ML20055H310
| ML20055H310 | |
| Person / Time | |
|---|---|
| Issue date: | 07/18/1990 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9007260034 | |
| Download: ML20055H310 (145) | |
Text
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lC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION i
b.
BRIEFING ON ESSENTIALLY COMPLETE DESIGN ISSUE FOR PART 52 SUBMITTALS LOCatiOD ROCKVILLE, MARYLAND OtO JULY 18, 1990 h0963 122 PAGES l
NEALR.GROSSANDC0.,INC.
COURT REPORTERS AND TRANSCRISERS 1323 Rhode Island Avenue, Northwest Washington, D.C.
2p005 (202) 234-4433
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90072600M 900718 l
r DISCLAIMER l
This is an unofficial transcript of a meeting of the United states Nuclear Regulatory Commission held on July 18. 1990, 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 j
contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is 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 dectrmination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
I HEAL R. GROS $
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BRIEFING ON ESSENTIALLY COMPLETE DESIGN ISSUE i
FOR PART 52 SUBMITTALS PUBLIC MEETING 1
Nuclear Regulatory Commission One White Flint North Rockville, Maryland Wednesday, July 18, 1990 i
The Commission met in open
- session, pursuant to notice, at 2:00 p.m.,
Kenneth M.
- Carr, Chairman, presiding.
COMMISSIONERS PRESEN'i:
KENNETH M. CAR 1, Chairman of the Commission KENNETH C.
ROGERS, Commissioner JAMES R. CURTISS. Commissioner FORREST J.
REMICK, Commissioner i
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STAFF SEATED AT THE COMMISSION TABLE:
u' WILLIAM C.
PARLER General Counsel' i
ANDREW BATES, Office of the Secretary l
JAMES TAYLOR, Executive Director for Operations DR. THOMAS MURLEY, Director, NRR MARTIN VIRGILIO, Chief. PTSB,.NRR WILLIAM
- TRAVERS, Assistant Director for Special Projects,.NRR i
REBECCA NEASE, Technical Assistant, NRR i
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2:00 p.m.
3-CHAIRMAN CARR:
Good afternoon, ladies and' 4
gentlemen.
5 An issue - currently before the Commission 6
is the question of how detailed an application and 7
design certification must be under Part 52 in_ order to 8
aupport both a
safety review by the NRC and to 9
encourage standardization.
10 On Mondav, July 16th,. 1990, the Commission 11 was briefed by the industry with their-views on the 1
12 subject.
- Today, the Commission will be briefed on 13 this matter.by the NRC staff.
r-y 14 I understand that copies of the briefing 15 slides and the staff's
- paper, SECY-90-241,-
are 16 available at the entrance-to the meeting room.
17-Do my fellow Commissioners have any 18 opening remarks?
19 Nr. Taylor, you may begin.
20 MR. TAYLOR:
Good afternoon.
With me at 21 the
- table, to my far
- left, Rebecca
- Nease, Marty 22 Virgilio.
To my right, Doctor Murley and Bill Travers 23 from the Office of NRR.
24 With regard to the subject of the span of 25 design detail, the staff has prepared and presented Y..
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1 options on this subject rather than make a _ specific-2 recommendation because we feel collectively that this 3
is such a major policy issue and will have deep effect-4 on the work of the staff and will effect wh a't e v e r 5
future plants lie ahead.
6 The paper that the staff has prepared on.
7 the subject-I understand has been made publicly 8
available.-
I believe.there are copies at the entrance 9
to the room, as the staff suggested to the Commission.
10 With that introduction, I'll turn to 11 Doctor Murley.
12 DOCTOR MURLEY:
Thank you, Mr. Chairman, f
13 Commissioners.
There are two policy issues that we 1
~
14 have posed for the Commission in the paper.
The_first 15 one is the level of' design detail.
As you mentioned, 16 Mr.
- Chairman, the other is whether the. two-tiered 17 approach for certification as laid out by NUMARC last 18 Monday is an acceptable approach for certifiention.
19 Both of those, we believe, are important issues for 20 the Commission.
21 We'll start out talking about options and 22 the information that we've been able to gather on 23 level of design detail and what it means.
At the end, 24 because there were some questions that came up Monday 25 with regard to staffing and how we would conduct our 1k I
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1 reviews, I'd like to take a few minutes at the end and 2
talk about that.
3 With that, Marty Virgilio has done a large 4
amount of work uith Rebecca Nease and others on our 5
staff, talking with members of the utility industry, 6
the architect / engineer industry and also the reactor 7
vendors.
They've been able to pull together the 8
information and I'd - like to turn 1.
over then to 9
Marty.
.10 MR. VIRGILIO:
(Slide)
Could~I have the 11 first slide, please?
12 As Tom pointed out, there are two policy
_7-13 issues. that we addressed in our paper.
Back on April V
14 27th, the staff briefly discussed'these policy issues 15 with the Commission and since that meeting we have 16 reviewed Part 52 and conducted meetings with CE, GE, 17 Westinghouse,.
Stone and
- Webster, Duke, Northeast 18 Utilities and others and have conducted many internal l
19 meetings on this subject..
As a result, we've prepared 20 our paper that we presented to you.
21 (Slide)
If I can.have the next slide, 22 please.
23 In examining the level of design detail, 24 we found three-variables ~ associated with the contents 25 of the application, what's availab1'e for audit, and r- -
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1 material in the certification.
Section 52.47 makes 1
2 applicable Parts 20, 50, 73, 100' with regard to 3
technical information and requires a
proposed 4
technical resolution to all the medium and high i
5 priority safety issues in. 0933.
It requires ITAACs, 6
inspection, tests, analysis. and - acc.eptance criteria.
7 It also requires that PRA, site specific parameters.
8 postulated for the design and a conceptual design. for-9 the site specific - features not specifically included 10 in the application.
11 When we read this section, we view it to 12 require three
- things, sufficient detail for us to 13 judge the acceptability of the
- ITAACs, sufficient i
L..
14 detail for us to reach our final -conclusions on all 15 safety questions, and sufficient information to allow 16 the applicant to prepare procurement specifications 17 and construction and installation specifications.
18 We read this section to require, at the 19
- stage, minus the site specific and as-built 21 information typically included in an FSAR.
22 In the next variable, we look at ' material 23 available for audit.
What we see is that information 24 contained in procurement and construction and 25 installation specifications-be completed and available
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1 for the staff if necessary for us to make our safety l
2 findings.
We see that this section requires, at.a 1
3 minimum, performance characteristics to be include.d.
4 At the other end of the spectrum, you could see final-5 specifications including commercial information.
6 Then last, material in the certification.
1 7
The rule is not very prescriptive on what is to be 8
included in the certification.
The statements of
'I 9
consideration imply that the-certification-will be no 10 more-restrictive than Section 50.59 is today.
How thN certification, it 11 much detail that is ' present in 12 goes on to say, would have to be. resolved in the rule 13 certifying the-design.
What is clear to us -is. that y
-14 what is included -in the certification is what is 15 guaranteed in-terms o f.
standardization through the 16 process.
17 (Slide)
If I can have slide 3, please.
18 In examining this, we found four levels of 19 detail and we've chosen the four levels for 20 illustrative purposes only.
It's not to say that i
21 there are only four levels.
They are a spectrum o 22 choices.
We've just picked four.
On different 23
- systems, you may want different levels of details.
24 It's not to say that you pick one level and you apply-25 that for all systems.
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In our paper, we examined the HVAC system-2 in some detail.
We looked ~at the. differences in 3
levels as a result of varying the contents of the j
4 application, the material available for audit and what 5
would be included in the final-certification.
In our 6
paper, we've included-a table.
I t. 's' Tab l e 1 and it l
7 shows at the various levels what one would see.
8 (Slide)
If I can have the next-slide, 9
number 4, plecoe.
10 Looking first to level
- 1. -
~in our 11 application we see
.a number of fe'atures that 12 constitute the essentially > complete = design.
In this 13 case, we see a biddable, completely designed facility
~
14 with identical
- physical, functionn1 and performance l
15 characteristics.
16 I
draw your attention to the
-line, 17 component performance characteristics.
Here what 18 we're talking about is heat. removal capabilities, 19 pressures, temperatures, flow rates, sizes and filter 20 efficiencies when we looked at the.HVAC system.
21 There's also a significance associated with that line 22 and that's typically or traditionally how we've done 23 our reviews pursuant to the standard review plan.
24 Right below that line you'll see physical 25 attributes, orientation, location for components.
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Here we're talking in the HVAC system about supply and 2
exhaust fan type.
We're talking about the location._
3 and orientation of components.
You're talking about 4
the check valve type.
5 Next line
- down, geometric aspects for 6
suspended components.
What we're talking _ about here.
7 is cable trays, exact locations, piping, the ' routing 8
of conduit.:
In the next line we talk about component 9
support / restraint specifications.
Here you're talking 10 about component weights, mounting and support details.
11 All of ' this information, including the 12 ITAACs associated with this information, allow the r-13 staff to reach its final conclusions on safety and
?
14 standardization questions.
15 COMMISSIONER CURTISS:
Marty, before you 16 go on, that chart -- and since this question.will come 17 up, I think, in the subsequent ones, you indicated 18 that line there about two-thirds of' the way down 19 reflects the SRP level of detail.
You also indicated 20 that we could in how we approach _ this question vary 21 the level of_ detail depending upon the system and its 22 importance.
Is the refresh my-memory.
Does the 23 SRP do that now for a plant?
Do we. get different 24 levels of detail depending upon the system in current 25 SRPs?
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MR. VIRGILIO:
Yes, it does.
~
2 COMMISSIONER CURTISS:
'S o, this-line might-3 move up and down depending ' upon the system is what 4
you're saying?
5 MR.
VIRGILIO:-
.That's correct.
And ' the -
6-feed water system is a good example of where you would:
7 have today maybe.some less detail than you would have-8 in the reactor protection system.
9 COMMISSIONER CURTISS:
Do we have any 10 systems today where w'e in the SRP ; require a' level 1 11 level of detail?
12 MR. VIRGILIO:
No, not by the SRP today.
1.
13 CHAIRMAN C ARR::
And the SRP today permits
- a.
14 you to go back-and ask for anything you want to that 15 you're not able to get from what is submitted?
16 MR.
VIRGILIO:
Certainly it does if you 17 need that information to develop your' safety findings.
18 CHAIRMAN CARR:
,So, it's just a guide, 19 not 20 MR. VIRGILIO:
It certainly is.
21 CHAIRMAN' C ARR:
It's not something that 22 tells them what-to submit.
1 23 MR. VIRGILIO:
Right.
24 CHAIRMAN CARR:
Okay.
25 COMMISSIONER CURTISS:
Let me - sharpen my.
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1 question a little bit then.
In the Qs,and As process 2
that follows the application, do we get through the Qs 3
and As a level of detail that'would perhaps with.
j 4
the exception of requiring the specs to be included in l
5 the application, do we get a level of detail that goes-i
'6 up to level 17 7
M R.-
VIRGILIO:-
Not typically.
Not i
8 typically.
You may see then unless you want to 9
talk about level 2.
I think maybe that's 10 DOCTOR MURLEY:
Excuse me, Marty.
We have 11 to keep in mind that the process today. is a two. step-12 process and so at the early step, _the construction 13 application
- stage, we really are focusing on 7C 14 conceptual information.
At the final stage, we have.a 15 plant that we can go and look at, And so, to some 16
- extent, there is even more-detail to help us in our 17 review than would be in a level 1.
We would'actually 18 have a plant to go and.look at.in certain structural 19 areas, for example.
So, it's hard to strictly compare 20 the way we do today --
1 i
i 21 CHAIRMAN CARR:
Befo'e approving the r
L 22 operating license,'you mean?
23 DOCTOR MURLEY:
Before _ approving the 24 operating license, we have the plant built.
25 MR.
TAYLOR:
All the stress analyses are
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'done on piping.and so forth.
Actually, the. procured 2
date is available.for an operating-lic,ense.
3 COMMISSIONER CURTISS:
Okay.- Go ahead.
4 MR. VIRGILIO:
(Slide) ~0kay.
-If we could 5
go to slide 5.
6-Level 2 provides an essentially complete
' dentical 7
design that. includes physically similar i
8 functional and-performance characteristics.
Again, I 9
draw your attention to the line at component 10 performance characteristics.
-Everything above-the 11 line is the same as it was for level 1.
12 Withs regard to. level 2,
we look at key t
13 physical attributes for certain components.
Bas-d on
'Ca 14 lessons learned from operating experience, we would 15 select those physical attributes that provide,.mos t 16 risk sensitivity or we have seen the most problems 17 from. operating experience.
- Again, for example, we 18 would look at maybe check. valve type or ~in the HVAC 19 system we would look at maybe the coupling between the 20 fan and the motor for the supply and exhaust fans.
21 We 'would
- not, in level 2,
have exact 22 location and all physical attributes for components.
23 We wouldn't, for example,- have.for a heat exchanger 24 the exact location of
-the-nozzles.
But
.this 25' information would still provide the staff ' sufficient p
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standardization questions and would - allow -us to draw 2
final conclusions on safety matters.
3 COMMISSIONER C UR T IS S':
Back up on the 4
level 1 option.
I meant to ask ~ this question.
You S.
point out in the paper that thats probably 6
incompatible with existing Part 52.
.Is that because 7
we would be requiring procurement construction 8
installation specs in the~ application?
9
'MR.
VIRGILIO:
Yes.
That's principally 10 the reason why..we saw that.-
That might not conform to-11 part 52 as it's currently --
-12 COMMISSIONER CURTISS:
Are there other 13 inconsi iencies with.Part 52?
I tv 14 MR.
VIRGILIO:
That was the principal 15 reason.
16 COMMISSIONER CURTISS:
The only one?
17 Oany.
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~18 COMMISSIONER REMICK:
Let me ask a
19 question on level 2 before you leave it.
You have key 20 7.hysical attributes for components-under the -line.
If 21 I
look a t-table 1
for physical attributes and 22 configure each component, you show that as
.not 23 expected in application.
It seems to me they're 24 inconsistent with one an o t h e r..
25 MR. VIRGILIO:
What'we were looking -- ir l]
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1 you look at below the line of traditional standard i
2 review
- plan, you're starting to get the physical 3
attributes of cooling. coil type, heating coil type, 4
fan type, fan drive.
It's a matter of all physical.
5 attributes in line 8.
e 6
COMMISSIONER REMICK:
Oh, I see.
7 CHAIRMAN CARR:
The word " key" is.the key 8
to that problem.
9 COMMISSIONER REMICK:
Okay.
10 MR. VIRGILIoi Yes.
11 COMMISSIONER REMICK:' All right.
Okay.
12 MR. TAYLOR:
.In 1, you'd know---
13 CHAIRMAN CARR:
You get them all whether n
1
14 you need them or not.
15 COMMISSIONER REMICK:
O kit y.
All right.
16 COMMISSIONER 1CURTISS:
One final question 17 on level 1 and 2.
You note in your paper that.these l
18 two levels of detail, unlike level 3,
would-require
.19 what you call the standardization portion-of the 20 review.
Two questions.
Number-one, is that implicit 21 in the safety finding type review that you make and 22 the reference in Part 52 to you have to submit that 23 information necessary to make the safety findings or 24 do you view it as a separate finding beyond the safety 25 finding?
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(,">;
. like to know as you go-1
- Two,
_I guess I'd 2
through here,'either at this point.or'as you discuss 3
that, what the standardization portion of the review-r 4
wou14 focus on.
