed the number of issues related 8
primarily to evolutionary plants and we provided 9
comments on that document.
Later on, anticipating 10 that staff would be putting together a
similar l
11 document covering passive plants, we went ahead and 12 provided a separate list of central issues, what we 13 considered to be central issues. This was supplied to 14 the NRC in 1991.
These were basically high priority 15 items that had to be resolved or at least understood 16 well enough because they had a big impact.on even the 17 conceptual design development. One example of this.is
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18 the RTNSS issue that was just mentioned.
19 The staff identified additional issues 20 and released the draft positions on this several times 21 during 1992, in February and in-June, and we provided 22 comments in May, August and December.
I think the i
23 concept of developing a draft and reviewing this draf t 24 with industry is a very good concept and we-really 25 commend the initiative of the staff in doing so.
e 9
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We've had discussions.
with staff 2
management on some of these issues in detail, in 3
particular the RTNSS issue at our January 1993 meeting 4
in Palo Alto.
There was an extremely productive 5
session and we think largely responsible for the 6
progress that we have made to date, in particular with 7
respect to RTNSS.
8 Now, we have not had a chance to review 9
with NRC management a resolution of some of the other 10 key items that we felt were critical central issues 11 through the passive plants.
We've had a number of 12 interactions with the staff, but not had a chance to 13 interact with management on these items.
14 On the 12th of April, SECY-93-087 was 15 issued with really no explicit requests for comment.
16 We have reviewed the document internally and really 17 feel that generally it is a good document.
It's quite 18 clear that a lot of effort went into it and many 19 issues have been resolved to the satisfaction of both 20 the NRC and industry.
So, it's a very, very good 21 starting point. Nevertheless, some items important to 22 us remained open and we decided to comment.
We have 23 reviewed this with our utility steering committee and 24 they agree with this position.
Further, NUMARC and at 25 least two of the design teams have also decided to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
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provide their comments in writing and I believe.that 2
letters have been received.
I apologize for the 3
typographical error on the slide because it is two.
4 COMMISSIONER REMICK: Westinghouse and -+-
5 MR. SANTUCCI:
And ABB.
6 COMMISSIONER REMICK:
ABB.
7 MR. SANTUCCI:
Yes.
GE has not decided 8
as yet to provide written comments, but they may 9
still.
We're still interacting with them.
10 I should clarify for the benefit of all 11 that we've had, of course, a number of interactions 12 and discussions with all of the design teams and we 13 all agree with respect to the positions in which 14 you're going to be hearing today about the critical 15 items of differences of opinions.
16 Now, we supplied comments to the NRC 17 staff on the lith of May.
I took us about a month to 18 sort through that'very comprehensive SECY.
Then, of 19 course, we had to review these comments in detail with t
20 the Utility Steering Committee, which we have done,
-L 21 and on the 7th of June, really just last week, we were 22 able to provide an official reply endorsed by the USC.
23 It turns out that the June 7th submittal and the May 7
24 lith submittal are identical effectively.
There.was 25 really no change that we obtained from reviewing this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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matter with the steering committee.
2 So, we're asking for this briefing 3
because the USC really wanted us to communicate that 4
not withstanding the great progress that has been made 5
today, we do have a few critical issues.
We have 6
three or four that we want to talk to you about in 7
detail today_which have been closed by the staff, but 8
which we believe warrant further consideration.
We 9
did not realize at the time that this took place and 10 that the final SECY would not reflect a resolution of 11 our concerns in these particular areas.
In the past, 12 really much of the success that we have -- much of_ the 13 progress that has been achieved has really resulted j
l 14 from our ability to resolve issues with NRC i
15 management.
I think the meeting in-January was a 16 beautiful example and the resolution of the RTNSS 17 issue is just a beautiful example of that process i
18 working.
I 19 We've not had the benefit of this for the 5
20 issues that we're going to be talking to you today and 21 this is really part of the request that we're making 4
22 to you, for us to be able to go back-and work these 23 things through with NRC management.
1
- j 24 So, this concludes --
25 CHAIRMAN SELIN:
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at this point, Mr. Santucci.
2 MR. SANTUCCI:
Yes.
)
3 CHAIRMAN SELIN: The Commission is not in 4
the habit of asking outside advice on documents that 5
the staff prepares for us.
But in this case, partly i
6 because there hasn't been as much work done in closing 7
the loop on this set of issues as before and partly 8
because the staff has asked for resolution rather than 9
publication for comment of these points.
We've 10 acceded to your request to hearing, to hearing your 11 arguments at this point.
12 MR.
SANTUCCI:
We understand and we 13 really thank the commission for providing us this 14 opportunity.
15 CHAIRMAN SELIN:
Thank the staff.
16 MR. SANTUCCI: And the staff, yes. Thank 17 you.
18 Next, Jack DeVine will cover in detail 19 the issues in the SECY.
20 MR. DeVINE:
Good morning.
21 Thanks, Joe.
22 As Joe indicated, my objective is to walk 23 through in some more detail the issues with which we 24 have concern, point out our basis for concern and give 25 you a better idea of why we're really here, i
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In so doing, I will try to be responsivo, 2
Chairman Selin, to your question about specific l
3 examples of good requirements turning into regulation 4
which then turn out to be restrictive or pose some 5
difficulty to the designers or to the operators and 6
there are examples.
7 I would like to simply provide the 8
observation that across the board, since 1985, we've 9
been creating requirements, working with the utilities 10 and with the Commission.
In the lion's share of these 11 areas we've reached closure, both in terms of what the 12 requirements should be and what the regulatory 13 treatment should be.
The bulk of the items which 14 showed up in SECY-93-087 reflect that agreement.
It 15 is only in those specific areas where we --
16 CHAIRMAN SELIN:
Let me just make sure 17 that I understand the process.
At the end of this 18 point the Commission is being asked to vote on the 19 staff's positions, but it's my understanding, is it t
20 your understanding that even at that point the 21-positions are tentative in the sense that they will be 22 cmbodied in a draft rule which will then go through 23 the full public comment where yourselves and the 24 general public will have a chance to comment on these 25 positions or do you feel that the positions will be NEAL R. GROSS j
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embedded so deeply in the rule that it will be 2
difficult to have general discussion of them?
3 MR. DeVINE:
I may be the wrong person to 4
ask.
5 MR. MCDONALD:
Let me answer that.
I 6
think in the things that we'll bring forward, such as 7
the first one on the seismic, our comments on this 8
previously were not reflected in the dialogue and 9
there was no rationale that we know of, for example, 10 of requiring a.6g, which is in excess of a.5g, which 11 is far in excess of what present plants have.
So, in 12 terms of completeness of presenting this to you to 13 pass it on for comments, we thought it would be better 14 to talk to you at this time about it rather than wait 15 until later.
16 CHAIRMAN SELIN:
But it still goes into 17 a draft rule and this is not your last shot nor 18 anybody else's.
Is that correct?
19 MR. MCDONALD:
.Oh, I understand that, but 20 we've worked very closely together and we sort of want 21 to keep in lock step and not let this thing get too 22 far down the road before we note -- have our comments.
23 MR. DeVINE:
Let me make an additional 4
24 point, however.
Two points, one is the designs are 25 proceeding and they're proceeding based on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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designer's best assessment of what it takes to moot 2
the requirements document and what the Commission will 3
accept.
In two places that I recall, and probably 4
more in the SECY document, the words " final" are used.
5 So, this was presented as the final position of the 6
staff.
So, those who were busy trying to design the 7
plant figure, this is what we're going to have to live 8
with, notwithstanding later rules.
9 CHAIRMAN SELIN:
So, you'd like to get 10 these considered fully at the earliest --
11 MR. DeVINE:
Yes, sir.
12 CHAIRMAN SELIN:
-- before there's a lot 13 that might have to be walked back.
14 MR. DeVINE:
Yes, sir.
And we'd like to l
15 put in perspective that for the most part we're in 16 agreement that the points of disagreement may appear 17 to be minor, they're minor in numbers, but as Pat 18 pointed out the devil is in the detail.
19 CHAIRMAN SELIN:
My point had nothing to j
20 do with whether there are 2
or 200 points of 21 disagreement.
It had to do with the _ process by 22 which --
23 MR. DeVINE:. Understand.
4 24 CHAIRMAN SELIN: -- the public, including 25 EPRI --
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MR. MCDONALD:
I think we have a good 2
process.
I think this is trying to make me thorough.
3 MR. DeVINE:
(Slide)
Gary, could I have 4
the first slide, please?
5 Let me first try to lay out the score 6
card, if you will, on the whole set of issues in SECY-7 93-087. There were 42 issues identified by the staff.
8 They were really in three categories.
- One, the 9
earlier evolutionary plant issues in SECY-016.
10
- Secondly, an additional set of evolutionary and 11 passive issues which have evolved over time, and the 12 third is set which were considered by the staff to be 13 passive only and generally in the future.
In their 14 positions, the staff then further classified those 15 issues in terms of some which required a decision on 16 the part of the Commission, some which were provided 17 for information and some which were in the future bin.
18 I would point out that we reviewed them 19 all and while most of our comments relate to those in 20 the decision bin, not all, because we felt they all 21 deserved attention.
We've been way out front in the 22 requirements document.
Most of these issues that 23 we're talking about, I think in every case, the issues 24 are topics which have been covered very proactively 25 and aggressively in the requirements document.
In NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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many cases our concern relates to the specific working 2
of the application which we feel is either incorrect 3
or inconsistent with the understanding we have with 4
the staff or perhaps vulnerable to some 5
misinterpretation later on.
6 From that total set of 42, we ended up 7
with three issues which we classified as disagree in 8
part.
There were no issues with which we disagreed 9
categorically and even in these three we're largely in 10 agreement with the staff's position.
There were six 11 for which we felt some additional comment or 12 clarification is needed to the degree that it was 13 worth talking to you about it. There were many others 14 in which we might have some fine tuned details and 15 we're just not worried about those.
16 In the process of the vendor's review, 17 two other issues were raised which we had not raised 18 and we simply point out that if you look in the 19 correspondence you'll see those as well.
