ML20056B023

Transcript of ACRS Improved LWRs Subcommittee 900808 Meeting in Bethesda,Md.Pp 1-136.Viewgraphs Encl

ML20056B023
Person / Time
Issue date:	08/08/1990
From:	Advisory Committee on Reactor Safeguards
To:
References
ACRS-T-1808, NUDOCS 9008130235
Download: ML20056B023 (155)

Text

{{#Wiki_filter:cmmpww n n;~ kg>de,,~#- d~,.;g aw 4 m av>;n

w$ On

- y ~ + w' q~-

• a s

'Q t M -u R &;;4[i%fh.,.,[ [<.%w# OFFICIAL TRANSCRIPT OF PROCE Q-9!M s kd $[. --- 91 Ne m a kOh dim? Ut - mly q& n, :' i[ y [ hmy: 'y ,, y' J . ~ ~. - &gn 2 H (q}., a p, %y.y} QVe @ e&; W.ni W' k( 6\\ MM; j A -' -t/f}t -;kat-va s1 TR04 (ACRS) ^>"

4,

Ma AQ,%. RETURN ORIGINAL TO W A]4 g

1. " N E

B.J. WHITE, AC'd-P-315 MG_ . r:) -M " . ? % i% m ': &- y' f.p, W4; f;;;' p'+,zMl?m; l+., 5 s 4 1 THANKS! BARBARA JO .c W:g 4% wJV W.Hi,

1. 27288 s.

a: 2 +. '7 i > q w@ o 3 ril if $ '! h s ,Ijh h" % m ~c +' ~ 1 s M: c f g y.g'Wh ;&' + ? Jgy Nik$ vy ( % e!)Cy0 U.S.. Nuclear Regulatory 'Comission; W ['

q 8

u. ^ -

Advisory Comitte On betorjSafeguards; O d ~T! ' f, s

,o e r F< y] %: y; Mj; gh ghy$c., 3Titler, 1.provedLtigwe watertaeaccor. subcomttee.- weetiing , hg.; e s - 3 , ?t s % s a z. m g ${ d ed, }i d, [p:!f, ii'# && N \\ s p ;,L q,4 0 - 3k , t L ;-,, ..o yB a ?

cq t-i.U b c t

1 e .w d P. S, , y. Docket No. f 8 gp 7,, m,. mw A.,- q g 7., v w + ,. ~. p, v . w+ i t"c' 1 ,f4 p .g ! '. I'c.:{ g.3 a ' + .g L s bn ' i s i u m o d. 'a cto Qh M O Fj,1 ,%i i;!Q ,1 -s a i m. e gm, q u,a m m> ta i sbt i . } -c ui* v.,c M m[s ~h'l p-c,e kb N . 31iig,,

R

~ o ex m s m e m m{4 6 o, m. } g j TtOR1 -Bethesda,1MarylandI s q> 'g^ ' e. , p. ' j [. k > $. L ~ ; g w{ -{4 m' mI. y j E. y 4 1

Wednesday,: August 28,71990-

- PAG W j y 1 1 1 - 136 (flQ ' .{I ji lDATIC A.

t ;

g s fMJJB ; r;i i s 'h)' 3 I i & Q (, ' ' [' h~ j.s . $Oll;'$ s An Y ) f; \\ 'r;Yb!Qi 9 { 3.. s ,3 9 v(?-,g! s,,p s i 4 -, ',E n3v jei f't Y;& g _, Pgjggg {4,} [. y010 lemovefrom ACl8 0" ice w:p 4.,'-- m 0lNf[ d g a gif .,e i n ANN RII1Y & ASSOCIATES, LTD. N 4 W W_ 1612 K St.N.W, Suke 300 .r 't

• - -' fk h

41, PDR'

$l i. T-1808 r [n. (202) 29F3950 M vy.Q (, x g,;,J L.f[.y@hb % - g e _m

,j .in.

,h

!!: 5 /Eh y g 2 1 u - 3. p A 4 PUBLIC NOTICE BY THE 51 . UNITED STATES NUCLEAR REGULATORY COMMISSION'S 6 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS e V 4 j. 7. 8 DATES. Wednesday,-August 8, 1990' 9 -3 10 11 i ..( 12 e i 13 The contents of this transcript of the

14.

proceedings of the United States Nuclear Regulatory 15 Commission's Advisory Committee-on,1:eactor Safeguards, E l'6 (date)' Wednesday, August 8, 1990 I 17 as reported herein, are a record of the discussions recorded at-- i 18-the meeting ~ held'on the above date, , l'9 This transcript has not been reviewed, corrected 20 or edited, and it may contain inaccuracies. 1 l 21' , 22 23 24 1 25 i l .i_________.______.______.._._.___._____________.______ ___ _ _ _ _ __ _ _ _ _j

.... ~ _. _... -. .,f l' 1 l 2 '- UNITED' STATES OF AMERICA 1 3 NUCLEAR. REGULATORY COMMISSION j 4 .I 5 ADVISORY COMMITTEE ON' REACTOR SAFEGUARDS 1 IMPROVED LWRs SUBCOMMITTEE MEETING . ll. 7 s 8-Nuclear Regulatory Commission ) t 9-Room P-110 L h -10' 7920. Norfolk Avenue t lli Bethesda, Maryland 12 Wednesday, August 8, 1990 l} 13 14. 'The above-entitlel proceedings: commenced at 1:30 1 15 .o' clock p.m., pursuant to notice, Charles J.

Wylie,

'16-

Committee Chairman, presiding.

,;? 17 PRESENT FOR THE ACRS SUBCOMMITTEE-i 18' Carlyle Michelson, Vice Chairman I' 15L James. C. Carroll, Member I L20 Ivan Catton, Member L' 21-William Kerr, Member 12 2: .Chester P. Siess, Member a 23 ~ David A-Ward, Member 24-Lawrence E. Minnick, Member I, _ 25 Dr. El-Zeftawy, Cognizant Staff Member

r<g 2 1 PARTICIPANTS: \\ r ) g) 2 3 M. Virgilio 4 R. Nease 5 M. Rowden } l 6 T. Cox i p 7 G.. Imbro 8 B. Rasin 9 J. Cort 10-11 12 L O l 14 15 16 17 18 l-19 20 21 22 23 24 l 25 l 1 gi e-+ .a. e ,w-e h,..g w*w.- w-, w w w +- - g g

3 i 1 PROCEEDINGS j k,) 2 (1:30 p.m.] 3 MR. WYLIE: The meeting will now come to order. 4 This is a meeting of the Advisory Committee on Reactor 5 Safeguard, Subcommittee on Improved Light Water Reactors. I 6 am Charlie Wylie, Subcommittee Chairmr.n. ACRS members in I 7-attendance today are Dr. Siess, Dr. Kerr, Larry Minnick and 8 joining us whortly wi31 be Carlyle Michelson, James Carroll 9 and Dr. Catton. 10 The purpose of this meeting is to continue 11 reviewing the NRC and the industry proposal for the 12 completeness of design issue for the evolutionary and { } 13 passive reactors. Dr. El-Zeftawy is the cognizant ACRS 14 Staff Member f0r this meeting. 15 The rules for participation in today's meeting 16 have been announced as part of the notice of this meeting 17 previously published in the Federal Register on July 24, 11 8 ' 1990. A transcript of the meeting is being kept and will be L L 19 made available as stated in the Federal Register notice. It 20 is requested that each speaker 1trst identify himself or f L 21 herself and speak with sufficient 'latity and volume so that 22 he or she can be readily heard. 1' 23 We have received no written comments or requests f-24 to make oral statements from members of the public. 25 This is a continuation of the meeting which we ~

i i 4' 1 held last month on July 10, 1990 $n Subcommittee maating, 2 and the meeting on July 12 with the full ACRS, the staff and 3 NUMARC made presentations at the meetings on this subject. 4 We had discussions regarding the completeness of design. We i 5 will attempt to write a letter on this subject at the ACRS 6 meeting later this week. I would ask the Subcommittee 7 members to consider what they would like to have advanced 8 for consideration by the Full Committee on the subject. 9 Are there any comments by members present? 10 (No response.) 11 MR. WYLIE: Hearing none, we will proceed. I will 12 call on Mr. Virgilio of the staff to lead off. l -l j ( 13 MR. VIttGILIO: Good afternoon. My name is Marty 14 Virgilio, Chief of the Policy Development and Technical 15 Support Branch NOR. That is part of the program management i 16 policy development and analysis staff working for Frank i 17 Gillespie. With me today I have several members of the L 18 group responsible for our SECY paper on level of design 19 detail. 20 I would like to introduce Gene Imbro, who will be 21 speaking a little later on the design effort; Rebecca Nease, t 1^ L 22 who will also be speaking with me today. I have Tom Cox, a 5 23 section leader in our group who has also worked to develop 'f 24 'our paper. l 25 (Slfde.) 1 ~ _ -.

5 1 What I would like to do first is bring you up to ~ ls) 2 date on the program. On July 11, we signed SECY 241 and 3 provided it to the Commission. We provided a copy to you, 4 the ACRS, on the 12th. We discussed this subject with the 5 Commission and released the paper to the public on the 18th 6 of the July, and noticed the paper for public comment on 7 July 27th. 8 In our paper, SECY 904 141, we discussed four 9 possible levels of design det..1. We provided from one 10 example system, the HVAC system, we diccussed the two-tiered 11 approach for flexibility proposed by the industry and, in 12 summary, requested Commission guidance and recommendation on ( 13 policy on the two-tier approach and the design level of 14 detail to support standardization and certification pursuant ) 15 to Part 52, 4 16 The levels in that paper, each of the four levels, 17 were merely examples of level of design detail that can be 18 achieved and not the only options available to the 19 Commission, and we stressed that in the paper. What I would l 20 like to do now is talk a little bit about ongoing 21 activities. Based on feedback that we received from the 22 ACRS and Commission at the briefings that we had, we have l l 23 undertake two efforts. 24 The goals of these efforts are to determine how we 25 can maximize standardization and, yet, still preserve ,. ~, - - -n.,.

6 1 commercial feasibility. The second is tu provide the \\-- 2 appropriate degree of flexibility that will allow the plant 3 to bo designed and constructed. Gene Imbro will discuss the 4 programs underway to further refine our understanding of the 5 design process so that we can, in fact, maximize or set a 6 level with confidence that we are still preserving 7 commercial feasibility. 8 Rebecca Nease will then discuss our programs 9 underway to evaluate the two-tier approach, and how we can { 10 accommodate changes in the design process and still preserve 11 standardization. These are very couple efforts. You will 12 see, as they provide their discussion, Gene's efforts lead 13 Rebecca's and we cannot do one without the other. 14 With that, I will turn it over to Gene and then I 15 will give a summary. 16 MR. WYLIE Let me ask a question to begin with. 17 Is it your intent as to what recommendations are adopted for 18 design detail for certification to apply equally for l 19 evolutionary plants as well as passive plants? 20 MR. VIRGILIO: As of right now, yes. I don't see 21 that there's a difference, but it may be too soon to tell as 22 we go through the process as to whether there would be 23 justifiably some difference. If you goal is standardization 24 and yet allowing flexibility in the design process, it is 25 not obvious to me that you would want to establish two l

l 4 7 j ). 1 levels at this point in time. j-s 2 MR. WYLIE It certainly would be a lot easier to 3 describe details in evolutionary plants. 4 MR. SIESSt Not if you have a prototype. l 5 MR. WYLIEt It all depends on what the prototype l 6 is. 7 MR. MICHELSON: That's the proble:n of course, is 8 the passive plants require a prototype or go through some 9 other sort of equivalent process which is developing quite a 10 bit of the information which is not developed as such in the 11 evolutionary plants where there is no prototype requirement. I r 12 I would think that these are two separate problems. ) 13 Maybe it is intended that both of them be 14 addressed in 241, but it still doesn't come through very 15 clear. The only method that comes through to me is that it 16 applies equally to all of them, and I just don't think that 17 should be the case. Even Part 52 clearly snrts out the i 18 passive plants as being a different kind of problem. 19 MR. VIRGILIO: It does in a sense, bitt it doesn't 20 when we look at what is required to be included in the 21-application and what is to be included in the certification. 22 It doesn't make that distinction in 50.47 (a) or any of the 23 other subsections related to what is to be provided and 24 reviewed. 25 MR. CARROLL: Is my impression correct? I thought

~ _ I 8 i \\ 1 that the ptssive light water plants, there was no ys 5 h' 2 requirement. for a prototypas is that right? i 3 MR. VIRGILIO: It depends. The rule gives you 4 that f?.exibility. i f 5 MR. WYLIEt Not necessarily. 6 MR. MICHELSON: It may or may not. 7 MR. WYLIE: Or, it may be just prototypes of 8 individual components. 9 MR. MICHELSON: Clearly, your approach to 10 standardization will vary according to whether a prototype 11 is intended or not. None of that is sorted out in 241. 12 MR. WYLIE: Let's move ahead. We can discuss this I! 13 later. 14 MR. VIRGILIO: I would like at this point to 15 introduce Gene Imbro, and have him speak on design detail 16-and our program in that area. i 17 MR. IMBRO: Good afternoon. My name is Gene 18 Imbro, Section Chief in the Office of Nuclear Reactor 19 Regulation. I would like to talk with you for a few minutes l 20 this afternoon on what our role is in developing a level of 1-l 21 design detail. 22 (Slide.) 23 As Marty mentioned, there are two ongoing tasks, /N 24 which is to basically define a level of design detail that lg 25-can be completed at the time of design certification. As a

f 9 1 further task, defining what then can be in tier-one and ,s d. 2 tier-two if we adopt the industry approach. j 3 As I said before, what we are trying to do is look 4 at how far the design can proceed at the time of design 5 certification from the point of view of both maximization of 6 standardization, but aIso recognizing that vendor-specific 7 information will not be available at the time of design 8 certification at least for the components that will be in 9 the A/E scope. We are really trying to see how far the 10 design can be developed from a practical engineering 11 standpoint without certain information like vendor data. .i 12 Once we do

• hat, we are going to try and make some i

13 reasonable estimate as to what the engineering man hours 14 would be to complete the design to that level. 15 MR..SIESS: What is the advantage to NRC of 16 maximizing standardization? 17 MR. IMBRO: There are perceived benefits to 18 standardization, safety benefits. I guess I look at in the 19 way of sort of a double-edged sword. With standardization, 20 if you have old plants that are essentially alike, if you 21 find the problem once or do the design once you should be 22 able to flush out all the problems up front. 23 MR. SIESS: Except most problems are not j } 24' mechanical, they are human, and you are not going to 25 standardize the operators.

j s 10 1 MR. IMBRO: You have standardized control room, 7s t' ') 2 you are looking at man machine interface. You could make j 1 3 the design probably safer. 4 MR. SIESS: You think you could make it a 5 standardized plant simply because it is standardized, can'be 6 made safer than custom plants? i 7 MR. VIRGILIO: Let me add to what Gene said. The 8 Commission had four objectives when it set off in 9 standardization that are delineated in the statements of 10 consideration. I think first, it allows us to rapidly 11 accumulate operating data. 12 If you have standardized plants and standardized l ,-n lL . components, you will amass that operating experience 13 14-quicker. 15 MR. SIESS: Wait a minute. You snuck in a word 16 there. Standardized components. l L 17 MR. VIRGILIO: I would say structure systems and L 18 components to the level of detail we decide -- ( 19 MR. SIESS: Are you talking about getting 20 statistical data on component failures by having the same 21 components in all the plants, same pumps, same valves, same 22 manufacturer? 23 MR. VIRGILIO: That may be beyond what is 24 commercially feasible. 25 MR. SIESS: I think it is. l 1

i .11 l 1 MR. VIRGILIO: It hasn't been explored to that h \\~/ 2 level of detail thus far. 3 MR. SIESS: Go ahead then. 4 MR. VIRGILIO: The second objective is to allow 1 5 those utilities to share that information. It allows the 6 ease of transfer of information and operating experience 7 from one licensee to another. 'The third is, it allows a 8 vendor link. It creates or fosters an atmosphere where the 9 equipment vendors will stay in touch with the' utilities, and 10 they will have more incentive to stay in the market. 11 The fourth objective is to allow NRC to take or 12 the industry itself to take rapid action should it be f i 0; 13 nece wary, and to know exactly who has what and to be ablo 14 to act on that information. Those are. basically the four 15 objectives toward standardization that we are trying to 16 achieve. 17 MR. SIESS: Right now you don't know who has what, 18 do you? 19-MR. VIRGILIO: Sometimes it takes us a few minutes 20 to figure that out. 21 MR. SIESS: A few minutes? We asked the question 22 a few months ago about a question of containment hatch 23 design, and we haven't gotten an answer yet. I think I can 24 say with some assurance that you don't know who has what. 4 25 You think you are going to know who has what on standard

12 1 designs? _s ,) 2 MR. VIRGILIO: That was clearly one of the 3 objectives. 4 MR. SIESS: Not only who has what but who still 5 has what. 6 MR. WYLIE: If you have just one design. 7 MR. SIESS: If you have just one plant, but I'm 8 not sure when you -- 9 MR. WYLIE: It seems to me that would be contrary 10 to your second bullet up there. 11 MR. IMBRO: In what way? i 12 MR. WYLIE: You are saying that you want to do

(

13 this without having vendor-specific data for components. 14-You could have a whole conglomeration for the same 15 application. 16 MR. IMBRO: Tant's true, but there -- the plants 17-would be a lot more si'ailar than they are today. For 18 example, you may have a pump and it's going to be in the 19 same location and it's going to do the same function in all 20 the plants. Ostensibly they would be, at least to that 21 degree, functionally equivalent. 22 MR. WYLIE: Isn't it true though that the problems 23 have been sort of manufacture-specific as far as problems i 24 are concerned? 25 MR. IMBRO: That's probably true. History has , ~...

13 -w 1 shown that. 2 MR. SIESS: I think there are plenty of arguments 3 for standardization. I can see why the vendors could 4 benefit from standardization, I think the utilities could 5 benefit from standardization. I think pre-approval of a 6 design which is not essential -- you could have it without i 7 standardization I guess of the kind we are talking about. 8 All of these are beneficial to the industry and the public, 9 but I was trying to find out just why the NRC thinks that 10 maximizing standardization is a good idea or is it essential 11 for the public health and safety. 12 MR. IMBRO: I'm not sure it's -- 13 MR. SIESS: The statements that I have heard, I 14 sort of hope, if all the plants are alike they will be 15 better. Or, if they are not better, we can fix them all at 16 the same time. 17 MR. IMBRO: At least in my estimation, a lot more 18 things will be defined up front. 19 MR. SIESS: That doesn't make the plant safer. I 20 MR. IMBRO: For example the containment hatch, you 21 may be able to ask the question for some components once 22 what people have because a lot of the components may be the 23 same. ,s( ) 24 MR. MINNICK: While you are groping for good 25 reasons'to maximize -- and you have listed four semi good

i 14 1 1 reasons -- did you come across any reasons that might be ] j 1) 2 considered counter to broad gage nuclear safety, any 3 detriments? 4 MR. IMBRO: I suppose the obvious one would be 5 that if you found a mistake on one then likely you find it 6 on all of them. 7 MR. MINNICK: Then what do you do, shut them all 8 down? 1 9 MR. IMBRO: Then you fix them all at once. 10 Hopefully, you only need one fixed. 11 MR. MINNICK: Wouldn't you have a situation at i 12-least possibly that the need for those plants was too strong ) 13 to shut down a whole class of plant and, therefore, you 14 prolong this common mode failure if that's an appropriate 15 term. 16 MR. IMBRO: You would have to make an appropriate 17 safety judgment. You would have to weigh the significance 18 of the -- ll 19 MR. MINNICK: That's what I am groping for. I 20 don't really want to argue -- 21-MR. IMBRO: It's hard to answer on not a case-by-l- 22 case basis. l l 23 MR. MINNICK: I don't want to debate individual } 24 points. I do want to find out if you consciously thought 25 about the other side of the coin and balance. You have

.c I 15 ,es 1 given some advantages. Have you considered the ' I, 2 disadvantages from safety. I think Chat's point is well 3 taken. NRC's basic motivation should be assuring adequate 4 safety and not anything else., just assuring adequate safety. 5 6 In order to do so I think you usually find pros 7 and cons, and those have to be weighed. I would like to be-8 cognizant of that process. t 9 MR. MICHELSON: This discussion I find very 10 interesting, but untimely. This is a discussion that should 11 have taken place before Part 52 was ever adopted. Now we l 12 have the rule and now we have standardization and our t 13 subject I thought today was how do we decide on the level of 14 detail in the certification. l l 15 MR. SIESS: The question is how standard is 16 standard enough. 17 MR. MICHELSON: Yes. 18 MR. SIESS: Part 52 did not define the level of 19 standardization, and I think if Part 52 was intended to make 20 plants safer then that's important to know in deciding how 21 standard they should be. 22 MR. MICHELSON: I guess the assumption of course 23 was that it was intended to make them safer or certainly not l[(~ 24 less safe. 25 MR. SIESS: The question of a common error is, 20 = - -

~_ 16 1-plants our there all have the same defect or the same error. ( 2 There is a brighter side to that, and that is the chances 3' that you will find that mistake is greater with 20 plants j 4 than with only one. Then you might get it fixed for the 5 other 19, you see. It is a tricky concept. 6 MR. MINNICK: Yes, it is. It has pros and cons t 7 and that's my ealy point, have they been weighed? I would 8 like to say to Carl's point that I know this debate has been 9 raging for a long time. Maybe it's because it's such an 10 important question. I notice with some interest that 11 there's a major meeting on September 13 and 14 of industry, 12 NRC and all to beat some of these questions further and O Lj 13 longer. Are we so far ahead of the game that we know all 14 there is to know about this? -15' MR. MICHELSON: We are dealing with a regulation 16 which I think -- 17 MR. MINNICK: Occasionally we thought regulations 18 weren't absolutely optimum the first time they are done. 19 Just as the NRC's primary responsibility is safety, I think 20 our primary responsibility is safety too, and that's what we 21 should be digging at. .< 2 MR. SIESS: The level of standardization bears on 23 two different kinds of things that are embodied in Part 52. 24' One is Na certification process. The other is the combined 25. license process where you don't have the two stage

i 17 i 1 licensing. If you read this stuff on the two-tier type of fm 2 thing, both of those enter. l 3 If somebody came in I guess with a turnkey type y ) 4 design and offered it to people and got the first one 1 5 licensed and came in the second one and said it's the same 6 as the first one, we wouldn't have all this argument. It's 7 been done a couple of times. We had two or three so-called } 8 replications. I am not sure that the level of similarity 9 issue comes up when you start talking about certification 10 and signing off at this stage and go out and build it. I 11 don't think it has anything to do with safety, I think it 12 has to do with the level of confidence that reviewers have ~( 13 in what is there and whether people can be trusted to design 14 it and build it. 15 MR. MINNICK: I agree, and I wonder if that's a 16 really legitimate reason to do all of this. Maybe it is, 17 but certainly it is primarily to the advantage of the 18 industry and we t,ught to let them fight that battle, l 19 It has been expressed as basically as a quid pro i 20 quo. I think commission Curtis has used those words. The L 21 more you let us approve, the fewer things we will change in 22 the future. That's an interesting concept, but exactly what 23 the hell it has to do with safety is more than I know. 24 MR. SIESS: Do you believe it? l. 25 MR. IMBRO: When we finish this task we will 1

t 18 i 1 basically hope to define what is meant by an essentially 7 s i. 2 complete design. That is one of the terms that has been 3 stated in Part 52 that is giving people a lot of cause for 4 scratching their head in terms of what does that really 5 mean. It means different things to different people. So, i 6 we are going to try to the best of our ability to define 7 what that means to us. So, let me continue. 8 (Slide.) 9 I guess the way we are going to try to accomplish 10 this task is to first of all, try and really get a good 11 handle on the different design processes, both for Part 50 L I 12 and Part 52. In terms of gaining insight'into what the .r ((,)h 13 design output documents are, what they are, what information E 14 is necessary to finalize them, determine the extent to which 15 the design can be completed without vendor information and 16 possibly as a feed in to Marty and Rebecca's effort is to e l 17 identify areas where some flexibility is needed, where the 1 18 design actually can't be standardized as much as it can in 19 other areas. 20 We feel that the degree that the design detail can. L

21 be completed is going to be somewhat dependent on the 22 building it is located in, what the system is and what the 23 particular components are.