Clearly, that's the focus of Part 52 l
~
5 and perhaps if there is a _ distinction between the 6
safety part of the review and-the standardization part-7 of the review, which I've always viewed as a single 8
entity, maybe we ought to elicit that.
9 MR.
VIRGILIO:
If we go back and think 10 about what drives the review today by the technical 11 staff, it is'the standard review plan.
Right now, as I
12 I've pointed out, by the line.and on' table 1, you can 13 see that the standard review plan doesn't.go into some J
14 of the additional-' features that are - shown.below the 1
15 line.
16 I'm not sure I
would say a
separate 17 finding, but certainly we would have to go back and 18 revise our review guidance to focus the staff-and the 19 applicants on the addi'tional information that would be 20 needed.
21 COMMISSIONER.CURTISS:
Okay.
I take it in 22 what you're saying here that since you view level 2 23 standardization and that portion of the review as 24 implicit in the Part 52.47 contents of application 25 where it focuses on that information necessary to make NEAL R.
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the safety findings?
~
2 MR. VIRGILIO:
If we select option 2.
3 (Slide),
Let's take a look at application 4
under level 3 and that's slide 6.
5
- Here, I.
would characterize essentially 6
complete design _
as identical.
functional and-
--q
'7 performance characteristics.
- Again, all the items 1
8 above the line are the~same and the same in both 1 and 9'
-2.
Here, with regard to the HVAC system, you would 10 have the principal components of the HVAC' system' I
11 identified on the P& ids and plant layout drawings..
1
- l 12 They would be in a specified room and they would f
j 1
4 the characteristics you want.
Now,-
the fat, at 5
slightly different designs can come in mean tha. you j
a G
mount them differently on the-pipes, that your seismic 7
analysis is a little different and that sort of thing.
8 MR. TAYLOR:
Foundations and --
9 DOCTOR MURLEY:
Foundations might be a 10 little different.
11 COMMISSIONER CURTISS:
It depends on how i
12 tight the procurement spec, I guess, is and I gather r--
13 there are different views about how you define that.
u_
14 DOCTOR MURLEY:
Yes.
We had in mind that 15 the level I would include all the exact information so lo that you would have done the seismic analysis and you 17 had the locations.
So that if company X wanted to bid 18 on that particular procurement spec, he would have to 19 maybe build a design that was not his design.
He'd 20 have to build somebody else's design, whereas for the 21 level 2 and the level 3 level of detail that we're 22 talking about here, that kind of detail would be'done 23 after the applicant ordered the plant, but before he 24 came in for a
COL.
He would have to do that 25 engineering once he found out who the vendor was, i
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1 COMMISSIONER CURTISS:
Okay.
Go shead.
2 COMMISSIONER REMICK:
Let me follow on.
3 On the level 1, the example you used --
4 DOCTOR MURLEY:
- Well, he
- would, yes, 5
select a design --
G COMMISSIONER REMICK:
Or either write 7
specifications as specified where the inlet, outlet 8
and all those things were, the way it was.
9 DOCTOR MURLEY:
Exactly right.
10 COMMISSIONER REMICK:
Otherwise, he would 11 have to have selected a pump.
12 DOCTOR MURLEY:
Hight.
And than there may r --
13 be competitive reasons why that is not feasible, but O
14 that could mean that company X would have to be 15 building company Y's design if they wanted to bid.
16 CHAIRMAN CARR:
But he's going to have to 17 do that anyway between certification and COL.
18 MR. TAYLOR:
He should by'that time.
19 CHAIRMAN CARR:
From what you told me.
20 DOCTOR MURLEY:
Yes.
In other words --
21 MR.
TAYLOR:
And then design the 22 foundations, the connecting' piping, cable work.
23 CHAIRMAN CARR:
Okay.
24 COMMISSIONER REMICK:
The utility would 25 have selected the pump?
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1 DOCTOR MURLEY:
The utility would have 2
selected the --
3 COMMISSIONER REMICK:
In one case we're 4
talking about the vendor having to select and in the 5
other case we're talking about the utility for the COL 6
selecting a pump.
They're two different things.
7 CHAIRMAN CARR:
They're probably not.
I 8
mean I imagine it will be both of them in either case, 9
but --
10 COMMISSIONER REMICK -
Not necessarily.
I 11 can see 12 CHAIRMAN CARR:
-- it wouldn't have to be.
13 COMMISSIONER REMICK:
I could see a
e
"~
14 certified design without a buyer.
15 CHAIRMAN CARR:
But there's nothing that 16 keeps any pump manufacturer from building a pump to 17 fit that 18 COMMISSIONER REMICK:
No, thtt's true.
19 CHAIRMAN CARR:
spot.
20 COMMISSIONER REMICK:
That's true.
21 CHAIRMAN CARR:
He's going to if the 22 Job is
- there, he'll hang those inlets and outlets 23 wherever you want them for a price.
24 COMMISSIONER REMICK:
For a price.
25 CHAIRMAN CARR:
Let's proceed.
i
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MR. VIRGILIO:
(Slide)
All right.
We can 2
continue with slide number 10.
3 Under level 2, we certify essentially all 4
the information that's included in the application and 5
what's come f re.a our review and audit that's material G
to our safety finding and support the standardization 7
that we're trying to achieve through level 2.
i 8
Here you get a
substantial degree of 9
standardization and resolve a significant number of 10 issues at the certification phase.
There is a cost, 11 as we've discussed.
In this
- case, there is some 12 flexibility outside of 50.12.
You're not certifying 13 all the physical attributes under level 2.
You're not 6
14 certifying the exact location.
Geometric aspects of 15 suspended components are not being certified, nor is 16 there support and restraint data being certified.
17 This will allow for some changes through the 18 construction process.
19 COMMISSIONER REMICK:
It's at this point 20 where I have a little difficulty and I realized when 21 you wrote this you didn't know exactly what the 22 industry was coming in with.
But when they made a 23 presentation you do say in here that your level 3 24 is very close to what the industry is proposing, but 25 they proposed, as I understood it, that they would i
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1 provide not only room size but the location of major 2
components in those rooms and orientation.
3 So, presumably under levcl 3,
you're 4
saying that as you see it, that wouldn't even be 5
necessary in level 2.
There seems to be an 6
inconsistency here and I can understand why.
But we 7
addressed that question a little bit in depth because 8
they did say that in a room they would address the 9
location of the equipment and orientation.
That 10 surprised me and I asked the question and they said 11
- yes, they would be addressing
- that, presumably in 12 level 3 If level 3 is consistent with what they were l
13 proposing.
1
~
14 MN.
VIRGILIO:
We discussed the 15 application under level 3.
I talked about the P& ids 10 and the layout drawings and that's what they have in 17 mind that they would have. They would know the pump is 18 in the room, they would-know the valve is in the room, 19 they would know the heat exchanger is in the room.
20 But if it was of substantial size, they would know the 21 orientation of those components.
22 COMMISSIONER REMICK:
Yes.
They did not 23 say if of substantial size, but that might be what 24 they meant.
25 CHAIRMAN CARR:
I think they did say i
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37 1
safety significant ones.
'2 COMMISSIONER REMICK:
Yes, I presume that.
3 I presume that.
4 MR.
VIRGILIO:
I think industry has 5
characterized themselves in a meeting we had with the 6
ACRS as being somewhere around a 2.5.
7 COMMISSIONER REMICK:
Okay.
8 COMMISSIONER CURTISS:
On level 2.you're 9
going to certify everything that's in the application.
- 10 Do I understand that correctly?
11 MR. VIRGILIO:
Yes, essentially the entire 12 application.
13 COMMISSIONER CURTISS:
On
- Monday, the i
14 industry made the point, in fact read our language 15 back to us, that' in the statement of considerations 16 the Commission envisioned that there ' will be less 17 detail in-the certification than in the application.
18 Assuming that's an accurate reflection of the-10 Commission's sentiment, how do you reconcile n level 2 20 approach that requires everything in the applica t ioni 21 to be in the certification?
7 22 MR.
VIRGILIO:-
I would have -a difficult 23 time justifying the level 1 approach in_that regard,-
24 but I
think with level 2
there's still a certain 25 amount o f-flexibility.
Not all the information--
i, L _.
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1 essentially the significant portions of the 0
application, but not all the application.
As in level 3
1, all the application is incorporated into the 4
certification.
5 COMMISSIONER CURTISS:
Do the Qs and As go 6
in?
7 MR. VIRGILIO:
They may.
It depends.
It 8
would depend on whether the Qs and As got you down to 9
a level where you were looking at key features and 10 physical attributes associated with key features and 11 you were trying to incorporate that information in 12 order to ensure standardization.
13 CRAIRMAN CARR:
But when I
read that 1
~
14 statement, all that meant to me was that certification 15 might be like your college degree.
It doesn't show 16 everything you learned in the course, but you had to 17 complete the course before you got your certified 18 degree.
And all that meant to me was that we weren't 19 going to turn around and issue everything in a
20 certification that the application had in it.
It said.
21 that an application is hereby certified.
It could be 22 a small piece of paper.
That's the way I read that 23 before I got all the legal opinion.
24 COMMISSIONER CURTISS:
I guess that's 25 consistent with my view.
But if you take a two-tiered r---
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1
- approach, then it's very important what you have in 2
the certification and in tier 1.
So, I gather they're 3
making that point and again here I'm just, I guess,-
4 making the argument here not because I
happen to 5
support it but because they're making the point that 6
the detail on the certification would be less than the 7
application and then it's a
question of how much 8
between tier 1 and tier 2.
l 9
What you're saying here is that there are
'I
'10 going to be some things in the application, depending 11 upon the specific system that you're talking about, 12 that would not find their way into the certification 13 under level 2.
r-14 MR. VIRGILIO:
Under level 2.
15 COMMISSIONER CURTISS:
- Then I think that's 16 consistent with the way I read Part 52.
17 MR. VIRGILIO:
That's correct.
18 COMMISSIONER CUKTISS:
Okay.
19 MR. VIRGILIO:
(Slide)
If we go to the 20 next slide, slide 11, we talk about level 3 and what 21 would be included in the certification.
I've i
22 enumerated a number of features, the design criteria, 23 bases, system functional descriptions, right down to l
24 the P& ids and the layout drawings.
l 25 To be fair, this level provides a marked
- t. _
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,1 1
degree of standardization.
You've standardized the 2
functional and performance characteristics far in 3
excess of what we have out there today.
It allows a 4
certain amount of flexibility for change. pursuant to 5
50.59.
6 (Slide)-
Go on to the next slide, slide 7
12.
P Our paper highlights this as a
second 9
policy question, flexibility.
This could'be applied 10 to any of the levels.
It's not necessary that it 11 applies only to level 3.
12 As industry told you on
- Monday, this 13 approach involves formatting the application into two 14 distinct parts and allowing one part to change 15 pursuant to 50.59 type tests.
The resolution of all 16 safety issues, the grouping of the issues in two parts i
17 and the 50.59 type process would all be subject to the 18 rulemaking process certifying the design.
19 The desired effect is to allow flexibility 20 to change the design as necessary; to deal with tt 21 construction deficiencies, unavailability of equipment 22 over the life o'f the certification and to be able to 23 take advantage of improvements in technologies or new 24 technologies.
25 COMMISSIONER REMICK:
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On your table 1,
you 2
identify the F as flexible change w i t h o u t, 5 0..~ 2.
I 3
assume, however, with 50.59.
4 MR.
VIRGILIO:
Or whatever test you so 5
choose to govern those changes.
G COMMISSIONER REMICK:
Okay.
7 MR. VIRGILIO:
That's correct.
8 COMMISSIONER REMICK:
Okay.
Thank you.
9 MR. VIRGILIO:
We --
10 COMMISSIONER CURTISS:
You touched on the 11 three points the industry advanced for why they need 12 this kind of flexibility, interferences, obsolescance 13 and the need to take advantage of the advancements in 14 the state-of-the-art in technology, I guess.
15 Focusing on the interferences question for 16 a minute, get out in the plant and construct it and 17 your cable tray runs into your pipe and you're off by 18 three inches.
To what extent can that issue be i
19 addressed through the use of tolerances and how much 20 of the problem that they've identified and as yod 21 understand it could be addressed by the kind of i
22 latitude and flexibility that tolerances contained in 23 the license in the vendor design or the COL would 24 provide?
26 MR.
VIRGILIO:
- Today, with the use of i
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42 1
1 computer-assisted drawing techniques, I believe that 2
you do get some advantage, but I believe that some 3
interferences are inevitable in the construction i
process.
I'm not sure even with increasing the 5
tolerances that you're going to be able_to completely 6
eliminate these types of construction inter.ferences.
7 COMMISSIONER CURTISS:
Okay.
Then on the 8
question that I
guess we raised last Monday of 9
obsolescence and the flexibility to take advantage of 10 new developments, new kinds of components, as the 11 Chairman pointed out, if you don't certify nameplate 12 data in the certification, how much of a concern 13 remains under this heading?
Hov much of a
need 14 remains to still have that 50.59 flexibility, in your 15 Judgment?
16 MR.
VIRGILIO:
If I think about how much I
17 we've advanced in the instrumentation and control area i
18 alone in the last 15 years, there's a lot more than 1
19 nameplate-data involved.
We've gone from relays that 20 constitute our voting logic for initiating protectivs 21 actions to software that does that today.
So, there's 22 a significant advance over the course of the last 15 23 years in that area.
24 CHAIRMAN CARR:
But you didn't -- in the 25 current thing, you didn't certify a relay.
You said I.
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k-1 there was some switch there.
2 MR. VIRGILIO:
That's correct.
But if you 3'
were to look at level' 1, we are really talking about
[
t 4
certifying the relays and in some cases maybe the 5
physical attributes associated --
G COMMISSIONER CURTISS:
Since it's illegal, 7
focus on the differences between 2 and 3.
I think we 8
all recognize that --
9 CHAIRMAN CARR:
No, that's -- you're going 10 to do it at the-combined operating license point 11 anyway.
12 MR. VIRGILIO:
No, sir.
That information 13 would be available, but it's not necessarily going to 14 be incorporated into the application-or certified at 15 that point in time.
16 CHAIRMAN CARR:
But it's going-to be 17 available at that point in time is what I'm saying.
18 He's not going to change it from that point until he 19 builds the plant without getting our permission.
l'h e y 20 don't walk in there and change their instrumentation.
21 DOCTOR MURLEY:
Excuse me, but that 22 information that goes beyond what's in the-23 certification would -- he could change through a 50.59 24 process.
That is anything, no matter what level we're 25 t'alking here, 1,-2, 3 or so forth, there is a certain l
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amount of design information that needs to be done 2
before you to the COL.
Any information in that part 3
of the design can be changed, as I understand it, 4
through a 50.59 type of process.
COMMISSIONER CURTISS:
You're talking 5
6 about the vendor certification?
7 CHAIRMAN CARR:
I'm talking about the 8
difference between the certification and what goes on 9
between then and the combined operating license.
The 10 guy can do anything he wants to as long as he doesn't 11 change the certified portion.
12 COMMISSIONER CURTISS:
That's correct.
13 CHAIRMAN CARR:
Which is some degree of r
- w. _
14 standardization.
We standardize whatever we 15 certified.
16 COMMISS7.ONER CURTISS:
That's right.
17 That's why the geestion of what you certify, or if you 18 take a two-tisr approach --
19 CHAIRMAN CARR:
Standardized power level, 20 kilowatts, flows, pump numbers.
21 COMMISSIONER ROGERS:
Well, just on this, i
22 this question of tolerances, is a
tolerance 23 flexibility a way of putting something in tier 1 and 24 not having it available for 50.59 change by just using 25 a tolerance?