Then, 29 20 issues with no disagreement at all.
21 (Slide)
Next slide, please.
22 Walking through the three specific ones I
23 in which we have concerns, the first is issue II.N and I
1 24 it -- and specifically our point of concern has to do j
i 25 with the seismic considerations to be applied to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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design beyond the design basis.
.That is, more 2
specifically, what assessment is required of the 3
seismic capability of the plant beyond the design 4
basis safe shutdown earthquake.
We agree in concept 5
that there should be an assessment of the additional 6
seismic margin in the plant design.
We took an 7
aggressive position in the requirements document to 8
provide such margin and in that respect we've gone way 9
beyond what is required for current plants.
10 I would first like to point out to you 11 what level of margin really does exist here.
Current 12 plants were built or designed without any assessment 13 of margin beyond SSE.
In the IPEEE process, current 14 plants are now going back and doing that examination 15 to consider events that are outside the envelope or 16 caused by external events and they're applying margins 17 which are substantially less than the margins we 18 proposed in the requirements document.
For round 19 numbers, most sited plants have peak ground motion 20 accelerations in the neighborhood or less than.2g for 21 those plants.
NRC, for current plants, requires that 22 they examine their capability to withstand earthquakes 23 up to.3g or a factor of one and a half above that 24
.29 25 In the requirements document we've gone NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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r 22 1
beyond that in two levels.
First, we established a 2
standardized SSE, which was intended really to permit 3
standardized plant designs and to envelope all sites.
4 We'd point out there that that is implicit margin for 5
most sites.
We've established
.3 as the threshold.
6 Most of the existing sites in the U.S. would fall well 7
below that.
So, we're already starting out with 8
margin.
We've proposed on top of that a seismic 9
margin assessment to the.5g level, which is one and 10 two-thirds again on top of that.3g and aa factor of 11 2 or 3 or 4,
depending on what the actual ground 12 motion is on a site-specific case, which is really the 13 margin which counts in terms of the confidence we have 14 and additional capability of the plant design.
15 The staff position largely reiterated the 16 importance of assessing and assuring that the designs 17 have some margin beyond SSE and we concur with that, 18 but the specifics we disagree with are in two areas.
i 19 First, they use the number.6g rather than. 5 as that 20 limit for seismic margins assessment, and secondly i
21 they proposed a methodology for analyzing it, which 22 further compounds the problem.
I'll try to describe 23 clearly how that works.
24 Point one, we've gone way beyond where we 25 know existing plants are.
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discussions with the staff -- and I've got to tell you f
2 that seismic has been one of these things that goes on' 3
and on forever and we've just discussed it endlessly.
4 We have not yet heard a
rationalization or 5
justification or some specific benefit which accrues 6
if we go from.5 to
.6.
With any margin discussion, 7
we come up with the how much is enough issue.
We 8
really think
.5 is enough.
Our concern with going 9
beyond
.5 is more than simply a matter of it is 10 potentially more hardware, potentially more analysis, 11 potentially more difficulty, potentially more 12 requalification, more burden on the operators.
It's 13 also venturing into an area of significant 14 uncertainty. There is much less information out there i
15 among the component suppliers based on hard experience 16 and previously demonstrated analysis in that region of i
17
.5 to
.6.
18 The staff has taken some comfort from an 19 analysis by one of the vendors to the effect that a-20 shutdown path which they examined would be 21 satisfactory at the
.6 level.
We think that's fine.
.]
22-It's evidence of a good, strong design in a plant that J
23 we want.
I think it is exactly the kind of. thing, l
i 24 however, that you raised in your question to Mr.
25 Mcdonald.
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-sure -- and it's not one of the three categories you 2
laid out.
We're not sure how this will play out to 3
the whole set of components and systems and structures 4
in the plants to which it might be applied and we may 5
be in an arena in which that seemingly easy extension 6
of the regulatory requirement results in real pain and 7
cost on the part of the owners.
8 CHAIRMAN SELIN:
Not to nit-pick the 9
thing, it doesn't sound to me as if this case meets 10 Mr. Mcdonald's situation.
You really don't know if 11 the design would meet a.6 requirement.
It's not that 12 there's a safety margin that would make
.6, but you 13 just don't want to m'ake it mandatory.
You're saying 14 that both for cost reasons and for the weakness of 15 analysis it would be hard to certify a design at --
16 MR. DeVINE:
But if the staff or if the 17 Commission were to require
.6, we would then be in a 18 mode where even though we don't know how hard it would 19 be to meet it, we'd have to meet it in the cost.
20 CHAIRMAN SELIN:
Sure.
21 MR. DeVINE: This thing was aggravated by 22 the second point of our disagreement with the staff's 23 position and that had to do with the methodology one 4
J 24 uses. The industry, working with EPRI, has made great 25 progress in deciding and figuring out, and with the i
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Commission as well, obviously how to deal with IPEEE.
2 The seismic margins assessment is fairly 3
straightforward and it involves ensuring by analysis 4
that there are two safe shutd wn paths which will 5
survive an earthquake at the mandated higher level, 6
which is generally at the.3 level and in some cases 7
it's higher, depending on the site-specific seismic 8
design.
9 The staff's position requires a PRA-based.
10 analysis which requires the probabilistic likelihood 11 of higher seismic events comes into play and it's one 12 of the areas in which there is least certainty because 13 it's out at that high acceleration end,. 5 to. 6, that 14 the uncertainty is gceatest, that there is the largest 15 disagreement among us and among the industry.
I'll 16 tell you there are wars 'iithin EPRI and the other 17 industry advisors about what those seismic hazard 18 curves really should look like.
If we compound the-19
.6g with the requirement to analyze it 20 probabilistically with all kinds of uncertainty about 21 what the likelihood of that higher earthquake is, we 22 end up with potentially much higher loads, potentially 23 more difficult design considerations, and we think for 24 no value.
If you - walk. around existing plants and 25 listen to what people complain about, they complain a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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1 lot about what seismic design costs and what demands 2
it places on the plant.
We think we've gone way 3
beyond existing plants prudently to provide extra 4
capability, but this incremental step from
.5 to
.6 5
and the methodology requirement we think is simply 6
carrying it too far.
7 MR. MCDONALD:
And would be far beyond 8
the safety goal.
9 CHAIRMAN SELIN:
There's sort of three 10 kinds of questions one might ask, at least three 11 kinds.
One is what's the thread.
In other words, 12 what information do we have on seismic pieces?
Do we 13 have empirical evidence that says such a high over 14 pressure is just so great that you really shouldn't --
15 this acceleration is just beyond what we need to look 16 at?
Are you contesting the seismic historical l
17 information that the staff is using in arriving at 18 this situation or do you draw different conclusions 19 from the same data?
l l
20 MR. DeVINE:
I. don't think we have seen 21 from the staff a basis for this extension from.5 to 22
.6.
Our experts at EPRI claim that it's not there.
23 CHAIRMAN SELIN:
Second is if a plant 24 were to be built in a relatively high seismic area, 25 would you just say you wouldn't build a plant or are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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+
1'~
there steps that you would -- non-standard steps that 2
you would see if one were to the high end of the 3
envelope?
4 MR. DeVINE:
We established an envelope 5
in the requirements document which would be suitable 6
for most sites and we think that's in the 90 percent 7
range.
For those outside, and that would have to be 8
dealt with in the specific design application.
9 CHAIRMAN SELIN:
Would you just rule out 10 the sites, or would you say, "No, there are measures, 11 but we don't want to see them standard because it's 12 too expensive to do?"
13 MR. DeVINE:
Exactly.
14 CHAIRMAN SELIN:
What kind of measures 15 would you see in sites that were otherwise suitable 16 that close to.the edge?-
17 MR.
DeVINE:
That's_ a hypothetical 18 question.
I think in those cases, depending on how 19 far outside the envelope it was, the' specific design 20 requirements and the demonstration that one could meet 21 it.
22 MR. MCDONALD: We simply haven't designe.d 23 the standard plant to meet all sites at the higher 24 seismic level.
1 25 CHAIRMAN SELIN:
Yes.
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MR. MCDONALD:
We've excluded those.
2 CHAIRMAN SELIN: Well, the third question 3
is sort of the second question skewed a little 4
differently.
Not that you're required to do this in 5
oi-der to make this comment, but have you some sense of 6
a difference in cost between these two standards?
7 MR. DeVINE:
No.
It's very difficult to 8
quantify. And again, GE's look at one narrow piece of 9
the plant suggested that for at least that subsystem, 10 the equipment they had selected would meet both 11 requirements.
So, the costs would presumably be zero.
12 We're very unwilling, however, to enter into that, on 13 the strength of that small sample, the conclusion that 14 it would go beyond.
15 Again, I will tell you from operating 16 plant experience that where seismic gets us in trouble 17 is -- I think most painfully and continually is in the 18 purchase and selection and use of replacement plant 19 equipment which requires greater analysis and failure 20 information or questions come up in the arena of other 21 licensing issues or other plants and we're continually 22 in this highly complex analytical mode at plants for 23 which I used to be responsible, oyster Creek was put 24 on-line in 1969.
We are still redefining the seismic 25 envelope and reanalyzing equipment in that plant, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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we'd prefer not to start out with a very onerous set 2
of seismic requirements for this new one.
3 CHAIRMAN SELIN:
It's a little unusual, 4
but what I would suggest since these are quite 5
disjointed issues is the Commissioners just ask the 6
questions on --
7 MR. DeVINE:
Sure.
8 CHAIRMAN SELIN:
-- the specific issues 9
as they --
10 COMMISSIONER ROGERS:
Fine.
11 CHAIRMAN S"LIN:
I think we're all 12 looking to you.
13 COMMISSIONER REMICK:
Oh, okay.
14 Jack, the words that the staff'used are 15 a PRA-based seismic margins analysis.
Now, I must 16 admit I'm not sure exactly what the staff meant, but 17 I assume from that that they were saying that you 18 would perform a seismic margins analysis based on the 19 intelligence of PRA on where might the vulnerabilities 20 be.
