ML20058E539

Transcript of 901025 Periodic Briefing on Industry Implementation of GSI in Rockville,Md.Pp 1-63

ML20058E539
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Issue date:	10/25/1990
From:	NRC COMMISSION (OCM)
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REF-10CFR9.7 NUDOCS 9011070210
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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMIS SION 1

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PERIODIC BRIEFING"0N IED'NS 5Y" IMP.L'EMENTATION OF

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' DISCLAIMER i

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n This is an unofficial transcript of a meeting'of the United States Nuclear Regulatory Commission held on October 25, 1990, in the Commission's office at one I

White Flint North, Rockville, Maryland.

The meeting was

'l open to public attendance and observation.

This transcript 1

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informational purposes.. As provided by-10'CFR 9.103, it is y

not;partJ of ' the -f ormal-'or inf ormal record of decision =of s

the' matters discussed.

Expressions of opinion in this a

. s transcript 1. do not1necessarily reflect finalcdetermination

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No pleading-or,other paper may;be filed with

,t the' Commission-fin 'any. proceeding as-the result 'of, : or a

u addvessed i to, - any - statement or' argument contained herein, except as'the Commission may authorize.

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f lc NEAL R. GROSS COURT RfpoRTtts AND TRAN$CRttfR$

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,u-PERIODIC BRIEFING ON INDUSTRY IMPLEMENTATION Of GENERIC-SAFETY ISSUES s

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PUBLIC MEETING-ly

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The Commission. me t in - open session, p

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COMMISSIONERS PRESENT:

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.KENNETH-C. ROGERS, Commissioner ~

i, 1 JAMESR. CURTISS,l Commissioner:

1 FORREST J'. REMICK,.:Commissionerf

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NEAL R.~ GROSS r

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significance of each. GSIs 6" "3 are issues for which there may be safety concerns and 4 I 4 which may have the potential f or safety improvements. 5 USIs-are c^nsidered t' o pose important questions j 6 concerning-the adequacy of existing safety ) .7 requirements. So,~the level of safety concern and the. o 'l [ 8 degree of certainty about that concern are higher for s,. , s I Y. understanding of j 9 USAs than for GSIs. So, that's my .r

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10 the. definition.' of these two types of issues and I'di 'l t , 4 . appreciate any correction or clarification ' staff may 11 y S l12 care"to, offer at the outset of this briufing. m a i 13 Further; we are here today to talk about' developed!, .14 those issues for which the commission has s 15 .and' promulgated a' resolution and will be focusing.on l16 the) progress. of -licensees in. implementing the 17 resolutions !as appropriate l at-U.S. nuclear power; i 18: plants.- 'T i m e Again,Lto m'ake it clear to everyone what. ,.9 I 1* '20 ~the " term " resolution" and " implementation"- mean, let. F ) - 21 me -of f er nontechnical definitions.: 'ResolutionL of 'an k - 22 issue refers-to the determination and statement by NRC-i .i 23 of-what the nature and magnitude of the problem is-and b' E . 24 what measures are necessary to correct any 25 'ueficiencies'that may exist. We were last briefed on ? NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS ( 1323 RHODE 1SLAND AVENUE, N.W. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 232 4 600 'dn, i .)

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5 t 1 the remaining unresolved GSIs on May 29th and we'll {.- ' o 2 not be hearing an update on these today.- R 3 Implementation refers to the actions taken j -l j 4 by a licensee to identify specific measures 5 appropriate to that. i licensee's plant or plants and to i g f 6 'make th'e necessary changes. These changes may vary 4 7 from plant to plant and may involve analysis, .i ju 8 hardware,. procedures,

training, or various

] 4 l 9 ' combinations of these.. The implementation process. i I F s ~10 usually includes NRC approval' of the licensee's: ,,4 11 proposed specific actions.to address its:deficiencihs'.- j 12 -Thus,.we'll be talking aboutrail of the c s .USIs-and ' about those GSIs which - are ' considered. ] '13 <4 14 resolved. We were last; brief ed -. on the ' status i of D 15 ' implementation of the USIs on Febru ary -.14 th. .This' ? 16 . briefing ~ j l. + will provide ani update to-that information c -17 = and will',-in addition, provide a status report on-theJ ,] 18 resolved GSIs. All genericiissues,.GSIstand.USIs are-1 19 tracked.by'research in the NUREG-0933' database'.: i '20 Mr.

Taylor, you may. nowl begin. - youri

[ 21 presentation. n l' 22 MR. TAYLOR: Good morning. With me'at'the.. 23 table from the staf f are Dick Wessman, Herbz Berkow, 1 ? 24 Jim ' Partlow, Bill Russ' ell, Jim Richardson, all .m h 25 representing'the Office of NRR. NEAL R. GROSS COURT REPORTERS AND TRANSCRICF.RS -f ('l 1323 RHODE ISLAND AVENUE, VW. [ lm .(202) 2344433 WASHINGTON. D.C. 2000$ - (202) 2324600 .p n g .f ,i, 6 j 1 First, that was.an excellent tutorial on a o 2 subject of the insider term, so to speak, of the way l 3 we' talk about these various issues. I-think basically 4 we're in agreement. In fact, I'd like to extract it 'S from the record so we can use it to explain to those 6 t at may not be as close to the center of the 1 l~ i 7 activity,- and I must admit we sometimes with these y. m 8 names if-you 're immediately associated it with it, l 9 it's not completely obviously what they are, where '10 they are and.whether the actions are complete. 11 So, I do mean it. I believe ' the staff i S 12 would have'a hard job improving -on that definition. '13 But I willohave it read = carefully by all involved. .14. COMMISSIONER ROGERS: Thank you. 15 MR. - TAYLORf:- Thank 'you very much, 16 actually, for the tutorial of'what we think we mind. '17-COMMISSIONER, ROGERS : - Well, I think we 18 ought. - to know it to understand that we are Ltalking 19 about'something and understand it. J 20 MR. .T A Y L O R':- Y e s,. sir. I' ve very - c 21 'important because the < ~ concept when peopl~e ' say e,7 22 resolved, you think, "Well, everything -.is taken care i J -23 of." That, in fact, is.not the. case. Indeed, today's 4