For example, certainly the site- [ ) 24 specific attributes can't be addressed at the point of 25 design certification. The way in which the environmental

.~ 19 fw 1 parameter, site ambience reflect their way through the L ~ 2 design, you can try to envelope it as much as possible but 3 you may need certain flexibility in the design to account 4 for things like different geographic location of the plant 5 and whether it's located in the desert or located in 6 Northern Minnesota and different areas of seismicity perhaps 7 and different areas of -- we have different service water 8 temperatures and that type of thing. 9 What we are going to try to do essentially is to 10 see how far people can go with the design, how much of the 11 design can be completed up front, up to the point where you 12 need to get to the point of writing specifications, just i 13 short of going out to purchase components, l:[ 14 We would envision that this may require some i i 15 interface with vendors as you proceed through to develop the 16 design, you may need to look at vendor catalogues to see 17 what types of equipment is available. If I write a 18 specification for a pump and I want the pump to be a i 19 horizontal suction pump,'how many manufacturers specify -- 20 can I actually buy the things that, in my mind, I want to 21 put in the plant. You want to get it down to a level of 22 detail where you-know the types of equipment, general 23 orientation and general layout of the plant. 1 [ [ 24 I can't really go into a whole lot more detail. I 25 would certainly be happy to answer your questions. We

20 7. 1 really just started on this process. What we basically -- (' 2 our approach is to come up with a -- we have retained some 3 consulting services and people with a lot of A/E and NSSS 4 experience, and try to come up on our own with what we think 5 is a level to which the design can be pushed before you 6 actually get the certified vendor data. 7 With that in hand, we would like to go out and 8 visit several architect / engineers to explore our ideas or 9 concepts with them just as a kind of double check or 10 validation that what the degree to which we think the design 11 can be completed is really feasible. -As a final step, we 12 will turn it over to Marty and Rebecca. After we have f - 13 defined what the design outputs are and how far the_ design 14 can be pushed in terms of completion, then it is a question 15 of I know how far I can go but how much do I really want to 16 standardize. 17 If we take the NUMARC approach of tier-one and l ~ 18 tier-two, how much of the design do we absolutely want to 19 fix, how much flexibility do we need to leave into the 20 design to account for maybe variances in vendor data, 21 emerging technologies or developing technologies that need l 22 to have some flexibility in them. For example, in the 23 computer field things are changing daily perhaps, and you s (~~} 24 might not want to standardize to a very high degree things \\s 25 that, perhaps if they were built in 10 years from now could

I 21 .~- 1 be substantially safer. s N 2 That's basically our approach and what we are 3 trying to accomplish, i 4 MR. SIESS: I have a question that I could not 5 find an answer to in the SECY. If it's at all possible, I L 6 hope that somebody could address it as they go through this 7 additional presentations of the levels of detail. I could l 8 get no feel for how the levels of detail propose that the 9 four levels compared say with the level of detail that was 10 _in the SNUPS application, a level of detail that was in 11 standard plant designs that we have reviewed in the past up 12 through an FDA I believe on something or the level of detail l t l 13 that the French have adopted in their standard designs of 14 which they build eight, nine and the plants alike, or the 4 15 level of detail in the German Convoy Designs. 16 I would like to get some feel for what these four l 17 levels that you are proposing, how they relate to other 18-things that physically exist in the world today. 19 MR. IMBRO: I guess we would rather not dwell on 20 what was in the Commission paper because I think what we are - 21 saying is that we would like to define the level of detail 22 that may not fit any of those four but maybe some variation 23 of that. To answer your question at least to the extent D[~) 24 that I know, and I'm a little bit familiar with SNUPS, I 25 think that SNUPS would be pretty much considered a Level w m 1 -r e ,-e

22 1 one, at least as I understand it. if 2 MR. SIESS: SNUPS was a level one. 3 MR. IMBRO: They actually had models built and 4 plants essentially were identical. I may be mistaken, but I 5 think they had common procurements. 6 MR. VIRGILIO: In the end, SNUPS was a level one. 7 I think your question was directed to the application, and 8 the application was probably a lot closer to the application 9 received for level three. What we asked the applicant to 10 conform to was the standard review plan and the standard 11 format and content, the SFAR -- the application -- l l 12 MR. SIESS: That's as far as the NRC is concerned, 13 but I am sure they sold the SNUPS plants to the utilities I 14 with some other arguments, l-15 MR. VIRGILIO: Certainly, and that's Geno's point. 16 Where you came out with was -- 17 MR. SIESS: Level one. l' 18 MR. VIRGILIO: Standard family of plants if more 19 than two have been built.- It was not in the original l' 20 question. R21 MR. SIESS: I was just simply asking for the level I, 22 of -- okay, I get your point. What you approved and what 23 the utilities bought -- ) 24 MR. VIRGILIO: Two different things. 25 MR. SIESS: Not too much different but different

23 ,1 scopes. 2 MR. VIRGILIO: Yes. 3 MR. SIESS: What about the French designs, do you 4 know anything about.how they go about it? I have a 5 suspicion they are level one. 6 MR. IMBRO: No, sir, I really don't know. 7 MR. MICHELSON: Where do you think GSAR II was, i 8 which I believe was one of Chet's questions. There was an j 9 FDA on it. 10 MR. IMBRO: I really can't answer that, Mr. 11 Michelson. I haven't looked at that yet. 12 MR. MICHELSON: It was probably one of the most l 13 classical exanple of what to look at for an ABWR short of 14 looking at the current ABWR. It was reviewed extensively by 15 the staff and the FDA was issued on it, as I recall. I just j 1 16 wondered how you would have put it into your level one 17 through four categorization. 18 MR. VIRGILIO: I would say it would fit in three. 19 It would have to meet the minimum safety requirements. We 20 impose no additional standardization requirements. 21 MR. MICHELSON: Maybe you have changed your l 22 definition of level three. I am looking at level two, 23 wherein it says the depth of design detail submitted in the 24 application for design certification will be similar to that p 25 of a final safety analysis report in an operating license

s 24 1 for recently licensed 1989, 1990 plant minus site-specific ') 4 2 and as-built information. I 3 That seems to fit GSAR II quite closely, and 4 that's' level two and not level three. Maybe you wish to 5 correct your response, or do you really believe it's level 6 three? j I 7 MR. VIRGILIO: I think if you go back and look at 8 the definition for level three you will find essentially the 9 same-words. Where we pushed level three was beyond the SRP 10' and standard review plan to capture additional benefits 11 derived from standardization by, if you will, certifying or 12 solidifying certain physical characteristics associated with G-V 13 the components. 14 MR. MICHELSON -You are quite right, the 15 definition has somewhat of a parallel structure. The 16 inference in reading level three is that it doesn't really 17 meet Part 52. Level two, the inference is that it does meet. 18 Part 52. 19 MR. VIRGILIO: If it does, we didn't mean to imply 20 that. 21' MR. MICHELSON: You mean level three would be also 22-by your definition meeting Part 52? 23 MR. VIRGILIO: It's another point on a spectrum of 24 many points that we felt could meet Part 52. We did feel 25 .that level four, because the contents of the application and

f 25 ,-~ 1 the fact that you are talking about essentially a two-step '~ 2 licensing process again, it didn't meet the letter or intent 3 of Part 52. 4 On the other hand, we looked at level one and 5 found that seemed to be pushing beyond the point of 6 commercial feasibility. It seemed to imply that in the j 7 application you would have much more than what was stated in 8 Part 52.47. Therefore, we felt that the option one really i 9 didn't fit Part 52, ~ 10 Where Gene's effort is going is to get you as far 11 as you possibly can within Part 52 and still -- within the 12 purview of Part 52 or still meet Part 52 -- still remain 13 commercially feasible. He is going to define a new point in 14 the spectrum where we said level one was clearly outside of 15 the realm of commercial feasibility and did not meet Part 16 52. Where Gene is going, if you read the Chairman's 17 transcript, maybe it's that 1.05 in his discussion in the 18 Commission meeting; how far can you really go and still be 19-commercially feasible. 20 MR. MICHELSON: There were two questions in my 21 mind. One question was, how far do you have to go to meet 22 the requirements of Part 52. Clearly you have to go that 23 far, I assume. The next question is, how far could you go, ) 24 It sounds more like Gene is looking at how far you could go p l 25 l l

26 j 1 MR. VIRGILIO: Yes. n N_) n 2 MR. SIESS: That's right. 3 MR. MICHELSON: Keeping in mind that you might not i 4 want to go that far because you don't even have a customer 5 to pay the bill to go that far. You do have the wherewithal ) 6 to provide enough information to go to meet the requirements ] 7 of Part 52 in an applicetjon. I thought you were only ) 8 dealing with what is the minimum requirement under Part 52 9 in terms of defining scope of equipment and level of detail 10 and all this sort of thing. I didn't know you were going 11 beyond Part 52. 12 MR. VIRGILIO: I don't view this effort as beyond 13 Part 52. I believe we told you as we met with you last time 14 that we thought that the level one, as we defined it in the 15 paper, did not meet Part 52. We even said it in SECY 341 l 16 that that was beyond -- 17 MR. MICHELSON: It goes beyond Part 52. S 18 MR. VIRGILIO: It goes beyond Part 52. But you 19 characterized it, I think, very well. Gene's effort is 20 going to take you out to the maximum that you can achieve 21 and still maintain commercial feasibility snd still stay 22 within the provisions of Part 52. 23 MR. MICHELSON: If it goes beyond Part 52 that's /~T 24 IV okay, if it's practical to go beyond because it is practical 25 to do a lot -- if you have enough money, it's practical to

1 i 27 j .fm 1 do most of this design effort. k 2 MR. VIRGILIO: We would like to work within the 3-confines of the existing Part 52 at this point in time. 4 MR. MICHELSON: That's a different issue. I j 5 thought that was the issue. What is the minimum requirement J 6 in terms of level of detail to meet Part 52, and that's the 7 lev 61 of information that must be in the application for 8 certification and part of which has to be in the 9 certification rule. t 10 MR. IMBRO: That's the question that we are trying 11 to answer. Our approach is to find out at least what is 12 practical or possible. 13 MR. MICHELSON: You know that given enough money 14 it's practical to do nearly all of this. 15 MR. IMBRO: Practical is probably a bad word 16 because it implies an economic -- 17 MR. MICHELSON: What the problem is, is people 18 don't have a' customer yet. Therefore, they are asking 19 really, how much do I have to put in an application in order 20 to get certified. 21 MR. CATTON: It's money at risk. L 22 MR. IMBRO: We understand'that. I 23 MR. MICHELSON: I thought what you were going to 24 do was tell me what is the minimum requirement to meet Part 25 52, and I keep hearing words like -- you are looking at what .-y -,--y. ,m-

28-f~ 'l is it possible to do. 4' 2 MR. IMBRO: We haven't gotten that far yet. 3 MR. MICHELSON: It is possible, clearly, to go 4 well beyond the requirements I believe, of part 52 unless I 5 misjudged the requirements. 6 MR. IMBRO: We haven't answered that question yet. 7 I don't think we are able to answer that question yet. 8 First we are going to try to see what is possible and then 9 maybe from that point, decide how far is it really i 10 reasonable to go. At least look at how far people can go 11 without all the information. 12 MR. MICHELSON: I think if you had much of any b 13 experience at this business you would know that it is L 14 possible to develop virtually all of this information given 15 enough money. 16 MR. IMBRO: We agree. L 17 MR. MICHELSON: That isn't a practical thing to l: 18 do. l L 19 MR. MINNICK: If I can add two cents, I think 20 there is more to it than just money. I really think it 21 would help here this afternoon -- the term " commercial 22 feasibility" has been used time and time again. It bothers-23 me, feasibility is a little like beauty -- it's in the eye ( ) 24 of the beholder. What is feasible is really dependent upon 25 how much effort you put in to how much is feasible. It's a I

s 29 ,e's 1 non-term. It's a non-definition. ) 2 I would like to hear what do you mean by that. I l 3 think you mean more than just money. 4 MR. IMBRO: I guess what we mean is pretty much 5 vhat Mr. Michelson said. Maybe feasibility is a bad word, 6 but if I am looking at this from an engineering point of l ? 7 view how much of the design can be completed without 8 actually having detailed vendor information. I agree with 9 Carl that you can probably complete one hel) of a lot of it. 10 That is fairly obvious. [ 11 MR MINN1CK: I read your report -- there are 12 other considerations besides that, considerations of '13 competition to consider. l 14 MR. WYLIE: Isn't that outside -- that's outside l 15 .the scope though isn't it? 16 MR. MINNICK I don't know. 17 MR. WYLIE: I think Carl -- 18 MR. MINNICK: That is what I am groping for. We 19 should let him tell me, when you say commercial there's 20 another word there, commercial feasibility. 21 MR. VIRGILIO: Proprietary information certainly 22 is one bound on whether it is commercially feasible. We 23 discuss in the paper that the Commission can't have -- what ] ) 24 we build into rulemaking will have to be available in the 25 public domain. That is certainly one bound.

1 1 30-j 77 As Gene has explained, if you'get into a point in 1 d(JN 2' the design process where'you start iterating with as ] 3= procured information and finalize your design details, 4 without that nameplate data you are over the line. That 5 defines another overlay our boundary on commercial 6 feasibility.'It is not.just money, you are' absolutely right. 7 There are these other thi'.gs. Looking at.it from a design 8~ perspective you can only go so far without nameplate data, l 9 and then you have hit the wall. Essentia.ly, you are no 10. longer able to push this.. 11 MR. SIESS: What you end up with and what gets 12 certified has to be still valid ten to 20 years later, 13 doesn't it? l -14 MR. IMBRO: Yes. i 15 MR. VIRGILIO: What you certify will live for the' 16' ' life of the facility unless we make a change pursuant to 50. 17 MR. SIESS: There is always-the argument 1that-if' 18 you specified a particular component you were then at the 19 mercy of the vendor of that component. 20 MR. IMBRO: We agree. That's why we are saying 21 you defina.some flexibility in the design to account for 22 that. 23 MR. SICSS: If he goes out of business you are really in trouble. 24 .25 MR. IMBRO: Yes. I don't think we want to -- U

i 31 c, ems. L1: MR. SIESS: You have to buy his business. tNm l' s 2 MR.-MINNICK: The bottom line and I will quit as 3 soon as I say.it is, this is another matter of degree. It 4 isn't' black'and white it's gray, and you have pros and cons -c S' of going further and further in some areas probably much. 6l greater.than others.. In safety-related areas, if I may, j 7 certainly the incentive is to go more into detail and in 8 unsafety related areas less. 9-It is matters of degree that are so difficult'for 10 you and for us and for the industry to weigh the pros and 11 cons. I think we all have to try to:get them out on the [ .12 table and take a look at them. There are cons as well as Q. = hs / 13 pros totany matter of degree. 14 MR. WYLIE:. Gene, in what you described a-while 1 15 ago aus to what you -- maybe I misunderstood you -- what you - 16 planned:to do=or what you would like to do is do a lot more =! 17 studying with A/E and what have to, to come up with -- 18 MR. IMBRO: Where.we are constricted by time -- 19 MR. WYLIE: I ask that question -- 20 MR. IMBRO: Whatever we can do in the raxt month; 21 i t- -22 MR. WYLIE: How much time have you got, very short 23 ~ I gathered. h 24 .MR. IMBRO: Yes. Several weeks is all. 25 MR. WYLIE: All the things that you said a while

32 .f)2-KL 1 ago that you would like to do and plan to do, you are going X 2 to accomplish in several weeks? 3 MR. IMBRO: Yes, as much as we_can. 4 MR. WYLIE: Thank-you. 1 5 MR. CARROLL: 1[n your attempt to describe the ~ 6 design _ process and define the engineering product, it seems 7 to me that one of the things you are going to come-up 8 againse almost immediately is Q/A. I wonder if you can tell 9 us anything about what level or what approach to Q/A is 10 going to be appropriate for all of this. I guess my c. 111 impression is that the Q/A world is changing, that these new 12 plants are going to be a lot more performance-based Q/A 13 programs. v l 14 Is that going to have a big impact on your view, L 15 in what the design process is? Listening to m. design 16 friends, plants that were recently designed there was ten 17 Etimes more Q/A on them than was really needed to get a good-18 product and, that sort of thing. L L 19 MR. IMBRO: I am not sure that we are going to L 20 require any more in the way of Q/A than what is stated in '21 ' Appendix B. 22 MR. CARROLL: Well, -- 23 MR. IMBRO:- Then 45-211 and Q/A-1 and those. I T 24- ((N / think in some ways the program implementation may be 25 somewhat different.

33' 1 y -11 MR. CARROLL: There is a new standard review plan lb2,) ' \\ 12 that is available as an option to people. l 3 MR. IMBRO: Seventeen point three, yes. 4 MR. CARROLL: Is that the one that will be used 5 ~here, and do you see that perhaps-reducing the amount -- O 6 reducing the design process? 7 MR. IMBRO: I looked at 17.3 very briefly several-8' weeks ago, and it didn't seem to me that there was any 9 inconsistency in that than what we are doing now. 10 MR. CARROLL: I think when you go to a Bechtel and

11 say what is the design process, they are going to lay on you t;

3 12 we have to do all this and all this and all this. I read

I f %s/

13 17.3 as-perhaps reducing some of that af what the process _ g-14 was maybe 20 years ago. 15' MR. IMBRO: I don't -- l l 9.K b 16 MR. CARROLL: That makes a big ~ difference. 19;; jw 17' MR. IMBRO: That is something that we can look at b> N" '18 and ask about. L :. c t t'?f 19 MS. NEASE: My name is Rebecca Nease, and I work L hN_ 20' with-the Policy Development Technical Support Group. As H L + !.Y5 .i l ' TD N ~21 Marty and Gene mentioned -- lif(f, 4 22 MR. WYLIE:- Do you have a microphone on? a. . 23 MS. NEASE: My name is Rebecca Nease. I am a L 24 Technical Assistant with the Policy Development and l 25 Technical Support Group. As Marty and Gene mentioned, I am j ,Q

-..-.1 ,...,,...,...,o, .,.m., 1u.. ......,,,,,,...,--n. 34 looking'at the; flexibility issue. ~ 1 k 2 (Slide.) L 3 Looking at this, we need to take a look at Part 52 4 again. Part 52 says there are three. bodies.of design ? 5 information; that submitted in the application and h 6 certified, that submitted in the application and not . certified, and that information to be completed and 7 8-available for audit, again not certified. L 9 Part 52 recognizes the need for flexibility by 10 allowing changes to certified material by the granting of an 11 exemption via 50.12. Part 52 also allows changes to 12 uncertified material after COL using the 50.59 process. In 13 the period between certification and -- Y 14 MR. CARROLL: In that third bullet, completed and 15 available for audit, does that mean completed at the time 16: the application is submitted? 1 17 MS. NEASE: It is upon request by the NRC staff. 18' If it is needed to make.the safety-judgment it can be'either 19 requested'and completed and available for audit at their 20 offices, not necessarily has to be in the application. 21 Howevnr, if -- 22 MR. CARROLL: I am.just' worried about the timing. 23 of it. Is this a body of design information that needs to - 24 be completed at the time of application? MS. HEASE: Part 52-talks about this, and it says

35 1 l' that it is information that is.necessary to permit the LiO ~ 2. preparation of inspection and to permit the preparation of 3 specification in construction and installation 4 specifications. 5' MR. MICHELSON: Also, for the staff to make a 6 safety determination which is -- 7 MS. NEASE:~ Yes, sir. If the staff needs it for 8 the safety determination it will have to come into our 9 offices, and it will become part of the application. In the - 10 period between certification COL, there appears to be no 11 mention of a change mechanism, anything for changing the. non-certified portion of the design. As the rule is . 12 13 written, this non-certified design information is not - 14 . precluded from COL hearing. 15 (Slide.) 16 Industry is proposing a two-tier. approach to - 17 design certification. Tier one would include design 18 information that is submitted in the application, reviewed 19 by the staff and certified by rulemaking. Changes.would be 20 allowed only through the granting of an exemption via 50.12. 21L Tier one information would not be open to adjudication at 22' the COL hearing. 23 Tier two will include design information submitted - 24 as part of the application, reviewed by the staff and not

25 certified but referenced by the rule certifying the design.