Now, that was just how I read their words.
21 You've been interacting with the staff.
Do you have 22 definite indications that'it's other than what I've 23 indicated?
I read those words differently.
l 24 MR. DeVINE:
Well, I think that your 25 general description is correct, Commissioner Remick, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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but the specifics of how that analysis is done are 2
rather uncertain.
Let me tell you I am no expert on 3
seismic margins analysis, but I've spent a fair amount 4
of time trying to understand what the levels are.
As 5
I understand, the analytical processes, if you will 6
there's a
continuum of possible more and more 7
sophisticated analyses.
But the approach that has 8
been agreed upon for existing plants and which we are.
9 proposing involves simply the demonstration of two 10 shutdown paths which can tolerate higher seismic l
11 independent of PRA.
12 The idea is that --
13 COMMISSIONER REMICK:
But the staff is 14 saying, "We don't want to follow the seismic PRA - "
15 MR.
DeVINE:
Right, that's the other 16 extreme.
I 17 COMMISSIONER REMICK:
"-- that we should i
18 go through a margins analysis."
19 MR. DeVINE:
Right.
20 COMMISSIONER REMICK:
Intuitively that-21 appeals to me and I thought this is what. people 22 generally felt was the more realistic approach.
So, 23 that's why I read their-words as a former seismic 24 margins analysis and I presumed it would be somewhat 25 similar to what we've done in the other plants.
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I must admit I haven't put that question to the staff 2
to make sure my understanding of the words is correct.
3 MR.
DeVINE:
I think we're reaching 4
closure because as you point out, and I had the same 5
reaction, the other extreme is a seismic PRA --
6 COMMISSIONER REMICK:
Right.
which is applying an 7
MR. DeVINE:
8 infinite number of different probability, different-9 intensity earthquakes to the plant.
It's very, very 10 complex and it's dependent upon this projection of 11 likelihood of high earthquakes which is very uncertain 12 besides.
13 COMMISSIONER REMICK:
Yes.
14 MR. DeVINE:
The PRA-based analysis is 15 more in the middle in which point values are taken,- as 16 I understand it, from a seismic hazard curve and then 17 applied through the PRA process to those parts of the 18 plant which may be vulnerable.
As a consequence, the 19 numbers of parts and pieces.and components which have 20 to be analyzed to a higher seismic capability is 21 likely to be greater than in the baseline approach 22 we've proposed.
My understanding, perhaps even more 23 importantly however, is that this goes from ugly to 24 very ugly if you try to get out to the
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very uncertain.
That's why I said these two are l
2 really compounding in their effect on the design.
3 COMMISSIONER REMICK:
Part of the IPEEE i
4 process was plant walkdowns. Now, we're talking about 5
paper reactors at this point with no walkdown.
Does 6
that give you any kind of -- is there any kind of a 7
conflict there in carrying out the process that was 8
done with the existing plants? The analysis can still 9
be done independent of an actual plant.
1 10 MR. DeVINE:
I think so.
11 COMMISSIONER REMICK:
Okay.
Another 12 question.
The.3g design basis earthquake and the 13 utility requirements document, what part of the U.S.
14 roughly would that exclude or include?
I assume --
15 MR.
DeVINE:
I believe it includes 16 virtually all of the U.S. except the California sites, l
17 or the West Coast sites, j
18 COMMISSIONER REMICK:
That was my 19 impression too.
1 20 MR. SANTUCCI:
I think the target was to 21 cover more-than 80 percent of the sites east of the 22 Rockies.
23 COMMISSIONER REMICK:
East of ~the 24 Rockies?
Okay.
25 Now I have a question I'm not sure you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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can answer. But suppose for existing sites when we're 2
doing the seismic margin studies that are ongoing or 3
I'm not sure if they're completed or not, but suppose 4
the seismic margin earthquake at that time had been 5
.5g as you're proposing for the new design.
Do you 6
happen to know for how many plants this would have 7
represented a margin of at least 1.67?
8 MR. DeVINE: I's looking through my notes 9
to see if I have some numbers on those.
I'll answer 10 from memory, but I really have to qualify it.
I 11 believe that when I asked a similar question the 12 answer was that 90 percent, approximately 90 percent 13 of existing sites have SSEs of.2g or below and then 14 consequently as a result the IPEEE process would do a 15 seismic margin analysis to
.3.
So, I think the answer 16 is 90 percent, but-I'm doing that from memory.
I 17 don't see it on the sheet.
18 COMMISSIONER REMICK: Yes. I wouldn't be 19 surprised by that, that most of them are.2g or less, 20 except for Diablo and a few others that are in there.
21 I would assume from what you're saying'then that if 22 they had met -- if the. seismic margin earthquake had 23 been set - at
.5g, they would have margins even in 1
I 24 excess of 2.
25 MR. DeVINE:
Yes, well in excess of 2,
l I
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34 1
and also it may -- I didn't mention this, but as a 2
separate issue with which we agreed with the staff 3
- position, we've eliminated the operating base 4
, earthquake and one of the real reasons for doing that 5
is we ended up with two competing design trains and in 6
some cases the'OBE became controlling.
In the case 7
that you're describing, if a plant were designed at 2 8
SSE with a margin at
.5, the.5 would probably end up 9
dominating at least parts of the design.
10 COMMISSIONER REMICK: So; also from that, 11 if you're right that 90 percent of the sites, the 12 design basis SSE'would be two-tenths of a g or less 13 and you use.5g, the margin would be over two anyhow.
14' MR. DeVINE:
Yes.
Yes.
Absolutely, and 15 that's the real margin. That's the margin that counts 16 and that's the point we're trying to make because our 17 standardized design is such that we've got a lot of 18 plants out there that were designed to
.3 and 19 installed to.3 as an SSE, as a design basis SSE in an 20 area which a site-specific analysis would suggest 1.8 21 is good enough.
22 MR. SANTUCCI:
.18.
23 MR. DeVINE:
Or.18.
Thank you, Joe.
24 CHAIRMAN SELIN: We can accept that of fer' 25 right at --
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COMMISSIONER REMICK:
That's all the 2
questions I have on seismic margins.
3 COMMISSIONER de PLANQUE:
Just one.
If 4
you look beyond the United States and look to 5
countries where they're actively considering new 4
6 plants, how much does that percentage change that 7
might be within the.3?
8 MR.
DeVINE:
I think it changes 9
significantly for the Far East plants.
But --
10 COMMISSIONER de PLANQUE: And if you took 11 it to the.5?
12 MR. DeVINE:
I am guessing.
I think it 13 is the same kind of ratio, but I'm really not 14 guessing.
I am guessing and I'm not qualified to 15 answer that question.
16 MR. SANTUCCI: Conversely, if you look to 17 Europe as an example, the.3g number is very, very 18 conservative.
19 COMMISSIONER de PLANQUE:
Right.
Okay.
20 COMMISSIONER REMICK:
But am I correct 21 that some countries in the Far East where bids are i
22 out, that 3g is considered the SSE?
23 MR. SANTUCCI: - Are you thinking about the 24 Taiwanese --
I 25 COMMISSIONER REMICK:
Yes.
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1 36 1
MR. SANTUCCI:
Yes.
I am not -- I know 2
that they've used the utility requirements document in 3
large part as they prepare their bid specification, l
4 but I am not familiar with what actually changed this 5
number.
6 MR. TAYLOR:
I would suspect they might 7
be designing to a higher number then.
8 COMMISSIONER REMICK:
You think'so?
9 MR. TAYLOR:
I don't know.
Just like we 10 would in California.
11 COMMISSIONER REMICK: I'm not sure you're 12 right, but you might be.
Okay.
13 MR. DeVINE:
The next issue is number 14 II.M.
I think this one is easy.
Design reliability 15 assurance program.
Once again, let me emphasize that 16 we've been in sync, I think, with the staff all along 17 on reliability assurance program.
Doctor Murley 18 raised the question initially, probably four or five 19 years ago when we first started talking passive plants 20 and we picked up the charge and developed a plan for 21 both design reliability assurance programs and 22 operation reliance assurance programs.
23 This issue was identified by the staff as 24 a future issue.
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are a lot of nuances about how the reliability 2
assurance program is going to play in operation of the 3
plant, which need to be agreed upon.
However, there 4
is the specific requirement in the issue-statement to 5
the effect that the design reliability assurance 6
program should be a part of tier 1 rulemaking for 7
design certification.
In our view this is quite 8
inconsistent with the concept of rulemaking on design-9 specific issues which are important to safety.
10 This is a program.
It is by definition 11 a framework.
It is somewhat vague in the sense that
~i 12 interpretation will be applied through the course of 13 the design. Some flexibility is needed and we've felt 14 it was important to extract this element of that issue 15 even though the issue itself will come back to you 16 later and bring it to your attention, because again j
17 the designs are being ' developed now and design s
i 18 certification work is in process.
So, that decision, 19 if the vendors are going to comply with that, they 20 need to know it today and we would argue strongly that 21 it shouldn't be.
Had very strong support from the 22 vendors on this point as well, and that's really our 23 only concern with the issue as__ stated.
24 COMMISSIONER REMICK:
How would you 25 classify this, then, as Tier 2 or is it a programmatic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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,a-w e
38 1
XTAAC?
2 MR. DeVINE:
Tier 2 at most.
It could 3
certainly be handled programmatically and, as we point 4
out in the slides, we've covered it through the 5
requirements document and our initial intent was to 6
carry it that far and let it guide the design.
We 7
didn't even see a regulatory role for that, although 8
we don't disagree at all that reliability is important 9
to you and at a tier 2 level I think it's quite 10 tolerable.
At tier 1 it becomes a rigid inflexible--
11 COMMISSIONER REMICK:
Have you had 12 discussions with the staff of why the statement, tier 13 1 versus tier 2?
14 MR. DeVINE:
No, we have not.
- Really, 15 this is a very late addition to our list, frankly. We i
I 16 had set that aside as a future issue and when we 17 examined it carefully we thought we'd better raise it.