24 briefing is to take resolutions and -i s everything l

25 taken care of, that is the implementation status, NEAL R. GROSS COURT REPORTERS AND TRANPORIBERS h 1323 RHODE ISLAND AVENUE N W. (202) 234 4433 WASHINGTON, D C. 20000 (202) 232 4600 g ( >i' 1 ~. .c, 4 7 ~ 'i ~which is<at'the heart of all the issues', and that is 1 4: l 2 'what has happened at the individual plants. .,l a;. g 3 I'd like to start getting to say that 4 over the past 18 months, NRR, as you know, has placed l v 5 special emphasis on upgrading its procedures and .q 6 information systems to provide controlling status for 7 plant-specific. licensing actions and multi-plant-I i. m 8. actions. Today's-briefing on the status of li 9 implementation of generic safety issues follows other N - 10 recentireports to the Commission on the-status of.NRR' l i' 11 l plant-specific.. licensing: actions, TMI action, plan 1 i 12 -items', and unresolved safety issues. 1 13 This implementation status of'GSIs is the i ~ 14 final vrea' that has needed.this. attention and thus in -1 15 terms of.its procedures and tracking,- NRR has-l !9 16 ~ substantially. conpleted the > improvements which they e c17 intended to put in place some. 18 ' months to.-- 18 beginning.'18 months or'so ago. ~ ~ 19 While' this ' whole-effort in the various-3 c 120 actions will continue and the control-will continue, I j i 21 .would like' the - Commission to consider that = the - 2 22 frequency:Lof our. status reports to you may be reduced.- i G 23 Some;were. reporting on a quarterly basis,.iothers on a l .- l l ,24 periodic ' basis. My' ultimate concept is now that we "25 have our' system in fairly decent shape for both status l l NEAL R, GROSS COURT REPORTERS AND TRANSCRIBERS = 1323 RHODE ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 232 4600 d. 8' .i 1 and control, the Commission may want to consider [ 3 2 getting a combined report on these various actions l '3 with appropfiate' definitions and perhaps a briefing.on s 4 a semiannual or a frequency to be set by the 5 ' Commission. I think we're now in a position to treat '). 6 all those actions and give you regular reports in a T 7 way that we'were not able to do previously. ] 8 With those thoughts, I'll ask Jim Partlow ~ 9-to commence the formal briefing, a I '10 MR. PARTLOW: Thank.you. i pA . e're going to get right to.the briefing. -11 W (only.want to-say that Herb Berkow, on my left, will

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- give the ~ briefing.on the status of GSIs and Dick 7 },1 .14 ' Wessman will update you on the' status of USIs You 115 were briefedby, Dick in February, an initial' briefing,

16 and nowiwill tell To.1 what's happened in the ensuing n

17' eight-month's'. 18 Just~quickly also to' point out that Herb' 19l and ' Dick, their main job day to '- day 'are project- '20 dire ~ctors and handle all the administration of J 21 licensing' actions' and events in Regions 'II: a n d.'I

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-respectively. But they have taken on this coll'ateral. ~ 1 23 job over the11ast months:to pull together from all the. 24 plants, 'all~ the project managers, the status of these 25 items. So, I'm- ' happy that they get the chance to NEAL R. GROES CoVRT REPORTERS AND TRANSCRIBERS j ~ 1323 RHoDE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 2324600 L sI' r M -7 9 4 6 1 t' ell you what they've done in the past months. q .c gig >2 So, we'l1~ start with Herb Berkow and GSIs. J 3 MR. BERKOW: Thank you, Jim. i 4 (Slide) May. I have the first slide, 5 please; Debbie? 1 6 As has already been established, we have y' 7 a dual.. purpose here this ' morning. The first is to-jh 3. H 8 briefl'you on our recently completed ef f ort - to 9 . determine; the implementation ' status of ' resolved, GSI; + J 10-and.' this : is ' the: first briefing to you on GSIs.:.And

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- second, to? provide an'. update. of changes that have l12 staken. place in the implementation status of USIs since s II.. -thelinitia1Lbriefing some eight and a halfEmonths.ago.. 114' In: both " cases, we. sought to determine whether W ~ ( .15 ' implementation = was : completed and, if so, when was.it-a L16 completed? If i ti. h'a s n'ot. yet ' been completed, what: ~ I H4 l'7 remains 1 t'o : be 1 done - and when?. We intend ' to 'use the. q s, S1 918 results of these ef forts:.to :. updat A cur SIMS database b. .19 - with accurate and reliable'information. m,4 j '~ 20 .(Slide). Can I have the next slide, 4 i l' 's l' 21 please',fDebbie? ~22 In addition to presenting the results ;. of l l,x the effort,L"think it's important to briefly describe 23 I t 24 w you ? the procedures and process we went through to o '25 get the information. I'll start with just a brief NEAL R. GROSS l' 1 CoVRT REPORTERS AND TRANSCRIBER $ 1323 RHoOE l$ LAND AVENUE. N W. (202) 234 4433 ' WASHINGTON. D.C, 20005 .(202) 232 4600 '. ],. ' J ~. 10 i ~ 1 chronology of"the seven month effort and.then describe 2 to you what I think is important and was a very key -3 part of the effort we went through, and that was the [ ~4 GSI selection process, how we selected and why we 5 needed to select from the many GSIs. .Tha.t was a very j 6 time consuming, up front investment of time and L 7 effort, but critical to the success of the project. 8 Next I'll review how we obtained the data l ;, N 9 and how we evaluated that data to assure that we had a-f 1-10 reliable. and accurate database, and then finally we-l 11 . g'e t to-th e- -s umma ry.and evaluati'on of-the 1 ['F< ~12 implementation status. At the conclusion of the GSI 13 . portion,. Dick will brief you on the update'on USIs.- the.first of.these efforts 14 - The TMI which dealt.--with the TMI action plan items /was done I ,15 m .16 back in earlyIto mid-1989 and that: was followed by the. 4 i

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USI project 4 in late '89.and early90.

In each case, 18' ' there - were important lessons., learned.and we-profited i 19 . from the experience of the ' previous ef f ort such,that . r: able'to-do the job more. ~20 this time, I'think, we were 4 > M 21 . efficiently.and effectively-and with-less of.a burden 22 both to the licen' sees and the staff. .p - '23 Foll'owing the USI briefing in: February, a't 24 the requ'est of the Commission,'we began the GSI effort i y '25 and we formed the.GSI team to work on the project and 1 NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS JJ 1323 RHODE ISLAND AVENUE, N.W. (202) 234 4433 - WASHINGTON, D.C. 20005 (202) 232 4600 ,~ =7 ..y.. r .y e-b .y r ll

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F 11. j j..R i f ~1 spent the-next'several weeks defining exactly what it' L 2 was we thought we needed to know and preparing the 3 request. On April 25th, we' issued Generic-Letter 90-s l: ri' 4 04,to all licensees, requesting them to give us the 5 implementation status of the identified GSIs. We gave o 6 them adequate time to respond, about six weeks, ,!N 7 requesting their answers back by the end of June, und-1 l, L 8 we had. essentially all the answers back by August'lat.- j l= .\\ ir 9 (Slide) Can I have the-next slide, L 10 please?

1

-11 I had planned to go-through s o m e.- h, l> e 12 . definitions, but Commissioner Rogers did a far better ,{'c . job - than' I could have. So,.I think. we 'll just; skip .I 13 i,, r ,[ l l

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.over that one. ~ t 15 .(Slide). Okay.- The question might come up ,16 Lwhyfdid weLhave a: selection process-that.we needed to lc., !;, y. y

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go throuen for USIs, but not with GSIs?. Well, as has 9 18 already.been established, there was a total population 4 d they-19

of only. 27 USIs.