( i --__.__---_a

36 n r"[ l1 Changes would be allowed through 50.59 or similar change hy_ l 2-process. Only the changed information is open to challenge '3 at COL. 4- -Industry is also proposing a new~50.59 type change l 5

mechanism for changing the tier two information between 6

certification and COL. It is not clear whether'this 50.59 1 7 type change process will be certified with the tier one 8 material or if it is going to be referenced like-the-tier 9 one information is. 10 MR. CARROLL: When you say industry, you mean 11 NUMARC? 12 MS. NEASE: Yes. t .. M d\\ /- 13 MR. MICHELSON: If it's 50.59'it's part of the 14 regulation. I am not sure what certification has to do with 15 that at all, other than it can cite that~section. You can't 11 6 change-the regulations any by certification unless you 17 rewrite the regulations in the process. 18 MS. NEASE: Right. The proposal is that we have -y 19 some type of certified or certified by reference change 1

20 mechanism to change the tier two information.

The whole 4 L 21 idea with the tier two information is basically _ issue =22 preclusion. If you have a body of information that is 23 certified, a small body of information -- tier one -- that s i

q. }

24' can only be changed by 50.12. You have another body of 25 -information that supports tier one, the proposal is that the i 4 s

g 37 1-information is also-precluded from challenge at the COL iO. 2-hearing if they don't use the change mechanism on it. 3_ Any information in that tier two, even though it 4 is-not actually certified -- referenced in the certification 5- -- is not open to hearing unless you use the change 6 mechanism.' This is the way I see it. I am sure that NUMARC 7 'can describe this a lot better in their presentation a 8 little later. 9 (Slide.] 10-There are advantages and disadvantages to this 11 two-tiered approach. The-two-tiered concept will allow the 12 application to takte advantage of technological improvements I 13 that may be developed during the 15 year life of the 14-certification. 1s the design is finalized and procurement-15 activities proceed, modifications _to the design will be 16-easier-and less costly. 17 Also during the 15 year life of the certification, 18 equipment may become unavailable'if the vendors go out of 19 business. This approach will make it easier to incorporate 20 new equipment into the design. The two-tiered concept also .21 allows the owner some. input into the procurement process. 22 This is especially important if a utility with an existing 23 unit on an existing site wants to put up a standard plant. [ ) 24 This utility may want to use some of the same equipment that 25 the existing plant has.

38-1 The disadvantages:-- 21 MR. MICHELSON: Before you leave the advantages,- 3- -the third bullet talks about unavailability of equipment in 4 the future but maybe I'm just not understanding this S= standardization process well enough. I thought I have heard 6 an; awful lot of arguments that we are not going to-get down 7-to'specifying the particular manufacturer and-so forth.. 7 8 Indeed, it will specify the factor must be a p'ttp there but 9 not~necessarily who'is'to make it. -10 MS. NEASE: Yes. 11 MR. MICHELSON: So, clearly, I think we have to '12 concede-pumps are always going to be available or-you are I -13 not going to build that plant. I don't know that this is a 14 problem or even why it is raised here as an advantage, 15' -because we are not getting down to equipment supplier level 16 of detail I thought in the certification process. 17 MS.-NEASE: - You are right. It depends on where 18 you draw this line between tier one and tier two. 19 Obviously, the NUMARC proposal is going to want to draw the 20 line so that you have a very shallow tier one, a very small-21 amount of tier one material. Therefore, the tier two 22 material you won't have any problem with unavailability of 23 equipment. 24L However, if we determine the line has to be drawn 25 down further in the design process to the point where you

f i 4 'i 3 91 l 1. .actually define performance requirements to the point of'the r - M,' amperage it is: going to use, then you'may not have a-pump 2 j :. available the*..will fit that exactly _in the future.- You may i 3' s 4 say it's-a five stage pump, six stage pump. You might not 5 have that. Maybe all you can get is a four stage pump at 6_ that time that's in the market. 7 of course, if you have enough_ money you can have 8 the pump designed to your specifications but that is really 9 costly. l ,q ( l 10 MR. MICHELSON: Yes, I guess it depends upon ' ll again,'it's a question of how much detail you are asking f 12 for, and I thought-that is why we are here today. q! 13 MR. WYLIE: That's right, but I think what she is 14 pointing out is that this is an advantage over level one. )'! 15 MR. MICHELSON: Yes. I don't have any problem - 16 with that,'I'm just trying to understand the unavailability i . 17 of-equipment argument. It depends on how precise you are in . 18 this whole certification process specifying equipment. If i 19 you say it must be a'four stage pump utilizing a 2,000 amp _ . 20 draw:on the motor, it is entirely possible you won't find i 21 -that after a while. That is one level of detail. 22 I don't think you ever envisioned that level'of 23 detail, but perhaps you are. 24 MS. NEASE: That's right. You have to remember 25 that this :two-tiered process -- this approach can be applied \\

i i 40 1 s>- - to level one. Wo justLaight push them down to the nth j -2 ' degree offevery. tiny design detail, but we might not certify ~ 3 but a small part of that.. The two-tiered concept can apply-4- ta) any of those levels. 5 The' disadvantages, by allowing the changes to tier 6 two information, there may be some loss of. standardization. 7' Changes will also lessen the utility's ability to be certain 8 of design details and the cost of the design.- There may be L 9 some minor decrease in regulatory stability. 1 1 10 Part 52 puts additional restraints beyond those in i l-11 51.09 on the-NRC to backfit certified, which'is tier one 12 material. However, the uncertified, the tier two material, I 13 is not covered by these additional restraints and would-be, 14' .perhaps, a little more vulnerable to backfit. l-15 MR. SIESS: I have a little problem with that 16 first item, again, potential loss of standardization. This .17 - reference to standardization as if it were some higher level. 18 of existence, just by itself, is going.to make this world 19 more perfect bothers me. Standardization isn't a word, it l 20 is something that you' haven't even defined yet. To say a 21 potential loss of it, I don't know if that's an advantage or l 22 disadvantage. l-23 MS. NEASE: You are right. Again, it depends on j ) 24 where you draw your line on standardization, whatever 25' standardization is or what we find or define it to be.

t 41 I + l !1 MR. SIESS:.Right now I'm not even convinced that 2' standardization is a good idea. At one time I though*,it -3 was.. f4-MR. MINNICK: Chet, it's a panacea. We are all in -5 favorLof panacea aren't we? 6-MR. MICHELSON: If it were a panacea. 7L [ Slide.]- 8 MS. NEASE: I am tasked with the second 9 ' initiative, which is to look at flexibility. This has two

10-parts.

After Gene Imbro determines at what point he is 11 going to draw the line between maximum standardization and ,12 . commercial' feasibility, we will use this to determine where 13 to draw the line=between tier one and tier two. 114 We are also examining how to control. 15 standardization. Toward this, we are looking-at changes to

16 the tier two

information between certification and COL, fl7.

utilizing tho.50.59 type change mechanism. We are also .w 18 looking.at changes after the COL to tier two information, y 19 via the 50.59' process. o H20 .Are there any questions?

21 MR. MICHELSON:

Although in SECY-241, although you 22 did point out some more that this two tier approach might be 23 applied other than the level three option you didn't mention (f'24 it anywhere but in the level three option. Is there some .25 reason why it is associated with that particular option and <] ,,a

h

5 o

^ 42 n 1 not tho'others, and'could you explain it?1 o+- 1 ) 2 MS. NEASE:- Yes. The level three was our o 3' characterization of~the industry-approach. Of course, the 7 [ - e' 4 two-tiered concept was also part of the industry approach, f v:, p, 5 We chose to describe it'under the level three. "i 8

v:

W 6' MR. MICHELSON: Clearly, a two-tiered approach f .y 1 7 could be-varyingLamount in tier one and tier two for any one ie. d' .? ,8 -of these four options. You didn't present to the Commission i 9 any particular choice. You only mention it one place, and 10 it isn't clear why it wouldn't have been mentioned under 11 level two and with' varying amounts of material in tier one, 12 tier two. There are extremes to this thing, little or s [h 13' .nothing in tier one.or nearly everything in tier one. y 14 MR. SIESS: There are ranges to this. 15 MR. MICHELSON: Yes. 16 MS. NEASE: We are realizing that. We are d e 17 continuing-to look at this. 18, MR. MICHELSON:. If.I were the decision maker.and I 19 went through this, it looks like you were trying to give me '20 four ways to go and, yet, you only gave me one way to go if 21 I like the idea of tier one and tier two for instance. It's i 22 only really mentioned and covered in level three options. 23 FDt. VIRGILIO: It is subtle, but in the ) 24 introduction to the four levels we do have a statement to 25 the-effect that this two-tier approach could apply.

L-1 43' F , f /~s? 1 MR. MICHELSON: I gave you credit for.that in my \\ qw,J:i 2 opening remark.- It.certainly didn't come through after that i 3 as to how the decisions to be made -- the acceptability of~ t l L 14 this whole idea dividing the tiers and thereby dividing the 5 regulatory approach is heavily dependent upon what is in 6 these tiers. There is no discussion of that really. 7: .MR. SIESS: Right now, NUMARC has' proposed some n -8 division between tier one and tier two, haven't~they? 9 MR. VIRGILIO: Yes. Their methodology is 11 0 basically if you were to look at an-FSAR Section 1.2 and 11 enhance'that section with material contained typically.in a 12 staff SER supporting a license -- 13 MR. SIESS: Does level three describe the NUMARC 14 division? 15 MR..VIRGILIO: As best we could characterize it,. 16 we went through.Section 1.2 of FSAR -- 17 MR. SIESS: Really when ycu say' level three'is '18 like two-tier, you.' mein level three is like the NUMARC 19 proposed two-tiev.. .20 Mr.. VIRGILIO: ' Yes. l L

21 '

MR. SIESS: You could visualize other divisions as 22 you pointed out. 23 MR. VIRGILIO: Yes. That is an objective of .7 24 Rebecca's effort, is to go back in and look at what 25 methodology one might use to apply to determine what is in

e

Yl 44 l m 1 -a 1 ' tier one, what is.in tier two and whatzis the test then to k, ' it control what is in tier two to ensure standardization and -3' safety. 4 MRi MICHELEON: For that particular option, what + h

S

. staff SER is being considered here since the reference is to th 16-Section 1.2. Is that the staff SER for Section 1.2 or the- .7 staff SER for the whole design? 8~ MR. VIRGILIO: It's the SFAR for the -- 9 HMR. MICHEISON: Is the -- 10 .MR.- VIRGILIO: The SER for the entire -- '11 MR. MICHELSON: It wasn't the SER related:to 1.27 p l l. l 12 MR. VIRGILIO: No, sir, for the entire design. We

h l Aj.13

) used Clinton as an example to help you with this. L a 14 MR. MICHELEON: Whatever might have been said in

15 the staff SER about requirements,'about differences that 16 must be. changed from the SFAR,-all'of those are a part of E

17 tier one; is that right? 18 MR. VIRGILIO: That is the approach that was l 8 11 9 proposed. 12 0 MR. MICHELSON: A typical SER for an entire.

21.

project has all kinds of extra requirements sprinkled u 22 amongst the-various sections of the document, where the SFAR 23 says one thing and the staff says no, we won't accept it.

1h 24 MR. VIRGILIO:

At the time of licensing, what we L %) i 25 .have done is ensure that there-is consistency netween those I i lt 0' i' / se- , k '.) }Y jl I

1 45 11 documents. One of the things _that we do is ask'the a .C '2 licensee at.the last stages of certifying -- 3. MR MICHELSON: If there is truly consistency, 4: then why not just use the SFAR. Why.this mickey mouse about S-the staff SER? 6-MR. VIRGILIO: I-envision what NUMARC had in mind .7 was it would provide additional ~detall'. If you were to look l - 8: at Section 1.2 of a typical SFAR and then look at an SER in -9 its entirety,Lyou would find that-you would, by combining 10 the two,.get an. additional level of detail. 'll MR. MICHELSON: - By combining the two. 12 MR. VIRGILIO: That is what I understand as I- .C\\. V 13 rinterpreted their submittal. 14 MR. MICHELSON: Maybe I understood it wrong. They 15 were'only to use-the SER plus Section 1.2, not the SFAR plus-16 the SER. 11 7 MR. WYLIE: They are-here, they can tell us. 18 MR.-VIRGILIO: It is SFAR.Section 1.2 as the-1 19 entire SER. 20 MR. MICHELSON: Right, but the entire SER deals 21 with the whole SSAR. 22 MR. VIRGILIO: Right. Section 1.2 -- -23 MR. MICHELSON: And, it contains a lot of ) '24~ requirements on -- 25 MR. SIESS: What is Section 1.2?

=- T-4 1 -l 46 Jew 1-MR. VIRGILIO: It's an overview of a plant. 2' MR. SIESS:' It's the'one that says it meets all 3 the GDC's?- l \\ 4 MR. VIRGILIO: And a little bit more. It will tell jp r,. 5 you about, for example, your battery system and say you have g 6 four trains, and they are separate and independent, and they .c 7 meet the IEEE standard -- 8 MR. MICllELSON: It's what you-read if-you don't 9 want to read anything else. l 10 MR, SIESS: It's been so long since I saw an SFAR. ,.4 11 MR. MICHELSON: It is strictly and overview. You 12 certainly don't want to hang your hat on the overview. ?'% I(_) 13 MR. CARROLL: Is it fair to say that'what is in- .14 the NUREG is interesting history but you are really going a 1 15 step beyond that now, and.what we should be interested:in is 16 that product? L 1 17: MR. VIRGILIO: The simple' answer is yes. I'think 18 that'what we are doing now is very important and is 19 consistent with the direction we got toward the end of the 20 meeting. We don't have an SRM yet from the Commission l~ '21 specifying a' direction, but we anticipate from the feedback W 22 that we got frem you all and the feedback that va got from 23 the Commission at the briefing that they needed additional {( ) 12 4 information in order to make a decision. That is what we ic 25 are working on right now. I +

o 1 47. 1 I don't think it is a wasted effort.. It serves as -i 2 a point of departure for us to work forward now and further i 3' define the level of detail that is commercially feasible. 4 Remember, I said one is just outside -- you come up outside-5 of what is feasible.. Going back to the definitions we } 6 talked about. earlier, you are actually procuring equipment ~ n 7 -and factoring in as procured information as option one aus we 't 8 defined it in the paper. 9 Now we are looking for what is the maximum degree- <t 10 of standardization you can. achieve and still maintain that 11 commercial feasibility and still comply with'the provisions d 12 of Part 52. Take it as, we are going to define another f^5 h.j.J13 point. 'We define four-in the paper, and this.is'an attempt i L 14' to define.another point. If you want to use the chairman's D '15' terminology, it may be 1.05'. You seem to like that. 16' MR. SIESS: Why would you be looking for the 17 maximum degree of standardization rather than looking for i 1 18 the minimum degree of. standardization that would permit you 19 to fee comfortable about the safety? ~20 MR. VIRGILIO: I think what we briefed on the last 21 time that we were here that the minimum degree of safety is + 22 defined-by our regulations and the standard review plan. t- .23 What we want is a little bit more. We want standardization j

24 for the-four reasons we talked about earlier; the ability to 25 rapidly develop operating experience, the ability for l

j 2

48 fg 1 utilities to change -- exchange-information -- j ^A"ff i

2-MR. SIESS:

If those are' safety-related, they 3 . would come'in under what I. asked you. .4, MR. VIRGILIO:- If it is:important to safety yes, ) 't 1 5 it'is a feature of.our review in-'even option three. You are '6 right. You have to provide -- ) -7 MR.=SIESS: It just-seems to me that the i 1 8-regulatory agency -- your job is public health and: safety. 9 You should be looking for the minimum level that you are 10 willing to accept to= achieve your. objective. If the t 11 industry wants a higher level to achieve its objectives and-r . 12 its objectives are not in opposition to yours, then that's 13 their' business. 14-MR. VIRGILIO: That.is not-the principle upon 15 which Part 52 were really founded. You go back-to the o m; 16 statements of consideration and you see issue preclusion and .n 17 . enhanced standardization and safety through standardization. 18 In Part~52 we are pushing beyond.where we were under'tr.e 19 Part 50 licensing process for those two reasons. l 20 MR. SIESS: Okay. 21 MR. VIRGILIO: I think you have heard from Rebecca 22 and Gene in a lot more detail what our planned activities l-23 are. We expect to interact with NUMARC and others during 24 this process as we pointed out. We intend to begin 25 evaluating comments, as I said earlier. We published a y q. e m w

l 49 4 I I Federal Register notice and requested comments. That .l

1

m '2. Federal Register notice requests comments up to August 31st. 3 We will be folding those comments into our evaluation-41

process, 1

15 What we intend to do -- our product is to-develop 6 another Commission paper.- We are' currently on a schedule to 1 7 complete that somet'ime_toward the-end offSeptember. What we '8 -will do in that paper-is define the level of detail that y

9 maximizes standardizationyet preserves commercial 10 feasibility, define the proc and. cons to the industry's two-y

=11 ' tiered approach,_and define in the staff's opinion or V l 12 recommend in the staff's opinion a two-tiered approach if 1 [vf\\. I 13 one,ts necessary depending on what level of detail you 14-include in-the certification. P 15 MR. MICHELSON: Have you thought of a definition 16 yet for commercial-feasibility or is that a part of what you [ '17 work on?- 18 MR. VIRGILIO: That's going to-be a part of what 1 When we actually do draw that line that 19-we are working on. L 20 Gene was referring to earlier, we will try to describe the 21 basis on which we drew that line. Again, I think it will be f 22 related to not having the as procured information, not 23 having nameplate data, ensuring that you are not into 24 antitrust issues, you have not limited the procurement 25 process to one and only one vendor. l

t 1 e 50 c, os 1 MR. MICHELSON: I guess your approach, if T can-f f \\ \\ 2 ' shorten it up-a little bit,.your approach is going to be to 3 require _a level of detail commensurate with commercial' 4 feasibility, not necessarily related to how much'do I need 5 to know to determine'if it's safe and so forth.

Clearly, 6

you will'have to know if.it's safe in any event. .( ~7 MR. VIRGILIO: That's true. 8. MR. MICHELSON: You will'go beyond that, t 9 MR. VIRGILIO: Yes. 10 MR. MICHELSON: Apparently, to the extent of.where 11-you finally define' commercial feasibility. '12 MR.1VIRGILIO: Yes. j !"'y (,/ E13 MR. MICHELSON: Is that the idea? 114 MR. VIRGILIO: Yes. .You summed it up very nicely. 15 MR. MICHELSON: That same approach pertained to 16 both the evolutionary and the passive plants? 17 MR. VIRGILIO: As we see it today. As I i 18 understand and accept.the comment that you gave earlier, we 19 need to think about that. t i 20 MR. MICHELSON: Commercial feasibility, again, 21 would be viewed -- once you come up with a definition that 22 same definition will apply to both passive and evolutionary. 23 MR. VIRGILIO: As we envision it today, but I will j 24 take into consideration your comment. 25 MR. MICHELSON: I am trying to get a rough idea of

k s 51 1 4 + 1 ~ 'l where you are headed. 2 MR. VIRGILIO: And make sure we consider that. 3 MR. MICHELSON: Thank you.. m l 4 MR. VIRGILIO: That concludes the prepared portion j s. 5 of our presentation, and we_are willing to accept'any other ,g. 6. questions:that you might have. 4 J2 7 MR. WYLIE: Are there any questions?- y 8-MR. MINNICK: Could I ack one? ~It's really a q [ -9 matter of education for me, and I apologize. At several 10 points you talk about differences in the site having an /L 11 effect on the plant which, of course, it does,; and that 12 thoce make standardization a little difficult in some kT l v(' 13' instances. 14 A. couple of them come to my mind, but I would like 15-to have you elucidate on how do we handle different seiaaic 16 situations that vary rather dramatically around the country. 17-Then, an even more amorphous situation I think is the haat 18' sink and the cooling water and the goodies that you find in 19 the cooling water ranging from muscles to plankton to jelly- '20 fish to this, that and the other and coming back to how does 21' this-effectftbe joy of developing operating experience real 22 rapidly because it's going to be all the same for every 23

plant, j

{ 24 The bottom line of'all that is there really isn't 25 going to be a standardized plan.

4u 52 n- ^ l 1: MR. VIRGILIO: Gene alluded to'this earlier. In jc4 KL '] s '2; some of'his discussions-he talked about designing an HVAC 3 ' system to fit in' Arizona and to fit in Minnesota. There is-4L one way to do it. One approach is to make sure that the 3 m

5:,

design is so~ robust it could stand both sites. Another way 6L to do it.is to take into that consideration those different i .( V7' features that you would have in different operating-8 environments that the HVAC system would have to deal with. 9 MR. MINNICK: It's really a matter of robustness. '10 If it's just. robustness which may handle seismic I don't

i 4 11 know, not always.

It gets heavier,'it shakes. Isn't that a ' 12 penalty for the low plants compared to the h3gh? n d(_)., f13 MR. VIRGILIO: We have-heard numbers =-- q q 14 MR. IMBRO:- I think that the standardization, just 15-by its very nature,= standardization is not going to result 16 in optimized -- if you want to standardize you will have to 17- -make the design envelope fairly large to compensate large q, i

/

18 variances in that situation like service water or climatic 19 conditions, seismicity. You are right, I think the plants l 20 are over designed for some areas.