18 And again, I think it's maybe to some 19 degree an example of the question you asked.
This is 20 an area in which we've tried to establish requirements 21 which are important which in effect add marginal l
22 restraints to the design.
But once they become i
23 regulations, then we can become a slave to those and 24 we can be trapped and that's further than we wanted to 25 go.
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COMMISSIONER -ROGERS:
But on this 2
particular issue, you really haven't tried to thresh 3
it out with the staff yet?
4 MR. DeVINE:
To my knowledge, we've not.
5 Let me ask John Trotter, who is here, if a
6 that has come up.
7 MR. TROTTER:
No.
8 COMMISSIONER ROGERS:
I heard a mumble.
9 MR. TROTTER:
No, we have not.
10 MR. DeVINE:
It was an unamplified "no."
11 COMMISSIONER ROGERS:
Thank you.
12 MR. DeVINE:
The third issue is, and I 13 keep saying this over and over and over again, it is 14 yet another issue in which we've had very productive 15 dialogue with the staff and come a long way to 16 reaching closure.
But on one specific point, we've 17 not reached closure and it's a very important one, the 18 high pressure gas samples in post accident sampling i
19 system.
l 20 The PASS requirements grew out of TMI.
l 21 Those of us at TMI are fully in favor of having a 22 capability to safely secure samples quickly after an 23 accident.
We didn't have that capability and w.e 24 needed it.
5
- 25 The specific issue here is, must there be NEAL R. GROSS f
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a capability to withdraw a pressurized gas sample, and l
2 that is a sample of reactor coolant under pressure so i
3 that both the fluid and the gas and the gas content in 4
the fluid can be analyzed as distinct from a sample l
5 which should logically be attainable and that is a 6
sample of a pressurized reactor coolant system, i.e.,
7 a system which can extract fluid from a pressurized 8
- system, knock the pressure down and deliver it 9
depressurized to the sample station, two distinctly i
10 different approaches.
11 For the advanced plants we have p
12 epressurization system capability, automatic 13 depressurization capability for the advanced PWR 14 designs, the AP-600.
So immediately we're struck by l
15 the inconsistency of the staff's position that a
{
4 16 pressurized gas sample would be required in the PWR 17 case but not the BWR case.
We think that's 18 inconsistent and we see no justification for that.
i 19 Very importantly and-I think 20 fundamentally this is an issue of complexity.
The i
21 simplicity versus complexity trade-off of going from j
i 22 the capability to get a sample of a system under l
r 23 pressure to a pressurized sample is substantial and I 24 would point you to Combustion Engineering /ABB's letter 25 in that respect because it was quite thorough and much l
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more thorough than my slides or our response.
In 2
their estimation, the number of valves increases by 3
about a factor of ten, from four to five to 40 to 50, 4
with attendant increase in cost.
They estimate it's 5
about $10 million.
6 But it's not the cost effect that's 7
really bothering us.
It's living with that complexity 8
and with the valves which have to be tested and 9
maintained and which threaten reliability of the 10 system. As you know, we've been on the simplification 11 crusade for seven, eight years now and one of our 12 findings has been there's no Holy Grail for 13 simplification.
It's a matter of system by system 14 eliminating unnecessary parts and pieces, and there 15 are a lot of unnecessary parts and pieces in this PAS 16 system as prescribed by the staff, so we would argue 17 very strongly that that specific requirement for 18 pressurized gas sample be changed, deleted from the 19 staff 's requirement. The residual aspects we're quite 20 comfortable with.
21 With respect to exchange with the staff, 22 I have to say that we have been arguing this point for 23 five years and this one is well understood and if'the 24 staff were here they would say, "Yes, we know they 25 want that," and we still think it's important and we NEAL R. GROSS COUPT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234-4433 W ASHINGTON, D.C. 20005 (202) 234-4433 x
42 1.
simply have never come to _the point that we even 2
understand, let alone agree with, the rationale for 3
adding complexity to the plant for this very marginal 4
increase.
5 If you think in terms of the need for 6
this, it would be only under an accident, a very 7
severe core damaging accident in which for reasons we 8
can't comprehend the plant would not have been 9
depressurized.
And even in that case, the advantage 10 is the marginal increase in analytical information one 11 would gain from being able to get the undisturbed gas 12 as part of the sample.
And if that were going on in 13 the plant, I think we'd have a lot of other things 14 going on, on our minds.
i 15 This is not something which would be a 16 very great help under those circumstances.
It would 1
)
17 provide some marginal benefit. It's unlikely it would 18 be required and for that very marginal additional 19 benefit we'd be paying a price from design right on 20 through the life of the plant.
21 COMMISSIONER ROGERS:
You're saying that 22 this really wouldn't be of value to the operators in 23 dealing with the accident?
24 MR. DeVINE:
I'm not saying it wouldn't 25 be of value.
I'm saying it would be a marginal value NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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in either case.
Getting a sample is of value, 2
absolutely, and we had great difficulty with that at 3
TMI.
It took over a day to get the sample and our one 4
single over-exposure of a human being, the single one 5
in the course of the accident
- recovery, was i
6 withdrawing the primary sample.
7 We were using the existing sample station 8
which wasn't designed for post-accident sampling, 9
three or four orders of magnitude higher activity in 10 the sample than the sample station was designed for, 1
11 so we're fully in support of ability to withdraw 12 samples after an-accident, but having a pressurized 13 gas sample -- and let me carry it further.
In that 14 case, we got very quickly the confirmation of serious-P 15 core damage and some approximation of the extent of 16 core damage and one can get that with this fluid 17 sample.
This is not a highly diagnostic laboratory 18 event.
19 For years people were studying data from 20 the TMI event afterwards and precisely determining 21 what was going on in the core.
At the time, there was 1
22 still uncertainty about just how badly the core was 23 damaged.
We overexposed a person to get the sample.
24 Once we had the liquid sample we confirmed the 25 conditions and we also confirmed the level of activity NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W..
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in the fluid, which was very important in helping us 2
make the decision not to switch on to decay heat
-3 removal which was not designed for that high level of 4
activity.
All that information would be obtained 5
without this capability.
It's only the additional I
specifically what happened in the 6
diagnostic l
7 accident -- kind of information that you'd gain and we 8
don't think it's worth it.
9 COMMISSIONER REMICK:
Jack, when I read i
10 the staff's position I misunderstood what they were 11 saying.
I interpreted them to be questioning the 12 reliability of the depressurization system for PWRs 13 and I found that is not the question.
2 i
14 As I understand it, the staff's concern 15 is that you might have an incident like a steam 1
16 generator tube leak and you have concern that you 17 don't want to depressurize the primary system too far 18 because the secondary then might come into the' primary
)
19 so that you might not want to'depressurize the whole 20 Way down.
But you might want to know did this lead to
)
21 core damage, so you might want a sample at that 22 somewhat elevated pressure or you might want to.know l
23 in a coastal site had the secondary side water come in 4
24 and you had chlorides and so forth.
That is my 1
25 understanding, that they thought there might be some l
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cases that you might want to ride at pressures other 2
than being fully depressurized and that was the 3
reason.
4 MR. DeVINE:
However, we think in almost 5
any conceivable case that would not be a core-damaging 6
accident and we have the capability to draw that t
7 sample.
And if one wanted to be absolutely certain, 8
and obviously the operator should have a sense from 9
many other parameters of the extent of damage to the 10 core if there is
- some, but one could draw a
11 pressurized sample with the simpler system we 12 prescribed and when that confirms no core damage you 13 could then get that pressurized gas sample.
There is' 14 the capability to do this.
The question is, is it a 15 safety-related post accident sampling system as 16 prescribed.
17 COMMISSIONER REMICK:
So that's the 18 bottom line, the difference between whether it's 19 safety, safety-related?
20 MR. MCDONALD:
No, no.
You said one i
21 thing about if you had a steam generator tube rupture 22 and you didn't want to depressurize,.could you get a 23 sample.
You can always get a sample, but the sample 24 is depressurized in the process of getting it.
This 25 thing would not depressurize the sample.
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CHAIRMAN SELIN:
In other words, you can 2
get a sample from a pressurized primary --
3 MR. MCDONALD:
That's right.
4 MR. DeVINE:
Right.
L l
5 CHAIRMAN SELIN:
-- which depressurizes l
f 6
just the sample, not the primary --
ff 7
MR. DeVINE:
Exactly.
8 MR.
MCDONALD:
That 's - right.
That's 9
right.
10 MR. DeVINE:
I'm sorry, I thought I made
]
l 11 that clear.
That is expressly the point and we 12 support fully the capability to sample a pressurized 13 Ffstem.
- I 1
14 COMMISSIONER REMICK:
So the design as j
15 proposed would allow a sample at any primary pressure?
16 MR. MCDONALD:
Yes.
17 COMMISSIONER REMICK:
I see.
Okay.
18 MR.
DeVINE:
Those are the three and l
19 they're not show stoppers, but every one of them has i
20 potential to be significant in the design.
21 COMMISSIONER REMICK:
One other area.
22 Your third bullet says the area is also being 23 considered for reduction elimination because of its 4
24 marginal safety significance.
Is that something the 25 staff is pursuing or industry is pursuing?
Have you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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done it yet?
2 MR. DeVINE:
No.
No. That's perhaps not 3
well worded.
We are proposing that it be considered 4
for elimination for those reasons.
The-staff's 5
position is to let the requirement stand.
6 COMMISSIONER REMICK:
Oh, in this case?
7 MR. DeVINE:
Yes.
8 COMMISSIONER REMICK: You're not talking 9
beyond --
10 MR. DeVINE:
We are not talking anything 11 else.
12 COMMISSIONER REMICK:
Okay.
13 MR. DeVINE:
The following two slides i
14 address those for which we think some clarification is 15 in order.
Let me just very quickly cover it.