,They're all. uniquely labeled, [20 zwere high visibility -issues, all were resolved and! 1 21 ..there was:really.no' decision. We addressed'them all.' 22 .In the case of ~ GSIs, we> have a more. 23 amorphous f category. Over the years, there havelbeen v. 24 hundreda, literally hundreds of GSI-type issues ~ that j l 25 have been identified, of varying-types, varying I NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS .1323 RHODE ISLAND AVENUE, N.'.1. (202) 23W33 WASHINGTON, D.C. 20005 (2c" 232 6600 j \\,.. 4 A 1 g 4 6 12 'i w, i * = 1 . s t a t, u s, applicability and significance. It was i nL, 2 neither practical nor necessary to address them all. o 3 We had to initially identify all of them, research [ 1' '4 each one, characterize them and then make-a decision 5 as to which ones were important enough to address, and g-j' 6 then assure that we had se? eted the proper ones. We. l 7 only had one bite at the apple. So, we had to be~sure: h, 8 that the ones we identified.were the' proper ones and g 9 .that we had not omitted any important ones, y' '10 Generally, GSI responsibility is split ~ l l ~11 between the Of fices ' of. Research and NRR. Research ~ 12 prioritizes and resolves the -' issues and NRR'has the a ? 1 1 . responsibility for determining implementation actions 1, 13 ~ 14 and tracking: the implementation. Verification, if-ls l 15-nee'dedi-'is done by the' regions. Requested actions are-l 16 generally documented by, NRR in the' form' of. generic i 1%M 17- ' letters, bulletins,. NUREGs,. reg guides. Sometimes <18 they'rei promulgated by regulations > or orders 1 and in 19

those. cases' they're no longer: r e q u e s t's, b u t they l

20 become regulatory requirements. l 21' We began with - NUREG-0933, which is the U: r; [g',, 22 official research database of all generic safety-23

issues, and we also cross checked'- that with. SIMS,

24 which is the NRR database, and we got several hundred 25 'cardidate -issues. We gathered inf ormation on all of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N.W. y [' (202) 234-4433 WASHINGTON, D.O. 2000$ (202) 2324600 D s

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[ 1 . them and.that was sometimes difficult because a lot of 1 2 these issues are-quite old and some of the people-- 3 and they've'been inactive for a long time and some of. 4 . the people-who were familiar with them are no longer h. 5 - here. But we did manage to get.a story on each of 6 them. r 7, We.then went through a systematic process r '( 8 ~ with the GSI team' in coordination with the cognizant -t 9 NRR. divisions 1 and Research in eliminating from that L 10 group of several hundred. We eliminated those that. f L' M 11 were.not resolved, those that were. resolved but where L-

12 no' actions ~were recommended, those'which were coveredL 13'

'n the TMI action plan ' and USI ef forts, previously i 1 q 14 - those which have been subsumed over the years' 1into 15 'other. efforts and' are being covered under the; other 16 efforts, and those which-hadia rulemaking or an. order 17 associated with them. That. then ' puts them - int

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.18 enforcement issue rather than a tracking issue by'NRR.' v .19. WeLalso. eliminated those that'are applicable to future. 20

plants only.

' L This-gave us a group of 32 ' issues and( N -21 22 subissues which survived the elimination process. We 23 then got~the concurrence of all of the NRR divisions

24 and Research-on that group, to make sure that we had 1

25 the right ones. We identified and described those 32 NEAL R. GROSS y COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. [ -c (202) 2344433 WASHINGTON. D.C. 20005 (202) 232 4600 { >4,L )g i. ,g ' 3.:, e 14 1-issues and ' subissues in the generic letter which we .F. 2 issued on April 25th. Again, in the letter we asked-3 ~ the ' licensees to tell us whether they had completed 4 each of these issues that were applicable to their > : 4. 5 'acilities;. when; if it was not completed, what-f [6 remains to be done; and when.do they think they will H 4 7 be completed. c 8 (Slide) May I have. the next slide, 9~ .please? Oh, Debbie, the next one, please. Okay. ) .10 The primary input to our database,. of. 1 jyM 11-

course, was the licensee response.

However, as was' r j; 40 L12. Ithe: case in the.USI effort, we did not rely solely on ) i t , 1. 13 .:wh a t -the licensees. told us. We. required an L 14' independenth staf f --determination. That was d'o n e " b y' 15 using lthe' project manager's own records, interaction .16

between the project' mansger and ' the licensee, input.

i l*' '17 from the lead multi-plant action PM.. It. turns out. .l s r 18 that most of.these 32 issues are also being tracked;as y 19 . multi-p1' ant 1 actions,'and each of those hasic' lead,PM.. u. .20 -So, we got input from the lead PM and also'. j .r o 5, - - t -- r s> 21 Linput ' f rom tha cognizant. lead ". t e chnic al - branch.' 22 Fortunately, in most cases, we had-agreement between- - t Nb '23 ~ what ' > the licensees told' us and what the staff-1 m j ? 24 determinat*on came up with, but there were'a number of 25 ' differences. Those differences generally resulted 1 u -NEAL R. GROSS i CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N.W. l (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 6600 i . a -. Je 1= 'l' l I ei 15 l h '.9 ta t 1 fromLincomplete responses by some of the licensees, a 2 misunderstanding. Even though we felt that. we had 3, 1 ~3 made a very clear

request, there were some i

w 4 ~ misunderstandings on the'part of some of the licensees W 5 .as'to what we wanted.- a 6 Some. of them miscategoriz'ed. We had rm ~ suggested: four categories in which the licensecs: 7 I ,8 should put each of these issues. One was complete, 9 thet second',was incomplete, the third was ' NC or no' l 1 10 ' change required'as a result of. the request, and' the. l 3 1 1 11 fourth and final ' issue was E, that ' the request. is, 1 12

still under., evaluation by the licensee and'has not yet j

. 13 made.the determination as to whether anything needs to i I 14 be done. J 15 'CCMMISSIONER REMICK: Excuse me,; Herb, a q s ~16 .questi'on. 1 '~;u ~ MR.[BERKOW: Yes. : 17, u 2 ' 18 COMMISSIONER REMICK: Noticeablyf-absent '. ,J [Y 19. f rom' the '.peoplei you" mentioned-is the s enior. '.residenti ) i; 20 or the' resident. Is there a reason.why they are not. j', 4,, - 21' . involved? l 22 MR.. s BERKOW: .Well,-they'would be involved: 4 [ .23 ~in t hel verific a tion-aspect - rather than - the - 24 implementation aspect. Where verification was ~ = -) 25 required and temporary instructions were. issued', NEAL R. GROSS . COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. i . (202) 2344433 ~ WASHINGTON, D.C. 20005 (202) 232-6600 u s 1 ~ 4 ll - t p 16 s 1 either the resident inspectors' 'o r the regional 2 ' inspectors carried out those inspections. But for 3 purposes of implementation status, we didn't feel that l '4 the residents would have anything to offer to us. 'S COMMISSIONER REMICK: I guess I don't 6 quite - understand, not yet. Verification means they -7 viewed it', they've observed it. 8 MR.-BERKOW: Yes. Yes. 9 .MR. PARTLOW: They tried that on selected L 10 GSIs, not.on all of them. But on those'that we felt e 1 11 were especially Laportant' and. those where we felt we 4 y . 1 - 12' coul'd afford the inspection' resources, we write. 1 13: . temporary inspection procedures and. in.those - cases s 14 -then the residents or the regional inspectors will go L ..15 out1and verify for us that those have, in fact, taken a .16 place. So, ~ that 's-the major.. role that the residents .i ( - 17 and inspectors p1'ayed in this.' process. l 18 ER. BERKOW: And we.had temporary 1, f 19 Linstructions'on--16 of the 32 issues. 20 COMMISSIONER. REMICK: So, in all cases,- did not necessarily rely on what' project managers 21 you2 -i . 22 told you or others - or" documentation you.had in ~ ~some '23 cases was-actual' verification? 24 MR. BERKOW: That's right. I 25 MR. PARTLOW: That's right.. l - NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS p 1323 RHODE ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 232 4600