, 4 o

]pg[ ' 21 -MR. MINNICK: That sounds-like.a disadvantage to u o QINic 22: me. T.w lh 1 23 MR. IMBRO: It is a disadvantage in that regard. s f '24 MR. MINNICK: In other case that I think has been 1"' 25 neglected in this country is the heat sink and how we get w .+. (' >} gg,, q

i y' It

c. e q

-a 53 t1~ - from: the ut stuff in tho' plants: through a series of systems ,,.k L

2

-and heat exchanges out into the ocean or the cooling. tower, 1 s I (' 3; the lake or the stream or inlet that is filled with oil I L 4-sludge or whatever. 5-Every one of those is a different situation.and

l 6

robustness-won't solve the problem. 1 7. MR. IMBRO: That's right,.and I think that some of-c 8 those things need to be custom engineered depending on the l 9 site conditions. I think what you can do -- I mean, you can 10 take the designs so far as to specify interface criteria. 11 such as possibly. heat rejection rates. 12 'MR. MINNICK: Half the problem is, it is very h-(O difficult to know ahead of time what is the optimum _) 13 l= 14 condensate mat'erial in this particular location. I have 15 been there. 16 MR. IMBRO: You are right. You cannot 17 standardize. You have to allow a certain points-of -- '18 1 standardization, in terms of will the-NSSS system be the 19-same, yes. When you start to get out to-the systems and. 20 things that are really influenced by the site specifics, -21 then I think the best you can do maybe is certify to a 22. conception of preliminary design stage, something in a 23 functional level not to a point that you can do detail -j 24 engineering obviously. 25 MR. MINNICK: I guess the reason that I am raising

54 1 1 'this is b'ecause'it really raises another philosophical ,_q; k-2 question. Should we push to an ultimate degree in those 3L areas.that are easy.when there are those areas that are so j i 4' difficult you can't do it anyway. 5 MR. SIESS: You know, every time somebody mentions 6 . performance as a measure, they do it sort'of apologetically. 7c After all,; performance is the object of the game. I wouldn't 1 8-apologize for using performance as a measure of 9 acceptability. They say if you can't specify the components 10 we. will simply specify the p'erformance, as if that is a 11' second rate, second hand. type of acceptance. 12 MR. MINNICK: That's another point I think, ym L\\ 13 MR. SIESS:- No, I wasn't addressing your question.. 14- ] 15 MR. WYLIE: Are there other questions? 16I MR' SIESS: Do you realize that the core will d 17' never be standard on these plants unless they'are operated 18 under precisely the same load. conditions and refuel atl 19 precisely the same times and so forth that, after a few > 20-months of operatinn your cores aren't going to be standard; 12 1 does.this bother you? 22 But, you will worry about a pump, no radioactivity 1 J 4, '23 in a pump. jf,gY 24 MR. MINNICK: Safety analyses are really based on 25-a whole lot of core -- It depends on all kinds of things f

t 55 'l other1than'the original standard design of the beast. j 2 MR. CARROLL: Yes, but they are boundable, Larry. 3 MR. MICHELSON: I have a question. I just want to:

4 make sure that I understand what your intention was in SECY 5-241.

In Table 1 in the-SECY for option'two, you show 6 several itens going beyond so-called traditional review, I 7 mean standard review plan review. For level two you show o 8 going beyond. For level three, you show going up to what q I L "9 might be considered. traditional review. 10 Is the correct inference that all parts of Part 52 4 11 would be met with a submittal equivalent to what we now look q 12 at under traditional review in the standard review plan? b _)( r~% 13 MR. VIRGILIO: We believe it is an' option that is q 14 acceptable:under the rule. 15 MR. MICHELSON: That's a little different answer 16 than I expected. The answer I wouldLlike to hear is that j 17 option three meets all of the requirements of Part 52, and i 18 then I would have no doubt in my mind. If you give me f 19 another answer then I think you are hedging Gomething, and I y 2f 7 tid like to know what. 2' MR. VIRGILIO: I think it's a policy decision. l 2, ) tion three does meet the provisions of Part 52. That's 23 the way we envisioned it when we set it out. l---([ } 24 MR. MICHELSON: That's the way you intended when v '25 you wrote it. l_

56. r y ~ 1" MR. VIRGILIO: That's correct. a b. l '2' MR. MICHELSON: If you gave,a submittal equivalent m,p 3: !.to a standard FSAR which is then reviested by standard review ,a f ' ' k. ( .-4 plan, the-adequacy of that submittal would meet Part 52. If 5 you looked at it, it would be' adequate.to meet Part 52. J6 MR. VIRGILIO - We have' asked the Commission to im g y' 7 give us guidance.on this. We believe that it does. If you 8 look at the -- 4 '9 MR. MICHELSON:- It looks the definition of the x y 10 amount'of detail of design required is the same as we have. '11 been giving now for FSAR's. You don't need to write a four .,p option SECY to say do what we have been doing and you will-12 - p ' 13. Q meet Part 52. That is-thenlevel of detail required. l 14 MR. VIRGILIO: It goes back-to the intent'of Part 15. 52 in increasing and maximizing standardization. Certainly, l. 16 you get your safety issues' resolved with level three. We I 17 envision that you have your issue preclusion. You have o L 18 satisfied the SRP, the standard format and content, we have j b 19 'done our review and ensured the safety issues are resolved. 1 20 L L 21 If your intent is and the policy decision is to 22 forward standardization -- 23 MR. MICHELSON:

Okay, i

24 MR. VIRGILIO: That's where you don't do it. 25 MR.-MICHELSON: Then that's option two. If you j l i'

a iN, l 57. . +..g 1 want:what you' think is ~ anl appropriate level of T's_,2 ~ 2-standardization'you:go to option two. 4 3 MR. VIRGILIO: Or the points-in between. Again,- s 1 14. that's just one point on the spectrum. ~ 7g 5-EMR. MICHEIEON: Yes, clearly. W o. 6 ':MR. CARROLL: Or, to option 1.05. '7 MR.-VIRGILIO: Or, option 1.05. 8 .304. MICHELSON: I don't know anything about this-9 . option 1.05,.I'm sorry. I don't find it yet. Can you tell-10: me what it is? 4 f: 11 )m. VIRGILIO: It's Gene's effort. Again,'it'is + 12 'what werare'trying to define now as you characterized -J , bI ) =13. earlier, how far-can you go and still provide that'

g D

14. -feasibility. 15 101. MICHELSON: But it's almost option one;.is .i 16 that the-inference? 17 MR. VIRGILIO: It's a lot closer to.one than two,= l18: but it' lies somewhere in between. +19 MR. MICHELSON: Clearly,;you can even do one if i 20-you have enough money. i 21 .MR. VIRGILIO: Maybe not. That was the point we 22 were trying to make with one. I want to make sure that you 23 understand that. With one, I think you are plowing back a '24 certain amount of as-procured information in order to 25' . finalize some of the -- just take item nine on the list, the l

'l 58 1 geometric aspects of suspended components and your actual ., -s C] \\ 2 mounting and support data. Some of that, if you are really 3 going to finalize it, you are going to need to have your as-4 produced information, some of your nameplate information. 5 That is what we saw the difficulties associated 6 with the -- [ 7 MR. MICHELSON But there isn't anything wrong 8 with even that leve* . detail providing you don't freeze it 9 in the certification rule. 10 MR. VIRGILIO: That's again -- 11 MR. MICHELSON: One of your arguments it says 12 okay, if you have to make a change to the mounting you go f~ (%,) 13 50.59 changes and do it. That's the way it's done today. 14 When you have to buy a replacement pump and it doesn't have 15 original mounting bn- anymore. 16 MR. VIRGILIO: That's one way to return the 17 feasibility to option one, as to put the two-tiered approecn 18 on that. I agree with you. l 19 MR. MICHELSON: This two-tiered approach is 20 nothing magic. It is already provided for in Part 52 if I 21 understand it correctly. 22 MR. VIRGILIO: That portion of the design that is 23 not certified can be changed pursuant to 50.59 after the [ } 24 COL. 2S KR. MICHELSON: Yes. That's nothing new. That is l l

l l i 50 j l 1 nothing to do with two tiers, it just two tiers is ~ 2 somebody's way of explaining how they would go about j 1 3 applying Part 52, I thought. 4 MR. VIRGILIO: It's somebody's way of explaining 5 how one would go about certifying a certain portion of all 6 this material and referencing the rest in a manner that 7 provides issue preclusion. 8 MR. MICHELSON: That's fine, but it is not nothing 9 new. It is already provided for in Part 52. 10 MR. VIRGILIO: Not exactly. 11 MR. MICHELSON: No? 12 MR. VIRGILIO: I am not sure that the issue 13 preclusion of information that is not in the certification 14 is specifically discussed in Part 52. 15 MR. MICHELSONi I thought it was. I stand 16 corrected if it isn't. 17 MR. WYLIE: Dr. Kerr. 18 MR. KERR: Mr. Chairman, is it my understanding 19 that we are planning to write a letter at this meeting in 20 which we say that either we think the staff now has settled 21 .this issue or we think they haven't settled this issue,'and 22 we are to do it on the basis of no more information thLn we 23 now have? } 24 MR. WYLIE: My intent was that we would write or [ 25 recommend that the Committee write a letter making

I i 60 1 recommenda'sion. U-s 2 MR. SIESS: About what? I.am not sure. i 3 MR. WYLIE What we think the completeness of 4 design should b. i 5 MR. SIESS: I guess I was looking -- the staff has 6 submitted something to the Commission and have requested the 7 Commission's guidance. 8 MR. WYLIE: We have had meetings with the 9 Commission. 10 MR. SIESS: I am not talking about them, I am t 11 talking about us. I would assume that the Commission would 12 like for the ACRS to give it some advice about what kind of l l 13 guidance it should give the staff. Does that sound i 14 reasonable? 15 MR. WYLIE:

,uld say so.

I 16 MR. MICHELSON: Assuming it's the same. 17 MR. SIESS: Do we know then what kind of guidance 18 the staff is requesting? I couldn't tell. 19 MR. WYLIE: I don't know if they requested any. 20 MR. SIESS: Well, it says the staff requests 21 Cemmission guidance on this issue. Where does it spell out t ( 22 -- does it want the Commission to vote on level one, two, l l 23 three or four? jf'f 24 212. WYLIE: Those were options, I think. u 25 MR. SIESS: Is that what they asked the

6 " 61 U h: 1 Commission? x f. l 2 MR. WYLIE: And, the Commission gave them some 3 guidance. 4 MR. MICHELSON: They are going to write the SRM i 5 later. 6 MR. SIESS: The Commission gave them some <M, i 7 guidance? .) 5 8 MR. WYLIE: At their meeting, I think. pi, 9 MR. SIESS: Orally, at a meeting? Do we have a l 10 transcript of the meeting? 11 MR. WYLIE: Yes, we do. 7 12 MR. SIESS: Can we have a chance to read it before m (~, U 13 we try to write a letter? s-14 MR. WYLIE: Yes. 15 MR. SIESS: The staff asked about the two-tiered. 4 16 MR. VIRGILIO: That's correct. Let me clarify. 17 We didt ask the Commission to vote on the four options. l 18 We tried to portray the four points in a spectrum and asked 19 the Commission for guidance. We weren't asking the h 20 Commission to pick one of those levels by vote or any other L l ', 21 means. 22 MR. SIESS: knat would you like for them to do, to 23 say one and three-quarters or two and five-tenths? O 24 MR. WYLIE: Some say 1.05. f p% ) 25 MR. MICHELSON: Your statement puzzles me, if I 1 l,

62 g5 l' read page 12 of this -- 2 MR. SIESS: Excuse me just a second. On the two-3 tiered approach you just seem to say that Part 52 doesn't 4 quite commit the two-tier and I got the feeling that's more 4 5 of a legal issue than it is a technical issue; is that 6 right? 7 MR. VIRGILIO I view it as a technical issue. I 8 view it as a technical issue, as to how you could allow a 9 certain amount of flexibility to construct the plants, to r 10 accommodate or improvements in technology and accommodate 11 for new technologies. I am not viewing the flexibility 12 issue as a legal issue at all, I see it as an engineering 13 question. 14 MR. SIESSI Okay. All you have really asked the 15 Commission then is guidance regarding the two-tiered 16 proposal and the 50.59 typc change mechanism? 17 MR. VIRGII,IO And, if I may, guidance on the 18 level of detail. 19 MR. KERR: What is meant by providing guidance? 20 Do you mean you would like the commission to say what we 21 proposei here in this SECY is acceptable or what we propose 22 is not acceptable? What sort of guidance? I am groping for 23 what you would like -- I guess you don't know what the 24 Commissjon wants us to comment on, but it is not clear to me 25 wb.s t you want the Commission to comment on and the kind of i w m -a a-- ---..-w+ ..-,r 4 --m w--, ---,e-

63 1 detail you want them to comment on when you ask them for .,7 s k,- 2. guidance. m 3 MR. VIRGILIO: When the Commission has sufficient 4' information to make a judgment, I would hope that we could 5 get some guidance on a methodology that would determine what i 6 would be the acceptable level of detail, whether a two-7 tiered approach is an acceptable approach and some guidance 8 on the methodology for controlling what would be in tier 9 one, tier two, and the methodology for controlling changes 10 via the change process. i 11 I anticipate from the closing remarks at the 12 meeting that the Commission is going to ask us for more d 13 information before they make a decision. We don't have a 14 staff requirements memo as of yet. On our own initiate, 15 based on the comments we receive from you and the comments 16 we receive from the Commission, have undertaken effer'.s to l 17 further define our knowledge to support the Commissien in l 18 making their decisions. 19 MR. WYLIE: After the meeting with the Commission, 20 the Commission asked the ACRS to give our recommendation. l l 21 MR. SIESS: Orally? g 22 MR. WYLIE: Orally. 23 MR. SIESS: I think we could probably poll the 24 ACRS and come out in favor about a level two point three for p 25 mean with a standard deviation of point five. i 1

) 64 ,-sq 1 MR. MICHELSON: One of your statements earlier 2 puzzles me a little bit. You said you didn't expect the 3. Commission to pick one of these options that you gave, 4 although your clearly laid out four options and at the very 5 and of the paper on page 12 you say the staff recommends 6-that the commission provide guidance to the staff regarding 7 the level of detail to be required. 8 I think it'is not an unreasonable thing to believe t 9 that it relates then back to those four levels that you just 10 got done defining in great detail in discussing. 11 MR. VIRGILIO: I think you hit on the key word. 12 We gave the Commission four levels, not really four options. k) 13 We said your option is to pick any -- 14' MR. MICHELSON: You called them options as well as 15 levels. L 16 MR. VIRGILIO: Our. intent was to give the 17 Commission four levels of detail that represent four points 18 on a possible spectrum of literally an infinite number of 19 points and not asking them to vote on any one of those four .20 levels per se, but to give us some guidance on a 21 methodology. -22 MR. WYLIE: From the responses by the Commission, 23 I don't think they misunderstood that because they have } 24 given you something in between those levels. 25 MR. VIRGILIO: That is correct. -.m,,=< a. w m

• we-

-w-' E -A-- -T

65 l' MR. MICHELSON: Yes, because they didn't like any -f 2 of the four that are there. If they liked what was there, L 3 they wouldn't give you anyt.hing in between. 4 MR. WYLIE: Arc there any other questions? i 5 MR. KERR Is it the staff's view that this thing L 6 can be decided before one has tried it a couple of times? 7 MR. VIRGILIO: Yes. I do believe that's the 8 intent of Gene's effort to go out and then do that. I am 9 not sure what you are implying, that we would have to 10 actually build a plant? I expect that implementation of the 11 regulation will undoubtedly uncover some problems that we 12 will have to deal with. m k ) 13 It's like the Part 50 process. 2 14 MR. KERR I was going to say, my_ impression of 15 the licensing process that we now have is that it is one 16 that developed over the years and was markedly different now 17 from what it was. 18 MR. VIRGILIO: Yes. 19 MR. KERR: Now the standardization process is 20 supposed to arise full blown out of the ashes of our 21 previous experience I suppose. I don't get the impression 22 that it likely to do that in very final form, but perhaps k 23 that is -- 24 MR. VIRGILIO: We are doing the best job we can to g 25 make sure that it works.

i 66 j 1 MR. SIESS: 'I am not being critical of it. v' \\_/ 2 MR. VIRGILIO: I understand that. 3' MR. SIESS: Of the job you are doing, I am -- r 4 MR. VIRGILIO: I understand the reality of the 5 situation is that it is likely to have pitfalls we have yet 6 to uncover. We are going to work as hard as we can to try 7 to resolve this one before we get into it. We want to make 8 sure that this is a one-step process. We want to make sure -9 we have hit the level of detail and get the right level of i 10 standardization. 11 You are right, I do believe that we are likely to 12 see this evolve over time with experience, k ) 13 MR. SIESS: If that is the case, it seems to me it 14 is important that you not lock yourself into a process that 15 is very difficult to change. 16 MR. MINNICK: You might add that it is usually 17 easier and more feasible to add requirements to things than 18 it is to get rid of them once you got them. I am talking 19 about what degree of standardization are we shooting for in 20 the beginning, because it is likely to be an evolutionary 21 process. To me, you don't start at the ultimate you start 22 easy and work your way up as you demonstrate a need and a 23 motivation for additional and the practicality of additional 24 standardization. \\_/ 25 I wasn't there when it came down off the mountain,

1 67 1 I guess. ] ps 4* 2 MR. MICHELSON: Well, it's in front of you now 3 though. It is what we are supposed to be trying to address. 4 1 5 MR. WYLIE: Are there other comments? 6-MR. MICHELSON: Yes I wanted to check with you -- q 7-I looked back at 52.63 which deals with the finality of 8 design, and under (b)2 it talks about changes under 50.59. 9 So, it is provided for already in Part 52. 10 MR. VIRGILIO: After the COL. 11 MR. MICHELSON: After the COL, yes. 12 MR. VIRGILIO: Yes, it is. g(r~. MR. MICHELSON: So, it's not new. 13 14 MR. VIRGILIO: No. It refers to that portion of 15 the design that in not certified. 16 MR. MICHELSON: I misunderstood then. I thought 17 you were suggesting that's'a new provision that wasn't 18 already in Part 53. 19 MR. VIRGILIO: What is new is the development of a 20 process to control changes to the non-certified portion of 21 the design between the design certification and the COL. l l 22 MR. MICHELSON: That's new. 23 MR. WYLIE: Other comments? - (f 24 MR. MINNICK: Let me just say one other thing. 25 Correct me if I am wrong, but I think you wouldn't have I-l ~

.. ~. 68 1 investigated the four points on your infinite curve unless k 2 there had been some indication that all were feasible to a 3 reasonable degree within 50.52. 4 MR. VIRGILIO: No. When we looked at -- for 1 5 example, if we looked at option four or level four, we 6 clearly saw this as an acceptable process for a two-step 7 licensing. There was not sufficient information provided in 8 the application for us to complete our safety evaluation. j 9 MR. MINNICX: I stand corrected. Would you give i 10 me a range of what you do consider to be within 50.52. 11 MR. VIRGILIO: Clearly, something between one and 12 two, start sometime after you have gotten to a point where 13 you are now again consistent with the provisions of 52.47(a) 14 with regard to what is contained in the application. That 15 extends probably to where we are on level three now, as 16 still within the provisions of Part 52, sufficient [ 17 information for the staff to make its safety judgments using 18 the SRP as the guidance for making our safety judgments. 19 MR. MICHELSON: Part 52, of course, talks about 20 this essentially complete design. You believe that level 21 three detail is an essentially complete design? 22 MR. VIRGILIO: Again, I think that's a policy 23 decision, and that's why we have raised this to the 24 Commission. One could make an argument I think that, that 25 is an essentjally complete design. As a matter of policy, s

69 1! the Commission has thus far directed us toward more ) 7-(y N-2 standardization. e 1 '3 MR. WYLIE: Any other comments? 4 MR. CARROLL: I think going back to what Bill 5 said, maybe it will become clear when we hear from NUMARC, i 6 but I am still scratching my head as to what kind of a 7 letter we might write. 8 MR. WYLIE: Let's hear from NUMARC and maybe it 9 will come clear. 10 MR CARROLL: Given the fuzziness of the situation i 11 right now. 12 MR. WYLIE: Thank you, Martin. 13 MR. VIRGILIO: Thank you. 14 MR. WYLIE: Why don't we take a break until 15 quarter after. .l 16 (Brief recess.) 17' MR. WYLIE: Let's resume our meeting. I will call 18 Bill Rasin in from NUMARC again this afternoon. l 19 MR. RASIN: Mr. Chairman, you don't know how 20 delighted I am to have this few minutes to clear up all of 21 the questions from the earlier discussion. -22 ( Laughter. ] l l 23 MR. WYLIE: I bet you are. i 1 1 () 24 MR. RASIN: What I would like to do today is to i V. 25 continue on a bit from where we were last month in our I

f 70 1 I 1 discussions. Last month we brought in for you Dave Rehn and f-~g 5I 2 Mark Rowden, Dave Rehn to speak specifically to the ITAAC 3 document and approach and how that fit into the overall Part i L 4 52 and standardization process. Mark Rowden, to speak a bit 5 more about the industry position on tha application of Part i 6 52 or the implementation of Part 52 as we saw it, and from 7 that came the concept of the two-tier approach and the 8 flexibility. 9 You asked last month, Charlie, after the j 10 Subcommittee hearing for us to give that presentation at the 11 full meetina on Thursday, and we had to decline to do that [ 12 because of schedule conflicts, particularly with Dave Rehn -l()13 and somewhat with Mark Rowden. What I have asked them to do l L 14 this month is to be available Thursday, so we will have Dave 15 Rehn and Mark here for whatever degree you wish to pursue 16 that. Today, we do not have Dave with us. You heard him 17 last month, and we thought there was no need to go through 18 that again at the Subcommittee. 19 MR. WYLIE But, he will be available tomorrow? 20 MR. RASIN: He will be available tomorrow, that is 21 correct, and would be happy to do the presentation or 22 summary thereof that you heard last month. 23 (Slide.] [ As of last month's meeting, we had seen the 24 25 staff's presentation on 241 and their characterization of .n. +-.e