Does that make sense or not?
i i
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MR. TAYLOR:
I personally don't think you 2
could do that.
There are tolerances in the analyses 3
that are included, but if you -- those are usually not 4
Jarge tolerances.
If you are doing pipe stress whatever there are 5
analysis, when something is 6
lots of examples where they go beyond what are so-7 called normal tolerances and then ' you have to rerun 8
the stress analysis.
O COMMISSIONER ROGERS:
- Well, I
wasn't 10 thinking so much of interferences and things of that 11 sort, but questions of obsolescence.
12 CHAIRMAN CARR:
Let me go back --
13 COMMISSIONER ROGERS:
You-set a tolerance m-14 on a component, then it would allow perhaps for a new 15 design of some sort that was better but a little bit 16 different without necessarily having to --
17 CHAIRMAN CARR:
- Well, I've seen those 18 situations where the guy who builds.the computer says, 19 "I want an input of 120 volts and so many amps-plus or 20 minus 0.1."
The guy that builds the generator says, 21 "Okay,'I'll give you 119.6 plus or minus 3,"
and you 22 end up with a tenth of a volt overlap that makes it 23 work or not work.
That's just --
24 COMMISSIONER ROGERS:
Yes.
25 CHAIRMAN CARR:
Everything meets the. specs L
j l
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-1 as long as it doesn't drift a little.
2 DOCTOR MURLEY:
Okay.
We haven't talked 3
about construction methods here and we're not really 4
prepared to.
There is some discussion by the industry i
S that they would go to modularized factory construction 6
for a large p9rt of it, in which case you could hold 7.
tolerances better than field fabrication --
8 CHAIRMAN CARR:
And assemble submarine 9
sections by lasers and they seem to fit great, j
10 DOCTOR MURLEY:
'Yes.
And then you can do 11 that.
But I don't think, at least in the next decade 12 or so, that any nuclear plant would be-built that way.
13 So, you'd have to still rely on a. great deal of field
~
14 fabrication and field construction.
15 CHAIRMAN CARR:
What you're convincing me 16 of is what'the utilities convinced me of Monday and 17 that la that number 1 plant could have a tier 1, tier 18 2 or some degree of flexibility, but why would you 19 need that in a second plant?' If you've done it once, 20 you now know what the designs
- are, what the 21 interferences were and you don't have them anymore.
22 That's standardization as far as I'm concerned.
23 MR.
TAYLOR:
Only obsolescence in that 24 case really because it can extend over a 15 --
25 DOCTOR MURLEY:
They use
.the s ame
,)
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6-1 drawings 7 2
CHAIRMAN CARR:
Hopefully, the 3
construction period won't be so-long that things will 4
get obsolete during the building period.
5 COMMISSIONER ROGERS:
Yes, but the design 6
certification goes on for a long time.
7 DOCTOR MURLEY:
The design certification 8
can go for 30 years, as I understand it.
9 CHAIRMAN CARR:
But I see no reason they 10 can't apply for a change in the certification.
If a 11 guy wants to change that all he has to do is come in 12 and request the change, 13 DOCTOR MURLEY:
There's a process, yes.
e- -
14 CHAIRMAN CARR:
Let's go ahead.
15 COMMISSIONER CURTISS:
One other question 1G there on that, Ken.
I 17 If I understand the industry's proposal, 18 they are talking about a two-tiered process both for 19 the vendor certification as well as the COL, parallel l
20 to the COL, where under the tier.2 process they could 21 50.59 change this.
We've talked about the three 22 reasons why they'd like to have that and focused 23 really on what happens when you get out and construct 24 the plant, a utility goes out and finds out that 25 they're interferences or operates it over time and 7-C NEAL R.
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G
e 48 Fr-1 decides that the equipment is obsolete or needs to be 2
updated to take advantage of the state-of-the-art.
I guess I'm still struggling to 3
What 4
understand the need for a 50.59 provision for tier 2 5
in the vendor certification where they seem to be 6
implying that the vendor, for some reason, would need 7
to change the certification.
Obviously there aren't 8
going to be any interferences in just the paper 9
document of a certification.
What sort of need do you 10
- see, if
- any, for 50.59 flexibility in the vendor 11 certification and recognizing that the Part 52 already 12 provideo the flexibility to come in and get an r--
13 amendment or an exemption?
~
14-CHAIRMAN CARR:
I didn't hear him make 15 that particular -- if I did, I missed it.
16 COMMISSIONER CURTISS:
Maybe I
17 misunderstood what they said.
Aren't they looking for i
18 50.59 flexibility in the second tier?
There's a two-1 l
19 tier process --
20 DOCTOR MURLEY:
Yes.
21 MR. TAYLOR:
Yes.
22 COMMISSIONER CURTISS:
-- reflected in the 23 certified design.
24 CHAIRMAN CARR:
That's an uncertified l
25 portion.
i t
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49 1'-
1 COMMISSIONER CURTISS:
I understand that they're proposing that second tier 2
and my question 3
because of the perceived need for flexiM lity in the 4
information that a vendor has in a second tier of a 5
certification.
6 COMMISSIONER REMICK:
But, Jim, wouldn't 7
certification, including tier 2, be a part of the COL 8
of the combined license and therefore you would need 9
that S0.59 for tier 2 if it's --
10 COMMISSIONER CURTISS:
A COL holder would.
11 COMMISSIONER REMICK:
A COL, I
- assume, 12 would Just take a certified design and --
13 CHAIRMAN CARR I'm not sure we're not r--
14 confusing configuration control after the plant is 15 built and licensed.
That's different.-
16 MR.
TRAVERS:
What I have heard is that 17 the vendors don't anticipate exercising that kind of 18 flexibility between the issuance of the design 19 certification and the COL stage, but'rather it comes 20 into play at the COL period.
In
- fact, there's a 21 disincentive -- in fact, I don't even know if_50.59 is 22 applicable to vendors that hold design certification.
23 Perhaps the General Counsel --
24 MR. PARLER:
Well, I think that's already 25 been raised in this meeting and the answer was no, but F
k NEAL R.
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1 the vendors would be stuck with what the certified 2
design rule provides unless they wanted to seek to 3
have an exemption made or an amendment made to it.
4 COMMISSIONER CURTISS:
Okay.
Go ahead.
i 5
MR. VIRGILIO:
There were three attributes G
that need to be recognized regarding this approach 7
that we pointed out in the paper.
One is the 8
increased flexibility will lead to less engineering I
9 being completed at the time of certification.
- Two, 10 changes made under the 50.59 type process could be 11 subject to challenge in hearings that could delay 12 operation.
Third, the process will allow for erosion 13 of standardization, as we've discussed.
r 14 (Slide)
Moving on to the next slide, we 15 talk about the certification at level 4'and you could 16 certify the entire application and you would still 17 have a limited number of issues resolved and it would l
18 leave much to be certified at the COL stage.
19 In
- summary, our paper has asked the 20 Commission to provide us guidance on level of detail 21 in what's included in the application and what's 22 included in the certification, and we've asked the' 23 Commission to provide us guidance on that two-tiered 24 approach.
25 That completes my portion of the l
i.
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.g U
1 presentation.
I'd like to turn it back over to Tom.
2 DOCTOR MURLEY:
There were some questions 3
that came up Monday with regard to staff reviews and I 4
thought I would take a moment and discuss what our 5
situation is, what our status is and how we would plan G
on going about those reviews, 7
We, as you know', have been reviewing the 8
evolutionary plants for over three years now and we 9
view the phasing of thene reviews to be such that 1
10 the evolutionary plants would lead the way.
First of 11
- all, they look familiar to the staff.
We have 12 reviewed some recently.
We can use the standard t-13 review plan generally, The major areas where we do 1
14 see differences are in the severe accident area and 15 here we've just recently brought up the issues that we l
16 saw with the Commission and those have been resolved, i
17 So, we think that the evolutionary plants
~
18 then will lead the way and the reviews of those will 19 be used to flush up technical policy issues for the 20 Commission like we did on the severe accident issues.
21 And as we move further into the certification process, 22 we think they will flush up the procedural policy 23 issues as well that may arise and this seems to be one 24 of them, for example, the level of detail, 25 So, I
do not see any major. hurdles or FL_
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conceptual problems in the staff review of the 2
evolutionary plants with one possible exception and 3
that is we've not looked, carefully yet at the issues 4
of automation and control room design and certain I&C 5
issues.
We may be back to the commission with policy G
issues in those areas, what degree of automation to T
agree to and so forth.
8 Comina along next then would be.the 9
passive plants and I don't know but they'll probably 10 he at least a year or so behind in terms of the 11 evolutionary plants.
We will be doing some reviews of 12 the passive plants, particularly with EPRI, but I view 13 these as focusing on conceptual issues and broad m
14 safety policy issues.
15 There appears to be on the surface, for 16
- example, several areas whore the designs don't 17 strictly meet our current regulations and so we'd have 18 to flush those c :.1 and discuss those with EPRI and 1
19 with the vendor.
The standard review plan does not 20 apply strictis i: n we'd have to --
21 CHAIRMAN CARR:
Let me ask you about that.
22 DOCTOR Mt!RLEY:
Yes.
23 CHAIRMAN CARH:
I guess maybe I
don't 24 understand if we're only if we're going to certify 25 a design, a standard review plan seems to me to b e; I
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1 pertinent to where you've got 100 designs out there, 2
but we're only going to have four or five perhaps.
3 Each one of these is going to be its own standard i
4 review.
i 5
DOCTOR MURLEY:
That's right.
6 CHAIRMAN CARR:
So, I don't see that 7
DOCTOR MURLEY:
Well, because the 1
8 standard --
9 CHAIRMAN.CARR:
I guess what I'm saying is 10 why go through trying to change the standard review 11 plan rather than just reviewing the design.
12 DOCTOR MURLEY:
Because the standard 13 review plan is the collection of 20 years of r- -
(-o
~
14 wisdom --
15 CHAIRMAN CARR:
Oh, but if we l a g --
16 DOCTOR MURLEY:
on the' part of the 17 staff on what to look for.
How does one review 18 certain aspects of electrical systems, for example?
19 So, it's a guide and you're quite right, once we have l
l 20 a plant certified, then the standard review plan would 21 serve no purpose for th'at plant.
22 CHAIRMAN CARR:
Yes.
I guess my question 23 is you're going to have to go through the same process l
24 to review the standard review plan that you're going 1
25 to have to go through to review the design.
You're k..
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54 I
trying to match the review plan to the design to see 2
what you ought to be looking at.
It seems to me 3
simpler just to look at the design.
Am I
being 4
confused?
5 DOCTOR MURLEY:
I think I get your point, 6'
but let me say that --
7 CHAIRMAN CARR:
Because we're only going 8
to do it once for that design.
9 DOCTOR MURLEY:
Let me say it another way.
10 A plant comes in that doesn't meet our regulations, 11 let's say.
It's new, it may meet the intent, it may 12 even be better, but it doesn't meet what the staff has i,
13 seen before.
I don't feel I can just throw that u,_
14 design to the staff and say, " Review it."
What we do 15 is tear the applications apart and the electrical 16 branch gets a certain part, the thermal hydraulics 17 branch and systems branch get certain parts.
But we, 18 the management of the staff, have to stand above and 19 do an assessment of the overall safety of the plant.
20 That has to come first, I think, on that, particularly 21 on the passive planto.
In doing that, we'fe going to 22 have to give the. staff guidance that it's okay that 23 they don't meet the regulations in this area because j
24 of some other compensating features.
25 So, it's that kind of broad. view that
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55 y,
1 we're going to have to take and we just simply can't 2
turn a new design over to the staff because they 3
wouldn't know what to do.
And I
think that is or at least going to take a year, in my 4
probably 5
judgment, from what I've seen of some of the aspects 6
of the passive designs, discussing these issues.
We 7
can do it.
I don't feel that it's impossible, but 8
there are pretty broad issues at stake here.
9 CHAIRMAN CARR:
I guess I'm still 10 confused.
If you're going to look at a gas-cooled 11
- reactor, we'll
- say, and your standard review plan 12 probably doesn't fit that today, the same amount of e--
13 work is involved in trying to decide what the standard 14 review plan ought to be, it looks to me like, as to 15 decide what the reactor ought to be.
16 DOCTOR MURLEY:
Yes, you're quite -right.
17 The further away you get from --
18 CRAIRMAN CARR:
And as long as you're only 19 going to certify one design at a time, it's not like 20 you're going to have 35 BWR' designs to certify.
21 DOCTOR MURLEY:
- Now, your point is, I
22 think, the further you get away from the type of light 23 water reactors that we have licensed, then the less i
i 24 value is the standard review plan.
25 MR. TAYLOR:
So, that's the embodiment.
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1 CHAIRMAN CARR:
That's my --
2 COMMISSIONER ROGERS:
- Well, presumably, 3
the standard review plan embodies some sense of what's i
4 important.
5 DOCTOR MURLEY:
Yes, it does.
1 6
COMMISSIONER ROGERS:
What the key issues 7
are and it's very valuable te bring those up to the I
J 8
surface so that you're reminded of them, even if you 9
have to start anhw.
So, you don't want to be bound 10 and hog tied by the standard review plan, but on the 11 other hand as a guidance as to what the important 12 things are to be considered, certainly would seem to 13 be a useful backdrop to the new process.
~~
14 DOCTOR MURLEY:
And the way you do seismic 15 analyses, the way you do structural analysos would be 16 the same for any plant.
17 COMMISSIONER ROGERS:
- Yes, they're not 18 going to change that.
19 DOCTOR MURLEY:
The electrical systems and 20 how you ensure separation and diversity --
21 CHAIRMAN CARR:
I guess my concern was-22 hung up with having to work on the standard review l
23 plan for a year before you attack the design.
r 24 MR, TAYLOR:
I think he's emphasizing the 25 difference of the passive-features and how the passive i-NEAL R.
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1 plant represents a step change from the existing --
2 COMMISSIONER ROGERS:
Where the exceptions 3
are that have to be dealt with individually.
4 MR. TAYLOR:
an' there are going to be 5
differences.
We already know there are differences.
O CHAIRMAN CARR:
Okay.
7 MR. TAYLOR:
The point is getting those 8
areas identified and where they represent majer design 9
issues, to get them to the staff and to the Commie,sion 10 is going to be pnrt of our process and will be really 11 changed --
12 CHAIRMAN CARR:
Before, when you had seven 13 applications on your plate, I can see why you needed 14 some kind of standard review, but yeu're only going to 15 have one application probably at a time.
16 COMMISSIONER CURTISS:
And to some extent 17 those issues are going to be taken up, I gather, in 18 the EPRI requirements document as well.
To the' extent l
19 that they don't involve nitty-gritty detailed 20 licensing review, that may further minimize-the need 21 for an SRp.
22 CHAIRMAN CARR:
- Oxay, 23 DOCTOR MURLEY:
I was kind of responding 24 to Comt.issioner Remick's point on Honday-where he said 25 that we will have four designs.
I don't think we'll r
L_
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" :~
l' have them all at the same time and>at,the same_ stage.
'2 That was my point.
I think the evolutionary-designs 3
are going to move ahead and they're more traditional.
4 The passive plants, even though'we're_ working 1 on'them-5 at the same time, 'we're not at the same-level-of i
'6 detail and the. staff is not looking at-the kind of 7-detail in the passive' plants that they will be at_the l
8 same time for. the evolutionary plants.
I think it 9
will be at least a year or two later.
10 COMMISSIONER REMICK:
- Tom, I
have to 11 respond to that.