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j I x a., 17 .N: 4-1 MR. BERKOW: And when the implementation P 2 is promulgated, the cognizant technical branch decides s j .3 whether" verification is appropriate or not. If so, a i 4 temporary instruction is written. .j 5 COMMISSIONER REMICK: Now, the purpose of 'l L 6 my question - was just to see do' we use the-residents 1 i-7 for such things? r- '1 l O: 8 MR. BERKOW: ~Oh, yes.- Oh, yes. Yes. ,t 9 COMMISSIONER REMICK: Sometimes ignore-- O 1 s 10 them. Okay. g q 31-MR. BERKOW:

Yes, i

q 'l '.2 There's also ;some c on f u sion. 'on. Lj j '13 ' implementation complete versus licensing. action

• 4

. complete. They ' re. not necessarily the same. A j x n j 1C' . licensing 1 action can be closed;before implementation 1 1 116 is complete-or vice versa.' Some 6f the licensees gave d. gj f17: .us f or licensing ' action status rather' than the 18-implementation status :and '.we had to g e t-that g 1 .l 19 clarified. 4 .i ~ 20' The'GSI team then had individual meetings ~ '21 ._w i t h e.a ch : project manager to review the -licensee e L' 22 response and the independent staf f ' determination = and. l 23 to make - sure that.everybody 'was treating similar l i 124-situations consistently. The PMs then prepared-a memo i 25 to file which included t.he licensee response, the i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoOE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 2324600 4 g ,q v . l3. : u, 18-l .e 7 ~ c in & V' H

1 independent' staf f I determietion andihighlighted'those

) U2 issues which were'still considered::by the staff to be n i H

3:

,zincomplete and the licensee's plan for completing them 1 xw g '~ (4 and'- s chedules. - These-memos Nere.-QAed-by the GSI team j 06 L j y '5 'and;they'were concurred in by-the cognizant technical y 'ls i . %q ' ' '6 . branches to beaure that everybody was in agreement-as i @M, ',. 17. to the status,..what ' we were saying the.st;cus was of-y g #h

8

.these issues. ( ,(',M q -9 The data is presently ' being entered into-q i qG _ 1', SIMS database and.is scheduled to be completed by; j 10 the [, O 1 Thelone remaining. action.is'thatt ] {. 11 the'end of November. p 1 1 S (12

each ' project manager is going - to be. asked to send a-

~ [C., that-this is the E 7 y13l 1ettertto his or her:1d.censee saying rw v + n# 114 'lstaf f 's' cunderstandingf of ' those:. issues ' that 'are.still j3 ~ 4 a:. ', 15 ? open atL your 1 plant' and this i is ' 'our unders tandingi of '. j) 2;o+ 4 s {.

16.

your plans 1 to comple.te7 them. . Those letters ' will be l '~ ?A 3 . 17 sent bycthe'endhof' November.' ^ mq + E18. L(Slide) 'NextEslide, please. > :{ r a

r. @..m-n

,H $19' .AndL the ' results'. The results-shown-here d a .i 0 areftheEdata as of-the end of' September. We have'111 l M 'L +.21 reactors ithm we ' considered. We did not incluca c R a l Q, 22 'RanchoHSeco, Fort >St. Vrain or Shoreham. These plants' 1 E 23 are'no longer operating'-and we also did _not include. =- r 24 both of the Watts-Bar units and Comanche Peak =2, since- ' ~25 they ' re 's till-in the licensing process and GcI = m 3 NEAL R. GROSS COURT 'LORTERS AND TRANSCRIBERS ( *i,. 1323 RHCDE ISL AND AVENUE. N.W. '~~ [ CiO2) 2344433 WA? ilNGTON, 0.0,20005 -(202) 232 6600 l l %W> =- l 3;;. T a ~u v, i L. + g', y

19, q

d ,.y w <f 1 implementation will be covered as part of.the ]- t 3' G,/ 2 ~ . licensing process.,- Of course, not-all of the issues g, 3 wereiapplicable to all. of the reactors 1 either, so:we [ 3;- 4 ~had-a total cf,2,662' applicable GSI. actions. -Eighty-n. 5 three. nercent.of. those haves been implemented. The- -l ,c-L6 ~~numbsr unimplemented actions atL individual o plants t a L -7 ranges from one to eight. TheLaverage is about~four. J u 8 .(Slide) :Next slide, please.. j( t iq g, =9' COMMISSIONER'CURTISS: Herb, excuse me. m 10' >MR.-BERKOW: Yes. d ef q S q N, H 11; . COMMISSIONER CURTISS.:- On the. previous - i' f 4 - j2 v i = . 12: . chart, you identified the total ; unimplemented.- Does H 1, g' '13 ' that Linclude. those.' where the staf f has not dones -its< u ,n 14 l post-implementation review? N,, ' 9 -i MR.- BERKOW:

You' mean as=far;as the

i 4 W: c 16,

1. licensing ' action is. concerned?

.No.. We're dealing w. e 17l here only - -with 'whe ther or -not-the licensee had. .w el L 18 : completed implementation.- - The ' licensing action mays j

g

,

y g t s.' i' 19; still;be open. 0: H-3 l .f y,, 20 COMMISSIONER CURTISS: Okay. 21 MR.~ ' P ARTLOW : . And : verification may still il. ,5 ~ .22: be open. .m W "~ h '23 MR. BERKOW: And verification may still be; '] ' 24

open, right.

4 I ~25 .' COMMISSIONER CURTISS:

Okay, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.