71 1 the four levels that they identified. Shortly thereafter we I 2 actually received SECY 241 in conjunction with the 3 Commissioner's meeting, where it was made public the 4 following week. We have studied it and, in fact, are in the 5 process of preparing comments on that. 6 Additionally, as you know, NUMARC appeared before 7 the Commission to give a presentation on our views on this 8 subject two days prior to the staff's presentations. In 9 addition, we are assessing the questions and discussion of 10 those two meetings, and we intend to provide written 11 comments back to the NRC with comments on 241 and, 12 additionally, other points that we believe could be 13 clarified or where we could provide additional information 14 that came from some of the Commission discussion and 15 questions. 16 Let me say, in your package I have a few slides up 17 front that summarize really, speaking to the need for power 18 and the need for certification in this country. We had 19 Sherwood Smith appear before the Commissioners, and Sherwood 20 is the current Chairman of the Nuclear Power Oversight 21 Committee. We did this in response particularly to Chairman 22 Carr's statements that the industry had not come up and told 23 him yet of the importance of this process and the need for 24 it, and the importance for getting on with it. 25 Sherwood's presentation was in response to that,

' l "I i t O \\ ,F 72 I and I think it was a very clear statement of industry's 1 "'\\ \\ 7 7s,4 2 desire for this process and a statement that without this we i ? 3 are just not willing to go forward and return to nuclear 4 power. I don't intend to go over those. You gentlemen are 5 well familiar with all those points. They are contained in 6 the first few slides of your package. 7 (Slide.] [ i 8 I would like to go on to slide number six and 9 present what we see as the big points that have come out of 10 our review of 241 and out of the Commission discussions. I 11 think we are fairly on target in agreeing with the staff on 12 what the big points are. I am not sure that we_are quite , k ) 13 together on how to answer them. 14 Obviously, we need to finalize the industry's 15 definition of level of detail and provide additional 16 clarification on that. One of the things that I believe 17 came out of the Commission discussions was the concept that 18 the one, two, three and four is just a little bit too 19 simple. In SECY 241 and the discussions it became obvious 20 that we are using an example on that table of an HVAC 21 system,-and everyone seemed to understand that clearly the 22 examples would be different for each system and the level of 23 detail necessary for the staff's safety determination and j 24 necessary to meet what we believe is called for in Part 52 1 25 would vary.

k 73 1 We are going back with a feeling that the one, js =H )l '~' 2 two, three and four have essentially served their purpose of 3 focusing the debate, and we are now going to try a 4 definition a little bit more on an across the plant basis on 5 how the level of detail would vary and what level of detail 6 would be necessary to meet Part 52. 7. Unlike the staff, we are not taking the approach 8 of defining how far we could go based on some criteria 9 feasibility or practicality. I will only note that one 10 concern that I have with that is, as soon as we define how 11 far it is possible to go that extreme, the rest of the i 12 debate is likely to focus then on justifying why you don't N 13 go there rather than on justifying what in fact should be 14 necessary and reasonable. I think we will continue on our 15 different approach, 16 The second point clearly is the need for us to 17-express more clearly our need for flexibility in the 18 construction and operation of the plant, and to give some 19 better examples of the types of flexibility and the types of 20 changes that will be necessary. 21 I believe that we have failed to express thin i 22 clearly, and there does seem to be a level of shall I say 23 mistrust on the part of the Commissioners that we envision () 24 massive changes to the plant and as soon as we get this 25 certification we are going to run away and then make it the L

1 [ 74 1 way we really want it to be, certainly was not our intent. 7-sg. l(_) 2 I think the burden is on us to clarify exactly what we need I 3 and what we mean by that. So, we will certainly seek to do 4 that. 5 We have quite a bit of work underway to do that, 6 and I am not anymore prepared than the staff was today to 7 tell you what the final answers are. We are working to the 8 same deadline, to the end of this month of August to respond 9 to the request for comments on 241 and we will do so. l 10 MR. MICHELSCN: In looking at these questions, are 11 you differentiating between the evolutionary and the passive 12 plants? l 13 MR. RASIN: No. I think we are not making a great 14 degree of distinction between evolutionary and passive 15 plants. Part 52, we have right now the luxury before us -- 16 we were. talking about this a little bit recently -- of some 17 very clear examples which are well along in the design and 18 development process. It would be wrong to set all future 19 policy based just on what we have before us. I think we 20 have to look at a policy of what really makes sense and what 4 L 21 do we need to do, because the decisions made now will really L L 22 apply to whatever comes in the future. 23 We don't want to get too locked into any one f } 24' design that is on the table today. We are really trying to 25 take the bigger approach and speak to the implementation of

i 75 1 Part 52 in the larger sense. ~s '~) 2 MR. WYLIE: In tha' regard, Bill, I think you said-3 you covered this information on page five of your handout. 4 Would you maybe explain what he meant to the industry 5 estimates of design certification must be complete, and then .i: b.r 6 he shows evolutionary and passive plants. 7 MR. RASIN: The dates shown there are probably the i 8 schedules that the industry has been working to for some l 9 time, and that we at least thought up until recently that l i 10 the staff was working to. We were trying, as an industry, 11 to speak there to say that we are serious about these dates, 3 p 12 and we intend to do what is necessary on our part to meet i. (~ , h _j 13 these dates. 1. L 14 MR. WYLIE: I was referring to the statement, 15 design certification must be complete on page five. 16 MR. RASIN: By the; design certification being 17 complate, we meant the regulatory process at that time have [ I 18 a certified design. 19 MR. CARROLL: That means that the ABWR and the 20 System 80-plus are complete in 19927 21 MR. RASIN: That is correct. Our feeling is that i i L 22 we have to get by that right now so we can get on to proceed i 1 1' 23-with these dates. l - 24 MR. WYLIE: Okay, thank you, 25 MR. RASIN: Let me say that I have with me today, i

t 76 i 1 representatives from each of the three vendors that are 2 working hard in this area. We have Joe cort from ceneral ? 3 Electric, Brian McIntyre from Westinghouse, George Davis and 4 Stan Rittibush from combustion Engineering. If you have any 5 questions or clarifications that you need from the vendors 6 or on those particular designs, we will be happy to have l i 7 them answer them for you. 8 I believe, given the previous discussion and 9 particularly the staff's kindness in portraying our position 10 on tier one, tier two and your questions on that, that 11 perhaps we ought to have Mark Rowden take a minute and j 12 restate that and clarify for you what t'& mean by our O R,,/, 13 implementation of Part 51 and the tier one, tier two 1 t l 14 process, and how that fits in with he'.i de view Part 52. i 15 I will ask Mark to take a les minutes to do that. 16 Then, we will conclude by trying to answer any questions we e 17 can for you at this point. 18 MR. ROWDEN Based on the questions asked, I think I 19 that the presentation I made'at the last Subcommittee l 20 meeting was more effective than I dared hoped it would be, 21 because I believe at least on the part of the questioners j i 22 that there was a fairly clear comprehension of the origins l l 23 of the tier two approach, what it was designed to do, and l } 24 how we would propose that it be implemented. 25 I don't want to restate everything that I outlined 9 y

i 77 l 1 before, but I do think that several points deserve emphasis c\\ >7'l 2 because there has been a characterization in all good faith J 3 I know on the part of the staff, that our approach to tier j l .4 two and their understanding of Part 52 of which I think 5 deserves clarification. 6 First, let me emphasize again, the two tier 7 approach is simply a way of documenting and formatting the i 8 difference that Part 52 itself draws between the contents of 9 a design certification application and the contents of what 10 Part 52 calls the certified design. I think it is well to 11 recall that the licensing process or the review process with r 12 regard to these designs is going to be no different than the [ l( ) 13 review process that is classically applied. The staff is i 14 going to be reviewing the entire application. That is the 15 technical submission on the part of the vendor-applicant. 16 What goes in the so-called certified design in the 17 words of the Commission is going'to be less than the 18 contents of what is in the design certification application. 19 That differentiation has very great procedural and licensing 20 significance under Part 52. The one provision of Part 52 21 that hasn't been mentioned in the discussions this afternoon 22 is 52.97(b). And, 52.97(b) provides -- and I am summarizing 23 it but I think it's a fairly accurate summarization -- that 24 any change in the contents of the design certification by a g 25 referencing combined licensee including the contents of the

= i 78 i 1 inspections test, analysis and acceptance criteria -- and, I i\\_/ - 2 underline the word any and I believe the word is any 3 modification -- is to be considered an amendment to the 4 license. It must be preceded by a hearing opportunity. -l h 5 That is a fairly draconian consequence to confront 6 when you are building a project and want to make a change 7 which is required because equipment may be obsolete, because 8 there is some sort of interference, or because of the other 9 very predictable consequences of carrying out a complex j 10 construction project. i 11 To deal with that problem -- and I am quite candid 12 in identifying for you as I identified for the Commission -- ) 13 that problem, to deal with that problem and to relate it to ( 14 the specific provisions of Part 52 which, as I indicated, 15 drew the distinction between what is in a certified design 16 and the broader contents of a design certification j 17 application and the differing change mechanisms applicable 18 to each. As was indicated in the earlier presentation by i 19 the staff, what is not in the " certified design" can be 1 20 changed under 50.59. l l 21 To deal with that, we devised -- again, this is 1 22 nomenclature and nothing more -- what we call the two tier 23 process. Tier one would be the design which would be t 24 characterized by the commission in the design certification 25 rule that it issues as the certified design. What would be ~

l 79 l 1 in tier two -- and not simply for purposes of convenience ] ,() 2 but because it corresponds to the reality of tha staff ] 3 review and the design certification hearing process -- what 4 would be in tier two would be the balance of the 5 application, the technical application. In other words, the ) 6 SSAR. 7 We think, and we believe as a matter of fact, that 8 it is reasonable to deal with the matter in this way for 9 this ressen. One, this tracks the actual submission that 10 will be made by the design certification applicant. Two, it 11 tracks the review of that application that will be made by t 12 the regulatory staff. Three, it tracks what is going to be /^ I 13 considered and open to public participation in the design q 14 certification proceeding. l 15 Therefore, when the design certification rule is 16 issued, it should cover both what is in the contents of the t l 17 certified design and what is in the contents of the balance 18 of the design certification application. 19 I don't think that there is a differentiation in 20-understanding between NUMARC and the staff up until this 21 point in time. Where we do part company is in their 22 understanding of several aspects of our proposal, which I 23 will get to in a moment. Also, very fundamentally in a 24 statement that was made by Rebecca Nease and which was j'"3 V 25 echoed by Marty Virgilio, and that is that by following the i

4J h. t 80 ,o 1 two tier approach we do not obtain what we have 3~.q Nl '-) ' 2 characterized as issue preclusion, namely that what is in 3 tier two would be open for consideration in a combined 4 license proceeding with references the certified design. 5 The answer to that is, it is not so. It is not so t 6 simply because that is part of our proposal, it is not so 7 because Part 52 provides for the contrary, Remember, tier 8 twn will have been reviewed by the staff, tier two will have 9 been open to hearing consideration in the design 10 certification proceeding. The normal consequences of the t 11 regulatory process are, when you resolve an issue in that y 12 fashion it is not open to relitigation, and that is exactly-I ) 13 what we are proposing and no more. e 14 Beyond that, I believe that the language of 52.63 15 (a) 4 is very pertinent and explicit on this point. That 16 is, the Commission shall treat as resolved, those matters -- and they are talking about in a combined license proceeding 'i 17 l 18 -- the Commission shall trer.t as resolved, those matters 19 resolved in connection with the issuance of a design 20 certification, which is exactly what we are talking about i l, 21 with regard to tier two. l 22 We evidently have a difference of opinion'as to 23 the reading of the regulation, at least as I understand what l y} 24 the staff said. We believe that our position is not only l N-l 25 consistent with the literal terms of the regulation but with l

81 1 a common sense application of the regulatory proces2. If K/ 2 you have issues that have been reviewed, if you he.ve issues 3 that have been resolved in a hearing proceeding, what is the 4 basis for considering those issues anew in another 5 proceeding which involves the same design. 6 I think that is a very fundamental point, and I 7 -have spent so much time on it because I think it is critical 8 to an understanding of our position and hopefully, to a 9 better understanding of the staff of our position. 10 A couple of other clarifications, and then I would 11 invite several questions which I think might elaborate 12 further on some of the things that were discussed before. l 1;' ) 13 There was an implication, if not more, in the 14 presentation by the staff that the tier two part of the 15 design certification rule could be changed either by the 16 vendor or by an applicant for a combined license under 17 50.59. That is not so. As we understand the regulations, 18 only the holder of a combined license can utilize 50.59 to 19 change the r.on-certified portions of the design; i.e., that 20 which is in tier two. I think it would be reasonable to 21 give that latitude to the applicant to make that change, but 22 that'is not what Part 52 provides in this regard. 23 Secondly, this is not as characterized in the 24 staff's admission, and perhaps I am doing an injustice to qf-t k 25 what is just a headline rather than an explanation. This is i l :. I

l 82 1 not a new 50.59 type change mechanism that we are proposing. .j 3 - (y 2 It is 50.59 as applied to tier two of the design 3 certification, the uncertified portion of the design, as 4 expressly provided for in Part 52. 5 I can go further, but I think I would be burdening i 6_ your time, which might be more usefully applied to any 7 questions you have to ask. 8 MR. MICHELSON: I would like to get your view on i 9 wnat is included in tier one. 10 MR. ROWDEN: Tier one is a category for which we - 11 have made a proposal. There is limited guidance in Part 52 12 which, in effect, says that the certified design, that is ( 13 what is in tier one, is to contain those elements of the 14 design which could not be changed under 50.59. We have made 15 a proposal to describe what is in tier one in a particular 16 way. We have used Section 1.2 of the standard review plan 1 17 which calls for a very summary description, and said that 18 the breadth of the design described and provided for there 19 should be matched by the level of detail you find in the 20 SER. t 21 I think Marty Virgilio correctly stated our 22 position in that regard. I 23 MR. MICHELSON: That is not quite what he said, 1 24 unless I misunderstood him. I thought he said the staff's , p 25 SER would become a part of the tier one. L

P3 1 1 MR. ROWDEN: I don't want to take words out of his i I\\- 2 mouth. 1 3 MR. MICHELSON: Which is it? Did I misunderstand 4 him? I 5 MR. VIRGILIOt What I used in describing what 6 would be included in tier one is the latest draft submittal 7 that we received from NUMARC. 8 MR. ROWDENt That is right. 9 MR. VIRGILIO: On ITAAC's what would be the 10 proposal for what would be included in tier one. I think~ j 1 11 level of detail is. defined in Appendix G to that document. 12 In that document they talked about the FSAR Section 1.2, d 12 supplemented by the entire staff SER. 14 MR. MICHELSON: That is what I thought you said. 15 MR. VIRGILIO: That is a draft document. 16 MR. ROWDEN: It is with a level of detail 17 comparable to that. 18 MR. MICHELSON: To what is included in the -- 19 MR. ROWDEN: What is included in the SER. 20 MR. MICHELSON: That is quite a different matter, 21 whether you -- 22 MR. VIRGILIO: If you interpreted what I said 23 would embody the SER, that is not what I meant to say. It ,/ 24 would be the level of detail that would be included in the 25-staff's SER.

f ^ ) 84 1 MR. ROWDEN: That is our position. -s k- = 2 MR. MICHELSON: I am not sure what that says. 3 What document will be in? Who is going to write this 4 document that is comparable to an SER -- 5 MR. ROWDEN: Let me elaborate on that, because I 6 think it does call for some. This is a proposal that we 7 made, and it is level of detail comparable to that in 8 current SER's. What we have tried to do is give it content 4 9 by examples which are included in our ITAAC report as l 10 appendices to the ITAAC report. Since I have described it 11 and as it is described in the report, these are just 12 concepts. We have tried to give them tangible i 13 implementation by examples. 14 We have always recognized that what goes in tier 15 one is going to be a matter of ~~ I will use the term 16 negotiation in the best sense of the term -- negotiation 17 between the certification applicant and the NRC. The 18 determination as to what goes in tier one is going to be 19 mightily influenced by the degree of flexibility they want -20 to give to tier two changes, because what is not in tier one 21 is going to be amenable to change under 50.59. 22 I don't know -- I can't tell you right now where 23 that line is going to be drawn. We have made a proposal, we ) 24-think the proposal is a reasonable proposal in the sense q 25 that it describes the most significant features of the

85 1 design, but this is something that is open to discussion \\- J 2 between the industry and the Commission and ultimately a 3 determination by the Commission. 4 MR. MICHELSON: You are, I am sure, very well 5 acquainted with what is included typically in a staff SER. ) 6 I can understand if a person told me he was going to use a 7 staff SER as part of his tier one development. If he isn't 8 but he is going to use something at a level of detail 9 comparable, that leaves me a little lost as to what we mean 10 by a level comparable and who is writing this document 11 defining this comparable level that will become a part of 12 the staff -- I ) 13 MR. ROWDEN: The latter question I will answer 14 first. The proposal would be made as is the case normally l l 15 by the design certification applicant. l-16 MR. MICHELSON: He would write the -- 17 MR. ROWDEN: It would be reviewed by the staff. 18 It would be subject to consideration-in a hearing. In other 19 words, what I am describing is level one and level two would 2C be matters that would be open to hearing consideration too. 21 Someone could come in and say I believe a particular matter 22 is not appropriately covered in level two, it should be in 23 level one because I believe the change mechanism should be a 24 tier one. Forget about level -- a tier one change ((]s l 4 25 mechanism. l 1

); 86 1 In terms of doing greater justice to comparable to i 2 the level of detail in SER, all I'can do is refer you to the 3 example that we have in the ITAAC report. 4 MR. SIESS: What does that do, does that reference 5 an SFAR? I can't remember. I saw it, but I can't -- 6-MR. ROWDEN: What it does is tak9 2 carticular 7 element of the design -- I believe it's the containment -- 8 MR. SIESS: It is only a sort of legal document 9-that says this is what ye have certified. 10 MR. ROWDEN. No..It is a description. What is in 11 tier one is a description. What.is in tier two is a 12 reference. I h - 13 MR. SIESS: You are talking about the example for 14 the HVAC system. 15 MR. ROWDEN: Well, the HVAC system was used by the 16 staff. What I am-talking about in the ITAAC report, if you C 17 have access to a draft copy, is:the appendix which contains 18 an illustrative example of the design description that would ' 19 be contained -- t 20 MR. SIESS: Volume two, or the -- 21 MR. ROWDEN: No, it is contained in volume one. 22 An illustrative description of the tier one containment 23 design, eccompanied by an illustrative description of the q g -24' inspections test, analysis and acceptance criteria that 26 would apply to that particular aspect of the design. That

/ 87 1 -would be:in tier one. O. 2 MR. SIESS: That's not'a great deal shorter than 7 i 3 U an SFAR.- j . f 4I MR.-MICHEISON: No, and it's a lot more than in ^ l 5 1.2 I believe. l 1 6' 704. ROWDEN: It is more than 1.2; 1.2 is very 7 brief. 8 MR. MICHELSON: So, what does the 1.2 got to do i .9) with it? Clearly, a. description has to be written of --

10 some kind of description has to be written that goes into

.11. tier one. y 12 MR. ROWDEN: We ought to hear from one of the ( ) 13 L vendors on this, Joe Cort. i 14 MR. MICHELEON: Sure. 15 MR. CORT: My name is Joe Cort, from G.E. I'think 16 there is a misunderstanding here, Mark, is why I raised my-17 hand. What they were looking at there was volume two. That i 18' is the problem, they are looking at that thinking.it-is a 19 level of description that should be in tier one, and-it's 20: not. Let me tell you what it is that you are looking at ' w !; 21 there. y 22 That is 'olume two. What we have done is gone g 23 into the ABWR/SSAR and extracted out relevant sections of s. 24 .the entire SSAR that describe the containment system. We have provided that excerpt. 25 w i+ l

'4, 88 h l' MR.1ROWDEN - Chet,:you are going into volume two [- 1 i 2-now. You-don't want to go in volume two. You had the right h 3 . volume before, volume one. $( E . 4 MR. CORT:- That is SSAR information. I just wanted 5 to clarify that. 6 MR. MICHELSON: You didn't really mean that was 7 the lev 6? of detall -- 8 MR. CORT: Did not. .9 MR. MICHELSON: Then, what is the level of detail? 10 }UR. ROWDEN: Let me go back to.what I said before. 11 Chet, if you have volume one of the ITAAC report and look at' 12 the' appendix which contains an illustrative design 13 certification rule and a description -- I don't have the 14 index in front of me, so I can't'tell you offhand what the 15' appendix designation is, what the letter designation is -- ~ 16 you will find for both a BWR and a PWR, an illustrative 17, description of the containment system with accompanying 18 ITAAC. . 19: If I could have the document I could probably 20 ~ identify it fairly raadily. 21 MR. MICHEISON: Is that description that was in 22 the ITAAC, is that what you mean by level of detail 23 comparable to a staff SER? 24 MR. ROWDEN: That is our implementation of the g 25 that concept, yes.

7, E r ;" G, i - 89-y II 'l MR. MICHEISON:- That would have certainly .-;,m. pa f? 2 -classified'it as a very poor staff SER at best, and probably 3 would think it unacceptable as a staff SER. That's why I N 4-asked, I just didn't -- I thought at first ws wara going to i e + 5 include the staff SER as a tier one. i -6 MR. ROWDEN: No. It is not the staff SER. h[ -7 MR. MICHELSON: There are e lot of important 30 8-things said in staff SER's that have to be' frozen e-- p; 9 thereafter,,and you can't. change them. But yet, that will '10 all be bypassed by this process as long as whatever you wanti 11 to do doesn't create a non-reviewed safety question as I 12 . understand you proposal. L.(A) 13' MR. ROWDEN: We are talking now about the l L, 14 implementation of our proposal, and I was very direct in 15-stating that we have made a suggestion -- you can call it a 16 proposal -- as to how to go about characterizing the design- -l 17 in tier'one. There is nothing in Part 52 that dictates that O 18-that course be followed or another course be followed. This p l 19 would be something that we would have to develop with the-l 20-staff. gog 21 MR. MICHELSON: What is wrong with-including the (, ! i:. [p ' 22 staff SER as tier one? i L' 23 MR. CARROLL: It doesn't exist yet, l 24 MR. MICHELSON: It does at that point. 25 MR. CARROLL:- It's an application. l l

90 a 1 1G1. MICHELSON: This an. application now, that's' j

l!