I agree with you that you-won't_have 12 four at the same time, but you have two now and you j {
13 have presumably two in 1b92.
And the one Way. to i
14 identify these differences and the issues that need to 15 be brought up for decision is to be in there= reviewing 16 and know what those plants are, staff looking at them 17 and determining what are the problems. if there are 1
18 any.
The only way to do that is get the staff in.
We f.
19 can't do it around-the table, 20 DOCTOR MURLEY:
- Now, let me. turn to the R
21 question of staffing-levels and the skills because we i
22 have been concerned about that and we're taking action 23 now to -- I've, some months ago, usked my senior staff 24 to prepare a plan for how we're going-to i n c r e a s'e the 25 staff skills that we need because we recognize NRR is
- y.-
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{
l A-1 thin in seve ral' ' disciplines.
Although we have been i
2 reviewing plants all along, we.certainly do'not have 1
3 the workload that we had cen and 15 years ago.
4 Our focus since the organizational change l"
5 in 1987,'the focus has been on assuring the safety of 6
operat.ing reactors.
So thait's what my focus and'--
I 7
CHAIRMAN CARR:
We don't want to lose.that 8
focus.
L l
9 DOCTOR MURLEY:
I know it and what I tell i
10.
my staff is now we've got to move to a duel focus-.
11
- where, as
-I understand-the commission, the first 12 priority is still to make sure the operating plant;.
r- -
13 are safe.
At-the same time, we've got to _ have-the i
\\
p 14 capability to do these reviews.
I'll have this. plan 15 ready in.a month or so and I'll need to: talk with Jim 16 Taylor to go over that with him.-
.i 17 The Agency as a whole has'a great deal of 18 expertise for tech reviews.
Not all of it, of course, 19 is in NRR.
Also, we find that we're still able to 20 attract talented new people.
My-staff just'-told me l
21 today that we've been-able to attract, for example,-an 22 assistant professor in-thermal hydraulics area.
We've 23
' hired two new instrumentation and cont rol p~eople who 24 are talented.
They've got to, o f - course, now learn 25 the regulatory system and learn the standard review r
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)
i 1
plan and' that sort of-thing, but the people _are out 2
there and we -- at least I feel confident that we can 3
get them.
We have to have a plan 'and we have to 4'
organize our recruiting and that. sort of thing, but we 5
can do it.
0 One other point
-I would
- nke on the 7
paasive --
8 CHAIRMAN CARR:
Excuse me.
9 DOCTOR MURLEY:
Yes.
10 CHAIRMAN CARR:
Are you thinking about 11 project-izing these reviews?
t 12 DOC"'OR MURLEY:
.Yes.
Oh, I see what 13 you -- no, I haven't decided that yet.
In other 14
- words, would we take off all -the people that are 15 needed to --
18 CHAIRMAN C ARR: A -la the TVA effort, or the 17 Comanche Peak effort or the npecial projects?
18 DOCTOR MURLEY:
.We haven't decided that.
19 Mr. Chairman.
It's certainly a consideration.
20 CHAIRMAN CARR:
It's one thing to focus 23-on.
I don't_know if y'ou've got that much technical g
22 t: lent.
}
El 23 DOCTOR MURLEY:
That's right.
If we've 24 got t. ire e and four and five and six to do, I don't 25 think I can do it.
If there's maybe only one or one
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'r 1
at a time, that's a possibility..
It would certainly 2
be more' efficient._
I've had some experience - along 3
those lines.
4' We do now have'more management time'and by.
5 that I-mean the senior managers of NRR because we've 6
got Seabrook-and Shoreham and Comanche Peak =behind us-7 and Peach Bottom and: Pilgrim and so forth..
)
8 CRAIRMAN CARR:
If I make a noteinf-that, 9
you got more time.
10 DOCTOR MURLEY:
We I find that we'have 11 more time at least to focus on these conceptual; issues j
by the passive 12 that ~
being presented in the are I
13' plant design.
14 I think there's one other final pol't that n
15 we've touched on a bit.
That is the greater _.the level 16 of.de t ail, obviously the more information that comes,
17 into NRC and the more need - we have for management 18 guidance to the staff on scope and depth of review.
19 That's why even t ho t.g h we don't necessarily' need to 20 redo the standard review plan, we. do have to have 21 something to control the staff from getting into just 22 great gory detail because their mode of-operation is 23 to review something that's put in front of them.
24 If there's-material that is' brought in 25 that we would not normally ask for for. our safety i_.__
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1
- Judgment, but la required by the Commission.
for 2-
. standardization
- purposes, then the staff would' 3
normally want to get' into. it and ask a
lot of 4
questions.
We.. the management, would have-to give 1
5 them guidance on.what is the proper scope-and depth.
6 That's a point 'to consider. in your deliberations, I
l 7
think.
8.
COMMISSIONER ROGERS:
Isn't that -,
9 MR. TAYLOR:
Excuse me.
If we I think i
10 I'd-like to-add to that.
If we certify a large body 11-
'of design, Tom's point is well taken.
Depending upon 12 the area and
'. t s effect on
. safety and its 13 significance,.we'1e going to have to devise plans of e
~
14 an audit-type review in. specific design details 15 whereas in other areas we'll be doing a much broader i
16 review.
That type of management direction of the 17 staff is going to be important depending upon the 18 level of information that is to be certified.
It's 19 going to take a lot of planning to organize the staff 20 and limit the reviews where it'is appropriate to limit
~
21 them, but to ensure we very-carefully cover the safety 22 issues that are our mission.
That's'very important.
23 COMMISSIONER REMICK:
Wasn't that one of 24 the purposes in the standard review plan, to lay 25 out i( _
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a 1
MR.
TAYLOR:
But s ome - of these would--
4 2
and the balance of plant area' and other things that 3
may be submitted will represent additional areas of 4
review beyond what we do today.
5 COMMISSIONER REMICK:
I think that l
G-supports Tom's interest in having the standard review i
7 plan _ updated because it provides guidance to the
.--q 8
staff.
j 9
COMMISSIONER ROGERS:
Well, just on this, 10 it is a different ball - game because, as you pointed 11
- out, in the past, the reviews have ultimately had 12 available the whole plant almost, as-built.
And it's 13 very important to know where:-to make that cut so that c-14 you don't go below that.
Otherwise, you'll never get 15 there in terms of detail.
Just how to do'that, it I
1G senms to me, is very important at the outset that you 17 try to think that thing :through very carefully-and i
18 really essentially develop some kind of training 19 exercises for - experienced reviewers 'who are used to 20 the old system that may find difficulty in just 21 knowing where to -- how far to go.
22 DOCTOR MURLEY:
That's why, commissioner,-
-l 23 I think it's important for-the process to take through 24 the first certification, one that's close to what i
25 we've done before, namely' an evolutionary type of r --
L.
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G4 1
plant.
2 COMMISSIONER ROGERS:
Yes.
3 DOCTOR MURLEY:
Personally, I think there 4
will be less pitfalls, that we'll be able to handle it 5
better and once we've done that, then we can--take the G
more innovative-designs on through certification.
7 CRAIRMAN CARR:
Do yo.u' foresee level l' as j
8 encompassing lighting?
-l 9
MR. VIRGILIO:
Level l?
Yes, I would, l
10 CRAIRMAN CARR:
It's tough to tell where 11 you need the lights until you get the plant built.
12 Usually they're not where the gauge boards. are or 13 there's-a pipe in between that or it's too high or you i
14 can't reach it.
But you think that would'be in there, 15 huh?
1 16 MR. VIRGILIO:
Yes.
Level 3 today or
- l 17 let's go back to the way we do our traditional review.
L 18 You look at the branch technical position and our 19 appendix on fire protection.
We review lighting today 20 in certain respects, even --
4 21 CRAIRMAN CARR:
That's after the plant is 1
22-built?
23 MR. VIRGILIO:
.Actually, we have criteria 24 that requires i t.
to be built to certain 25 specifications.
o i_
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-G'5 U-1 CHAIRMAN CARR:
Incandescent or 2
florescent?
3 MR.
VIRGILIO:
Not to that level
-o f '
4 detail, no, sir.
l 5
COMMISSIONER CURTISS:
Let me jump back to 6
the resources question for a minute and-see if I'can j
?.
get some of the -- recognizing - that you're going-to i
8 come up in a month or so,with a more detailed plan.
9 Let me see if I' can focus on - some _ of the nuts and i
10 bolts of where 'we are -today in view of the process 11 that's been-established. and the issues th'at are 12 currently pending.
r-13 Tell me what the choke point is or the 14 critical path is today on the EPRI requirements 15 document and the two evolutionary designs.
Whose 16 court is _ the ball in?
Are we resource constrained?
17 Give me a feel for -as I say. what the choke point-is.
18 DOCTOR MURLEY:
Let me turn to Bill 19 Travers.
20 MR. TRAVERS:
We are continuing activel --
i 21 to review not only the EPRI requirement's evolutionary
)
22 document, but'alsotthe ABWR'and the Combustion 80+ LRB 23 submittal and wrapping._
up our review on the 24 Westinghouse SP/90 PDA.
25 But let me start'with the question you've-
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.F i
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1 asked about EPRI evolutionary.- What we're doing.today 2
on.-EPRI evolutionary is-tracking ~ reasonably well with 3
the process that we laid out;for you in SECY-90-065.
'4 We currently have been meetingnwith'EPRI.
We've had-S some-five meetings or so in the last' month-and a half 6
to go over the issues that-remain to be resolved with i
l 7-them.
I should note that the Commission decisions on 8
our SECY-90-016 have facilitated our heading towards i
9 closure on a number'of.these issues.
i 10 Right now, our goal is-to issue nearly all i
11 of the draft SER chapters by about October of this 12 year.
Of course that would follow submission to the l
13 Commission of each of.
those' chapters that we're i
14 working on currently.
As.you know.-we've issued draft 15 SERs on Chapters 1 through 5'to.date.
So this would.
16 encompass the remaining Chapter 6 through 13',
17 COMMISSIONER CURTISS:
Do you still plan i
18 on a roll-up. document?
19 MR.
TRAVERS:
EPRI plans
'o n a
roll-up 20 document and.we do as well.
EPRI's roll-up document 21 is due in next month, I 'believe, and our roll-up-22 document would be in the form of our final safety 23 evaluation report.
24 COMMISSIONER CURTISS:
Do you have a date 25 for that?
1
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(
'l 1
MR. T5 AVERS:
'And that's tracking, as I 2
mentinned, with the dates and I'll estimate case 1 in 3-SECY-90-065.
So, it's tracking on about a schedule i
4-for May or thereabouts in 1991.
{
S COMMISSIONER-CURTISS:
All right.
Is the:
6 EPRI review resource - constrained 7 You talked' about 7
-the t!a n nes s - in some of the NRR areas and the 8
question's beeni raised about
.the
- p o t e n t i a l --
9 shortcomings in. resources.
Are we constrained in any-10 way on resources?
i 11 DOCTOR MURLEY:-
I don't know.
What's-the 12 staff finding,~ Bill?
r-13
'MR.
TRAVERS:
- Well, I
think given the a
f 14 thinness that we do have in several areas,;you could 15 always improve the schedule somewhat.
-But I think 16 what we've indicated and I think what we still feel is 17 that it's not entirely resources limited.
You could
[
18 improve somewhat these schedules,- I feel, if you had 19 people you could devote today with the: necessary
~f 20 expertise and skill.
But I think that would be a 21
. difficult. thing to do at this point.
22 COMMISSIONER CURTISS:
Okay.
Could you 23 speak to the two vendor reviews?
[
l 24 MR.
TRAVERS:
Yes.
With regard to ' the 2S advanced bolling-water
- reactor, we have a current i
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-i 68-D-
1 targetLof trying to issue all o rz essentially all of 2
the ' draf t SER L chapters excuse r,
all of those-3 chapters early in. calendar year '91, reithin that-first I
4 month-or two;or thre4.
That,- again.-would track with j
5 the schedule-for case 1 listed in SECY-90-065, i
I 6
COMMISSIONER CURTISS:
Do you-have a
i 7
projected FDA date?
8-MR.
TRAVERS:
The projected FDA date. is-9 case 1 or somewhervlSetween case'l-and case 2 for 90-
]
I 10 065) and currently that's listed as-July '91 to 12/91.
1 11 So,- summer to end_of calendar year '91 is'the current 12 estimated FDA date.
13 COMMISSIONER CURTISS:
With_
design
~
14 certification taking roughly a year after that?
15
-MR.
TRAVERS:
We've estimated 18 months 16 for the purpore of scheduling.
i 17 COMMISSIONER CURTISS:
I_
guess that's 18 increased since I looked at it last time.
19 MR. TRAVERS:
It was 15 to 18 months.
20 COMMISSIONER CURTISS:
15 to 18, 21 MR. TRAVERS:
I think we've consistently 22 held with that kind of pro,)ection.
23 COMMISSIONER CURTISS:
So we'd be in a 24
' position to certify the first design, assuming that's 25 the first one out of the blocks, 18 months in mid
'93.
I
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^ =-- -
1 MR.-TRAVERS:
That.would put you at early-
'2 to mid '93, correct.
3 CHAIRMAN 1CARR:
Dependin'g on the level of 4
detail 7'-
5 MR.
TRAVERS:
Yes, -that's a caveat, I
6 should note.
Currently, of
- course, we're not 7
' reviewing to.certainly a:1evel~1.
I could say and
,8 I --
'9 CHAIRMAN CARR:.
Well, level 1,
I presume, 10 is not ready for review.
11
'MR.
TRAVERS:
No, it's not.
'If you asked 12 the question ab ou t_
-- ABWR and' 'where do they stand r- -
13 relative to the options. presented --
N 14 COMMISSIONERTCURTISS:
I was going-to ask 15 that.
16
.. COMMISSIONER REMICK:
So was I.
l 17 MR.
TRAVERS:
.I think it's fair to say 18 that in-some areas;the'ABWR review is at or close to 19 level 2.
I think you've heard -. presen t a t ions that 20 speak specifically to reactor" building structure and 21 so forth as areas in which-we' re getting-a very high 22 level of detail.
- Rebar configuration. and so forth, 23 spacing, levels of information that we traditionally 24 don't require and don't' request in the conduct of our 25 SRP reviews.
r- -
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18.
o a
m 1
COMMISSIONER CURTISS:
Do you have: level-2' 2
detail for control systems?:
3 MR. TRAVERS:
No.:
4 CHAIRMAN CARR:
I. would, wager-- you' ve got 5
level 2
detail for what' they're already b'uilding
~
F G
somewhere.
~
7 MR. TRAVERS:-
And I ' think in ABWR space, 8:
we have the' potential,forsgetting a very high level cf 9
detail across the board be'cause of what is being done L
10 or planned in Japan.
ButDwe don',t-have in a number of 11 areas level '2 information.
In fact, we're working in-12 some areas to'get to'leve153.
r-13 COMMISSIONER CURTISS:
.And CE's System i__
14 80+?
15 MR. TRAVERS:
-We are about to-send up our t
-~
16 comments to the Commission on the.LRB submittal for
~
17 Combustion.
I expect thatLwill be up within the next e
18 several weeks.
Several-of. the issues that we've
-t 19 identified in that. paper correspond ' to ' the kinds of.
20 issues you've already been considering in the 016, 21 So, I think you'l'1 find a great deal of parallel in 22 that.
23 DOCTOR MURLEY:
Now, Commissioner, we're 24 giving you our best judgments. right now, of course.