. (202) 234 4433 WASHINGTDN D.C. 20005 (202) 232-6600 p Q N, l @,1 m . i :- 4 g' 1-- s l,Qm-V 30; l

3. a J..

t I l- .,7 4.. ' 1" ' MR. - BERKOW: (Slide) . The; next slide, 'i ..y. @L '2; .x1please.' p i 1 \\.: 3. L;;, T ' We ' ref er to these as the big..five. It 1 lJ

( -s E

4 turns out i ... that these.five GSIs account for--94 percent-l t

• i

'5 of the 454 ' actions' that were. listed as : being open on @y +' 6 theLpreviousEchart, which' means that there are only a'. 0 $J 'T 1 total. of.128 ' others -on all of sthe:'111 plants that ; ar'e a i F' L ji - .8' /still.not completed. The staffJfinds that there-are-1: .i i,, .9 generally acceptable plan and schedulus.for completing m y s bC '10 these.

c. -

tw

11 These. actions or' these GSIs: are.all A

1 described in detail'in the' Commission. paper, but I'd> 1 1 '12 'g 7t,. !!, ' N 113'. .1ike ; to just brieflyi ufor your i nf ormation? ;run.' i =

y "u

m =through the-five~as-to what.they entail.- 14 - 1' 5 (Number 43 ' relates L to airj system -problems-W ,[ ( q 16 andf the request was. that;1icerisees verify the adequacy J, 17 o fI t h'e:. qu ali ty) ! d e' sign' ; main t en a nc e ' Lpra tic e s ', e 1s s 18 . procedures and' trainingErelated to: the: air systems.; m . ty, 19 < It's "a: relatively new issue e The.. generic J1etter went; w T 12 0 out. in.19 8 8 and the, implementa' tion <is virtually; j m a 121' complete at most of' the plants...They ' re - just "' : ting - ~ b> 22 -foria suitable outage to, complete the actions. From .l 7 ~ u ,;n roughly 90' percent of them, 23 the informati~on we ' have, ~ '91, with the ~24 will be totally completed by the end of o 25 remainder following not.too long after that. 1 NEAL R. GROSS COURT REPORTERS AMD TRANSCRIBERS e 1323 RHOOE ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTOft 0.C. 20005 (202) 2324600 4 h, 'Jth,., W.. , m: ,w, E di; ? e i 9,, w,' 21" l ' 1,: w

1 G

r C'O M M I S S I O N E R ' R O G E R S : What.ttypically. are . l 2/3 m', the changes that they Lare; l i*te v ' 2! ^ . they..doing?.; 'What; are o ?.4 1 j L', ',3 implementing?. l w 'c N V 4 MR. BERKOW:

Okay,

e s

k.. 'T

• ,1

'5' 1 COMMISSIONER. ROGERS: I've be'en s'omewhat + n 6 interested in' this air. system problem for-some time j m-I q' l' l., ~l seems_ ; to me. it( keeps.' popping. up. f rom time: i < >7 : .because it u a to' time-wh'ere a licensee' loses all instrument L

b air..

I 3 ~8' q 7 .9 f_:n

noticedi dust?:in' the last ' f ew months we 've seenl:a o

r W[

in

.10; numberiof t,' situations.i'itlfwhich i at least ithe 1 1oss i of J Q jil ';' It-mae'not'have" j ,ill!

instrumentlair-.was part ofLthe event..

j. Wi x

w, ,a lil been :the cwhole[ thing,: but it at.least was pat 6 of it.

j.

...J. - r_ 12: [; 1 ^ : y p v s. Kh *t. t13

MR. - BERKOW: -.Okay.

.The requestRinL theH l; ll l ',' y l . 14 generic;1etter.was-forza program of"verific'ationcwhicht m w. " } I', ~ ')[ t ,y-e e: .i: 15: i n c l u d e d i ?t;e's t 'v'e r i f i c'a t i o n: o f ' a i r 'q u a l i ti y,'. 1 1 s ,' m m. s gwm -. v.erifica tion;.of Edequate maintenance practices, -) I

1 64

.t 9 wl7J emergency: procedures and; training,,and verificationcofx m + ,, g y f18l design andffailurefmodest EThat's basically what i s,y p ,;g + u s k Ik. f M / 19: Lwasi- - n. i, ' 1 r c IV.

6 20 w

MR. RUSSELL:. To give'you an example _that? i s +9 4 N 21' we ' actually discussed with the' Commission at ' the time - a ' + w 3 _ of Lthe: Pilgrim restart briefings - and the variou's .22 e J23 status - reports, in some: cases accumulators areLbeing y i 's !( L. (.L - addedlusing nitrogen sur;, lie's in lieu of air supplies'.: I

24I a

4 i. l' L25 S o,1 there tare design modifications in. ' addition to N . NEAL R. GROSS $ ' tg p. COURT REPORTERS AND TRANSCRIBERS i 1323 RHOOE ISLAND AVENUE, N.W. b iV. L (202) 2W WASHINGTON, D.C. 20005 (202) 2324600 ') [h l ~ w m a .i r i a-.. 22! } o t l 1= looking at' quality capacity, ' how - long can your air f a, 2 . system hold and recall the -discussions regarding .j gy ^ 3

accumulators for the reactor. building or vacuum:

+ i ..*/: Q 4 breakers. . That 's. been' f airly typical. There have l 1 f l5- .been-air' supplies f o r ' s e a'1's for roll-up ' doors ', for'. w s .'L. r '6

example, that have not : ' b'een..reli able.

S o ~, it's + s s 7 1.ooking ' a t - the design aspects o'f the systems, :the< ^ [' ~ air 8

quality of the air systems, the rate ' of. loss of 9'

pressure associated with accumulators,.et. cetera.. lSo, - l f lm ' 10 - .-it.'s-.aL.fairlyLcomprehensive' review, looking overall atL [, i 1 G

the reliability of-air systems.

4

11.

MH> i 12: MR. TAYLOR: Accumulators -'have : been added' p ..,1 W ~ fcgl L13 at a number of stationsL ' depending 'upon the vital a s,yg - 214

2. function andi that's ' been.part sof this' whole Jissue.

1 . g

c. y

!C no 54 115 It's happened-at'.a number of' stations, q an '16

COMMISSIONER REMICK:

What.would : hold up

w.

the : purchase offthe: i W 17 '. ' the '. installation of f accumulators, o qi[, y, 18 . equipment or -- why would:it;take.-aLlong time to add x .i ~U: .(

19 '

accumulators?- 1; y' 20 MR. TAYLOR: To t designEchange,:' they Lhavei i ~ 4 g 21 to get.the engineering done~, the: procurement - andy then p L' 22-the installation. They've already. been put inLin a -23 number:of plants. ~ 24 MR. RUSSELL: In some' cases i t.' s --. when ; 25 we' say accumulator, it's a simple gas. -bottle with V NEAL R. GROSS R COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE, N.W. .g. (202) 234 4433 WASHINGTON, D.C. 20005 A202) 232 6600 < i, I

i! -

s ~. ) ' ! 23: g. 1 m ~' 111 usually a. regulator and tubing and sometimes. its _ m,. t g + .[ '2. ~ nitrogen-and siometimes it 's' air operating off the air 1 .f l: 1 31 -system;to just give you a larger volume. They're not. j .t X

4 complicated' designs,.it's just the = completion of the i-o,.."'

!5 / design review, the paperwork,-the procedures.that need~ + < ~

6~

'to be upgraded in completing that review. process'. s l7 MR. BERKOW: 'Some'of these -items require j{ y, _ shutdowns - ^ 8 '3 ' ' 9 MR. RUSSELL: Sure. a 4 e MR. BERKOW: 1-- and they're just waiting ,1[0 'l' @w ji ;it W ;, ' 11= lfor>the next convenient shutdown to complete:it. '] 'i m Z 312 ~ COMMISSIONER CURTISS:- Is that the reason-l o e 'f i - 3 3 ' '", /. < 13' Lf or 'the ' ten 1 percent io'f' plants? that: won' t : have. iti done: f 5 a, y ? 14 .'a t - the endl of gu '9' that-they won ' t have~ an. outagei .w ~ I + la - 15: ibetween 'now and. Jthen, or what ~is the reason that' 17 j $ 16 jyou've goti ten percent;'af ter 1' 91? t j 17i MR. -BERKOW: ~- Mo s tly, yes, - tha t 's?,the I "t - ~18

reason, that the outage they3 have,.the planning /onLto.