+ \\ 2 right.' l 3' MR. SIESS: Can-remember when a staff SER was 40 4 pages. S' MP.. MICHELSON: You have an.FDA, you-have to have 1 6 a staff SER.: .7 MR. SIESS: Carl, I guess I'm not sure what-you 8 are talking about:in'the SER. There are a lot of plants out 9 talere for which-the plant SER was about 40 pages. 10 MR. MICHELSON: We are talking about the SER which l t ' ll you have already looked at for BWR, at-least-for some of the 12 chapters. yx 4 13 MR. SIESS: I know, but a lot.of that is simply l 14 following the. standard review plan and agreeing it says i 15 this. p MR. MICHELSON:- But then it says but we-disagree-a 17-with this point, it must be done thus and so, and'that's put 18 into the staff SER. 7 1 19 MR. SIESS: You are only concerned about the l 20 disagreements. "q 21 MR. MICHELSON: Well, yes. I think the L22 descriptive material isn't particularly critical. 23 MR. SIESS: If you get down to'the supplement 18 24 there's no disagreement by then. 3 25 MR..ROWDEN: This is the way we visualize the r ,h

[y M! 91-J d .11 . process working. If the staff; takes that' position-in the l 'li J \\s-2 2 SERi we mend the SSAR. 3 MR. MICHELSON: If you mend the SSAR then it means-4 .that those agreements are okay'to change so long as you do 5 not introduce an unreviewed safety question in the process. 6 7 MR. SIESS: Which ought to be.the objective of-the ? 8 game, to have safety. I 9 MR. MICHELSON: It depends on your view. I am-not 10 surs that I share that view. 11 MR. KERR: If a thing doesn't involve a degree of 12' safety it has to be reviewed. If it involves only '(R 13, unreviewed safety -- j F 14 MR. MICHELSON: If you.want-to change something. 15' and it introduces an unreviewed -- i 16' MR. KERR: Unreviewed safety question, then it'has 17 to be~ reviewed. n u 18: MR. MICHELSON: Then-it has to be reviewed. 19 Otherwise it doesn't. m 20 MR. KERR: If it's not in that category it doesn't 21 need reviewing, does it? l 1 22 MR. CARROLL: It needs to be documented. la L 23 MR. MICHELSON: Only needs to be documented. I l' gg can make an awful lot of changes that do not introduce P ye != I j gg, .25 .unreviewed safety questions that might be very important [p 5 1' >

• 5 h

e

v 4 92 m l

=1-from the safety viewpoint.

2 MR. KERR: How can you introduce changes that have: L-3 , safety-implications and not have them fall into an r7 -: 4 : .unreviewed safety question?. Te yr -5 MR. MICK'4LGON: Because it says, and I will go b 6 back and re-read it. I think it says unreviewed' safety 7 questions as dincussed in Chapter 15-and so forth. In other B -words it says Chapter 15 classical accidents that they are .9 referring to. 10 MR. ROWDEN: It is unreviewed safety questions, 1 11-yes. It's'a generalized term. All we have done in that 12 regard is take 50.59. We have done it for several reasons, .v. M 13' not the lesst of which is that what Part 52 proscribes. ~I 14

think.a more fundamental reason is, that'is-a process that

- 15' everybody k1ows and is comfortable with. 16 ' 01. CARROLL: I made the' comment that'the staff 17 SER didn't exist at the time this application comes is; is f 18-that correct? I19 MR. ROWDEN: That's right. It wouldn't exist at .20 that til It would exist, presumably, at the time the FDA , j

• 21 is issued.

1G MR. MICHELSON: You have to have an FDA before you- ~2 3 - go in for certification. 24 MR. ROWDEN: We are not arguing about -- at least q 125-I am not arguing about whether it could be utilized 4 1}i im,l. N g

< m% .s '93 1 physically or.not. The question is, is it so structured as O 2. to make it the most appropriate document to utilize as tho' 3 basis for the tier.one design description. I don't know the 4 answer to that. 4 5' MR. MICHELSor, The question was, does it exist. 6 I think the answer is, yes, you didn't get an FDA without 7 it. 8 MR. ROWDEN: It will exist. 9 MR. MICHELSON: Yes, it will exist or we won't 10 have an FDA. 11 MR. ROWDEN: The process is-a.little more 12 complicated than that, because one has to also develop-thel lif '13 inspections test analysis and acceptance criteria. That is 14 a process ~which should get underway fairly early,. it's a 15 process which should be initiated by the design 16: certification applicant, and the normal document that it 17 would relate to would be the contents of its own SSAR or 18 . parts of its SSAR. 19 .If you wait until the SER is issued to develop the 20 ITAAC, I think it could be a complicating element in the .21 design certification process. I am not giving you a 22' definitive answer, I am-just saying that we haven't really 23 looked at the appropriateness of the SER for that purpose 24 nor, to my knowledge, has the staff. j 25 MR. MICHELSON: Of course, if the SER is totally I

94 1E refledted in'the'SSAR then in that sense you have a .g 2 documentation. In essence, youtare making the SSAR a part i 13 - of:the certification of tier one.. 4 MR. ROWDEN: Of tier one, that's right. 5 MR. MICHELSON. That's what you are trying to- ~ 6 avoid, because there are a lot of1 trivial changes that you (7 might want to make that might have been covered by the SSAR 8 but you don't want to go through 52.12 -- whatever that is'- 9 - change. I-think people can be fully sympathetic with that: 10 desire, but there has to be a reasonable definition of what 11 is-in tier one. The description included in 1.2'is pretty 12 minimal description. =( k 13' PGl. ROWDEN: I don't want to get bogged down for a 14 ery valid reason I believe, in the mechanics of. 15 . implementation. We are not frozen to the way we describe 16 the appropriate characterization of tier one. I mean, that 17 is something that I think lends itself to further 18 discussion. 150 What we do feel very strongly about, because it is 20 in Part 52 and is central to the implement ability of Part 21 52, is the capacity to differentiate between what is in the .22 . certified design -- whatever you call tier one -- and what 23 is in the-balance of the application, and to have a change .24 mechanism appropriate to each, taking into account th; 25-reality of the later COL licensing process and the l

h ) 95-1 construction. process. Those are the fundamental. fy fI t considerations. 3. MR. SIESS:- Mark, maybe you can answer this. 4; .Under the proposal tier two there are certain things that 5 you can only'get changed by amending the license and other l 6 things you do as a 50.50 non-review. L 7 KR. ROWDEN:

Right, i

8 MR. SIESS: Suppose I have a custom plant, and now 9 I have no tier one, tier two, I have a license. I have . 10 submitted an SAR-and I got back 18 volumes of SER. I now. want to change something. I want to change the layout of my ll 'f 12-control room, I.want to replace a diesel generator. Do I q. (- x_s/ ' 13 have to get a license amendment to do that? 1 l 14 MR. ROWDEN:- You have a combined license? -i 15' MR. SIESS: No. I have an ordinary custom plant, i 16 Diablo Canyon. 17. Sm. ROWDEN: The ordinary custom plant, Part 50 18. would apply. You can only use 50.59 under Part 50 if you 19 have an operating. license. -20 MR. SIESS: Okay, I have an operating license, my '21 plant is; built and operated but I want to change something 22 drastic. 23 MR. ROWDEN: You use 50.59. That process hasn't i 24' -been changed at all. 25 MR. MICHEIdON: But you can't change in a drastic

N l 96 -1 'way probably, without introducing an unreviewed safety _ uestion but you might. 2: q 3 MR.-SIESS: But if'it's an unreviewed safety 4 question, 50.'59 ---in that case, if it was up in what would 5. be tier one,'I would have to identify with a 50.59 as an 6 unreviewedLsafety question'and go back to tae Commission, i 7 MR. ROWDEN: If we are talking about a custom 8' plant, there is no tier one'and tier two.- l 9 MR. SIESS: I am talking about items that would be 10 covered in one of,these. I am trying to see how much easier

ll' it is for -- I am trying to figure out how much easier it is 12 for somebody with a certified plant to go in and make a

[ 13 . change which would reduce safety than it would be for 14' somebody'with a custom plant. 15 MR. ROWDEN: I don't know about reducing safety 16 since the criterion is the same. I will tell you' 17 procedurally,-it is much easier for the holder of an L 18 operating license under Part 50 to make a change that is l 19 covered by 50.59 than it is for someone -- this is really ] 20 anomalous for someone who has a Part 52 license to operate. 21 The-reason for that is this; under 52.97 (b) which I quoted I 22 before, any change -- any change from the provisions from i 23 the terms of license is considered aa amendment, and must 1 24 be preceded by a hearing opportunity. ( 25 Under Part 50, if you apply 50.59, changes that L L o

u z, ': .. ~ ; s gji, as 97 - i V y w qualify.under Part 50.59-do not need an amendment and even q/ 3;. }lL A i 2 if an amendment is' required, if you'can meet the no- 'f 3 significant hazards consideration test it doesn't have to be

4 preceded by a hearing.

W f5 So, really,.the Part 52 licensee is disadvantaged y aw MM .% '6-as far as 50.59 applicability is' concerned. Under our [ [s l7_ proposal the answer-would be it could be implemented an I '8' because, by definition, 50.59 does not require a hearing ,. e n.- r l: 9 under Part 52. i y 10 MR. MICHELSON: It's tier two material. 11 MR. ROWDEN: It's tier two, that's right. What I 1

12

-am saying is,_if it's tier one -- let's say it's the 4( 13-equivalent af tier one in a Part 50; license. The equivalent r 0

14 '

of tier one in a Part 50 license could be changed without a ' 15 prehearing if there are no significant hazards 16 considerations determination. i 17-It's a much more restrictive regime which we are 18 . accepting under Part 52. But we du say that we need 19 reasonable latitude to make the. sort of changes that one can - 20 foresee that_are going to be necessary during construction. 21 and which are not safety significant. 22 MR. SIESS: If the plant is safe as originally 23 . designed and certified it is not likely to get any more A 24 unsafe than a custom plant at the same level. hg 25 MR. ROk_.EN: That's right. The debate here..ever

" y; z t a-98 1 has really been around the safety significance of-50.59 O2 - changes. The debate has been around whether this somehow 3 compromises whatever standardization means. That is tha 4 issue. 5. MR. MICHELSON: It eliminates the look alike 6 possibilities.- 7 MR. ROWDEN: It has been characterized in that 8 way. 9 MR. SIESS: I think we are attributing more to 10 standardization than it deserves or could ever produce. 11 MR. WYLIE: Are there any other questions? ~ 12 (No response.] 13 MR. RASIN: Sorry, that's the end of the free 14 legal consultation. 15 MR.-CARROLL: Let the record show that it was 16-free. '17 [ Laughter.) 18 MR. MICHELSON: It was free, yes. 19 MR. RASIN: Let the record also show you probably 20 couldn't afford him. 21 As you see, these are some difficult questions and 22 we are still wrestling with them. We will proceed to put 23 our comments and position in writing, and I am sure you will .{ g_ 24 see those when we send them to th= Commission. We, too, lot 12 5 me say that we are proceeding with a serious purpose with

>Q k 99 >^ k .1 standardization. We are concerned with some of the It 2 discussion here that we think we are losing sight of the -3 purpose and attributing-far too.much importance to it, even 4 to the point of one-wonders if we are not'giving it more 5 -- importance at the moment than safety. That is of concern. 6-We will remind you that we have a number of other 7 activities underway. You are reviewing the EPRI t-8 requirements document. That document was put together by 9 the utilities as instructions to the vendors on how we 10 wanted the plants designed. In the embodiment of those 11 1 requirements is a whole lot of standardization saying this 12 in the way we want the system designed. We don't care if i 13 it's Westinghouse or New Combustionewho designs it, this is 14 the way we want it. 15 We want two pumps here, two heat exchangers here, 16 becaese.our experience tells us that in this particular 17 system that is the smart thing to do. 18 We have created a table'that says we want the 19 plant designed to this seismic capacity and that seismic 20 capacity will encompass 70, 75, 80 percent of the sites in-21-the U.S. We realized that for many sites that will mean 2:0 this plant is clearly over designed and we are willing to 23 pay for that so that we don't have a bunch of custom { ) 24 designed plants all the time. 25 When you get into the heat sink, we have to a k

w &~E ~ - - - - ~ - _ tla ~ O 100 w, A-gp ~ ' O' b jl: . certa niexten,-enve oped=the parameters again.to envelope a i t' l

• 2'

.large_ percentage of the sites in the country realizing that , a; 7 },

3 again will;tesult in some over design systems, but we are 4

willing to pay for that. We have gone we think'in that-ao [q, ' 5-regard, as far as you can. You can't take the envelope-so y i f 6 large that you begin to run with systems that are routinely as m 7 25: percent c.,f flow and 75 percent throttle, or you are not g snu L 8 going to have a very reliable plant r-nd probably not a_very h 9 safe plant. = u 10 So, there's a limit to which you can take that, ~ 11 and..I think that has to be recognized. 7 12 MR. MICHELSON: Let me ask, how'do the EPRI 13-requirement document requirements come into this process. 14 ~As I understand what I.have seen-of it, most of these would -m h 11 5' be-like tier two and end up in tier two' requirements. f} 16 MR. RASIN: That is probably correct. F-17 '- MR. MICHELSON: Therefore, there is no assurance m iN J 18 that these can't be changed as long as it doesn't introduce .19 .an unreviewed safety question. Although EPRI was right in [i(' 20 describing what ought to be requirements and industry was JM 3 21_ right, it doesn't mean that it will be carried out because s m 22 it will be a part of tier.two and it is subject to change on d 23 an individual utility basis. 24 MR. RASIN: That is correct, and that is the 25 question. As I said before, we need to communicate our need

> w 101 1D for flexibility and our intentions a little bit better so 2-that it_is understood that we are really not looking for the 3 certification so we can run away and then make the thing the 4-way we want it. I think if you look and thing hard even 5 about the 50.59 process, you are not going to be doing 6 things liXe changing _your mind about having three pumps here '7-instead of 7. will just have two. I don't think those'are 8' the kind' of changes you are going to see contemplated. 9 If you really go through the 50.59 process, it is 10 pretty hard to make'those large kind of changes and still 11 meet the criteria of no unreviewed safety questions or no 12 increase in the probability of existing accidents or no new 'l I-13 accident scenarios created. That locks you in pretty 14 tightly. 15 MR. CARROLL: Plus, every time that you do that 16 you have to documentLit. 17 MR. RASIN: You have to document it, and it is 18 subject to. periodic review. In fact, current companies in 19 their annual submittal of the FSAR updates point out all of 20 the changes made under the 50.59 process. The. staff reviews 21 those and can take exception to those that they may disagree 22 with,-and come back and either require to do something else 23 or review it and even give you a citation. 24-MR. MICHELSON: For these standard plants the ] 25 staff couldn't come back unless they disagreed with your w

' h5

• • T 102

-3 1 .1 evaluation of the.potentialifor an unreviewed safety k o O['/ / [\\- 2 question. Unless they can' challenge your view that this is

3 not an unreviewed safety question, there isn't a thing that' i

4 the staff can do about it, if I understand the process 3 5 correctly. L 6 MR. SIESS: The staff doesn't hesitate to do that 7 on occasion. 40# [ 8 MR. MICHELSON: No, but in this case they are 4 y 9 clearly by Part 52, prohibited from making those kind of -- 10 MR. KERR: They aren't prohibited from making a 11 judgment that something:is, indeed an unreviewed safety 12 question, are they? I f( 13 MR. MICHELSON: No. They can certainly audit,the 11 4 determinations and decide, but that doesn't mean anything 15 changes as a consequence of them saying we disagree-with 16 your view on this. 17 MR. KERR: It doesn't? i F 18 MR. MICHELSON: No. It all depends on'how '19 serious:it is. 20 MR. KERR: I got the impression that-NUMARC wants-21 plants that are almost standard. Standardization is not 22 like pregnancy, you can have a plant that is almost 23 standard. 24 MR. RASIN: That's interesting. I guess maybe if 25 you could define standard I could tell you if I agree we

" ' ~ ' - ~ " ' - ~ ' ' ' ' ' ,yp. y 1 xc 103 l-; want1almost standard. We have had a lot of discussion -- "O ' 1~ -MR.-KERR: Almost standard is a' plant that is, by

2 3

definition, standard but one plant can be different than the '4 otber. 5 MR.-RASIN: Okay. We have had a lot of talk here 6 today.; Iri all' these proposals we. are saying let's see to '7 what' degree of design: complete we cr.n go without specifying a 8 exact equipment. y 9 MR. KERR: EI'am'not against what you are --- il 10 MR. RASIN: There are all kind of differences of 11! equipment. - 12 MR. KERR: I am not against what you are proposing ? 13 necessarily, but:I' guess I thought for a long time that it-14-is'probably impossible to have standard plants. It sounds 15 to me'as if what you are proposing is -- standard is not 16 -identi' cal, that is a better term I guess. 17-MR. RASIN: Make it a regulatory comment, not 1 18 necessarily -- I think it was anticipated by some of the 19-remarks made. 20 MR. ROWDEN: Let me tell you what-the NUMARC 21 ~ position is. The NUMARC position is that we are going to 22 comply with the requirements of Part 52. That is what the 23 ITAAC report that you have in draft is designed to do. If 24 we comply with each and every one of those requirements we ( 25 will have met the standardization objectives of Part 52.

104 t,; 11 To be perfectly frank', and I have said it to other O 2 audiences, we are going beyond Part 52 now. -We are going 3 beyond, in my judgment, what Part 52 requires. When you 4-talk about restricting the ability to make changes which 5 Part 52 allows for tha uncertified part of the design,' when 6 you are talking about going beyond the level of detail which

7 Part 52 I believe fairly clearly proscribes for design 8

certification applications. I just want to remind everybody 9 because you were part of the process of commenting on Part l'O 52 when it was draft form, these are not new issues. 11 Part 52, as I have said elsewhere, isn't a roadmap 12 that gives detailed instr 1ctions for all aspects of this 13' process. With regard to level of detail and with regard to 14 appropriate flexibility, these were issues that were 15 -thraehed out between the Commission and its staff, between 16 the Commission and the industry, and~between the ACRS and 17-staff and the Commission. All we are saying, if you want to 18 know what the NUMARC position as I understand it and would 19 characterize it, we are prepared to comply with what Part 52 20. provides-in this regard. 21 MR. CARROLL: Another point of clarification. You 22 talk about design completion to the point that one can 23 prepare specifications -- is that true about the level of 24 detail of both tier one and two tier in your view? 25 MR. RASIN: Yes. That is correct.

105 1 MR. ROWDEN

It is the composite.

2 MR. MICHELSON:- Let me give you a hypothetical 3 example, and then you can tell me how y s think the prwf: 4 will work. So far.what I have seen of the ABWR for L5 instance, I have:not_seen drawings in which we have 6 allocated where cable trays might be, zones dedicated for 7 routing of cable trays. Eventually I expect that maybe_-- I-8 don't know -- maybe the SSAR will contain a drawing of that 9-level of detail. 10 There is a question of where are the cable trays, 11 -which divisions are in which areas and so forth, the same 12 question on small Lore-piping, particularly six inch and 13 other. That kind of detail is not in the SSAR and maybe it 14 will be, maybe it won't. Eventually I am sure-G.E. works 15 this detail out because they are going to build a plant. 16 Having worked the detail out and having it appear 17 on other drawings other than the ones in the SSAR -- in 18 other words, outside the licensing process completely -- as 19 long as that routing isn't defined and the SSAR looks like 20 if I were an individual utility and bought this plant and 21 decided I didn't want this six pipe where they put it and -22 want to move it to another location. I can move that to 23 another location since none of this was proscribed in the 24 SSAR anyway and the staff never evaluated it or whatever. 25 I do, I guess have to still determine that there )

... - - ~ i -106 1 is'an unreviewed safety question, but I am moving it.from. 7-. k,- 4 s 2 something the staff'never knew about -- one location-they 3 never knew about to another location they never knew about. l -4 How does'all this' work?;-Clearly this is what you are going i 5 to get into because I don't think the SSAR is going to ever 6 come in with that-level of detail in it, but G.E. can L 7-correct me if I am wrong. I haven't seen it yet. L 8 MR.'SIESS: Let me give you another scenario. 9 MR. MICHELSON: Let's get this one first, t R1'O MR. WYLIE: Let them pursue this one first. i 11 MR, SIESS: I would like for him to approach the l l 12 two together. y k ) 13 MR. MICHELSON: If you don't confuse the issue,-go-L 1 14 ahead. D 15-MR.:SIESS: I won't. I am going to have something l. 16 that the staff has reviewed. In spite of all their skill and. 17 wisdom they have missed something and it's been certified. 18, When you start to build it you decide that the pipe doesn't 19 belong in that room and you want to change it but the staff 20 has already reviewed it and certified it; what do you do l 21 now? 22 MR. MICHELSON: That's another case. The two are ii L 23 quite separate. The one case it was never looked at to 24 begin with because it was -- g l 25 MR. SIESS: The assumption is that if it had been L I ,!L

107

1 looked at-it would have been right.