25 The two things-I think -co'uld change is one you
,7 _
k.-
j l
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-71 U-:
1-'
mentioned,-the level of detail could change because we
'2 have not been reviewing certainly. -level l'
kind of 3'
detall.
- Also, I'm'a little concerned, as I mentioned, 4-about the use of automation 'and how m u c h ' w o u l'd be 5
contemplated in these plants, particularly_in'---
6 CHAIRMAN CARR;.
Especially in: control 7
systems and it.atrument systems.
8
'e0C TO R MURLEY:
-- t he control room and 9-control systems.
We have not in the past done a lot 10 of detailed review of that and so it would!be somewhat:
11-new to the staff and that could take longer than we 12
- thought, c-13 MR. TRAVERS:
And we are also looking to 14 identify, as early as possible, any additional policy 15 issues along-the lines of what Tom's mentioned.-
'One-t 16-of them, for-example, could. be an issue related to 17
. what positive control is necessary;for the ABWR vent.
18 That may be something --
L 19 COMMISSIONER CURTISS:
- Do the --
1 20 CHAIRMAN CARR:
Let. ne jump-into that for 21 Just a second.
22 COMMISSIONER CURTISS:
Go ahead.
23 CHAIRMAN CARR:
The review that'you do, I'
24 have a
little bit
-of trouble with the level of 25 standardization effecting your review.
In the - firs t 1
r--
(
l NEAL-R. GROSS l
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place, you' re going t o. ' look a t -- t h e c-s a f e t y primarily.
2 Standardization is goin? to be de'cided by.- how-much.
-3 detail we require,- but.thatistill doesn' t a f fect what.
4 you -have-to look' a t? from
.a safety standpoint.
5" Standardization,comes as a' bonus' requiring it, if we 6
put it in there.
That doesn't.mean you have to do a 7
deeper level - of detaild 'in your review, does it, if 8
you're satisfied that safety is:Lall right?
_Am I
9 missing something?
10 DOCTOR MURLEY:
I guess I'm not-sure I.---
11 MR. TAYLOR:
I ~ would think that if 'we're 12 going to certify by rule,'that the submission--in,that i
13 certification process, we're at'least going to have to 14 audit / review a
lot of material that we-wouldn't 15 necessarily have decided-it.was materi'al with specific 16 safety decision.
That's the way I view it personally.
17
.I would think you would expect that.
18 MR. TRAVERS:
T-think-that's the control 19 of process issue that Tom wa; referring to earlier.
20 Certainly as a minimum, I feel-we would need'to --
21 CHAIRMAN CARR:
But I. know if the guy 22 submitu the design and you review it - for safety and 23
- say, "Yes, that design is a safe design," then if we 24 certify it, why would. you ' have to look at it any 25 harder than you do now from a safety-standpoint?
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~Q 73 M'
1 MR.
TRAVERS:
For. one reason, to assure 1
2 ourselves that the level of detail; encompass'ed in the 3
Commission's policy was met, I
think.
And beyond' 4
that other staff questions may arise from --
_g 5
CHAIRMAN CARRi And you' don't normally get 6
the balance'of plant safety --
7 MR. TAYLOR:
That.'s right.
8 CHAIRMAN CARR:
-I understand that piece of 4
9 the action.
10 MR. TAYLOR:
'That_'s an expansion.
11' CHAIRMAN CARR:. Okay.
12 COMMISSIONER CURTISS:
I had two other 13 questions on resources.-
i 14 are they resource constrained today? :Is resources the 15 critical path?
16 MR.
TRAVERS:
- Again, I
don't think 17 resources are the. critical path.
18 COMMISSIONER-CURTISS:
Okay.
On the--
19 you indicated that you're going to submit 'the CE 20 licensing review basis to the Commission in the next-21 few weeks.
At one of the; recent ' meetings,
_the 1
22 Chairman raised the question about whether -- about-23 what the role of the LRB should be in view of what the 24-Commission has said on the EpHI requirements document.
25 Are we going to get the staff's views on the i
t.
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,i
+-
I continuing need for-an LRB in a time frame that would-f 2
permit us to reach that-policy decision in conjunction 3
with what you're recommending.on CE7 t
4 MR. TRAVERS:
I have.to look'at the date 5
that we owe you an answer on the question l relative:to 6
passive.
Of course we're talking about
.the 7-'
evolutionary combustion design.
I should clarify lthat
-8 what.we're providing the Commission or what we expect j
-\\
9.
to be providing the Commission in' the relative near i
10 term are our initial comments on the submittal on'LRB.,
q 11 There are subsequent steps-in the process which would 12 ultimately lead to issuance - of an LRB and my best.
13 projection of that right-now is in.the spring'to summer e--
-i 14 time frame of 1991.
That's -in accordance with the 15 process.
16 COMMISSIONER CURTISS:
'I guess
.as a
17 general observation, one of the - things I'd like to L
18:
recommend for us to consider,' we~now have the staff on 1
19 the hook for six month by t efings on-' this program.
It 20 would be helpful.in my mind, perhaps in conj unc tiori 21 with those briefings, 'if we had a submittal from the-22 staff around' that time that would go through a
23 discussion for the EpRI requirements document and the 24 individual vendor design reviews of what's been-25 accomplished in the past'six months, what the critical y
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1 path is, what you'see as the major policy issues,-and l
2 your continuing update of the schedule a's you get into 3
it so that we -- it's been very helpful to get a sense 4
of that here, but'a more formal presentation of-that 5
is something that I toss out for us to think about'.
I 6
CHAIRMAN'CARR:
But I'would' encourage you
}
7 not to wait six months if you've got a problem we can 8
help with.
-9 COMMISSION'ER'CURTISS:.; Exactly,. sir..
10 COMMISSIONER REMICK:
Did you give us the 11 expected date for
.the system 80+
for the FDA 12 certification?-
13
'MR.
TRAVERS:
I didn't, no.
I gave-you an w__
14 idea of the projected time' frame f o r; issuance of LRB,
-15 which is spring, summer of '91.
'SECY-90-065: dates for 1
16 CE 80+ lists August of
'93, case 1, and May of 1994, i
17 but we need to and the. Commission has asked us and 18 I know the Executive Director for Operations has asked 19 us to reassess these dates and we'.11 be doing that 20 shortly.
21 CHAIRMAN CARR:
Those dates are pre-level 22 of' certification dates?
23 MR. TRAVERS:.
Right.
i 24 COMMISSIONER REMICK:
I hope.
you'll 25 address what the vendor has requested as an l\\l NEAL R.
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?'-'
l-anticipated schedule from their: perspective.
-2 MR. TRAVERS:
Yes.
3 MR.
TAYLOR:
That concludes the--
4 presentation, sir.
If there are questions --
5 CHAIRMAN CARR:
I've lost track-of-where
-l 6
we were.
7 Commissioner
- Rogers, would you like
.t o 8
kick-off?-
9 COMMISSIONER ROGERS:. All right.
10 Do you have any feeling about the degree' i
11 of standardization that,~say, the French have achieved-12 in their program, how that might compare with what we
{
)
13 are thinking of here in possibilities?
l r---
t.
14 DOCTOR MURLEY:
Yes, as a matter of fact--
{
15
-COMMISSIONER ROGERS:-
Is there anything 16 comparable that we could grab onto?
17' DOCTOR MURLEY:
I' guess I didn't bring it 18 with me, but they have in fact six LWR designs.
There 19 are three versions of the 900 megawatt plant, two i
20 versions of the 1,300 megawatt plant, and they have a i
21 1 100 megawatt plant.
So in terms of the kinds of 22 e ambers of types of designs that they would have to 23 keep control of, it would be comparable to say a 24 couple of evolutionary plants and a couple of. passive 25 plants.
So it's not they. don't have rigid y
L._
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M" 1-standardization even in: France.
But within a class, 2
my sense of things is they have, primarily _ a,s a
3 commercial proposition,. bought - -things in ordered 4
from Framatom and bought.in bulk quantities, i
5 CHAIRMAN CARR:
. Buy.six at a time.
I 6
DOCTOR MURLEY:
Yes.
And it makes a lot 7
of sense.
You can have economiescof quantity and also 1
8 you can keep a shop operating routinely.
So I think i
9
.they!did it and'it's been quite good and quite useful
-10 from.that point of view.
11 COMMISSIONER ROGERS:
Just.within our own 12 realm of experience,.can we -- do you~have any feeling "l
13' about the differences in the level of-regulatory r
1 14 attention-that's been. required say for the two SNUPPS i
15 plants versus other
- non-standardized-. comparable-l 16 plants?
Have you seen any impact there?-
17 DOCTOR MURLEY:
Difference in the. level I
18 of--
19 COMMISSIONER ROGERS:.
Regulatory 20 oversight.
Do we need to --
.21 DOCTOR MURLEY:
During the review?
(
22 COMMISSIONER - ROGERS:
After they've been 23 open to operate.
24 DOCTOR MURLEY:
Oh, after Laey're open.
I 25-really don't think we' d. see much difference, no.
I
.l
.a
'l NEAL R.
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L 78-1 Just don't think there's much difference.
First of 2
all, they're in different-regions ~'so that the regional 3
attention is greater.-
4 COMMISSIONER-ROGERS:
.Well, how about 5
-during construction?
6'
=MR.
TAYLOR:
Wolf Creek-followed, the i
y 7
Callaway experiences 'very' carefully.
They still had 8
some construction problems, principally implementation H
9 issues, some welding issues and so forth that came up, i
10 But there was during that period a lot of back and 11 forth between those two-utilities.
My understanding 12 is that continues today, so there is=that benefit:
.j 13 of experience one to the other.
N 11 DOCTOR MURLEY:
But if I follow the'line j
15 of your questlon, there is no doubt in my mind that 16 standardization can lead to regulatory and safety f
17 benefits by being able to take the experience of a
{
18 large number of plants and - knowing that it applies.
19 And so there's clearly going to be a --
20 COMMISSIONER ROGERS:
But no way of 21 quantifying'that.
22 DOCTOR MURLEY:
- Yes, there's no way to 23 quantify it.
j 24 COMMISSIONER REMICK:
If I may, Ken, just:
i 25 ask -- I certainly agree with what you're saying.
No L1 J
L_
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H 79-Q 1
question about it.
But there is a down side to 2
standardization.
And that is right-now the Soviets q
3, are replacing the steam-generators. in all their VVER 4
- 1000s, all those plants'- steam generators,- because 5
it's common cause.
.And so-you increase the i
G possibility of common ; cause problems with standard 7
plants.
That'doesn't!say I'm against atandard plants.
'8 I'm for them.
There is a down side.
9 DOCTOR '1UR! EY:
Yes.
1 i
10 COMMISSIONER ROGERS:
Just coming _back--
l I
11 I
think you're really-answered it, but I've been 1
12 looking at your Table 1 ani the list of items, line 13 item 8, physical attributes and configuration of-each 14 component.
You didn't list that under level 2,
and 15 it's my understanding of your definition of l'evel 2 16 that it was to encompnas attributes.
Is that the key 17 attribute question?
Is that the separator?
18 MR.
VIRGILIO:
- Yes, that would be our 19
- answer, a
20 COMMISSIONER ROGERS:
Physical attributes 21 in level 7, but -- the key ones are in 7, but 8 --
22 MR. VIRGILIO:
Under the line, yes.
23 COMMISSIONER ROGERS:
--.8 has all the 24 attributes, is that 1
25 MR. VIRGILIO:
Yes.
t s,.
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-e*
80' N
.1 COMMISSIONER ROGERS:-
That's-the 2-distinci. ion between them, okay.
3
'Just' for the General Counsel, do you agree j
u 4
with the industry opinion t.xpressed'the other-day that l
l 5
the compar.y proprietary information that's submitted i
6
-in the' design be cer'.ified for rulemaking could'-.be
]
7' withheld from publir, disclosure?
the
-l 8
MR. PARLER:
I agree with what he i
9 testimony or the remarks said that we did in the rule f
~
l 10 in response to the' comment.
That is,-'we moved in the 11 diree': ion of giving guidance in the area-which would 12 be, at least for Part 52 purposes, _ compatible-with the r-13 procedures and the policies that were applied for i
14 licensing, j
15 However, the implication that the issues--
16 the inference, at least, that I-drew: that the matter i
17 had been resolved-so that you could reach the result i
18 that you just stated in your question-to me, I do not 19 agree with that.
That is not a new issue.
For years 20 we've had the -- it doesn't come up frequently.-
It
~21 hasn't come up frequently in my judgement.
22 But the balance that has to be struck.on 23 the one hand for protecting proper protection of-24 proprietary data in a licensing decision -- with the i
25 necessity to make public the underlying rationale.for L_
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81-1 the safety findings and-for.other licensing decisions.
2 And if you cannot strike that balance, you.would have.
3' a problem.
We cannot license something without an 4
adequate publicly-stated rationale-for the safety 5
findings.-
6 COMMISSIONER ROGERS:
So.there-still might 7L
' be.some questions?
'8 MR. PARLER:
Which would.have to be dealt 9
with on a case by case basis.
10 COMMISSIONER. ROGERS:
'Okay.
Because that 11 seemed to be somewhat handled the other day as if it-12 was really very clearly sett. led.
13 MR.
PARLER:
That implication. I do not i
14 agree with.
15 COMMISSIONER ROGERS:
Okay.
In the.SECY 16 paper on page 11 -- and I-think.you quoted it, Marty,
'17 to some extent -- it s tates-- that solidifying only the 18 top level design criteria and performance standards in 19 tier I will among other things reduce the s a f e t y ' an'd
'20 cost benefits of standardization.
I wonder if. yoti 21-could just say a little bit on what, you are really t
22 thinking about with respect:.to safety reduction 1
23 foreseen from reduced standardization.
24 MR. VIRGILIO:
With regard to level 3, let 25 me back up a little bit.
What's flexible in the i
'\\.-
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1
- design, you're: not goin g.. t o see the finalization of 2
all the detail,s for-that portion _ of the design.
If 3
you allow some flexibility, I believe in certain areas 4-the. tendency is going 'to be to do less engineering 5
work up front than there will be if you certify. the l
6 design.
7-You have to when you -certify the 8
design, _the NSSS vendor or whoever is marketing the ib 9
product has to know that they can deliver it - for a 10 cost, that - they can actually produce.this information, i
11 If you allow some flexibility in it.
- well, they're 1
12 going to assess the risk of being able to supply this 13 information or complete this design.
And on that i
1 14
- basis, they're going -to do more engineering-work or l
15 less engineering work.
Now what's not. certified, 16 then, is then less solidified.
i 17 COMMISSIONER H00ERS:
But isn't the safety
-l
.18 protection of fered _ by-the entire process that has to 19 be followed before we finally issue a construction and 20 operating license?
21 MR.
VIRGILIO:
We will have to make our-
-i 22 minimum safety findings in all the levels, except for 23 level 4.
You know, we still have to find that all the 24 safety issues are resolved.
It's a matter of how much 25 additional detail and-how much additional engineering i
' b. -
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83
'~
l you have.
All across the board in 1,-2, and 3 you can 2
draw - that line that follows along with the standard 3
review plan minimum safety findings, and that line is
-4 common to all
-three of those levels of-4 5
standardization, plus you've got ITAACs thaticarry you 6
' through to ensure-that the as-built plant matches what 7
you certified.
8 COMMISSIONER ROGERS:
Well,.I just wanted
-9 to try to understand a little bit' bet ter -the whole 10 notion behind the phrase " safety reduction foreseen 11 from reduced standardization."
12 MR.
VIRGILIO:-
With additional 13 standardization you get additional safety benefits, as t.. _.
14 we've all discussed here today.