First 16 of all, it's our hope and our expectation that in all 17 of these we're in 100 percent agreement with the staff 18 and the only difficulty is that the specific wording 1
19 in the SECY, we think, is either inconsistent with 20 that agreement or is potentially open to 21 misinterpretation in the years ahead and we'd like to 22 make sure that doesn't happen.-
l 23 To walk through very quickly the kinds of j
1 24 things, I don't even think I need to discuss them all, 25 but for example in the intersystem LOCA, the first NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W, (202) 234 4433 WASHINGTON. D.C. 20005 (202) 2344433
48 1
item.
The issue here is that actually there are two 2
points of confusion.
One could read that requirement to specify that even for those connected systems, that 3
4 is systems connected to the primary systems which 5
extend outside the containment which we have hardened 6
and we've very aggressively approached this in the 7
requirements document and I'11 tell you that it caused 8
a lot of agony years ago when we first presented it to 9
the steering committee, but we've hardened connected 10 systems to ensure that directly rather than by 11 controls or instruments or quick closures that our 12 connected systems are not vulnerable to LOCA.
One 13 could read this to suggest that even in those cases 14 you have to do additional things to make sure that the 15 systems stay isolated.
16 More importantly, and not stated in my 17 summary slide, although it is stated in the letter 18 that we sent to you on June 7th, is that there is a 19 question of practicality.
The words in the SECY 20 suggest that in all cases, in all practical cases, 21 interconnected systems should be hardened.
By 22 hardened I mean designed such that the ultimate 23 rupture strength is below the design pressure of the 24 primary system.
25 We agree with that in principle. We went NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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further in the requirements document to say what 2
practicality means.
The SECY doesn't do that and we 3
would simply like to make sure there is some 4
reasonable bounds on practicality.
Practicality can 5
get perilously close to possibility in the eyes of 6
regulators sometimes and we'd just like to put some 7
bounds on the practicality question.
8 Hydrogen -- yes?
9 MR. MCDONALD:
We've been specific in 10 saying which of those systems we think do need it and 11 it is practical.
12 MR. DeVINE:
Hydrogen control.
I think 13 we're in complete sync here, although we've disagreed 14 with you for a long time over the specification for 15 hydrogen, the design basis for hydrogen treatment.
16 The words in the SECY use "such as" in describing the 17 kinds of systems that can be employed for handling 18 hydrogen.
Since the SECY was written, we've -- and in 19 parallel with the preparation of the SECY, we've been 20 working with our European colleagues to examine a 21 possive autocatalytic recombiner device which we're 22 very encouraged will be a better answer than ignitors 23 or inerting in the. primary containment and we simply 24 want to ensure that that option is not foreclosed by 25 the words in the SECY.
.I think it's just a
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-1 clarification.
2 COMMISSIONER ROGERS:
Has.EPRI done any 3
or funded any studies on that?
4 MR. DeVINE:
Yes.
5 COMMISSIONER ROGERS:
You have?
6 MR. DeVINE:
Yes.
We're working very 7
closely on that and we submitted a report to you I 8
think a month ago.
9 Similarly, the question of practicality 10 came up on testing of pumps and valves and that's an 11 issue of high importance to existing plants.
We 12 simply want some reasonable bounds on what 13 practicality means.
We would not want full pressure 14 test loops to be installed in plants just for the 15 purpose of testing motor-operated valves and that sort 16 of thing, and we don't think you want that either.
17 Containment leak rate testing was silent 18 with respect to some of the items in Appendix J which 19 we presume should be included but are not stated.
20 Had lots of dialogue about the defense 21 against common mode failure and the staff proposed a 22 very orderly process of assessing the vulnerability to 23 common mode failure and~ demonstrating adequate-24-capability to deal with it.
But there's a fourth 25 step, position number 4,
which involves putting in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W (202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4433
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hardwired backup controls and instruments.
We 2
specified hardwired backup controls and instruments in 3
the requirements document years ago and in that sense 4
our requirements are quite similar.
However, these 5
are proposed to be safety-related.
We're not sure 6
what the design basis is for the safety-related 7
design, what they are to be designed to do, under what 8
safety conditions since they come into play beyond the 9
design basis capability of the plant.
Nor do we think 10 they need to be safety related.
We think they need to.
11 be simple and sensibly engineered and they are purely 12 extra confidence builders in the plant.
13 Again, I would point out the comments 14 from the vendors.
I think Westinghouse was most 15 explicit on this
- point, but they support this 16 agreement in principle, but not on the safety-related 17 treatment of those systems.
18 COMMISSIONER ROGERS:
When was the last 19 time you talked to our staff on that particular issue?
20 MR. DeVINE:
That's been a very frequent 21 point of discussion.
22 John, do you have any --
23 COMMISSIONER ROGERS:
Well, the reason I 24 ask is that my impression is that and I may be 25 wrong on this -- that the staff had been reviewing NEAL R. GROSS COURT REPORTERS AND TRANSORIBERS 1323 RHODE ISLAND AVENUE. N W.
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their position and it seemed to'me that at least with 2
some of the vendors they didn't have a disagreement on 3
that particular aspect.
4 MR. DeVINE:
Yes.
Actually I'm glad you 5
raised that and I didn't pick it up from my slides 6
here and again it is in the letter.
Part of our 7
concern has to do with what we perceive as an 8
inconsistency both between what we're hearing from 4
9 different parts of the staff and also the vendors 10 report they're hearing from the staff.
Case A,
a 11 certain solution was adequate.
Case B,
the same 12 solution seems not to be adequate.
So, we are also 13 getting a sense that there's some ambiguity about the 14 position which we'd like to see clarified.
15 Probably the most important of these 16 items requiring clarification is the steam' generator 17 tube rupture.
Again, our discussions with the staff 18 have been very good and really reached closure.
We 19 have agreed that multiple steam generator tube 20 ruptures deserve consideration in the design.
i 21 Westinghouse has already done some analysis in that i
22 respect and we're requiring analysis of multiple steam 23 generator tube ruptures.
But it had been our 24 understanding with the staff that the design basis 25 will remain single steam generator tube rupture with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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an additional requirement to analyze in a best 2
estimate basis multiple steam generator tube ruptures, 3
five specifically.
Interestingly, it turns out that 4
when those analyses are made that the best estimate i
5 analysis of five works out to show pretty much the 6
same kind of plant transient you would see with a very.
7 conservative design basis estimate or analysis of a 8
single one.
9 In several places in the
- SECi, the i
10 decision about the design basis is lef t unclear.
It's 11 suggested that it will be determined later.
The SECY 12 implies, it states in fact, that the analysis should 13 be required and then they ask for the Commission's 14 confirmation that the analysis of multiple steam 15 generator ruptures be required.
It's silent with 16 respect to whether those are best estimate or design 17 basis, but in two places, not in the part that asks 18 for your approval, but in two other places in the SECY 19 the SECY document indicates that based on those 20 analysis the determination will be made as to the 21 design basis.
That will be, we think, too late down 22 the design process to know what the design basis is 23 and we propose that it remain a single steam generator 24 tube rupture.
25 COMMISSIONER REMICK:
Jack, I'm not sure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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I completely understand.
I thought I heard you say 2
that the staff is not proposing to change the design 3
basis.
That will be a single tube failure.
- However, 4
you agree that there should be analysis done beyond 5
the design basis for multiple tube failure.
Am I 6
correct then that the concern is -- do you think that 7
beyond the design basis they should be best estimate 8
calculations and the staff thinks they should be 9
conservative calculations or that they still might 10 come back and make the multiple tube failure a design 11 basis event?
12 MR. DeVINE:
Let me be real specific.
I 13 again apologize for not being complete'.y clear on 14 this.
The staff -- the SECY, the position stated in 15 the SECY -- I want to make three points.
The first 16 point is that we seem to have strong agreement with 17 the staff orally on this point.
It's the words in the 18 SECY that are bothering us.
19 Secondly, the SECY is silent with respect 20 to whether the analyses of multiple steam generator 21 tube ruptures be done on a best estimate or design i
22 basis conservative method.
23 Thirdly and explicitly, the SECY requires 24 that or indicates -- in fact, I'll read a sentence.
25 "The staff will determine - " this is one place and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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there's another in here someplace.
"The staff will 2
determine the appropriate number of steam generator 3
tube ruptures that should be included in the AP-600 4
design basis after evaluation of the submitted 5
analysis."
So, what the SECY says is, "Do the 6
analysis and then we'll decide on design basis."
So, 7
it sort of puts it in a future category even though 8
this one was a -- it's a resolved issue.
Those are i
9 the words that are of most concern to us.
10 COMMISSIONER REMICK:
And you feel that 11 the analysis should be handled like we're handling 12 other analyses, severe accidents and so forth, best 13 estimate --
14 MR. DeVINE:
Exactly.
15 COMMISSIONER REMICK:
-- and not have it 16 uncertain as to whether this will eventually become a 17 design basis event later on in the process of these t
18 existing designs?
19 MR. DeVINE:
Yes.
20 COMMISSIONER REMICK:
Okay.
21 MR. DeVINE:
That's exactly right.
And 22 the best estimate analyses that have been conducted 23 have been illuminating and I think it's been good 9
24 dialogue about what they show.
They'd have been 25 concerned if some kind of a threshold effect -- after NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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a few tubes the plant is unable to cope.
On a best 2
estimate basis Westinghouse shows it out to five 3
tubes.
I think the SECY describes that result.
The 4
plant can cope.
So, it's been a useful process, but 5
we're concerned about where does the design basis go l
6 as a result of this process.
7 That concludes the -- and that's it.
Of 8
the 42, those are the ones with which we have issues.
4 1
9 (Slide)
I would point out on the next
)
10 slide --
11 COMMISSIONER REMICK:
Jack, when you 12 mentioned 42, I added up your numbers on your earlier 13 slide and it came out to 40.
I was wondering what the 14 other two were.
15 MR. DeVINE: I have at least two separate 16 charts of those and every time I add the numbers 17 different ways.
There are three distinct sets of the 18 42, but the total number is 42.
Maybe the difference 19 here, there are two issues which came out -- and let 20 me back up.
In large measure, the vendors have come 21 up with very consistent positions. They point out two 22 additional ones.