1 a' j 4 -l complete it w'ill.not be done by,the' end-ofJ91. j l19: 4 It j\\: ~ 20 COMMISSIONER CURTISS:. So,. f or. the- / u 21 1 remaining ten percent,= we:. would.-expect those to1 be o' .a,, ~ 22 ' resolved. at f.whatever point they reach their outage- ';( 23 after.'91? '24 MR.'BERKOW: Yes. Right. q Y 125-COMMISSIONER CURTISS: 'Okay. j 1 s 1 NEAL R. GROSS i m-j! COURT REPO8Trc~RS AND TRANSCRIBERS [ s y' 1323 RHODE ISLAND AVENUE, N.W. b (202) 234-4433 ' WASHINGTON. D.C. 20005 (202) 232-6600 - q;, l Vl i s-ww n, [ J ,4 4 ~ i ? gg 39 l i i. El-MR. ; BERKOW: And these schedules are [{

2

generally in accordance with ' the schedules that were i

s r .i li

i 3

. offered in the-generic letter. They were-given time l i 4- - to.do this.- f -5 Item 51 deals with the compliance _ of cl c 6

service water-systems with: the Lregulations and - the i

r L7 Eneed. to establish programs to implement recommended j

.v 4+' t' 8 ~ actions that were given in the-generic letter-which w, -:In

wasifairly recent.

This~ generic letter was not issued Q, 9 M 10 until-1989 and; the licensees were given

• t couple; o:'

i 'A 'll years ' to complete the (is' sue.

Here "again, we exper.t.

x L '-

n: 12' L 'most of-them to be done by the end_-of '92.- This_again i ,4;. ; / 131 21 sL in. 2conformance ~ with the guidance in the Tgeneric. 1, n 4,. >< y c 14 - ' letter, j y m. r i M c15 ' 6' 7.' 3. 3 - deals :with. compliance with >o 16 ' regulatory guide ' tl. 97' of' Revision '2. Tha ts ' t he ' d 3 4 s 17.- l instrumentation f ollowing Lan_ accident, and the d b schedules andaplans f romx the licensees 1for g

18:

requested j o i 'I L19 dealing- ^ with these issues Now, it 's -open t on - most w 4l A ?20 plantsJfor two' reasons. I'n. ' 4 R s the item is. Category-O ~ c g l21 1 neutron flux monitoring, which? the industry has-y m- - j i. 22 appealed..They claim that the current instrumentation ~ i 23 for normal c,peration is adequate'and there is a formal. . s '24 appeal in by the BWR Owners Group 1which is - currently 1 under-review by the staff. As I understand it, that l 25 Mai'_R. GROSS Cot /'. r -' JATERS AND TRANSCRIBERS q ...s _{ 23 RHODE ISLAND AVENUE, N W. j .-(202) 234 4433 WAf M'WTON, D.C. 20005 (202)' s2 4600 a' + -m ww, M> y. o Q m. L ,s J M g. ~ ' 25 }N.gg& J '1 . review'is> scheduled to be complete sometime before the %]'t,, j 's i \\ i'l j$ ~ Tend of the year ' Is that correct? I 12 ~ ~ w ' ~ y, ?. '3 . COMMISSIONER CURTISS: Is that a backfit 1 3 y,:. t .p w -7,

4 appeal then?

sw s ' l-m <S' MR. B E R K O W.:. N o,-- i t s. n o t a-backfit u[ '6' appeal. I don't believe it's categorized as-a backfit-' ~ o 1

7

1 appeal.. s ..to X 8 .MR. RUSSELL:- The, issue. relates to the _M y 6 ]',

9-rangei that you: need ' to '.~be able to, monitor down into.

j y, the ' l s our ce 1 range and' the quality of the; neutron .:[ m 10f i + ,gc fl;

1. 11 l ins trument --itself.

'That appeal is presently under. p

12 '

" review.at the-office' director-level. The staff at my: l,Q G my -( " 33' 11,y,y land Ilower have t'aken a position. and thatL l p y 1; 4 'l ! 14. position is t eing reviewed now and ' Doctor. Murley is' to. C g m 'ti tt t V 115 .beibriefed'on that11ater ---orz early in NovemberJand w a s { 16' - t will ?'make ! 'a' decision.'

So,,we are-in the 'appealy l

4 x; J; 1 75 process 4 of. the position > thati 'the staff has taken. ls '1 ? 0* V k 18; This~ i s' a Reg. -Guide.197: requirement ' ' that did 4 4 previously. go.through the review.and it's associated j 19 i [ 20

now with..the ; ranga and the quality of the instrument

[ g 'A y m N. % i, 21L 'that's'being. proposed to meetJthat? requirement. G ye j' l t; > r + 4 22': ' COMMISSIONER ROGERS:- Is'the problem only 4 t 23 with theLBWRs? 24 MR. BERKOW: This particular one. D 25 'MR.. RUSSELL: Yes,'this piece that's being NEAL R. GROSS ( COURT REPORTERS AND TRANSCRIBERS j N 1323 RHODE ISLAND AVENUE < N.W. I P . ASHINGTON, D.C. 20005 (202) 232-6600 ,(202) 234 4433 W .)., ~.;.. 5 ' 7I$ i. i vm s@W 3 26' t al held up. { s aa [ t2 MR. BERKOW: The neutron' flux; monitor. j i { 3, 3 COMMISSIONER ROGERS: And not PWRs?' ' i4. MR'. LBERKOW: . There 's another one on PWRs-g: 3 1".ii 5 with this particular' generic " issue' and that,is - the .g. N p [ '.6 Jn'eed f or: ' Cat'egory 2 instrumentation to monitor the-4 7' . accumulated tank level ~and pressure and ' the .f 1 P ', :i-: 8 , containment sump-temperature. '.Here again; industry Mi 9 has - appealed. that, claiming'that there's no~need for.

- j

• >!.I

, 0.'. kI

this.-

L Theistaf f.he.s generally agreed and. right.now, j ii D -10 / 8;- f 3; f- . 11-h a s.'.t o l d ' t h e indue try - th'ati no f urther' act' ion Lis ' <l W gm 413;.: f. - i s f;h "12 Enecessary. However, either'1the generic <1etter needs j ~ e m }ki ' .. ~be---La:new' generic ic#:ter Tneeds to be issued'or 'k} l' 13. .to 3 ? l: .t j :p,. -1' ,1 i l67 9 14 the : reg. ' guide -i

• )

e modified. , The. staf f; is: + 3jp,, 9 + m,. y. .x. m considering ',:bothi ofl those }ac tions..