And' with less 15 standardization, to an extent, I
think there is an 16 over --
17 COMMIS S 7c'.ER ROGERS:
But that would not 18 necessarily relate to the design, though.
I mean, 19 they may relate to other questions such as being able 20 to maintain it or something.
21 DOCTOR MURLEY:
What -I had in mind,'this 22 phrase, I think the -- I don't think the reduction in 23 safety relates to
- design, quite frankly.-
Because 24 50.59 almost says that it can't change in a
25 fundamental safety way.
Where it a f fects is the i
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a-1 operating experience area.that I was mentioning.
2 COMMISSIONER ROGERS:
- Well, it might; be 3
well to make that point clear, to separate that out.-
4 DOCTOR MURLEY:
Yes.
5 COMMISSIONER ROGERS:
Because it is--
6 it's built into the SECY right now,- and one might 7
infer that this relates to the design.
8 DOCTOR MURLEY:
Yes.
That's a good point.-
9 COMMISSIONER ROGERS:
It probably relates
-10 to other matters than. design.
d 11 DOCTOR MURLEY:
Yes.
12 CHAIRMAN CARR:
The intangibles of m-13 standardization are in standardized training,-
r 14 standardized spare parts, you know, all the-things
~
15 that=go along with it that contribute to safety.
16 COMMISSIONER ROGERS:
I think I'll Just 17 pass.
18 CHAIRMAN CARR:
Commissioner Remick?
19 COMMISSIONER REMICK:
Well, first I'd like 20 to compliment the staff on Lne SEu? paper.
I thought 21 it was very concise.
Table 1 was extremely helpful to 22 me to put the various levels in perspective, so I want-23 to compliment you on that.
24 I
guess I'm becoming convinced or have-25 been convinc>. ' hat there's a need for s ota e kind of W
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,o-85 I
controlled flexibility - beyond what 50.12 provides' for t
2 possible amendments.
_ My big experience with 50.12 3
some! of you might remember was the Clinch River 4
project, and it.was not a simple process by any=means.
i 5-So I'm not-sure that 50.12 provides _the type of 6
flexibility that I think is needed.
7 The ' proposed.two-tier - approach-is
'o n e 8
possible way of incorporating the flexibility.
One of
_l 9
the biggest difficulties ~ on the technical side I
10 don't know what the legal-implications are -- would be-11 the ability to adequately develop what's-in tier l_and.
12 tier 2 in a very concise manner and hopefully in a-r-
13 manner that would be little confusion in future years, l
t.--
14 what was in and what was not in.
But I think it's i
15 worthy of consideration.
L 'r 16 My understanding is that 000 provided you,.
q 17 Doctor Murley, with documents some time -in. the past i
o IEs outlining what_they thought was-level detail in part 19 52, required in part 52.
And although I think I lean d
20 where Commissioner Curtiss is,-- that _ somewhere between 21 2 and 3 is where.I'm starting to c o m e -- o u t,. I think.we 22 certainly have to_--
I have-to still consider n-level 23 1.
So if I look at. level 1,
2, and 3, and-I look at 24 what the General Counsel has provided of what part 52 25 requires-on level of detail, do we know that level l~,
s _
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=
1 i
86 1
1 2,
and 3 would provide that level of detail?
And if 2
you don't remember, the is were that it would be at 3
least FSAR, perhaps final FSAR level.
Would all three 4
levels provide that type of detail?
5 MR. VIRGILIO:
Yes, and 2 and 1 more.
6 COMMISSIONER REMICK:
Allow final safety 7
resolution of all safety issues?
I think you've 8
answered that already in the positive.
Is that i
9 correct?
10 MR. VIRGILIO:
Yes.
In all three cases, 11 you're going to have sufficient information to make 12 your safety judgments.
r-13 COMMISSIONER REMICK:
Permit judgement on 14 whether the-proposed ITAAC will work?
15 MR. VIRGILIO:
In levels 1, 2, and 3,'yes, 16 you will.
17 COMMISSIONER REMICK:
Permit a
design 18 specific PRA?
19 MR. VIRGILIO:
Yes.
20 COMMISSIONER REMICK:
Permit the drafting 21 of procurement and construction specs?
22 MR. VIRGILIO:
Yes.
And what we talked 23 about earlier today was without recourse to 24 significant additional engineering on the part of the 25 applicant.
Iu i
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COMMISSIONER REMICK' Okay.
And then 2
there was another.
It says the detail on the 3
certifying rule should permit replacement of old 4
equipment with the latest advances without the need 5
for NRC approval.
6 MR.
VIRGILIO:
It becomes a problem in 7
level 1.
8 COMMISSIONER REMICK:
Level 1.
9 MR.
VIRGILIO:
Where your recourse is 10 50.12 for making changes to the design.
You've 11 cer.ified that level of detail.
12 COMMISSIONER REMICK:
Okay.
Now you've 13 answered the question en the ABWR and System 80+ where 14 you essentially you say that essentially those are 15 about level 2 submittals.
Excuse me, I guess Bill 16 sai' that, 17 DOCTOR MURLEY:
I think they actually 18 eheracterize it as somewhere between 2 and 3.
19 COMMISSIONER REMICK:
Oh, okay.
And some t
20 exceptions like IAC you don't have, and so forth.
l' 21 Okay.
Now would you consider --
1 1
l 22 CHAIRMAN CQR:
Let me step in for a --
'23 COMMIS$10NER.kEMICK:
- Yes, please.
Go j
24 ahead.
25 CHAIRMAN CARR:
That's where you say they JL-.
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currently
- are, right?
What do you think they're i
2 requesting to be certified?
You heard them pitch what 3
they want certi fied.
Where does that fit in your f
4 levels?
5 MR. VIRGILIO:
Depends on the system.
For 1
6 some systems I believe + hat they'll have the detail 7
'and would --
8 CHAIRMAN CARR:
No, I don't mean --
l 9
MR.
VIRGILIO:
would accept 10 certification.
11 CHAIRMAN CARR:
I don't mean where they 12 happen to be now.
What did you think they want in --
13 MR. VIRGILIO:
Approximately level 3.
I 14 CHAIRMAN CARR:
Three.
15 DOCTOR MURLEY:
First I
should
- say, l
m 16 though, that I at least have not had any discussions 17 with General Electric on the two-tiered approach.
18 CHAIRMAN CARR:
Yes.
19 DOCTOR HURLEY:
.So we're --
20 CHAIRMAN CARR:
And I gather that industrp 21 hasn't had a long time to look at your papers.
22 DOCTOR MURLEY:
That's right.
23 CHAIRMAN CARR:
So I assume there's going 24 to be some iteration here.
25 DOCTOR MURLEY:
Yes.
i L--
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89 s-1 COMMISSIONER CURTISS:
And ' when you peg l
2 their certification at level 3,
that's a combination 1
3 of tier 1 and tier 2?
l l
4 MR. VIRGILIO:
Yes.
That's correct.
1 5
COMMISSIONER CURTISS:
I gather tier 1
6 would be somewhere down a ways?
7 CHAIRMAN CARR:
Well, I,think we're back l
8 to what you said.,
Thirty percent of a -- or half, i
0 COMMISSIONER CURTISS:
Standardization, I 1
l 10 guess in my view, is a two-sided coin.
The first side i
11 is provide all the infor ation up front and get it l
12 finalized.
And the other - side of the coin is and t--
13 don't change it, perhaps with the exceptions that have t
14 been identified on obsolescence, developments in the l
15 state of the art and interferences.
16 And I guess that's why I see the tier 2 l
\\
l 17 distinction being so critical,- because that moves you 18 away from standardization to the extent that you can 19 50.109 -- 50.59 issues, and unless the safeguards that 1
1 20 were cited Monday by Mr. Rowden prove to minimize the l'
21 extent of 50.59 even more tha'n we've seen in the past.
22 CHAIRMAN CARR:
The only thing that would 23 be certified would be tier 1.
24 MR. TAYLOR:
That's true.
25 CHAIRMAN CARR:
And therefore, the only l-L-NEAL R.
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1 thing to be standardized would be tier 1, actually.
2 COMMISSIONER CURTISS:
That's quite a ways 3
down, isn't it?
4 MR.
VInGILIO:
What they envision for 5-certifying is what you typically see in chapter 1.2 of 6
hn FSAR today, which.may be about 100 pages of design 7
information an'd 20 pages of layout l
8 CHAIRMAN CARh:
- Yes, it's a basic plan 9
description is all it is.
10 MR.
VIRGILIO:
It's implemented by the 11 staff safety evaluation report.
12 COMMISSIONER CURTISS:
That's one of the r- -
13 questions I have.
I don't mean to jump in here, but 14 while we're on it I asked the question on Monday nbout 15 what was meant in Mr.
Rowden's statement that the 16 level of detail in tier 1 would be what's contained in 17 an SSAR 1.2 based upon an SER level of detail, which 18 is in 1.2 of the SER.
I went back and pulled one'of 19 those out since the meeting and got the Shoreham one.
20 The SER on 1.2 is a page and a half.
21 MR. VIRGILIO:
Let me try to clarify tiiat.
22 I' read the transcript over and it is a little bit i
23 confused.
What the intent is is to go back to the 24 Shoreham FSAR and pull chapter 1.2 of that FSAR, then 25 supplement it with the staff's SER in total.
And.that I
1 l
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91 l-I would be what the proposal is, as I understand it 2
right now.
3 COMMISSIONER CURTISS:
1.2 chapter level 4
of detail --
5 MR. VIRGILIO:
1.2 in your FSAR.
6 COMMISSIONER CURTISS:
general 7
description --
8 CHAIRMAN CARR:
FSAR.
i 9
MR. VIRGILIO:
FSAR.
Now that's a general 10 description of the facility.
[
11 CHAIRMAN CARR:
It's a plant description.
i 12 MR. VIRGILIO:
And it is a description of 13 the systems.
It'll talk a
little bit about the
~ _.
14 batteries, for example.
It'll tell you what IEEE 15 standards the batteries are designed to meet.
It'll 16 tell you you've got four batteries and they're.
17 separate and independent.
18 Now what they would. propose to do in.
19 addition to that would be go back and look at the 20 staff's SER with regard. to the battery system and 21 supplement that section
23 COMMISSIONER CURTISS:
Everything that's 24 covered in the FSAR --
25 CHAIRMAN CARR:
Description, only a little I
( -
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92 1
more detailed.
2 MR. VIRGILIO:
Yes.
If you think about an 3
FSAR being 20
- volumes, this may be about three-4 quarters of one volume.
5 DOCTOR MURLEY:
Commissioner, I don't know 6
.if I understood you to say that th6 tier 2 material 7
'would not be certified.
That's true, but it would be 8
standardized, as I
understand it.
They the 9
applicant would view that as being approved as part of.
10 the certification process.
11 CHAIRMAN CARR:
But he has the option of 12 changing, as long as he doesn't change it --
13 COMMISSIONER CURTISS:
It depends on i
14 whether you view certification na a one-sided coin or 15 a two-sided coin.
IG DOCTOR MURLEY:
They could change it 17 through 50.59
- process, but they would not my 18 understanding is they would not envision doing that'at l
19 all between --
20 CHAIRMAN CARR:
But I
don't have any 21 control over it if they do do it.
22 COMMISSIONER CURTISS:
We'd get notified, 23 but that's right.
24 CHAIRMAN CARR:
Notified.
25 MR. PARLER:
In any event, Mr. Chairman, e
L -.
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the tight controls over changes to what is in the 2
standardization rule which
' impose a
very high 3
threshold for changes, that certainly, at least as I 4
understood the discussion Monday, would not apply to S
whatever is in tier 2.
6 CHAIRMAN CARR:
That's right.
7 DOCTOR MURLEY:
The 50.59 process is, as 8
you know, employed by operating plants.
We require 9
them to keep records of it.
We sometimes go in and 10 audit it.
And we feel that we have -- that it is not 11 abused, that we have control over the process.
12 CRAIRMAN CARR:
But it doesn't necessarily 13 lead to standardization.
t
~~
14 DOCTOR MURLEY:
That's right.
IS MR. TAYLOR:
That is correct.
16 CHAIRMAN CARR:
They're not abusing it, d
17 but--
18 DOCTOR MURLEY:
Okay.
19 COMMISSIONER CURTISS:
Let me. put it 20 differently.
If you look at Part as constituting 21 sort of a
quid pro quo where-
.t a quid was the 22 applicant, the vendor in this
- case, supplying 23 essentially complete design information up front, in 24 exchange for that and in exchange for an optortunity 25 for the public to participate early in the process, r-N.. ~
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1 two things flow from that:
isoue preclusion you 2
could not raise issues later in the process that 3
you've had an opportunity to raise at the front end, 4
vendor certification or the COL; and backfit the Commission would ' not come in and 5
protection 6
change the provisions of the certified, in this case, 7
design, same thing for the COL.
8 If you'll look at it that way, then -- I'm 9
not sure I've reached a final view on the two-tier i
10 approach -- but what it seems to me to be saying is 11 that they are seeking -- I want to follow-up with the 12 General Counsel's question ---they seem to be seeking i
e--
13 issue preclusion for all tier 1 and'all tier 2 issues t.
14 but with backfit protection as we understood' it on 15 Monday under 50.109, not the Part 52 procedures but 16 with the flexibility under 50.59 to change.
17 Question.
Does that diminish the guld pro 18 quo in any respect?
Do you say that our part of the 19 deal a prove it up front right for the public to 20 participate and protection against at least Part $2 21 backfit is met by an equal quo in this case, the 22 commitment not to change that part of the certified 23 design?
It's important for tier 2 to be referenced in 24 some way so as to be certified in their view, as I 25 understand it, so they get those protections.
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o 95 1
Now it's not clear to me.
The question I 2
guess I had that l'd like.to follow-up on is do you 3
get issue preclusion with their approach under 50.59?
4 What are the-rights that would attach if an issue is 5
50.59 in tier 2 from the standpoint of opportunity for 6
a hearing either before or after that change has been 7
made?~ Either now or at some point I'd like it if Bill 8
could address that.
]
9 MR. PARLER:
Well, the paper covers that 10 to some extent.
To the extent that you have changes, 11 you could have challenges raised later on, either at 12 the CPOL stage or after the CPOL is issued prior to a
13 the time of authorization for licensing which the j
~
14 statement of considerations suggests and I've 15 already alluded to earlier sin this meeting, was not
{
16 necessarily what the approach had in mind, that is to l
17 defer the resolution of issues and defer possible 18 challenges to the time that the plant was ready to 19 op; rate but certainly to the extent that ine 20 applicant or the vendor.could.have an agreement in the 21 certified design rulemaking proceeding that certain 22 things have been resolved a particular way in tier 2, 23 and therefore the issue should not be raised again.
24 It would seem to me to make it kind of difficult' for 25 the issues to be successfully raised
- again, even f
i n_
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?
6-1 though the tier 2 resolution is not a part of the 2
rule.
That's the sort of hybrid that is kind of 3
puzzling to me.
4 On the other hand, I said in this paper 5
that I had no legal objection to it.
Mr. Virgilio at-G the beginning pointed out that there were two policy 7
issues involved.
I.would agree with th.at.
I've heard 8
some of the discussion here.
I do not know how the-9 Commission would wish to come down.
10 All that I can say is that the effects of 11 the tier 2 approach, say in the level 3 context, that 12 are talked about in the middle of page 11 and that I
13 were summarized to some extent on the slides are not j
14 necessarily completely compatible with some of the l
,\\
15 goals that the commission expressed in its statement 16 of considerations to Part 52, 17 Having said that, there is a need I gather 18 from what I have heard for flexibility.