2 MR. MICHELSON: Perhaps. 3 MR. SIESS: Not I've got it looked at and it was 4 wrong,,and I can't change,it. I-think they_are the same 6 5 thing. 6 MR. MICHELSON: I am just trying'to identify in my 7 case at least my question is, to what extent can you make 8 changes now to designs'that were certified but not certified 9 in-that kind of detail. Can you make such changes as that. 10 The vendor maybe General Electric in this case, 11 has indicated-the' routing of the pipe. Can a utility change 12 the routing'of that pipe? It is not a part of the licensing ( 13 process,.it-is not on_any drawings and not described 14 anywhere, not evaluated anywhere. I-am pretty sure it 15-won't be. 16 MR. WYLIE: Maybe'you ought to take that in two 17 questions. 18 MR. MICHELSON: What do you do now? That is my -19 question. 20 MR. WYLIE: Maybe you ought to take that in two '21 parts. What is the intent of the submittal, is it to map 22 out the piping routes within tolerances and cable tray 23 routes within tolerances as a pathway? '24 MR. SIESS: I am concerned about the point Carl is 25 making that for a certified plant the staff would have done l

.~ _ W PiY, i m j [h " 108 .] $N ' l j{ 1 a less complete review than'they do' for a custom plant.- C 2 RKR. MICHELSON: That is not.my point at all.. I li: 3 MR. SIESS: Nobody ever looked at it, the staff H 5E[, E I E .4 never looked at it --- q li) 5 MR. MICHELSON: Chat, I just presented a. 6 hypothetical question and wanted to get an idea of -- 7 MR. SIESS: But you said nobody has looked at it. ,.,l' 7' d' g s , r. 9 MR. MICHELSON:. No. I said it is not in the SSAR, 10 so they are-not aware of it. i 11. MR; SIESS: Whose not aware of it?- -12 MR. MICHELSON: The staff isn't aware of it. i l 13. MR. SIESS: They certified the plant without being q tw. .14 aware of;this detail. 15 MR. WYLIE: He's saying it wasn't there, i 16 MR. MICHELSON:' That's right. 17 MR. WYLIE: It wasn't' submitted. My-questionLis - L 18 l 19' MR. SIESS: I am saying that's less than -- 20 MR.'RASIN: I think that certainly depends on what 1' 21 system he is talking about. 22-MR. MICHELSON: This could be an RHR pipe of six 23 inch diameter. i e af"T 24 MR. RASIN: An RHR pipe, I guess I would be pretty i 'Q '25 surprised if it didn't show up on your -- l l' m

109 1 MR. MICHELSON: You might be' surprised -- ~_( 2 MR. RASIN: If staff hadn't looked at-it. 3-MR. WYLIE: That-is not exactly -- what has been 4 _done in the past is that the SAR and FSAR did not include a 5-lot of routes. But they were available by request from the 6 staff because at the SFAR stage they requested those things 7' andfthey got them,-because the design was developed. 8 MR. RASIN: If the routing was important. 9 MR. WYLIE: The question, what is going to be 10 submitted for the certified design. 11 MR. RASIN: I think if.you go back to the safety-12 point, if the exact location of that pipe that pipe _is l( 13' important in a safety determination then the-staff will ask 14 for that detail if it is not in the submittal and it will 115 become part of their decision making and part of the 16 application. 17= MR. WYLIE: Is that the intent to submit that with 18 the application? '19 MR. RASIN: Submit it what, up front? 20 MR. WYLIE: We will take -- cable tray routes -- -21 MR. RASIN: Let me ask Joe -- 22-MR. WYLIE: It sounds okay, but -- 23 MR. RASIN: Cort to speak to your -- 24 MR. MICHELSON: You might refer to your table one. 4 25 MR. RASIN: The SAR and the question of the -- i

N 110 ' 1T MR. KERR: May I-suggest that.the reporter has 2. difficulty recording more than three people talking at one -l ~3 time. It would.be very helpful to her if we could -- 4 MR. CORT: Let me respond this way. Mr. Michelson '5. made a statement that he believed that the cable conduit and 6 small bore piping details were beyond the level provided in 7, '7-the ABWR. I would like to confirm that, 'tha't is true.- 8 Further, he'gave an example that if you were to take a.small 9 bore piping and perhaps move it, because that was not in the-10 tier one certified design nor for that matter.in tier two ti 11 SSAR information the provisions of 50.59 don't apply nor the 12 hearing provisions of 52 and he could make this change f 13 w'ithout having to tell the regulatory person. 14 .I would say that-he could, of course, provided he 15-didn't change anything in his design that had been approved 1 16 by the staff. Let me.give you an example. In our submittal o 17. on ABWR, we have provided a fire hazards analysis. This 18 fire hazards. analysis takes the reactor building including

19 '

the containment and everything in it and the support 20 components outside containment in the reactor building and ,g 21 everything in those compartments, f 22 He goes floor by floor and identifies everything. X 23 Some 3,000 components that are located in various ,QO ' 24 compartments, and for these components they identified what 25 compartment they are in, what floor and what -- virtually q

4 h 111 1 1-that amountfof;information. We also know, based on our- ) f' 2-detailed design, how tho' electrical-leads.will be coming 3 -into that room and how the divisions will be handled within l 4 the room. 5 Therefore, we can assess fully involved fire in .i 6 one division what might it threaten in other divisions, and .{ 7 what is the impact on that equipment. We go through all t 8 that evaluation.and we submit it to the NRC. In this L 9 example you had where.someone decided we want to-relocate 10 this element and this component, and if it has been 11' specified because of the threat to fireEto be retained in a 12 certain compartment on the other side of a.three hour O h,f 13 barrier and1to move it would put it in another zone, he 14 couldn't do that. I: hope that helps some. 15 MR. MICHELSON: Yes, I think that takes' care of 16 it. Of course, that fire analysis didn't give all the 17 detail loading of every cable tray. 18 MR. KERR: I wonder why he used fire as an i 19 example. 20 MR. - ' CARROLL: I shuttered when he said it. 21-MR. MICHELSON: I think I got the snswer to my 22-question then. The answer is yes, indeed, such changes can 23 be made if they were never describea in the SAR and not [ covered by the certification in any way, you can go non-24 25 standard that way by moving things around.

i 112 1 11 MR..SIESS: And less safe. 7s 2 MR. MICHELSON: 'I don't know whether.it is less 1 3 safe =or not. It may be equally safe. I don't know..It is-l- H 4 just non-standard. 5 MR. SIESS: .I guess I'm having the same problem 6 that I have had all along, getting some relationship if any 7 between standardization and safety. 8 MR. KERR Let me suggest that we ought to adopt 9-another name. I think what we are seeing is that. standard 10 plants do not have to identical. They can be standard by; L' 11 definition if you follow Part 52. That doesn't mean that '12 they are identical. 13' MR. SIESS: Even if you wanted them to be they-14 couldn't be identical. The concrete in the structures Y 15 aren't going to come out the same anyway, even if they were \\ h 16 poured the same week. Itidepends on how far you want to r il 17 take it. o O 18 MR. MINNICK: Could I shift the gears a little h. lB 19' bit? I was beginning to understand it I thought, until we i made the blanket statement we are meeting 50.52 -- whatever. 20 21 22 Yet, we are here I think, trying to figure out l 23 what the really says in terms of the extent of the known and j/') 24 defined design. An easy way to put it is a one, two, three, r 25 four category. Aren't we trying to settle where in that l

113' j -I spectrum we are going to and up? Until we know that,.we ) .! '): k-2 don't re' ally know what the' regulation is. Isn'tDthat our 3 question,.and'if.that-is a question, how does that relate to 4 tier one'and tier.two? 5 A final question -- you might as well answer it at 6 the same time'-- what does it take -- what are you asking 7 --the~ Commission to do if, by any' freak of' fate, they thought 8 tier one and two tier was a.iegitimate and: proper approach; 9 what does it take to implement your proposal? 10 MR. RASIN: I think in terms of the first question 4 11 our statement that it is our position we intend to meet Part ~ .12 52',-is a clear statement. We want to do what is necessary. ] (( ) 13 Now, you come to the point of clearly what we are.all here j L 14-is about is because we do'not-have a common understanding of-3 l L 15-Part 52, the staff'apparently -- since they have asked the-16 Commissioners for guidance -- they do not feel that they l 4 17-understand completely the Commissioners intent. -18 We are here asking for that guidance of okay, here 1.- L 19. is how we are proceeding and here.is how we think Part 52 L20 should be implemented and what it means. We are asking the l 21 Commission for that guidance. 22 MR. MINNICK: Can you relate it to their cases .23 one, two, three and four? i (~' 24 MR. RASIN: No. 25 MR. MINNICK: Is there any relationship? i

.g.r. ^ 114 j.. 1 MR. RASIN: Remember, we said the staff ys \\. 2 characterized it as one, two, three four as four points on a 3 spectrum,.and they thought that they were illustrative of j four levels of de'all with some relation to the licensing 4 c 5 process -- 6 MR. SIESS: If you want to relate tier one and i 7 tier two to one, two, three and four, I think you can do it ~ 8 with table one in the SECY where the staff has a matrix of 9 the HVAC system, the one, two, three, four and varions 10 levels. If you simply consider C as certification and F cs 11 flexible, that is the difference between tier one and tier 12 two I believe. k 13 MR. RASIN: Perhaps. 14 MR. SIESS: Are you familiar with that table? 15 MR. RASIN: Yes. As I stated earlier,.I think one 16 of the things that I felt that came to us and fra.s the 17 Commissioners discussions, I believe that everyktdy realizes 18 that the table with the one, two, three and four is a little 19 bit too simplistic an approach. 20 MR. GIESS: Anything is going to -- 21 MR. RASIN: And that we can't do -- just pick one 22 of those levels with that table as an example and that, that i 23 answers all the questions. In fact, we don't propose doing 24 that. We propose to -- 4 25 MR. SIESS: That table -- .)

115 1 MR. RASIN: Find what level of detail 13 required p,. 2 to meet Part $2. I 3 MR. SIESS: If I looked at the HVAC system and ] 4 there's 11 pieces -- vertically 11 numbers with some 5 subdivisions -- somewhero, I ought to be able to draw a 6 horizontal line thet represents the NUMARC proposal for tier 7 one, tier two separation shouldn't I? 8 MR. RASIN: Certainly. Certainly, that can be -- 9 MR. SIESSt The staff has four different places 10 they have drawn the line. If I draw the line between C and F 11 and NUMARC may not put it in any of those places, isn't that 12 one way of definirig tier one and tier two? i) fg 13 MR. RASIN: Sure. One could do that. It's 14 intaresting in the approach the staff took there as I 15 recall, tier one kind of got bigger and bioger as you got 16 more detail, seemingly just because you had more detail 17 which we are not sure that -- 18 MR. SIESS: Tier one has everything except as 19 procured component performance data as being certified. 20 That would all be in tier one. 21 MR. RASIN: In the level one category you are ( 22 talking about, right. 23 MR, SIESS: Yes. 24 MR. RASIN: We would not propose that the 25 Commission can go to the point of giving guidance of drawing

4 116 1 us charts like that and drawing lines. I don't think that 2 that is really going to be practical. I believe that is 3 really going to have to come down to the staff implementing i 4 some guidance that is given the sense of the commission and 5 then the industry and staff really working together to see 6 what is acceptab1w. 7 A case-by-case might sound bad about it in the 8 Part 50 sense, bkt a cese-by-case here is only a few 9 applications. t 10 MR. SIESS: Yes, but you want to be consistent, 11 don't you? s I 12 MR. RASIN: You want to have some -- 13 MR. SIESS: You want to have some principle so 14 that what you do for Westinghouse and what you do for G.E. 15 is at least comparable, both in safety and level of 16 standardization. 17 MR. RASIN: I would hope that the staff would 18 apply the guidance with some degree of -- 19 MR. SIESS: We have to have some sort of one 20 sentence or one paragraph statement as to what belongs in 21 tier one and another one for what belongs in tier two. 22 MR. RASIN: Kind of that statement, yes. We would 23 foresee that kind of statement, not a bunch of charts and [ } 24 graphs that showed you that. We would hope that they would 25 be consistent. Again, remember what we are doing is to

= l 117 .l 1 implement Part 52. We are not looking just to get through 2 the process of the evolutionary plants or the passive plants j 3 or whatever. 4 It ' a quite conceivable that for different designs 5 that 1cvel onc : a level two line may very well change just 6 a little bl., and that would be necessary for the staff to 7-make a safety finding that they were comfortable with. 1 8 MR. MICHELSON: What the staff has done here in 9 SECY 241, there are really two considerations. One is the 10 amount of detail and that is level one through four, and 11 then there's a question of the two tier approach which-12 applies equally to one, two, three and four, and it's just a (p) 13 matter of what the mix will be perhaps. Any one of those ( 14 could have any combination mix of tier one, tier two that 15 one might elect. 16 From your viewpoint, do you have a problem with 17 the amount of-detail asked for in level one? 18 MR. RASIN: For certification. 19 MR. MICHELSON: For certification. I am not going 20 to say which is in tier one or tier two. l l 21 MR. RASIN: Absolutely. 1. 22 MR. MICHELSON: Assumies that you can divide it up 23 the way you would like, do you have a problem with the 24 amount of detail proscribed for option one? 25 MR. RASIN: Absolutely, and we stated that the 1 .s

i 118 .1 last time I was horn before you, and we stated that before 7._ (fk -) 2 the Commission. Wo do not think that level one it nossible 3 or attainable without an order that gets down to tpecifying 4 the exact components that are going to be used in the plant. 5 6 MR. MICHELSON: Because of the econom!.cs of it? 7 MR. RASIN: If that is required it will never 8 happen, because it will not be in order ever put forward for 9 10 MR. MICHELSON: The argument is that it's the 11 economics of the situation? 12 MR. RASIN: Economics, clearly -- 16 ) 13 MR. MICHELSON: Practically, I think you -- 14 MR. RASIN: --is a big part in it. 15 MR. MICHELSON: Practically you can do this, but i 16 you don't sincerely believe that it is not possible given-17 the adequate amount of money that you can't design these 18 plants. 19 MR. RASIN: There are other considerations. It is f 20 not just a matter of money. 21 MR. CATTON: It probably says that they are 22 identical physically in level one, and that means that is 23 the same vendor. 24 MR. MICHELSCN: Yes. 25 MR. CATTON: For everybody, forever.

119 1 MR. ROWDEN This is a consideration that the 2 Commission was very sensitive to several years ago. We 3 still think it is a relative consideration, and even if the 4 Commission from a legal standpoint isn't sensitive to it, 5 certainly the utilities aren't. 6 MR. MICHELSON: Let me ask then, another item 7 under level one is the geometric aspects of suspended 8 components. If you don't know the geometric aspects of your 9 suspended compotients, how do you do your external hazards 10 analysis, things of this sort, the effects of pipe break, 11 the effects of fire and so forth. G.E. just explained that 12 they have done it and, indeed, they have that level of 13 detail in their fire analysis, l 14 It isn't required as a part of level two for l 15 instance, but it is required as a part of level one. I 16 wonder how can you make safety determinations of that sort 1~ even on the part of the staff if they don't know the 18 physical relationships of the components, if they don't know 19 where the cable trays are, if they don't know where the 20 small bore piping is and so forth? 21 MR. RASIN: Again, I think there is a level of 22 detail there that you are talking about. If you are talking 23 about the location and the relative location and where this l 24 piping run is versus where that cable tray is, is one thing. 25 The orientation of every valve or damper is going --

G L 7 120 i 1. 1 MR. MICHELSON: I am talking about just the first U,,_;\\ i '\\~s( 2 part. l 3 MR. RASIN: That orientation thut you need to do - i 4 i 5 MR. MICHELSON: Just the first part. Where the 6 cable trays are and where the pipes are. That is not in the ] 7 SSAR. i 8 MR. RASIN: To the extent that that is important l 9 in making a safety determination, the staff would ask for l 10 it. And, it will be placed and accomplished in this level l 11 of detail based on certain limitations. Obviously, you have 12 to meet the requirements of your fire analysis, you have to (( ) 13 meet your seismic analysis, you can't have a non-safety 14 system impact to safety system. There are all kind of 15 rr.strictions. It is not just that you are free to go put J 16 " hat anywhere you want. 17 MR. WYLIF: What you visualize is that.anything 1 18 the staff needs to perform its safety analysis, they will 19 have to ask for it if it's not in the submittal. 20 MR. RASIN: If it's not submitted they ask for it. 21 22 MR. WYLIE: As part of the application. 23 MR. MICHELSON: They are not in any way prevented ps 24 from getting that information. You are not going to claim mu a l 25 that is beyond the scope of what was agreed to, because it d r , -, +

j I 121 1 is clearly beyond the scope of item two for instance. 1 If) \\-< 2 MR. RASIN: Wait a minute. I am not bure that we 3 won't ever make that claim during the course of the 4 proceedings. The fact is that the staff is the holder of j S the determination. 6 MR. ROWDEN: In the course of all of these 7 discussions the one issue suggested that is not adequate to i 8 discharge the safety review functions -- 9 MR. MICHELSON: You said level three though. 10 MR. ROWDEN: Yes, level three. 11 MR. MICHELSON: Okay, but that's not in level 12 three. It is not a requirement. A 13 MR. ROWDEN: Then it would have to be supplemented-E k,) 14 to a level -- to a scope or level which would allow the ~ 15 staff to make a safety determination. 16 MR. MICHELSON: You are saying that if I look at 17 table one here and I see where these ends are which mean not 18 expected in application, it really is saying not expected 19 unless the staff thinks they need it. 20 MR. ROWDEN: That's right. 21 MR. MICHELSON: That is a little dj'ferent 22 insight. 23 MR. ROWDEN: My understarding is that the 24 conclusion that the staff states in 92.41 is that level (~ 25 three, even though in many respects we are going to go

p 122 1 beyond level three, level three should be adequate in terms ( 2 of safety review functions. I don't see any dissent in 3 that. l 4 MR. WYLIE: In the past what has happened at the 5 FSAR stage, the staff ask for information that was not 6 submitted in the application and the applicant submitted it. 7 8 MR. RASIN: That's right. 9 MR. WYLIE: Hundreds of drawings. 10 MR. RASIN: That is what would happen now. 11 MR. WYLIE: You visualize that they will have to 12 do the same thing here. 13 MR. RASIN: Surely. There is always a round of 14 questions, and you always have to respond to the questions. 15 One other thing -- 16 MR. WYLIE: In defining level of design detail you 17 are really not defining everything that is needed for the 18 staff to do their analysis. 19 MR. RASIN: We think that the discussion we are 20 talking about here is going beyond what the staff needs to 21-do their analysis. 22 MR. WYLIE: If you don't submit cable tray routing 23 and small bore piping, it doesn't. 24 MR. SIESS: Until they get a certification they 25 are going to do whatever the staff tells them.

123 1 1. MR. ROWDEN: Let's do justice to the regulations. U 2 The regulations -- 1 3 MR. SIESS: There's nothing in tnere that's going 4 to say you don't have to -- 5 MR. ROWDEN: The regulations -- ) 6 MR. KERR Gentlemen, the reporter is having great 7 difficulty recording all these important statements. Mr. 8 Rowden, you hwe to use a microphone. 9 MR, ROWDEN: I think we also ought to recognize 10 that they are fully adequate to deal with the sorts of 11 questions that have been raised. Number one, it is 12 specifically provided that if the staff so requests and the 0 13 'information that you have to submit will be sufficient to 14 prepare for audit, the procurement installation and 15 construction specifications. Further, there is a catchall 1 l 16 provision in Part 52 as you would normally expect, if the 17 staff needs any further information to make its safety 18 determinations, it has to be provided. 19 I think the regulations are fully adequate in that 20 regard. l l: 21 MR. WYLIE: Are there any other questions? 22 MR. CARROLL: You indicate Bill, that one of the 23 things you are going to be doing is assessing the cost

/"]

24 estimates for this essentially complete design given in the V 25 SECY paper. I am interested if you have any reaction to the

124 1 thoughts I earlier expressed about perhaps the level of ( 2 design and construction Q/A could be substantially less than 3 we saw in the last plants that were designed and constructed 4 based on some of the staff initiatives. 5 MR. RASIN: In terms cf the construction, clearly 6 we said -- that is in response to a direct question from the 7 Commissioners, do you have any comments on the cost numbers 8 in 241. We will give a response to that. 9 Your point on the Q/A activities and the 10 construction activities, clearly we believe this process is 11 going to bu a big improvement over the last one, if you will 12 bu starting out construction with a much higher degree of i( 13 detail. You will be subject to very few design and 14 construction changes as you go through the process. It has 15 clearly got to be better. 16 In fact, this is where the big part of the 17 investment savings will be, is during the construction 18 period of this plant. 19 MR. SIESS: Jay, I don't think he has seen Chapter 20 17. 21 MR. CARROLL: Have you read it? 22 MR. SIES9: It hasn't been released, I'm pretty 23 sure. 24 MR. CARROLL: It hasn't been released. 25 MR. SIESS: You haven't seen the proposed revision i

125 1 to Chapter 17 of the standard review plan? ,_s i' \\' - kl 2 MR. RASIN: No, I have not had the good fortune to 3 have seen that yet. l l 4 MR. SIESS: I didn't think so. I would be 5 surprised if you did. j 6 MR. RASIN: Would I be pleasantly surprised or 7 should we give up? 8 MR. SIESS: I think you would. 9 MR. CARROLL: I think you would be pleasantly l 10 surprised. I think that, if I remember right, the billion 11 dollars to do design may be a gross over estimation of it. 12 MR. RASIN: I believe when the billion dollar r li 13 number was thrown out, that was touted as coming from some 14 New England utility that had completed a plant sometime in 15 the recont past under this process, and that seemed to be 16 all of the engineering expended up to the point of getting a 17 license and all the questions and hoops you jump through and i 18 what not. Clearly, there ought to be a savings from that 19 process, yes. 20 MR. WYLIE: Are there other questions? 21 (No response.) 22 MR. WYLIE: Thank you, Bill. We have two hours t 23 tomorrow at 8:45 to 10:45, and we have presentations I p believe by staff and NUMARC and more questions and 24 25 discussion. I guess we will wait for discussion at that

i 126 1 neeting to decide what the Committee will propose to do. N_- 2 MR. SIESS: I guess it would help if somewhere the 3 guidance that the staff has sought from the Commission and 4 that we will give the Commission advice on, is this two 5 tiered or it is -- 6 MR. WYLIE: Martin, do you think you could do 1 7 that? 8 MR. VIRGILIO: Yes. MR. SIESS: Maximize standardization, minimize 9 l 10 standardization -- 11 MR., WYLIE: I think they tried to do that a while 12

ago, i

' k,-. 13 MR. SIESS: I mean for the Full Committee. The 14 issue is on the floor for the Full Committee. 15 MR. NYLIE: Okay, sure. 16 MR. SIESS: So that te don't spend two hours 17 trying to find out what the issues are. i 18 MR. VIRGILIO: I think the issues are pretty 19 simple, if I may. It is one, what is the level of detail 20 that the Commission would like us to seek in. defining an 21 essentially complete design. 22 MR. SIESS: That is one through four. 23 MR. VIRGILIO: By methodology, I guess I am not '( 24: asking them to pick one of four options. What we are ( 25 looking for is the methodology. Each one of those four