Unti1~ that - a.si

'l ~ ,- N / E 15' 4 o p1, T - ~ U f .j L, - 16 ; ' donel. we : have. considered = this L action ; as' unimplemented-- r' r i 9 17 'on these plants.- j ^\\ j. ,i O> jl8: S c o t t ',.'d o you; have' 'anything you want 5 to : j m a;,. 1, .,.~ - -

19 add to that?.

,1 a .j' 'Ei i . COMMISSIONER ' C U R.T I S S :. But i.t s. 1 '20

s

^21' effectively been resolved' f or the PWRs, 'it' sounds L if '.M a g: i

.k

'~ ') ' ". r.. 22 like. We ' ve - reached a consensus on the technica1L ' i f, ~ O' position. [ 24-MR.-BERKOW: It is, but;the paper'that.we. ] 25 Navetout though still is not ' consistent with - tha't tNEAL R. GROSS-l

i' COURT REPORTERS AND TRANSCRIBERS

~ 1323 RHOOE ISLAND AVENUE, N.W. j f6{ -,(202) 234 4633. . WASHINGTON l 0.C. 20005 (202) 232 4600 - e l ?g r Q,);? f' p .E o . e+. 1 ~ x c >& ' ' N 27 l

JM; '

Vp];6; Q - t t '1

revised'positione 2

3 .2 } COMMISSIONER. CURTISS: It 's.a paperwork f v 7 .d_ j;, o ;;

19 N

(3. ' ques tion J. f or the-PWR and' it's an appeal questionE for y ; k ,y 4 thelBs. L 4 4 i !-Q ' (5 ' COMMISSIONER - REMICK:. What is the ~ basi'c j q m f 6, i'ssue ~ on the'BWR case?' 'Is it suberitical monitorin'g y /...' s 'a n < a c c i d e n t and the qtiestion '.of ,ys J7 . of: the ' core raf ter , a; ,s .8: =whetherytheL ' source range. monitors are ' adequate?' ein. r o l. \\ v * ,~[ "WL

9 LWhat'ssthe industry's response, that theylcan'tfdo it or'it's n'ot needed?;

i. Q' - lo; ~ yv j..r (Mf h,; 5'T d 11 1' MR. ' RUSSELL: .let ..1-try-and o broadly! ] ~ y .pm

t Y

12l 1 summarize it.

For certain1 accidents, wetwant to.mak'ei q.

s a SN4 'j?n s, %. sc en 4l. i

sureuthat you can ensure that the' reactor?is shut down

' ' 13 = 4 %..G,

• ylbmp. m

~

t.-

14 : oand! : remains J shut' down. -So, the: low'er-level '.of W u o 7.y 3 n-u' %ja ' , :15' .detectability; with :the (instruments, Ewhether; you ;go hh? 1* v3 g s m. ~ ] QC '

16

. down) t'o110- 5 percentipower-orLyou go be'1'ow'tnat point s y s il7 .to assure'tha't youl don't havela problem, l'et 's, say a, 4 1 s q l ,18 frecriticality, 'et' cetera,. ' that 's 'part J of othe'--issue ~,. D19. what'.s: ther rightilevel thata. you should ' be '. able" to 4 B m a

l I

measurel down' to to; assure that : you. are -indeed" shut .i L20-W'

1..

\\r { o21s down. mm, ', -;t 1 i;4 .22 The second issue-has to do with' cost' H: p L l23 associated. with providing a qualified instrument - and: ] a s }' k " i24 ~whetherg instrument's are available that will meet ' a.Ll' l Lv L 125 of the equipment qualification requirements for the a il 7'. NEAL R. GROSS l e COURT HEPORTERS AND TRANSCRIBERS - s

1. e 1323 RHOOE ISLAND AVENUE, N.W.

I_ i %'f4

j.,

C . (202) 234-4433 l WASHINGTON D.C. 20005 (202) 232 4600' t t -l l

at

'l ~ hfl 9-28 -,. d s s 3 ? 1

postulated conditions that would exist.

Those are the i h. 2; itwo-issues. j x L, 3 The staff believes.that - it ' is possible-- '4 .this is' the -issue that's under review. The staff wo jf. -S-believes it. is' possible to provide an appropriate j m '6 range and qualification for'the instruments. We have .7' approved some cases. y 9;, 8 Scott, was it Grand Gulf? ) ..m .#: 1. MR. NEWBERRY: Susquehanna and WNP 2. 9 , s

n.

e i m # 10 MR. RUSSELL: Susquehanna and WNP 2 have. 11' been approved, but other-owners are' objecting and .i .t P ~ That's'the issue' I 112: Jdon ' t 'believe that ' that 's ' f easible. 'f \\jl w 1.13 that'stunder! review. i I uY,' 14-LCOMMISSIONER' REMICK: Well,g what was the n I Q f~w 15 solution in"the' case,.for example of Susqu'ehanna?' q y. '16

MR. ' RUSSELL

I ' d 'like -to - have - Scott 5 4 17I Newberry-address the specifics. '18 MR. -NEWBERRY: Scott .N e w b e r r y'- ~ q q .q. f fl9 In'strumentation and Control-Systems, Branch. r. t 20 . There 's two real dif ficulties - with.t,he~ 3 b qy current' systems. One is the' environment'all q 21 i both involve the environmental. 22 Equalification L' l.i. 23 ? Qualification of equipment ' inside the drywell 'where-L '24 you may experience a harsh environment after an [ 25- . accident. There 's -the connectors. Of course, this' i h4 NEAL R. GROSS 1 .f' i; COU9T REPORTERS AND TRANSCRl6ERS 1323 RHOOE ISLAND AVENUE, N.W. (202) 234 4433 ' WASHINGTON, D.C. 20005 (202) P37 660u 4 i ( tb . R-4Wy1 j. 4 - 29 7, f ,A J " ' M ". T 1' instrumentation iis going.to be very ' low cyrrent, in { i j-)y,# ' 2'. the milli / ampere range, and it could be; subject'to the '1

c 3.

environment and ' current ' leakage. So, there's the l] M" 4: Lconnector= qualification issue. + 5; But ; the' other interesting issue is this ) i y b l 6 instrumentation is withdrawn from9the core at power and 'l

~

a h' 7 ' has = to-' be - reinserted. af ter- - the ' accident. The drive . f... '8 ' motora n that perform that function are-locat'ed inside x F,t 9 the ' drywell ' around the reactor vessel.. skirt and T-are N' !10

nott.t qualified' to perform their function in the harsh o

\\n 4, 11 environment. -So, you 'd either have ? to. provide'., an HT ' l'21

environmentally qualified ' drive system, which.is>. one-

[ ..v v , M ' JM(, . alternatiOe, or what: onexplant/hasJdone is to design. p, {. .13 O

o..

u N* 14!

.and oinstall an

-t l ex-core instrumentation system around a a 4 u -. k J_ I

,, j j f

,p ',.