Indeed, the 19 Part 52 rule and its statement of considerations 20 recognizes that.
A question is whether you have to 21 have a two-tier approach as ' described in order to l
22 provide the requisite flexibility for the several 23 reasons that have been mentioned.
So it's not just 24 flexibility.
It's also issue preclusion, which 25 perhaps.I would question.about whether the trade-offs i
i w.
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1 are equivalent or roughly in parity.
2 COMMISSIONER CURTISS:
It's a difficult 3
question.
There are some statements in the statements 4
of consideration-that talk about as they were 5
described, suggest this tier 2 approach.
At the same 6
time, as I-think the industry acknowledged on Monday, 7
the so-called 52.97(b)(2) provision which simply says 8
if you make any change in your license, including a 9
change in the
- ITAAC, that shall be' considered an 10 amendment and require a
hearing before operation, 11 seems to me to reflect a sentiment as well about how 12 you strike the balance between flexibility on the one 13 hand and the 50.59 or some other approach and L._
14 stability or standardization as we've called it here.
15 DOCTOR MURLEY:
It seems to me, 16 Commissioner, that there might be some additional--
17 if this flexibility under 50.59 were allowed, I felt 18 that we in the staff for operating reactors kept a 19 relatively close eye on it so that it didn't become 20 abused.
And it could be that maybe there are some 21 procedural requirementa on how 50.59 is implemented 22 that the Commission might want to consider.
23 For example, there is a three part test as 24 you know to decide whether at issue involves an 25 unreviewed safety question.
I r emember when I was a 4k NEAL R.
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98 fl.
1 regional administrator I
would have my staff 2
periodienlly look at their 50.59 reviews, because the 3
rule does require them to keep records, and where we 4
were able to go in and look at those et any time and and we were the ultimate 5
decide ourselves if it 6
arbiter, I felt, on that three part test as to whether 7
an issue did involve an unreviewed safety issue.
And 8
if we felt it did, then wo said no you cannot do that 9
under 50.59.
10 COMMISSIONER CURTISS:
One of the i
11 observations I guess I've' had about 50.59 is
- that, 12 while I don't have any disagreement with the way'it's r-13 been implemented in the past, it has been implemented f
}
14 in the context of single plants, customized plants 15 where it didn't make a lot of difference if.they went 16 in for a single plant and 50. 59, let's say, a steam 17 generator replacement.
18 Question.
Are there considerations that l
l 19 have to do with standardization-and the need to keep 20 those plants of a given vendor certification looking 21 alike in some respect that would suggest a criterion t
22 under 50.59 that would focus on that aspect?
As 1 23 say, that's the -- when we take the 50.59 approach and 24 apply it to standardized design, I think there are 25 additional considerations that arise that may call --
I 7
p l
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1 DOCTOR MURLEY:
Yes.
2 COMMISSIONER CURTISS:
for some 3
modified approach if one was necessary.
4 CHAIRMAN CARR:
' would think after the 5
plant started operation yor.'re under a configuration 6
control problem rather'then a-standardization problem, 7
and there are going to be changes made that won't be 8
the same for all plants.
Some guy will have a bad 9
component that somebody else didn't buy.
10 DOCTOR MURLEY:
That's like we're seeing 11 in Callaway and Wolf Creek.
They are slowly changing.
12 CHAIRMAN CARR:
So you would have to look 13 at
- that, but I doubt that we'll maintain the same 14 degree of standardization throughout the li' of the 15 plant that we have when we started.
16 COMMISSIONER CURTISS:
For example, if we 17 say that it's important for us to know that this pump o
18 or this valve in the aux. feedwater room has to be l
19 reachable and has to be designed in a certain way so 20 that if that issue comes up we can go. ahead and step 21 in and treat that issue the same for all plants.
If' 22 it's been 50.59, our ability to do that diminishes at g
l 20 the plant, and if that's a consideration that we'd 24 like to see standardization so that:we.can treat that 25 valve or that pump the same way should it. lead to a L.-
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~
i 1
problem, that's the kind'of consideration that
=.
2 COMMISSIONER ROGERS:* Excuse me.
3 COMMISSIONER CURTISS:
Go ahead.
4 COMMISSIONER ROGERS:
This point of S
configuration control I think is a very interesting 6
one that I hadn't thought about in terms of the long-7 term effects here on standardization.
Do we 8
contemplate something in granting the construction 9
permit operating license to do anything beyond what 10 we've been talking about 11 DOCTOR MURLEY:
Yes.
12 COMMISSIONER ROGERS:
with respect to 13 50.59, maintain standardization --
1 14 DOCTOR MURLEY:
We-have asked the 15 applicants for certification to submit their tech 16
- specs, their maintenance program, their s u rv ei l l a r,c e 17
- program, and in general their overall reliability 18 assurance program that will assure us that the level 19 of safety we think is in the certified plant will-be 20 maintained over the life of the plant.
Now we haven't 21 got into a lot of detail in reviewing this, but that 22 is our means of --
1 23 COMMISSIONER ROGERS:
It's safety, but not 24 standardization.
1 25 CHAIRMAN CARR:
But if they make a change i
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l i
1 to the certified portion of the plant they have to get j
2 our permission.
3 DOCTOR HURLEY:
That's correct, yes.
4 CHAIRMAN CARR:
What we're getting 5
standardized is the certified portion of the plant.
6 COMMISSIONER ROGERS -
Yes.
7 CHAIRMAN CARR:
I mean, at least we've got 8
configuration control over that piece of it, other 9
than from a safety standpoint.
i 10 COMMISSIONER ROGERS:
Well is that true?
11 Once the plant is built, everything in the standard' 12 design could, if there is a tier 1,
tier 2' approach i
13 here, anything in tier 1 that.was approved initially 14 and at the time that the operating license was granted 15 would not be subject to 50'.59 later on in the life of 16 the plant?
17 CHAIRMAN CARR:
That's what's been said.
18 DOCTOR MURLEY:
After the OL, that's a 19 good question.
20 COMMISSIONER. ROGERS:
Suppose ten years 21 down the road they want to change something and--
22 like a 50.59, could they do it?
23 MR. PARLER:
Well, we have a regulation, 24 52.97, that says any. modification to, addition to, or 25 teletion from the tarms of the combined
- license,
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1 109 a
1 1
including any modification to or addition to from the 2
inspections, tests, criteria,.et cetera, is a proposed j
3 amendment to any such license.
There shall be an 4
opportunity for a hearing.
5 But if something is not an amendment--
6 and you figure that out on a case by cace basis -- but I
7 la a change that's under 50.59, a chang. and.not an i3 amendment, you can go the 50.59
- route, no matter-t 6
9 whether something is in tier 1 or tier 2 or anyplace 10 else.
11 COMMISSIONER ROGERS:
It's just a question 12 of whether we could start to drift apart and lose r-13 standardization after having established it initially.
1
\\
14 COMMISSIONER CURTISS:
You can't -- if I 15 understand it correctly. you can't 50.59 anything in 16 your license, t
17 MR.
PARLER:
You can't change something 18 that's in the license.
19 COMMISSIONER CURTISS:
They are under 20 standardized designs, right?
21 CHAIRMAN CARR:
My understanding was we 22 were going to make tier 1 part of the license.
23 MR. VIRGILIO:
Yes.
24 COMMISSIONER ROGERS:
Then the answer is 25 no, it.could not happen.
Okay.
!L.
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CHAIRMAN CADR:
That's what they said 2
yesterday, that they were going to make it part of the i
3 license -- or Monday, I mean.
4 Commissioner
- Remick, it's your question 5
period.
G COMMISSIONER REMICKt As I was.saying, I 7
have several gaestions that relate to the GE and CE 8
submittal in reference to levels and implications.
I 9
can get those outside this meeting, but I'd like to 10 pick up on the discussion because I was going to bring 11 up some similar questions.
12 I wondered if anybody has given thought to 13 the idea -- and I say this not facetiously, but to put 1
^
14 it in perspective of something called ASARA, as 15 standard as reasonably achievable.
Has anybody i
16 thought about n' condition in the combined operating l
17 license to the owner or industry owners group 18 commitment that in making something like 50.59 or-19 whatever it's tailored to be, if one goes with a two-20
- tier, which would assure that consideration to ths 21 advantages and so forth of standardization be included
'22 in the 50.59 type of reviews?
I think you've alluded i
23 to some things very close to that here in your 24 discussion.
25 MR.
TAYLOR:
- Well, the opportunity for l
i 3
'I -
I 4
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]
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1 hearing and challenge at the time of combined license 2
would help to --
3 COMMISSIONER REMICK:
It certainly does.
4 MR. TAYLOR:
-- what you will.
5 COMMISSIONER REMICK:
It certainly does.
6 MR. TAYLOR:
-- cause them to hesitate 7
COMMISSIONER REMICK:
The condition or-8 commitment might still assure it in those cases where 9
they wanted to take that risk nnyhow.
10 Yes?
11 MR. PARLER:
Mr. Chairman, keeping in mind 12 the goals vi stanouroization is a
point that is 13 emphamazed in the Part 52 and the statement of 14 considerations now, even if the request is a granting 15 of exemptions or amendments I would assume that if 16 there is something like a tier 2 approach that would 17 permit the use of 50.59 in connection with that tier 18 that there would be a similar admonition from the 19 commission or the staff, if not by clarification or 20 regulation in the approval that's issued by the rule.
21 COMMISSIONER REMICK:
Okay.
One other 22 question.
Have you thought about if the Commission 23 opted for either level l ', level 2,
or level-3, what 24 the implications on staff resources might be?
25 DOCTOR MURLEY:
Not in
- detail, but I
c__
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1 alluded to them.
The greater the amount of detail 2
that comes in, the greater the amount of effort by the 3
staff.
And it's not linear.
It's geometric, I think, 4
because --
5 CHAIRMAN CARR:
The other side of that is 6
you don't have to go ask for more.
7 COMMISSIONER REMICK:
Knowing the staff, 8
they'll ask for more.'
O DOCTOR MURLEY:
No, no.
We'll ask 10 questions.
In fact, it's a matter of understanding 11 what we've got in front of us.
And there will be two 12 aspects to it.
13 One is, my managers will have to and
~~
14 I'll direct them to lay out some guidelines for the 15 scope and depth of this massive amount of material IG that would come in under level 1.
That's a complete 17 design.
And we don't quite know how to quantify it, 18 but people talk in terms' of roomfuls of information.
19 So we'd have to sort out what the scope and depth 20 that they review.
21 And then once even once that's done, 22 there will be a large amount remaining we believe that 23 will engender Os and As because we don't understand 24 some detail of it.
So I can't give you a firm answer, 25 but the more detail the more staff effort it will take I
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106 I
' -d I
we feel.
2 COMMISSIONER REMICK:
So you don't know 3
whether we have adequate resources if we went one way 4
or the other?
5 DOCTOR MUDLEY:
That was the important 6
caveat that I put in my answers to whether_ we h r.d 7
enough staff.
8 COMMISSIONER REMICK:
Okay.
'I 9
DOCTOR MURLEY:
It depends a little bit on 10 the decision that the Commission makes.
11 CHAIRMAN CARR:
The schedule depends on 12 the decision we're going to make.
13 DOCTOR MURLEY:
Yes.
,r -
14 COMMISSIONER REMICK:
If you look at Table 15 1,
my last question -- I'm sorry, I forgot I had this 16 one.
If you look at Table 1 -- and I guess I'm coming 17 out somewhere between 2
and 3
personally at the 18 moment, 2.46 or 2.32 I don't know which -- but if you 19 look at level 2,
starting with 7,
component 20 descriptions and characteristics, and if where you see 21 the C there for certification, if that were chunged to 22 flexibility and then one had some kind of a provision F
23 as General Counselor says is already in Part 52 or we 24 had something which I say you might call ASA3A which 25 would hopefully guarantee that people would very 7-NEAL R.
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1 seriously consider the importance of standardization, 2
if that wouldn't provide reasonable standardization 3
and yet, you know, provide the other benefits and what i
4 we're trying to get here.
5 Is there anything that you see wrong with G
something between 2 and 3 which would be basically, 7
taking Table 2 whether I would put item 8 in or 8
not, I'm not quite clear at the moment, but changing 9
the Cs to Ps, if there would be some potential for 10 flexibility, 11 CHAIRMAN CARR:
Where are you going to 12 start changing the Ps?
13 COMMISSIONER ROGERS:
Seven on?
i L_
14 COMMISSIONER REMICK:
It would be 7 on, 15 yes.
16 CHAIRMAN CARR:
We don't do that today.
I l
17 mean, they review that.
18 COMMISSIONER CURTISS:
There'd be less 19 information than we --
20 CHAIRMAN CARR:
That's less information 21 than we're doing today when we license.
22 COMMISSIONER REMICK:
No, it would be in 23 the application.
It would not be in certification.
24 I'm sorry.
I would eliminate the C and replace it i
25 with an F.
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CHAIRMAN CARR:
- Well, but that's what I 2
nay.
Today when we license the plant to operate we've 3
got that, detail.
And you're saying we're going to-4 give it a combined license without that?
I 5
COMMISSIONER REMICK:
I'm saying' it 6
basically would be in tier 2.
Some of those items I
7 would be in tier 2, so there'd be flexibility.
8 MR. VIRGILIO:
As I said earlier, we could 9
pick any point, you know.
We've Just offered four-It points on a spectrum of choices.
11 COMMISSIONER REMICK:
I understand, but 12 I'd like to hear the advantages and disadvantages of 13 something like that.
14 MR.
VIRGILIO:
We specifically asked 15 industry with regard to the 50.59-type test whether 18 they had considered a
factor into control 17 standardization, as you alluded to earlier.
And they 18 went back and considered it for some period of time 19 and came back to us and said it would be very 20 compl.icated and we don't know how we could do it right 21 now.
So we asked them to think about that and that 22 was their response, so I'll offer you that with regard 23 to flexibility and your proposal to maybe have another 24 factor in addition to the three factors for an 25 unreviewed safety question.
I'm not saying it's out l
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1 of the question.
That was just their response.
2 COMMISSIONER REMICK:
Okay.
- Well, a
3 basically what I'm trying to say here is suppose you 4
took level 3 and added in the items starting below the 5
line there that are in level 2 as A&c?
It's a 2.3.
G It's a 2.4.
It's something like that.
Are there 7
obvious advantages or disadvantages is the question 8
I'm asking.
I realize it can be done, depending on 9
what the Commission
- decides, but what are the 10 implientions?
1 11 MR.
VIRGILIO:
I think the implications 12 are you would probably get more engineering done for 13 those issues than you would have otherwise.
~
14 MR. TAYLOR:
You have the engineering.
15 COMMISSIONER REMICK:
Okay.
16 COMMISSIONER ROGERS:
Could I Just Jump-in 17 for a second?
18 COMMISSIONER REMICKt Sure.
19 COMMISSIONER ROGERS:
I have to get 20 recharged in between my questions.
21 As you've pointed out, these levels 1, 2,
22 3,
and 4 are just examples of some possibilities.
23 Have you thought of any more general principles for.
24 establishing levels beyond Just the cut-off here at 25 the traditional SRP?
In other words, is there any way E.. -
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1 that one could establish some kind of a general rule
~
2 that might guide essentially the kind of level 3
definition that you've established here?
t 4
MR.
VIRGILIO:
With regard to the 5
differences between 2 and 3,
remember it's the risk-6 significant physical attributes.
That's a
7 characterization I like to fall back on when I think 8
about how do I describe the difference between 2 and 9
3.