The Westinghouse letter questions 23 issue I.H regarding core debris coolability.
As I 24 read that comment, it primarily is one of consistency, 25 use of service level C for the containment both for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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1 core debris coolability considerations and for 1
2 containment performance.
3 There is another issue in which the staff 4
takes that position and with which we agree.
So, it's 5
a consistency issue.
- Also, they refer to some 6
additional specifics on shell buckling and I'm not 7
prepared to describe that.
But in any case, the 8
Westinghouse letter covers it.
9 The second potentially more important, 10 but just for clarification, we recently submitted some 11 requirements document changes that addressed the 12 containment performance.
Very explicitly in our 13 dialogue with the staff and our letter we pointed out 14 that we're doing that in order to ensure that we have 15 a
very rugged plant performance and containment 16 performance which can support simplified emergency 17 planning for the passive plants and perhaps for other 18 plants when and if we're at the point that we're ready 19 to support that.
We wanted to make sure that we had 20 plants designed that had a very specific and very 21 demanding containment performance requirement to 22 support simplified emergency planning.
23 And we didn't question or challenge the 24 SECY position on this.
It was in the future category 25 and it was simply a dialogue that discussed what's i
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1 been happening.
2 ABB Combustion raised a question on that 3
which was intriguing.
Because that was identified as 4
a passive plant only issue, their question was why 5
should this be limited to passive plants?
It was 6
never our intended limitation over the long-term to 7
limit it.
We simply haven't crossed that bridge.
We 8
did make the requirements document change as a volume 9
3.
That is a passive plant requirements change.
We 10 would intend to catch up with volume 2 sometime later l
i 11 on.
Combustion Engineering's design, they feel, can 12 meet those requirements.
That's an indication it's a 13 good, robust containment building and I think they 14 simply want to get a placeholder in that says, " Hey, 15 wait a minute.
We want to be considered candidates j
I 16 for this if and when it comes as opposed to being 17 rejected because it was proposed by EPRI as a volume 18 3 change only."
So, it's an applicability issue.
19 MR. MCDONALD:
May I state that in a 20 little different way?
What we have required is the 21 containment type of criteria that would be used as 22 inputs for emergency planning and we put that in the 23 requirements document as criteria for design for use 24 in future emergency planning.
So, what this says is
~
25 that they want that recognized as the criteria in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODti ISLAND AVENUE, N W.
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-1 utility requirements document for emergency planning 2
likewise in the evolutionary plants.
3 COMMISSIONER REMICK:
I asked the staff 4
at one of our meetings this very question about 5
emergency planning for the evolutionary plants.
As I 6
- recall, the staff's answer was that they had no 7
specific requests from any vendor to relax the 8
requirements for the evolutionary plants and the staff 9
was not going to initiate this themselves.
They did 10 indicate that they thought EPRI was working on this.
11 Perhaps they were referring to what you've just 12 described, but that without specific vendor requests 13 for relief in this area, that the staff did not have 14 any basis.
15 MR.
MCDONALD:
- Well, I didn't quite 16 understand that.
I read that dialogue that you hed 17 also of what the staff might expect. We're proceeding 18 with the Part 52 process and we're dealing with design 19 criteria.
So, when we specify a certain design 20 criteria for how much a containment would leak or how 21 gas is handled and things like that, that criteria and 22 the results of that then is used outside the Part 52 23 process for determining emergency planning.
4 24 COMMISSIONER REMICK:
Yes.
25 MR. MCDONALD:
So, I didn't understand NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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that either.
2 COMMISSIONER REMICK:
And that I
3 understand, but just the fact that you've made those 4
requirements, utility requirement document does not 5
mean that automatically the agency would proceed to-l 6
relax --
7 MR. MCDONALD:
No.
No.
No.
No.
8 COMMISSIONER REMICK:
Yes.
And the i
1 9
staff's answer is, "We haven't had a request for 10 evolutionary plants."
1 11 MR. DeVINE:
Absolutely.
12 MR. MCDONALD:
Yes.
Well, you haven't I
13 had one for passive plants either.
14 COMMISSIONER REMICK: No, that's correct.
15 That's correct.
No.
16 MR. DeVINE:
(Slide)
The final slide is j
17 simply a table of those with which we have no
'I[
18 disagreement and I'd propose not to discuss any of 19 them except to point out that the lower right-hand 20 side, those category 3s include some pretty weighty 21 issues.
However, we think we're making continued 22 progress and some will be resolved shortly.
23 Regulatory treatment of non-safety systems we think is 24 resolved and the paperwork is catching up now.
Source 25 term is another which is making great progress, but NEAL R. GROSS COURT REPORTERS AND TRANWJiBERS j
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we're still reaching closure.
2 But in the main, we're very impressed and 3
pleased with the work that the staff has done in 4
closing all of these issues.
We think the relatively 5
small number of items with which we disagree is 6
evidence of a good cooperative job.
7 Thank you.
8 The next presenter is John Taylor.
9 MR.
TAYLOR:
These issues that have 10 identified has disagreeing in part and requiring 11 additional clarification are new.
We've made the 12 industry's position clear, I believe, and the staff 13 understands it.
We feel a potentially of major cost 14 and operational implications to the utilities in them 15 and should be resolved through the utility 16 requirements document and we would ask that 17 expeditious complete technical discussions with the 18 staff be completed, particularly at.the management 19 level.
We don't think that would require a scheduled 20 delay.
But if it's done on the contrary, the 21 resolution of those issues at the requirements 22 document will have beneficial effects on cost and 23 schedule in the design certification process.
24 That, in fact, has been one of the major 25 purposes of the utility requirements document and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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review by NRC, to establish a generic basis which 2
would permit design certification to proceed 3
expeditiously.
We're very pleased that the utility 4
requirement document reviews have been generally kept 5
on schedule over the several year period.
However, we 6
ara concerned that the NRC design certification review 7
schedule has recently been extended.
8 We're also concerned about other 9
potential delays.
For
- example, the proposed 10 rulemaking on severe accident performance criteria for 11 future reactors seems to us to be an unnecessary time 12 and resource drain that would impact schedules now and 13 could have serious schedule impacts during rulemaking.
14 We've been debating and corresponding on this question 15 of whether or not this intervening rulemaking is 16 needed with the staff for about five years.
17 The position the industry takes, and it's -
18 shared by the EPRI Utility Steering Committee, NUMARC 19 and the vendors, has consistently been that we resolve 20 the technical issues generically in the contents of 21 the utility requirements document.
Vendors follow 22 that guidance and NRC certified designs through the 23 rulemaking in its design certification that the 24 criteria are met, which they have approved.via the 25 safety evaluation report of the utility requirements NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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document.
That would involve the public comment that 2
is necessary for the process without any separate 3
rulemaking.
4 But we're not suggesting in this 5
expression of concern that NRC staff is the sole cause 6
of delay.
But we are suggesting that the industry and 7
NRC staff take constructive actions to minimize any 8
future delays and even identify ways in which we can 9
recover the present schedule over what it has been.
10 We would urge your support in asking the staff to work 11 closely with us to try to define that for us.
12 CHAIRMAN SELIN:
I should just say 13 something. We've said this at this table in the past.
14 We will not require that the vendors meet the 15 specifications of the industry document. We have made I won't call them concessions, but 16 significant 17 embracing of the document saying, "If you do meet 18 these approaches, we won't go through with a whole new 19 approach."
But we do take the vendor documents as 20 they come.
If they seem safe to us, it's between the 4
21 industry and the vendor to close that loop.
22 MR. MCDONALD:
We understand.
23 MR. TAYLOR:
Chairman, in fact we like 24 that for the reason cited at the beginning, that we 25 would not like the movement we've made in increasing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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the margin beyond what the regulatory requirements 2
would demand to be applied in the regulatory-sense.
3 So, we're for that.
We, however, do believe that the 4
basic technical understandings that have been achieved 5
by working with NRC on this requirements document will 6
provide a more expeditious review of those issues in 7
a design certification.
8 CHAIRMhN SELIN:
Fine.
Thank you.
9 MR. MCDONALD: Let me go back a minute in 10 sort of summing.
We stated the objectives at the 11 start were to try to assure stability in the 12 regulatory process and also to get good ' technical 13 requirements.
It might seem that we've strained at 14 some technical details here, but we have been very 15 detail oriented because we're trying to work that all l
16 out and have a good credibility.
17 I think we've come a long way on that.
18 We've worked well with the staff.
So, I would l
19 congratulate them.
20 We've brought these questions up at this 21 time now and we'd like to request you to ask the staff 22 to work with us.
With respect to schedules, I believe 23 this can be done in a one day meeting with -- plus 24 what time is necessary to write it up.
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delay.
-I don't think that we can really afford much 2
schedule delay.
There are several factors that 3
dictate that the new schedule for certification be 4
reduced significantly with the principal reason for 5
this being that the continuing slippage of schedules 6
as milestones are approached is eroding confidence in 7
our ability to accomplish our regulatory-related work 8
in a predictable and cost effective manner. We've got 9
to do something about it and we want to work with you 10 all we can to try to accomplish that.
We think it's 11 a very critical item.
12 CHAIRMAN SELIN:
If you want to keep to 13 the schedules, I suggest you also have conversations 14 with the vendors.
15 MR. MCDONALD:
I think we all need to 16 analyze exactly what's causing them and take some 17 appropriate action.
We will be working with your 18 staff and doing whatever we can to improve that.
19 CHAIRMAN SELIN:
Fine.
Commissioner 20 Rogers?
21 MR. TAYLOR:
And the vendors.
22 COMMISSIONER ROGERS:
- Well, it's not 23 quite clear to me what your position is with respect 24 to SECY-93-087.
The Commission hasn't acted on that 25 yet.
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these issues before the Commission acts on that?
Is 2
that what you're asking here or are you not asking 3
that?
4 MR. MCDONALD:
We are asking that these 5
issues be resolved before you act upon them.
We think l
l that the questions, the dialogues we've had here today i
6 7
indicates the incompleteness of the document on 8
presenting the case on those limited issues we've 9
talked about.