L 127 -1 options had a acthodology, and that is discussed in the j_3 kj 2 n0rrative section of tnw Commission paper. If any one of 3 those methodologies were to be adopted or another 4 methodology were to be proposed that the staff follow by the 5 Commission, that is the guidance we are seeking. 6 With regard to the two-tiered approach, we asked 7 the Commission specifically if they accepted the proposal of 8 a two tier approach and if they had any guidance for the 9 staff with regard to a methodology for what would be 10 included in tier one, what would be included in tier two, 11 and what would be the test to control the changes that would 12 be included in tier two. k ) 13 MR. SIESS: I have two questions. What is the 14 alternative to a two-tiered approach? 15 MR. VIRGILIO: One alternative might be to certify 1 16 all the material you need to control standardization to the L 17 level that the Commission feels appropriate and allow 50.59 l 18 or whatever to control the rest. 19 MR. SIESS: That is different from the two-tiered? 20 MR..VIRGILIO: Sure. That is a different 9 21 approach. You wouldn't need any second tier if you 22 certified everything, and that is really what we showed in - 23 i 24 MR. SIESS: Certify everything except what you are 25 willing to leave to 50.59 you say? i -..w- ....,r.. 4%w+.-

I 128 1 MR. VIRGILIO: Or some other process. Maybe there L- 2 changes that fall outside the 50.59. 3 MR. SIESS: Isn't that what -- what is the two-j 4 tier. How is that differ from the two tier. 5 MR. VIRGILIO: You can have expressly identified l 6 certain items that could be changed pursuant to a test that 7 would be part of the staff reviewed and approved as part of 8 the Part 52 licensing process. 9 MR. SIESS: I am sorry, I got lost in the syntax.. 10 11 MR. VIRGILIO: I would go back -- -l 12 KR. SIESS: What is the difference between the two I '13 cases? 14 MR. VIRGILIO: Let's go back to talking about a 15 formatting approach to all the information in-the i 16' application. You can format the application into two parts. 17 Part one would be tier one and part two would be tier two. L 18 You could P7ve a substantial amount of information in tier L 19 one or a very little amount of information in tier one. You 20 can have so much information in tier one -- 21 MR. SIESS: That's only a question of what goes l' I 22-where. t 23 MR. VIRGILIO: I know. You can have so much l [/l 24 information in tier one that you don't care about tier two %). 25 or how it is controlled. It can be controlled pursuant to l I w ,,,v r-,,, -,,,,.

f 129 1 50.59 or it can be outside the realm of 50,59. 2 MR. SIESS: I guess -- 3 MR. VIRGILIO: Remember, 50.59 is what is in the 4 SSAR. 5 MR. SIESS: When you ask the question do you 6 approve of the use of a two tier approach, you really mean 7 do you approve the use of this particular two tier approach 8 which is defined somewhere, because you keep talking about 9 two tiers and as to what goes in them. I said, what is the 10 alternative to the two tier approach. What is the issue? 11 MR. VIRGILIO: Do they -- 12 MR. SIESS: One tier versus two tier, or what goes 13 in it? 14 MR. VIRGILIO: What the final issue is going to be 15 is both what goes in it will drive whether you really do 16 need two tiers, and you need to worry about controlling the 17 second tier in order to ensure standardization. 18 MR. SIESS: Am I the only one that doesn't 19 understand this? If I am, I will defer to my wisdom of my 20 colleagues. 21 MR. KERRt I will join you. It sounds to me like 22 there are two categories of things, one of which does not 23 affect safety and one of which does, and I don't know 24 whether you can have some of the ones that affect safety in 25 the second tier or whether everything in the second tier is

130 l 1 irrelevant to safety. To me, that is still not clear. O2 MR. SIESS: I think I understand two tiers. What 3 I can't understand is not two tiers. I was given a choice, 4 two tier or something that isn't two tier, which I would say 5 is one tier. If I have one tier, I don't know what I put in 6 it, everything or nothing. 7 MR. VIRGILIO: That's right, everything. 8 MR. MICHELSON: Everything. 9 MR. KERR I thought you said everything -- 10 MR. SIESS: He didn't say everything. 31 MR. WYLIE: Everything relative to safety. 12 MR SIESS: Those things that are not relevant to 13 safety are the 50.59 things is what we were putting in tier 14 two. 15 MR. VIRGILIO: If you go back to level one as we 16 described it in the paper, we have included essentially the 17 entire application in tier one. 18 MR. KERR: Wait a minute. The entire application 19 doesn't necessarily mean everything that is in the plant. 20 MR. VIRGILIO: That's right. 21 MR. KERR: The things that are not in the 22 application but are in the plant form a second tier. 23 MR. MICHELDON: If is an essentially complete 24 design it's going to be almost everything. 25 MR. SIESS: Look, we are confusing two things. I

l 131 -{ 1 am confused. How complete the design is, is one issue. It -2 could be complete right down to the last nut and bolt, but 3 that doesn't all have to go in this one tier. The staff 4 could review every single thing about that plant and have a 5 complete set of blueprints filling up that end of the roon j 6 with the whole cockeyed room, but that still doesn't mean 7 the license has to cover it all. 8 How much the detail the staff wante in order to 9 say this plant -- this design can be certified and how the 10 certification is written seems to me ar. two different 4 11 things. If they are not, maybe I need straightening out 12 again. ) 13 I MR. VIRGILIO: I think you understand it. 14 (Laughter.) 15' MR. VIRGILIO: I think you do. You may not think i 16 you do, but you just said it. How much information is 17 included in thn applicstion is one question, and then how 18 much information you certify is a second question. c 19 MR. SIESS: That's two tier. Is there any 20 alternative to it? You have asked the Commission whether 21 they agree to the two tier approach, and I can't see that 22 there's any alternative to it. 23 MR. VIRGILIO: You are saying that there is no 24 alternative to certifying the entire application? g 25 MR SIESS: I am saying there's no alternative to

132 1 using two tiers. 2 MR. MICHELSON: Sure, one tier. 3-MR. SIESS: One tier, which would certify 4 everything. 5 MR. MICHELSON: Right. 6 MR. SIESS: That's ridiculous. 7 MR. MICHELSON: That's the alternative. 8 MR. SIESSr Even the Commissioners know that is 9 ridiculous without us telling them. 10 MR.'MICHELSON: That is the alternative, so you 11 have to be logical and reasonable, and you try to divide it '12 vp. { ) 13 MR. KERR: That's one thing that we can put in our 14 letter about which we are in general agreement, that there 15 has to be at least two tiers. 16 MR. MICHELSON: Yes. 17 MR. KERR: That's progress. 18 MR. SIESS: I don't know if you want to put in my 19 comment about even the Commissioners -- 20 MR. CARROLL: I guess Charlie, I question we can 21 even write a letter until we hear more from the staff on 22 where they are really going or what the results of what they 23 are current looking at are -- 24 MR. WYLIE: We could write a letter to the 25 Commission saying if you guys think you are confused, we

i 133 i 1 will join you. p_- t i' 2 (Laughter.) 3 MR. SIESS: It seems to me that nobody is going to 4 be able to write anything' definitive at this time. The best 5 advice we could give the commission is look, this looks like 6 it's going to work, get on with it. Do one, and then you l 7 will know whether it works or not and how it works. Get 8 together and get a case going, and don't sit back and argue 9 about the words for the next two years. You can argue about 10 the details 11' you want. 11-MR. MICHELSON: On that particular point then

=

12 Chet, why are we even worrying about the certification k) 13 process? Why aren't we just worrying about the design -- l l l 14 the amount of detail to be put in the application? In other 15 words, the amount of detail we should be -- 16 MR. SIESS: I am not worrying about the 17 certification process. The certification process is 18 primarily a legal issue. It is primarily done in order to 19 provide the one-stop licensing and so forth, it's a_ good way 20 to go about your business, and I am not sure it has anything P 21 to do with safety. 22 MR. MICHELSON: Yes. 23 MR. SIESS: In spite of -- I am interested in y feasibility, and I guess if it's purely feasibility I would r~ 24 25 say nobody is ever going to build one of these things. I am -e -n m g v -r w*- - ----* m

1 134 1 interested in safety. If we can get it, the industry will l V(, 'l 2 decide whether it is economic or feasible. 3 MR. MICHELSON: The reason I am a little 4 interested in the certification process is, I think it's 5 i;portant for the reviewer to know how the information is 6 going to be handled and viewed later, how much of this will 7 become subject to Part 52 requirements and how much will 8 become subject'to Part 50, some idea of the approach that is 1 9 going to be used down the line. l 10 I think it affects how he reviews the material in i 11 front of him and how he writes his SER. To that extent, I t i 12 would like him to know what is going to be this two tier 13 approach. 14 MR. SIESS: You can certainly work something out 15 that wouldn't be that much different from what is in there i 16 now. The things that are really important you don't touch. 17 .The other things you do are 50.59. NRC can't review every 18 change, they have to assume that the people out there are 19 operating the plants are reasonably concerned about safety 20 and reasonable competence. 21 I think we can end up w .h something that is in 22 about the same ballpark as regards the future. I want to be L 23 sure that the standard plant to begin with isn't going to be l l jf '$ e 24 less safe than what we have been getting. I think we have V 25 reasonable way of assuring that with time it won't u ~ .. ~

135 1 deteriorate more rapidly than the existing plants have under 1 2 the review process. I think that's where I would look for 3 it. 4 MR. KERR It may well become cbsolete. That is 5 part of the process that bothers me. It may become 6 obsolete. 7 MR. MICHELSON: There's another standard coming 8 down the road then-if it's obsolete. 9 MR. SIESS: This is what really bothers me. If I 10 look at what the French have done whsce they standardize on 11 a design and use it for a certain number of years, 12 accumulate the changes they want to make, don't make them to k ) 13 that design -- but when you think they have enough to really 14 be an improvement in either safety or liability, then they 15 change ano come up with a new design. 16 I don't ces that process here, because I have no 17 feel for how much it is going to cost to make'that new 18 design and get it certified. If you sold ten plants on the 19 1991 design,.how long would you have to go down the line 20 before you could start making improvements and can afford to 21 go to the next one. That is not a safety issue. Let's face 22 it Jill, if it's serious enough in obsolescence, you will do 23 something about it and always have. 2 '. MR. KERR:

Chet, 25 MR. SIESS:

Look at the Russianc. Chernobyl had a

136 1 lousy design. They standardized it, so they are going to 2 shut them all down now. 3 MR. KEkR: I am personally convinced that we would 4 have better, more efficient and more reliable -- maybe not 5 safer -- reactors if some facets of the licensing process '6 weren't so difficult. The licensing process makes it 7 extremely helpful to use something that has previously been 8 licensed. 9 MR. SIESS: One of the big advantages of 10 standardization is going to be that you have the design 90 11 percent complete before you start building a plant. That is 12 going to lead to more economies than any multiplication of ( 13 how many pumps you buy at one time and fewer errors 14 probably. 15 MR. WYLIE: Are there any other comments? 16 (No response.) 17 MR. WYLIE: I would like to thar.k the staff and l 18 NUMARC for their participation today, and we will look 19 forward to meeting with the Full Committee tomorrow. 20 (Whereupon, at 5:00 p.m., the meeting concluded.) 21 22 23 24 . ( 25 l l:l'

( REPORTER'S CERTIFICATE This is to certify that the attached proceed-ings before the United States Nuclear Regulatory Commission in the matter of: NAME OF PROCEEDING: Improved IMRs Subcommittee Meeting DOCKET NUMBER: PLACE OF PROCEEDING: Bethesda, Maryland vers-held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court report-ing company, and that the transcript is a true and accurate record of the foregoing proceedings. Official Reporter Ann Riley & Associates, Ltd. 1----- u-,. ___e_

o O

Oj) NRR STAFF PRESENTATION TO THE ACRS ) 10CFR PART 52.47 COMPLETENESS OF DESIGN AUGUST 8, 1990 MARTIN VIRGILIO, BRANCH CHIEF POLICY DEVELOPMENT & TECHNICAL SUPPORT, 301-492-1257 GENE IMBRO, SECTION CHIEF SPECIAL INSPECTIONS BRANCH. 301-492-0954 REBECCA NEASE, TECHNICAL ASSISTANT. POLICY DEVELOPME:JT & TECHNICAL SUPPORT, 301-492-1281 SUBCOMMITTEE ON IMPROVED LIGHT WATER REACTORS

0; O o DESIGN CERTIFICATION 1 SECY-90-241 ONGOING ACTIVITIES MAXIMlZE STANDARDIZATION AND PRESERVE FEASIBILITY APPROPRIATE DEGREE OF FLEXIBILITY

O O O LEVEL OF DESIGN DETAIL u OBJECTIVES i I

• DEFINE A' LEVEL OF DESIGN DETAIL FOR 10 CFR 52 l

DESIGN CERTIFICATION THAT WILL - MAXIMIZE STANDARDIZATION - BE ACHIEVABLE WITHOUT VENDOR SPECIFIC j DATA FOR COMPONENTS IN TRADITIONAL A/E SCOPE j-I = PUMPS j = VALVES l l = HEAT EXCHANGERS I l = ETC. I j

• ESTIMATE THE ENGINEERING EFFORT REQUIRED TO DEVELOP l

THE DEFINED LEVEL OF DETAIL DESIGN CERTIFICATION 2 j i I 4

- g g g LEVEL OF DESIGN DETAIL APPROACH = I i

• DESCRIBE THE DESIGN PROCESS FOR PLANTS i

LICENSED UNDER PART 50 AND PART 52 l

• DEFINE THE ENGINEERING PRODUCTS WHICH MUST BE COMPLETED AT THE TIME -OF-DESIGN CERTIFICATION i

j - THE DEGREE OF. DESIGN DETAIL COMPLETED WILL VARY j DEPENDING ON = BUILDING l = SYSTEM l = COMPONENT I l \\ i j l 4 l DESIGN CERTIFICATION 3 i i l ) 1

g

= 3

Q -

DESIGN ~ CERTIFICATION 4 PART 52 IMPLIES THREE BODIES OF DESIGN IN FORM ATION. ~ RULEMAKING SUBMITTED IN-~ THE APPLICATION AND CERTIFIED BY o SUBMITTED IN THE APPLICATION AND NOT CERTIFIED-o COMPLETED AND AVAIL,'JLE FOR AUDIT o FLEXIBILITY CHANGES TO CERTIFIED MATERIAL VIA 50.12 CHANGES TO UNCERTIFIED MATERIAL AFTER COL VIA. 50.59 o o

~ 1 ~ 01 0 OL DESIGN ~ CERTIFICATION 5 INDUSTRY'S TWO-TIERED PROPOSAL W TIER 1 SUBMITTED AS PART OF THE APPLICATION FOR DESIGN CERTIFICATION o REVIEWED.BY NRC STAFF o CERTIFIED BY RULEMAKING o CHANGES AI. LOWED ONLY BY EXEMPTION PURSUANT TO SECTION 50.12 o NOT OPEN TO ADJUDICATION AT COL o y TIER 2 SUBMITTED AS PART OF ~THE APPLICATION FOR DESIGN. CERTIFICATION' o REVIEWED BY NRC STAFF o NOT CERTIFIED - BUT' REFERENCED BY THE RULE CERTIF' RING' THE DESIGN [ o CHANGES ALLOWCD VIA 50.59 OR SIMILAR CHANGE PROCESS o ONLY THE CHANGED:INFORMATION IS OPEN TO CHALLENGE AT COL o NEW 50.59-TYPE CH ANGE MECHANISM + - - - c.-- .,.w ,.y s .....,..._i,..,

= O ]5 Oi O DESIGN - CERTIFICATION.' 6 ~~ TWO-TIERED APPROACH ADVANTAGES L o ABILITY TO INCORPORATE TECHNOLOGICAL IMPROVEMENTS o EASIER AND LESS COSTLY ' DESIGN PROCESS o EASIER TO ACCOMODATE UNAVAILABILITY OF EQUIPMENT o ALLOWS OWNER INPUT TO THE PROCUREMENT PROCESS DISADVANTAGES o POTENTIAL LOSS 'OF STANDARDIZATION o GREATER CHANCE FOR ADJUDICATION AT COL o LESS CERTAINTY-ON DESIGN ' DETAILS AND COST o MINOR DECREASE IN REGULATORY STABILITY - ~ -,. - _-.sg.y,_w_ ,,~., - ruw. -,v. ~wwc----ww v '-v w-- ~,e

y Q ~ Q: ~~ 4 DESIGN CERTIFICATION 7 CURRENT ACTIVITIES-y DELINEATE' TIER 1 - AND TIER 2 CONTROL STANDARDIZATION WHILE ALLOWING FLEXIBILITY-CHANGES AFTER CERTIFICATION AND PRIOR TO COL o CHANGES AFTER COL 'VIA 50.59 o l h

,. = - - -. -....---:----.-----:-----------;-

O f

~ 10 0 :' ~ j. i k DESIGN CERTIFICATIO'N 8 [ l 5 l i PLANNED ACTIVITIES 4 l l COMPLETE INITI ATIVES j i i EVALUATE COMMENTS o i DOCUMENT STAFF RECOMMENDATION-i .i i s. ,,....~....-a.,

~ = - L w NUMARC DISCUSSIONS WITH-ACRS SUBCOMITTEE-ON LIGHT WATER REACTORS ON DESIGN CERTIFICATION AND ITAAC AUGUST 8, 1990 1 m w-

~

f r,

~- .F [ I m 5 i SPEAKERS BILL RASIN.... TECHNICAL DIRECTOR NUMARC 1 i MARcuS A. ROWDEN, ESo.... FRIED,

FRANK, HARRIS, SHRIVER &-

= JACOBSON......... CHAIRMAN 10F'THE NUMARC LAWYERS' COM4ITTEE [ I NUCLEAR STEAM SUPPLY SYSTEM VENDORS l ABB/CE, GE, WESTINGHOUSE 1 i I i 2. -f -i

:->,--..., ~ ;,,,% v -..

. u,-~ ~ c., r ... ~,, -

3

4 INTRODUCTION THE NEED3/0R CERTIFIED STANDARD DESIGNS FOR COMERCIAL o

NUCLEAR FACILITIES. EXPLANATION OF THE INDUSTRY'S DEFINITION OF LEVEL OF-o DESIGN DETAIL FOR DESIGN CERTIFICATION. THE INDUSTRY'S APPROACH TO STANDARDIZED DESIGNS BASED o ON 10 CFR PART 52 RULE. RELATIONSHIPJOF THE NUMARC INSPECTIONS, TESTS, ANALYSIS' o AND ACCEPTANCE CRITERIA (ITAAC) DOCUMENT TO THE DESIGN-CERTIFICATION PROCESS. 3

3

[,L 3 ' NEED FOR DESIGN CERTIFICATION j i l I o STUDIES INDICATE A NEED FOR: ADDITIONAL 1 BASE LOAD GENERATION IN NEXT 20 YEARS. o UTILITIES WISH TO-INCLUDE NUCLEAR 0PTION IN THE LONG TERM (10+ YEARS) PLANNING EVALUATIONS BEING PERFORMED 1 TODAY. o UTILITIES.WILL NOT INCLUDE NUCLEAR IN THE EVALUATION. 1 PROCESSLUNDER THE PRESENT SYSTEM.- 1l o NEED FOR PREDICTABLE LICENSING AND CONSTRUCTION PROCESS-i TO REDUCE FINANCIAL RISKS ASSOCIATED WITH NUCLEAR-l FACILITIES. i 1 4-i ,m ..j-3, p .-m. o 3 t- ~-a- --.mw w,, w vvs . a aw

to

o D i>

~ ~ ~ j l i l NEED FOR.DESIGNLCERIFICATION (CONT'D) l i 1 o DESIGN CERTIFICATION THROUGH THE-PRACTICAL i l IMPLEMENTATION OF THE PART 52 PROCESSLWILL'PROVIDELTHE l STABILITY THAT:THE INDUSTRY.NEEDS TO BEGIN EVALUATE: l THE NUCLEAR; OPTION. a l l 0 INDUSTRY ESTIMATES THAT THE DESIGN CERTIFICATION.MUST 1 BE COMPLETE. j l EVOLUTIONARY PLANTS- .1992 l PASSIVE PLANTSLBY DECEMBER 1995-1 i 5 i .y ...-~...,m-..n.. -p -a, e e.,,, A. s w.

.=. y .+ - d ~

• O

&4 ACRS SUB COMITTEE DISCUSSION ON THE LEVEL OF DETAIL.FOR DESIGN CERTIFICATION MAJOR POINTS FROM THE NRC COPHISSIONERS' BRIEFINGS BY NRC STAFF AND NUMARC .NEED TO FINALIZE THE INDUSTRY'S DEFINITION OF THE o LEVEL OF DETAIL. EXPAND ON THE CONCEPTS AND THE NEED FOR FLEXIBILITY o IN THE CONSTRUCTION AND OPERATIONS ASSOCIATED WITH STANDARDIZED-NIUCLEAR PLANTS. NEED EXAMPLES OF THE NEED FOR FLEXIBILITY. 6

~ ~~ ~ y ACRS-SUB 00lWIITTEE DISCUSSION ON THE-LEVEL ~0F DETAIL FOR DESIGN CERTIFICATION (CONT'D) CONTINUE TO EXPLAIN THE NEED AND DERIVATION OF THE o TWO TIER IMPLEMENTATION STRUCTURE. ASSESS THE COST ESTIMATES GIVEN IN-THE SECY PAPER. o ASSESS AND EVALUATE THE PERCENTAGE OF ENGINEETING o FIGURES QUOTED AT THE NRC STAFF'S PRESENTAION AND IN THE SECY PAPER. ASSIST THE NRC STAFF AND THE COP 91ISSION IN: o RECOGNIZING THE DIFFERENCE IN CONTENT AND TIMING OF DESIGN CERTIFICATION AND COL SUBMITTAL. ASSESS CURRENT PROPRIETARY INFORMATION PROCEDURES IN o LIGHT OF PART 52. 7}}