It's the lessons we've learned from operating 10 experience now incorporated in the certification, 11 focusing on those key attributes where we've known or 12 have discovered problems through operating experience.
13 COMMISSIONER ROGERS:
And that's going to e
14 be different for every kind of a system that you look 15 at, right?
16 MR. VIRGILIO:
That's correct.
17 COMMISSIONER ROGERS:
This Just happens to 18 be the HVAC system, so this kind of a characterization 19 would be quite different for some other system.
20 MR. VIRGILIO:
That's correct.
21 COMMISSIONER ROGERS:
- Well, it sounds to 22 me as if it's going to be very difficult to kind of 23 wrap that up in any kind of a general statement of-24 what would be in tier 1 and what would be in-tier-2.
25 It would depend very much on the system and the L _.
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particular design. overall, and it would have to be 2
negotiated individually it seems to me, decided 3
individually rather than as a Commission policy, a
4 generalized commission policy.
Am I right on that?
5 It sounds very difficult for me to say 6
that the commission could decide through a policy 7
decision of some sort what would go into tier 1 and 8
what would go into tier 2 if we adopted a two-tier 9
approach, because it all depends on what system you're 10 talking about.
11 DOCTOR MURLEY:
Quite
- frankly, 12 Commissioner, I think that we need to probably - - you 13 need to give us some guidance and then we need to come 14 back to you one more time with that guidance --
15 COMMISSIONER ROGERS:
Well, we need h esi p 16 on this, I think.
17 DOCTOR MURLEY:
about how we would 18 implement it and how you how we would finally do 19 it.
Because, I agree with you.
I don't know how you l
20 would formulate a
general level type of 21 standardization right now b a's e d on what we've given 22 you.
23 COMMISSIONER REMICK:
But you would need 24 the guidance if the commission. approved a two-tier or 25 whatever?
i l
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k-1 DOCTOR MURLEY:
Yes.
2 COMMISSIONER REMICK:
You would need that.
3 DOCTOR MURLEY:
Yes.
4 COMMISSIONER REMICK:
And some indication 5
about where you might draw the lines in general.
But G
we look to the staff and the industry to negotiate, 7
perhaps coming back to the Commission for approval, 8.
presumably coming back.
9 MR. TAYLOR:
Yes.
You'd have to agree for 10 what's to be certified, 11 CHAIRMAN CARR:
Well, we've agreed not to 12 vote until we get the ACRS commente, r-13 COMMISSIONER REMICK:
Oh, absolutely.
14 Absolutely.
15 MR.
TAYLOR:
You would ultimately be 16 there.
17 CHAIRMAN CARR:
I'd hesitate, personally, 18 to get onto a tier 1, tier 2. approval until I got the 19 staff's input on just how they thought they could make i
20 it work.
21 COMMISSIONER REMICK:
Oh, sure.
22 COMMISSIONER ROGERS:
- Well, could you 23 comment on that?
How do you see the tier 2 approach?
24 I mean, what's your feeling?
Is it a nice little way 25 of looking at it?
L _.
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(
1 CHAIRMAN CARR:
I got the impression you 2'
wanted to look at it a little.
o 3
DOCTOR MURLEY:
Yes.
I think we could--
4 I asked my staff that and I've thought a lot myself.
5 I think we could make it work.
I do believe that tier 6
2 is going to take quite a few -- I mean -- tier 2 or i
7 level 27 8
CHAIRMAN CARR:
Tier 2 --
9 COMMISSIONER ROGERS:
Two-tier.
J i
10 CHAIRMAN ~CARR:
Two-tier approach that the 11 utilities --
12 COMMISSIONER ROGERS:
Not level.
13 DOCTOR MURLEY:
We feel quite comfortable 14 that'we could make that work.
We would put in tier 1
[
15 the things that we felt were absolutely necessary.
16 CHAIRMAN CARR:
But would that not be 17 business as usual?
18 DOCTOR MURLEY:
No, because the even 19 though there is this flexibility under 50.59 to change j
i l
20 the tier 2
- stuff, there is an incentive for ths
'!q 21 industry not to do that, not to make changes, because 22 there is -- it's always challengeable at-some stage as i
23 to whether they did follow the right -- made the right t
24 decisions under 50.59.
So I. personally don't think 25 there's going to be a lot of changes, that they will--
l L_
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- p.,
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and we, the staff, can keep a_very close eye on it so j
2) that they only.use it when you run~
against one of up i
3 these real problems-like' obsolescence =or fit-out 4-
-problems.
So-I think we can make the tier 1, tier'2 S
system work, t
'S CHAIRMAN CARR:
Commissioner Curtise?
7-COMMISSIONER CURTISS:
- Well, I
guess; I-n don't have any questions.
I just havi 'a' closing f
9 observation.
i 10 Commissioner Rogers: kind of toucnci on the i
11 same point of confusion that -I guess I' have.
It's 12 been a
very helpful briefing and' I think between l
r-13 Monday and this briefing at least I personally-have a 14 better feel.of the entire. range of. issues-here.
15 At the same time, and if we wait for'the 16 ACRS views I-guess what we've got before us is a SECY 17 paper that's a notation vote with'four levels set out, 18 two of which probably
- aren't envisioned or-19 contemplated or maybe even permitted-under Part 52.
20 I gather from.what you're saying;here, to 21 try to distill some of the key points.that.I s e e,. the 22 level of information today that we get for a plant.'may 23 range from level 1 to level' 3.
There are - certain 24 systems or components that we may actually be getting l
25 level 1 information on today in the FSAR and the Qs l __
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1 and.As process.
There.may be other' systems-today that-2' we don't get that level of detail and in fact may get 3
down to level 3.-
4 So I'm reluctant,. I guess, to distill it
'5 all down to a directive that you use l e v e l.'2 '.; o r - y'o u 6.-
use level _1, but I'm intrigued by the thought that 7
there are certain principles that -- in fact, this has.
8 been one of my frustrations as -I've talked-to :.my-s 9
staff.
It's difficult to understand this.without-10 resorting to examples, and' then it seems to me' it's 11-difficult t o - implemen t a pol. icy that. consists-of a '-
12 series of Commission guidance on the isating! coil type 13 for the HVAC system.
i w__
14 MR. - TAYLOR:
Yes, it=is.
15 COMMISSIONER CURTISS:
I.' wa n t - t o think' 16
-about this, and I'll be anxious to see what'the ACRS 17 recommends.
But the
- ey principles it seems to me L
l 18 that emerge that may provide guideposts in my mind
~
1 19 are:
20 Oner I don't think we ought to re' quest any 21 less information than we do today.
I don'tDthink we 22 ought to bind the licensee -- in this case, the vendor 23 and the COL holder -- to any lesser extent than they 24 are today.
25 Two, I.think we ought to -- whateverilevel
-i
(
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116 p
b-1 it is.
I think we ought to -in the context of 2
standardization be able toLaay that we are looking at 3'
and responding to the risk-significant physical
-l i
4 attributes. based upon the lessons-that we have learned'
~
5-from our key operating;exper.ience.
And in large part 6>
that's: what standardization is.
all about,-
in my 7
Judgement, taking advantage of the experience that's 8-
-been gained over-the' past andt applying it to the 9
future reactors.
And that's, I
- guess, a
second 10 consideration.
11 Third,.a point' that's been touched upon in 12 the context of the 50 '. 5 9 ' d is cus s ion.
It does seem to-t 13 me that from the istandpoint of changes -- and that i
14-goes to the quewtion-o f t ly. r 1 'versus-tier 2,
if we
-i 15 use a two-tiered approach -- ought to be leavened -- I 7
16 don't know if-ASARA is the :rlght acronym.or whatever
'i 17 the concept is, but some-consideration -ought to be i
18 given not only.1by toe Iticense holder but' by-the l
19 Commission as well ubout the extent to;which changes;.
20 on issues that are a p p r o v e d',
whether in -- well, in 21 this case in
' tier 2,.
diminish the level of 22 standardization that we've ' sought to attain in 23 reviewing tier 2_information.
24 Now there may:.be other considerations and' 25 it's fortunate that we've ~ got some time to think about-1 I
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this and get the views of the ACRS here when they meet 2
next month.
I'll pursue my concerns-individually as I 3
.think about this, but this Las been,very helpful for F
F 4
me.
5 CHAIRMAN CARR:
I guess I need a little
=
1 6
explanation as to why you think the level 1 degree of 1j 7
stand'rdization would make the availability of a
I 8
components more difficult to
- assure, which is a
9 comment in the paper therc.
i 10 MR. VIRGILIO:
I think over the life - of 11 the certification you'll-find vendors that w c,a l i 12 supply these components going.in and out of business.
. r--
13 And what you would probably force is custom design.
14 You would have the specifications laid out for a valve 15 or a pump and what you would force is somebody having 1G to custom-design or custom-build that valve or pump in.
17 order to meet the certified specifications.
That's 18 the intent.of that statement.
19 CHAIRMAN CARR:
Except-there is -- you're 20 talking about the life you don't mean --during the 21 construction period; then?
il 22 MR. VIRGILIO:
No.
I would mean over the
{
23 life of the certification.
I 24 CHAIRMAN CARR:
Over the life of the i-r 25 plant.
And so you,'re talking about that becoming part r-
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1 of the license, the certified portion of the plant.
2 But there is a method,in there for him to apply for an 3
exemption to that.-
'i 4
MR. VIRGILIO:
Certainly, 50.12.
5 CHAIRMAN CARR:
One of.the
- reasons, i
1 6
obviously, for approvin'g an exemption - like that is 7
there's no'other source.
8 And you said that you roughly figured it 9
would take about a year to revise the standard review j
10 plan.
Let's suppose we went to level I br 2.
Do you 11 have.to redo the standard review plan?
j 12 DOCTOR MURLEY:
Yes, we would.
We'd have r-13 to do it.mainly-to give, as I said, the~ staff guidance U
14 on scope and depth of review.
15
. CHAIRMAN CARR:
Are you going to have to 16 do it anyway?_
17 DOCTOR MURLEY:
Not for the evolutionary 18 plants.
19 CHAIRMAN CARR:
No, no.
I'm talking about 20 the evolutionary-plants.-
If we.
go to level-I h
21 evolutionary plant, do you have to revise the standard 22 review plan?
23 DOCTOR MURLEY:
We would certainly -- if 24 not revising the standard review plan, I' d' have' to 25 prepare one that would give them guidance on what they B
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should look at and what they shouldn't'look at.
Now
-l 2
whether we did it in the exact context of a standard
_j 3
review
- plan, I
think. it would more-likely be' an 4
addendum.
4 5
CHAIRMAN CARR:
A supptement.
6 DOCTOR MURLEY:
-A supplement to the I
7
-rd review plan.
l 8
CHAIRMAN _ C ARR:-
Want to take a-' random 9
guess at
'w many FTE and delay we're talking about or 10 is that negligible in the overall pictu,e7 i
11 DOCTOR MURLEY:
Just a-thought.
My guess 12 is it would take us about six months to do it.
And if-i 13 we look at what it's taking _ _ to prepare a standard 14 review plan for license -renewal,: it's taken Jour 15 section six months or something.-
16 MR. TRAVERS:
Yes.
It's.on the order of 17 six to eight months.
'\\
18 DOCTOR MURLEY:
Yes.
And.how many. people 19 are working?
20 MR. TRAVERS:
That's Lto prepare it.
And 21
- then, of course, there's a process to getting-it j
22 approved, including the.ACRS --
r 23 DOCTOR MURLEY:
What I would probably do
'24 is the same thing.
25 CHAIRMAN CARR:
Well, do you have to.do r-NEAL R.
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1 that 2
DOCTOR MURLEY:
I'd have a
separate r-3 organization.
l 1
1 4
CHAIRMAN CARR:
At. level 3,.would you have.
- l 5
to do-that?
I'm_trying to find out where we. depart-6
~from business as usual.
7 DOCTOR' MURLEY:l I ~ don ' t-think so.:
No.
8' ForLthe_ evolutionary plants, the amount of detail that 9
would come in under level 3 I think' we -are handling 10' now.
I think we're kind of reviewing - -
11 CHAIRMAN CARR:
So level 3
is roughly 12 business as usual?
i r.
13 MR.
VIRGILIO:
- Yes, it is.
With the-
\\'.ml l
14 addition of
- ITAACs, I -would _say~
l' t ' s business as 15 usual.
}
16 CHAIRMAN CARR:
'Well, to balance off a
17-Commissioner Remick, I'm somewhere between 1 and 1.05, 18 I guess.
But-I'm flexible within that range.
19 Any other comments?
20 I'd like to thank the ' staff for the 21.
abriefing.
The Commission has agreed to hold voting on 22 the staff's paper SECY-90-241 until we have received 23 the Advisory Committee on Reactor Safeguards' view.
24 ACRS views are expected shortly following their August 25 9-to 11 meeting.
During this period, the :Ccmmission i
- a. -
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-Ir..
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1 will be ~ considering-the industry's views and the 2
staff's options in formulating-a position to meet the 3
goals of preserving public health and safety and 4
achieving standardization for the next generation. of in th's country.
5 plants built i
6 It would be 1:41pful,.I think,'if you could.
't 7
probably - give us a papesr that tells us how -- what I
8 problems you see in implementing the tier 1,
tier 2 9
industry approach so that we have some basis to factor 10 that into our decision.
.I'm still,,:I guess,.a little.
11 uneasy with the hazards in going.to-a level.1'or level:
12 2 from our standpoint.
So if-you could, after.you get 13 a
few comments from the industry on our approach,-
i u.-
~
14 maybe you can.give us a piece of Dpaper t o' kind of i
15 summarize how you see it at that point.in time.
16 COMMISSIONER REMICK:
Ken, you said level 17 1 and 2.
Did you mean that or t.ier 11and 2?
18 CHAIRMAN CARR:
Both.
I mean, I'd like 19 you to
--- you're going to :get comments from the 20 industry, no doubt, on this approach.
And so-I think 21
.if you could wrap it all up~ in some'l kind of a "here's 22 how we see it and here's what we think the problems 23 are," it would be helpful to me anyway.
24-I persona 11y' f a v o'r submittal of 25-procurement
- specifications and construction and L
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20005 (202) 234-4433
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k-1 installation specifications for all structure systems'
~
-i 2
and components in order to ensure standardization as 3
well as safety.
However, I would consider the staff's l
4-recommendations on.those' structures,
- systems, and 5
components for which itmight not be. feasible to 6
obtain. t hi s' level of detail or it might not be 7
necessary to achieve standardization and therefore for 8
which only a level of -detail which provides the key 9
physical attributes for criponents would be obtained 10 in-these areas.
11 Any other comments?
12 We stand adjourned.
r-13 (Whereupon, at 4;24 p.m.,
the~ above-i 14 entitled matter was concluded.)
15 y
16 l7 I
18 19 20 21 4
22 20 24
-i 25 l
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e
'l CEP.TIFICATE OF TRANSCRIBER This 1s-to-certify that the attached events of a meeting 1
of the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING:..BRI'EFING ON ESSENTIALLY COMPLETE DESIGN ISSUE i
FOR PART 52 SUBMITTALS PLACE OF MEETING:
ROCKVILLE, MARYLAND l
DATE OF MEETING JULY 18,.1990
'l were transcribed'by me. I further certify that said' transcription-o is accurate and' complete, to the best of my ability, and that the
- i transcript is a true and accurate _ record of the foregoing events.
l l
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l Reporter's name:
Peter Lynch
~l i
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(202) 23M33 WASHINGTON, D.C.
2000S (202) 232 6600
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