And you notice we gave those comments 10 and we had no dialogue on those comments because we 11 think they've done a good job.
But here again when it 12 becomes a matter of interpretation, that doesn't give 13 us stability in regulation that we need to go forward.
14 So, we need to make these as good as possible.
15 I must say -- add one thing here about 16 the foreign involvement.
We have a lot of foreign 17 involvement and there's more than just the U.S.
18 industry looking at this.
They are looking at us for i
19 how we pin these things down and how thorough we are 20 on these design things. We're trying to do a straight 21 number 10 job on this and we've come a long way.
I 22 just congratulate the Commission and the staff on it.
23 COMMISSIONER ROGERS:
On the other hand 24 they're developing their own requirement, European 25 utility requirements document, aren't they?
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1 MR.
TAYLOR:
They've started that 2
process, commissioner. We are talking with them about 3
a process where we would get draft information, 4
express our opinion on the requirements and so on.
5 There's a general goal that the fundamentals of safety 6
and reliability wherever possible be very similar. As 7
we see it, they're building up from their deep 8
participation with us in developing these 9
requirements.
i 10 CHAIR".Ad SELIN:
Commissioner Remick?
11 COMMISSIONER REMICK:
Just to make sure 12 I understand, you say these issues.
I read that to be 13 at least.the three that you disagree in part you've f
14 identified.
The six issues that you identified as 15 needing clarification, I'm not sure where the vendor 16 question -- there are two that have vendor questions.
17 Are you including those as ones that --
18 MR. MCDONALD:
Yes.
you're 19 COMMISSIONER REMICK:
20 requesting deferral also?
21 MR. MCDONALD:
Yes.
22 COMMISSIONER REMICK:
So a total of 23 eight.
I am concerned what that does to schedules.
24 MR. MCDONALD:
Well, the questions we've
^
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the fundament problems in most cases.
They are -- I 2
think they're pretty straightforward and I'm not sure 3
why a one day meeting and discussion of these things l
4 and resolving should -- could stretch out a schedule.
5 MR. TAYLOR: But we've had very wonderful 6
progrecs at periodic meetings with Tom Murley and his 7
senior staff as a means of final resolution af ter many 8
hours and weeks and months of work by NRC staff and 9
our own staff and I
think that's what Pat's I
10 suggesting.
We need one really intense session at L
11 that level.
Think we can very much accomplish what--
12 COMMISSIONER REMICK:
One other thing.
13 Let's see if I've characterized what you i
14 were saying earlier, Pat, and John you said recently.
15 As I understand your position, please t
16 tell me if I'm wrong, the utility requirements t
1*/
document has utility-specified requirements of vendors 18 that go beyond NRC regulations.
And from that, I 19 infer that you're saying that those utility requested 20 requirements of vendors therefore go beyond what the 21 Commission considers is adequate protection of the 22 public health and safety, that the designs which will 23 meet those utility requirements will be codified in 24 the design certification rule
- itself, will be 25 codified.
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In other words, the designs to meet those 2
utility requirements will be codified as a rule 3
through the design certification rulemaking process, 4
therefore those things that are utility requirements 5
and go beyond what our regulations currently require 6
need not be placed in the regulations in addition.
7 MR. MCDONALD:
That's right.
8 COMMISSIONER REMICK:
They'11 9
automatically be codified, apparently, as an appendix 10 to Part 52.
Is that the position you were trying to 11 express as to why you don't want additional 32 regulations?
12 MR.
MCDONALD:
Is that the way we'd 14 talked about it, do you think?
15 MR. DeVINE:
Yes, I think so.
16 MR. MCDONALD:
I think it is.
17 MR.
TAYLOR:
Very well
- said, 18 Commissioner.
19 MR. MCDONALD:
I tbink it's well said.
t 20 COMMISSIONER REMICK:
Good.-
Okay.
21 That's not inconsistent from the standpoint ' -- in 22 other words, these things will be -- the design will l
23 be codified in a rule which presumably will become an 24 appendix to Part 52?
i 25 MR. MALSCH:
That's not the industry NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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position.
Their position is they currently do not 2
want those requirements anywhere reflected in the 3
design certification other than in the fact of the 4
certified design itself.
i 5
COMMISSIONER REMICK: No, that's what I'm 6
saying.
But am I correct that the actual design 7
certification for each of these designs will become an 8
appendix to Part 52?
9 MR. MALSCH:
That's correct.
10 COMMISSIONER REMICK:
Yes.
11 MR. MALSCH:
But this would also mean 12 that these additional requirements would not have the 13 same enforceable status as other requirements in Part 14 50.
15 COMMISSIONER REMICK:
But the design 16 itself would, the certified design?
17 MR. MALSCH:
The certified design itself 18 would.
19 COMMISSIONER REMICK:
Would, yes.
20 MR. MALSCH:
But when you come to such 21 things as possibly renewing the certified design or 22 backfitting the certified design because of. new 23 information, the initial position would have these 24 additional requirements not be accorded the same 25 enforceable status as existing requirements in Part 50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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and to that extent they would not be codified like 2
other regulations.
3 COMMISSIONER de PLANQUE: Because they're 4
above and beyond.
5 MR. MALSCH:
Because they're above and 6
beyond.
7 COMMISSIONER REMICK:
Above and beyond.
8 MR. MALSCH: In that regard, some aspects 9
of these designs also do not comply with existing 10 regulations.
They are being granted exemptions as 11 part of the design certification process.
12 COMMISSIONER REMICK: That's right, yes.
13 MR. MALSCH:
So, it goes both ways.
14 COMMISSIONER REMICK:
Yes.
15 CHAIRMAN SELIN:
And if one of the 16 vendors met the utility document and a second vendor 17 did not, it's only the first vendor's design in that I mean, the feature of the first vendor's 18 case 19 design that would be in the rule and not the second?
20 MR. MALSCH:
That's right.
The actual i
21 certifications go according to the vendor-22 applications.
23 CHAIRMAN SELIN:
But another way, if the 24 vendors chose not to meet the specifications in the t'
25 utility document, we couldn't hold them to that if l
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1 they want --
i 2
MR. MALSCH:
That's correct.
3 CHAIRMAN SELIN:
Commissioner Remick?
4 COMMISSIONER REMICK:
Just one other 5
thing.
I have not seen the ABB/ Combustion letter.
6 I'd ask SECY if he'd see that we get the letter.
7 That's all I have.
8 CHAIRMAN SELIN: Commissioner de Planque?
9 COMMISSIONER de PLANQUE:
I have nothing 10 further.
This has just been extremely helpful, so I 11 would thank you for the briefing.
12 CHAIRMAN SELIN:
I would like to make a 13 couple comments.
14 I've asked some fairly sharp questions.
15 It does not imply, as your comments do not imply, a 16 lack of pleasure or agreement or satisfaction with the 1
17 way most of this process has gone.
I personally would 18 be disinclined, unless the staff upon having heard l
19 what you said, to take more time.
20 I
basically think we've
.got the 21 information and, unless the staff said, you know, they 22.
brought up a couple of ideas we hadn't thought of and 23 we would like to take the' time, my inclination would j
24 be to vote and to _take a look and say, "Well, 97 i
25 percent or three out of -- 94 percent they agree.
Do i
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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)
1 I agree?" and the other couple of places to see 2
between the two, unless the staff came forward and 3
said., "You know, we heard a few things today we hadn't 4
heard before and we would like to take the time."
5 Partly that's a process question.
6 I don't like the idea of the industry 7
being able to come in and in effect intersperse itself l
8 between the staff document and the Commission.
Part 9
of it is the point you've made that in some of these 10 cases, particularly in ambiguity questions, the loop 11 just hasn't been closed or one or two of these issues 12 had come up after the last time you talked.
But, as 13 you've pointed out, many of these are old issues and 14 you really haven't given us much reason to believe 15 that our forcing the staff to sit down with you and 16 say "Try once more" is going to --
17 MR.
MCDONALD:
I would withdraw the 18 request to force the staff to sit down and withdraw.
19 We sit down frequently. However we can get redress on 20 these issues --
21 MR.
TAYLOR:
- Chairman, there is one 22 difference.
We have in many of the other cases, in 23 fact all the others to my knowledge, had bef ore. ' a 24 final position was taken by the staff had a management 25 meeting to get through the final step.
In many cases-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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we yielded to the staff position.
We did not have 2
that opportunity on the issues that we've addressed to 3
you today.
We have not had that opportunity.
4 COMMISSIONER de PLANQUE: Just to clarify 5
in my own mind on the issues where it was a matter of 6
clarity, had you not seen the wording that's in the 7
087 document before it was issued where it's just a 8
wording subtlety that can be interpreted one way or 9
the other in the six items that you mentioned?
10 MR. TAYLOR: I didn 't.
I don't know that 11 anybody saw that material in advance.
12 MR. SANTUCCI:
This is what I understand 13 the problem was.
14 COMMISSIONER de PLANQUE:
Okay.
So you 15 hadn't seen the wording that we're looking at now in 16 93-087.
Okay.
17 CHAIRMAN SELIN:
In any event, we thank 18 you very much for the presentation.
As Commissioner 19 Remick's questions point out in a couple of places, 20 our understanding of your views or even our 21 understanding of the staff views is slightly different 22 from what it was coming in.
I hope that was worth 23 your while coming out from wherever you individually 24 habitate.
25 Thank you very much.
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(Whereupon, at 12:31 p.m.,
the above-t 2
entitled matter was adjourned.)
3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
{
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CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING: BRIEFING BY EPRI ON POLICY, TECHNICAL AND LICENSING ISSUES PERTAINING TO EVOLUTIONARY AND ADVANCED LIGHT-WATER REACTOR (ALWR) DE IIGN PLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING:
JUNE 10, 1993 were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my' ability, and that the transcript is a true and accurate record of the foregoing events.
AA vf' Reporter's name:
Peter Lynch l
l l
1 NEAL R. GRO$$
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(202) 232-6800.
ALWR UTILITY STEERING COMMITTEE and NRC COMMISSION MEETING 10 June,1993 NRC Headquarters White Flint, Maryland P
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Utilay/ALWR ALWR UTILITY STEERING COMMITTEE and NRC COMMISSION MEETING 10 June 1993 NRC Headquarters White Flint, Maryland Advanced LWR Program Utility /ALWR R. Patrick Mcdonald Vice-Chairman ALWR Utility Steering Committee Advanced LWR Program i
.p,
1 ALWR Program Presentation on SECY-93-087 Issues Presentation Outline Pat Mcdonald, USC Introduction and Overview Joe Santucci, EPRI ALWR Program review of SECY Jack DeVine, EPRI Discussion of Open issues John Taylor, EPRI Schedule issues Pat Mcdonald, USC Conclusions Advanced LWR Program introductlOn Objectives of ALWR Program are being reached:
Stable regulatory basis for ALWRs that provides high assurance of safety and licensability Utility 4 riven design requirements for standardized plants which are reflected in certified designs Technical requirements suitable for use as investor bid package that provide basis for strong investor confidence Progress sines last Commission briefing in Sept 1992 has been good, particularly with recent agreements on RTNSS issue.
Advanced LWR Program L
Basis for Discussion Utility and NRC objectives and interests in better, safer plants are aligned.
Long agreed upon process: Utilities set design requirements in URD, olRC reviews, approves and endorses via SER. On that basis, Design Certification proceeds with high confidence of codifying requirements that future owner / operators want.
No new regulatory requirements needed. URD requires plants to exceed current regulations and safety goals by wide margin. Many SECY-93-087 policies would treat these margins as regulatory requirements.
Advanced LWR Program
[ Utility /ALWR
/
Overview on SECY 93-087 Conclusive progress on all Policy issues. Mutually acceptable closure on most.
SECY-93-087 is an excellent summary of both completed issues and a few issues where important work still remains.
Recent action to finish the difficult issues of Regulatory Treatment on Non Safety Systems and Source Term have been very encouraging and portend more success.
Positions described today are in fact very close to staff recommendations on most issues.
Closure and implementation details are important to achieving design certification in a timely f ashion.
Advanced LWR Program
Utilny/ALWR l
Joe Santucci 1
- Manager, Advanced Reactors Development k
Advanced LWR Program
[ Utilny/ALWR
/
Policy History - ALWR Involvement ALWR Program identified " Optimization Issues" very early in the program.
The staff prepared SECY 90 016 list of " Policy issues"in early 1990 and received Commission guidance in June of that year, industry commented.
A separate list of " Passive Plant Central issues" was submitted by the ALWR Program in March 1991.
Additional" issues" continued to be identified by the NRC staff and were released as " draft" positions in February and June of 1992. The ALWR Program commented in May,.
August and December of 1992.
Some issues were discussed with staff management in January of 1993 in Palo Alto. Additional comments were provided to the staff in February and March during discussions of technicalissues.
Advanced LWR Program
Utility /ALWR Policy History -(ALWR involvement cont.)
SECY 93487 issued with no explicit request for comment.
ALWR Program reviewed SECY and decided to comment; USC concurred. NUMARC and three ALWR designers also decided to comment.
Initial ALWR Program comments were sent to NRC staff on May
- 11. Final comment letter sent to Commission on June 7. Final comments are USC-endorsed and are essentially as stated in initial letter, and are fully consistent with designers' letters.
This briefing was requested because the USC wanted to communicate that, great progress notwithstanding, there remain a f ew issuss closed by the staff which we believe warrant further consideration.
Advanced LWR Program Utility /ALWR Jack DeVine Program Manager ALWR Program J
Advanced LWR Program f
lssue Discussion Outline Three issues for which we disagree in part:
Seismic Considerations Beyond Design Design Reliability Assurance Program High Pressure Gas Samples in Post Accident Sampling System Six issues for which some additional comment or clarification is needed Two additionalissues noted in designer letters Emergency Planning Core Debris Coolability Twenty nine issues - no disagreement Advanced LWR Program Utilay/ALWR Seism!C Considerations Beyond Design (part of issue ll.N)
Concern is the instability of the decision and potential for unneeded COL expense.
Difference between 0.5g and 0.6g is significant because it goes into an area of much less data.
P Elimination of current (IPEEE) methodology in f avor of a new process causes unnecessary uncertainty, Advanced LWR Program
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Utiltty/ALWR
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Design Reliability Assurance Program (part of issus ll.M)
SECY.93-087 considered this a " future" issue, i
Do not consider it appropriate to put RAP in Design Certification Rulemaking (Tier 1).
Believe DRAP can be dealt with now through review of the Utility Requirements Document, Advanced LWR Program
[ Utilny/ALWR
(
High Pressure Gas Samples in Post Accident Sampling System (part of issue 11.1) i ALWR Program and all designers disagree with the need for this sample.
Both capital and O&M costs are significant.
This area is also being considered for reduction / elimination because of its marginal safety significance for current plants, Advanced LWR Program
Utility /ALWR Comment or Clarify Any problems here can be worked out between NRC and industry and documented in clarifying correspondence, l.F. Intersystem LOCA Allow change in valve requirements for higher pressure designs. Do not need specialtreatment for isolation of systems not connected to the primary coolant.
l.G. Hvdrocen Control-Clarify that Passive Autocatalytic Recombiners are acceptable once demonstrated.
l.N. in Service Testina of Pumos and Valves - Concern remains over " practical" and criteria for " practicality".
Advanced LWR Program Utility /ALWR Comment or Clarify 1
(continued)
II.H. Containment Leak Rate Testina - Does the NRC position cover, by implication, more than just Type C testing?
II.Q. Defense Aasinst Common-Mode Failure in DloitalI & C -
" Position #4" is being interpreted two ways by designers.
One way involves the addition of additional equipment.
II.R. Steam Generator Tube Ruoture Analysis of multiple tube rupture should be "best estimate", not " design basis".
Advanced LWR Program i
G b
Utiltty/ALWR Additional Comments from Designers a
The Design Certification applicants agree with ALWR Program corr *ments above, and in addition identif y the following:
1.H Core Debris Coolability-Specify use of Service Level C or, pref erably, specific clarification on "shell buckling" (See Westinghouse letter).
Ill.G Emeroenev Plannina - The ALWR Program and the design teams believo Evolutionary plants as well as Passive designs should have the opportunity to demonstrate and utilize the emergency planning criteria (See ABB-CE letter).
Advanced LWR Program Utility /ALWR No Disagreement (including " future" Issues) l A. Physecu Based Source r
Term 1S ATWS 11 A Industry Coese & Stardeos i
11 B ElectcalDatrtanen p
11 C Seerruc Hasard Curwee I I-I'' OC'* U*E H E. SWR Man $1oarrano iJ Cordamment Performanos M F TM W l K. Dedcated Contam M tl G Contammerd Bypass l L E4$8prnord &*varetetty H J. Lowet ot Dated iM Omssaten of 00E g g p, ML ITAAC n o SAMDAs 11 S PRA Beyond Doogn Certiesten H T, Control Room Annunastor til A Mogulatory Treatment of h'ety Systerre m B Deee n a Passa,.F u.
m c. $swa sue.my lit D Sale Shutdourn Pw_... _cca
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lil F. Redenutsale Attomation lit M Rois af the Passavo Piard Operator i
Advanced LWR Program l
'I
Utiltty/ALWR John Taylor Vice President, Nuclear EPRI Advanced LWR Program Utility /ALWR Resolution of Issues
" Disagree in Part" and " Additional Clarification" i
These are not new issues, industry positions are clear and well-known to the staff.
J These issues have potentially major cost or operational implications to utilities, and should be resolved generically.
For these issues, we should expeditiously complete technical discussions with the NRC staff. These need not cause schedule delay; on the contrary, resolution of these issues now is likely to have long range cost and schedule benefits for Design Certification applicants.
Advanced LWR Program I
c.
1 Utility /ALWR R. Patrick Mcdonald Vice-Chairman ALWR Utility Steering Committee Advanced LWR Program Bottom Line Need well-based, well-understood policies and technical resolutions.
P For the most part, the NRC staff and industry have achieved this.
Commission requested to ask staff to work with us to promptly resolve these issues.
Advanced LWR Program
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June 11,1993 1
Office ci the Secretary L.5. Su: lear Rc;uiator:. Cc---
asmn Washington, DC 20355
Dear Sir:
Subject:
June 10 Briefing on the Advanced Light Water Reactor Program In reviewing the results of vesterday s meetmg with the Commissioners, our team identified two areas of our cuestion/ answer exchange m which mformation we provided should be corrected. In order for the record of this meeting to be completely accurate, please note that:
At one point in my dialogue with Commissioner Rem:ch, I referred to the Post-Accident Samphng System (PASS) as a iaicty grade" system. This is not correct. PASS is a TMI 2 lessons learned item, identified in NUREG - 0737, and required by NRC per 10CFR50 10CFR50.34(f)(2)(viii). As a severe accident system it is not safety grade, but it is subiect to NRC lurisdiction in a manner similar to hydrogen control, station blackout, and other plant protective capabilitics, Near the end of our meenng, Commissioner de Planque asked-whether we had seen the finallanguage m SECY 93-C57 before it was issued. As indicated in our presentation mater:ai, we had in fact reviewed and :ommented on draft s ersions of the SECY, but we beheve that our input on the items discussed yesterday was not acequately reflected in the final document. More importantly, there was no managemem level discussion on these tems prior to finanution at SECY 93-057.
6/14...To EDO f or Appropriate Action...Cpy to: Chairman. Conrs, OGC, SECY. RF. 93-0520-
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Office of the $ccretary June 11,1993 Page 2 Horefully there was..: ceniasion in these avo areas,I':dkv.e these are gen'erally' peripheral :o the central message of our presentation, and they do not affect our condusions. Again we thank the Commissioners for their time and attention.
Very truly yours, em I-i
(
1)
John C. DeVine, Jr.
Senior Program.\\ lanz ger (Acting)
Advanced LWR Program e
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