15 ithe shield' wall. w-1 ,,,'L, 11 6 'COMMIS SIONER lREMICK: So.i t ' s ' n o t - a ej-i ,4 /f y; 17-(igues tion of the" use of then fission. detectors, it's w i,w-F L, g ' 1 81 connectors andidrives'and so:forth? < cm 4 .t 119 LMR..NEWBERRY: 'No, sir. As a matter of. 'o L20 f act,: the-other alternativelto the ex-core systemlisu a t{ s 4 a 21 fixed tin-core system tha ts; be en ' designed land' 4 E22 installed at.one plant. j COMMISSIONER REMICK: I see. Thank you, t to 23 1 4 24 COMMISSIONER CURTISS: Is there a 3 25 consensus on what the costL of this would be, or-is a NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS t 4<' 1323 RHODE ISLAND AVENUE, N.W. 1(202) 2344433 WASHINGTON, D.C. 20005 (202) 232 4600 : 3 d_.- 1 e +, w .. - - -. -. - ~ - . _ _.. _ - ~ _ _ _ 4

if j,.,k.y yy 30 N'

b' ~1 ^ there a rangefof. estimates? 4 1; y l. ^ 11 - ..NEWBERRY,: No. There's no-g 2 MR. W 4 ^ '3 disagreement on ' the cost. Any of - the ' alternatives lr ?' 4-would ' noti.be ' inexpensive. The lower cost ex-core m ) 5'- system is - probably. around $1 million. The in-core (+, l' 6 systems'wou'_d range upwards perhaps, depending on the l [

7. -

options:for fuel management and those. sorts of things. u, .It could: cost as much.as $5 or $6 million. I - LV 8' 4 [ 9: . MR'. - ' BERKOW : Okay.- The next issue is a i [ issue, vendor interface for; safety-related -.t 10' Salem"ATWS J p .} l Lili Lcomponents. This was ' originally:l part, of the Salem' A .a u,

• 11 2-

ATWS Generic Letter 83-28 and the ' position was-

,g w a f, a i: 1'3 recently: relaxed and-superceded by. another generic- ~ @s 1 l J14 lettier, 90-03; which was not issued 'until March. of - U ki 15 ':thist year which - essentially changes-the program = -to - b*

16'

' bring 'it into accord. with industry-developed program' I l l 17 oniven, dor-interface. ,a 1

18 The responses wereLnot'due until - th'eH end q

a ~19: of September. They're just about all'in now. They're j n 120 .beint. evaluated.: Some of them twill become in the .g

1 4

21 category of'no~ change required.

In other.words; the

] .22 . licensee ~alread',.-conforms with - the. sugge tions, 'and in. t l ..other cases there will be: actions thatHare required. 23 l Pij 24 ~ We' anticipate - that where additional actions are '25 required, procram changes are needed. ~ Most of these 4* o y NEAL R. LiROSS 'h j l t-COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AV8NUE, N.W. j '(202) D4443J WASHINGTON, D.C. 20005 (202) 2324600 !] * $S ,g_ y. ] n%l ', y > c. ; 37 j 7,%, g :pi,: ,g]o 1

should be. completed by.sometimeLin 1991.

Fc r the. time g +,. s ..'being,c wef se: considered them to ' be. all inco nplete. ig 2 c J wi 3 ECOMMISSIONER. ROGERS: What. is the' ^

i n.

I i l.i I k)l .:dif f erence between this': issue and USI A-9, anticipated 1 MK 4' j W. < ~ transient without scram? 5. c',l ! 8.. a: ,w [m, .6 MR. WESSMAN: Well,~USI A-9 involves some j 1 ,nti. p# 7.

- systems' and components -in ' order ? to create ' ae: diverse' m

1 us I 4 8: cmeans. of tripping : the reactor; in the. event that you=. O m n -1

9.

.have r a transien'. - and' the normal oseram systems' do..not j -q.',' q l5t;r 10 ~ 'perf orm. as' expected. For example, a < diverse, pump .L j ,/.-}r- -l l t.g ~ 11 :- trips, f eed:. trips, I; think changes to, the standby.- ji [ p L 'l J ;12 liquid control' systems f or < at ~ boiling water 1 reactor, ) }' 11 3-

thir" type ofJthing.

I I d J J141 MR. PARTLOW: Generic Letter-8 3 - 2 8,. ' I. j o 1 H believe,; Egenerally ' spoke.to procedural matters, j m a t 16 relationships with vendors, post-. trip revi'ew's -- 'q 7y l .( 'l . !b 17J MR.: TAYLOR:

Testing, g

ctesting - of protection 18' MR. PARTLOW:' g O,.' 19 i s. iterrs. - y .Q 20 ' COMMISSIONER CURTISS: Herb, can you. speak. i& k'h4 21 to the: dif ferences between what you are proposingiin -g g a l 22: .83-28 and the recent ' 90'-03? R 4 Y 23 MR. BERKOW:. Perha'ps Scott can do that. l, x ~ -l ]M 24 MR. PARTLOW I can do that. The original 25 one that said for every supplier of any safety-related. i M in i i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N.W, jj-l '(202) 2344 433 WASHINGTON, D.C. 2000$ (202) 2324600 $I i ~'s' h ,th -g ?,, '1: 4 Y p \\ ,y :., : 32; + ' c., 7 1 1 equipment' you_need a.' program to.be in touch with them .t '2: solthat'you'll'know what changes are going _onLin every s 3:

one' of. your saf ety-related. suppliers.

Industry' felt s .4 that that : was 'a very cumbersome - and_.not' at all cost 15 . effective kind of_ program tofhave' to set up. ~ y j. 6-So, they worked with'usaover several years .. + i li y

7 and last yew we changed our mind land'we' agreed and_we-

/

t 8:

said that,- "This kind of contract-with your. vendors j

..?, u 1 L\\g -} }: 9 -does/not need.to.be.on every_ safety-related supplier;_ 10 lbut:c you need to pick out," and we named for.them:some . i. W> 11 examples,: diesel. generators, for example,. or'.really f ipts L 12 ' . important ' equipment where " they should-be sure that-ypq g 13 they $ ave this kind of. relationship with,them. 'So, we: h

h4 ','

• s

~ l c .14

wrotega letter that;said more-that we expected them.on 3

l7',p>,W ,;n J 115 'a' : reasonable basis "' i 'y t toEestablish these.-things.where'it' \\ ~16 wasLreally, really importadt. ,' s M ~ N( b e t '17 So,lwe' changed our mind.. Q '< w j 18 COMMISSIONER CURTISS: lA111 right. And" k[gl~ r0 - q l 19 under the'recent; generic le$ter, the responses'are:all s q, 1 20 -now in, you indicated.' What happens.from here _on out?1 t W 'l I ?

21 MR. 'BERKOW

Welli, the responses. are W.

1 22 presently being evaluated and the status in some' cases 9 'i i t[, ' 23 will. remain incomplete. 'In - some ' cases iti will change l 4 ~24 t o' complete if: a licensee convinces us that _ they i ,h 25 .already are in' conf ormance with this new generic 1 I l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoOE ISLAND AVENUE N.W. 9 02) 234-4433 ' WASHINGTON, D.C. 20005 (202) 232 4600 'h I w;. s e, .x ,;.yfQ < ^ " ^ ~ '"^ ${}h,$ .i 133 a I s (, ft -l- . letter. ] -(>:g .y ,t _y Q)/ .2 MR.lPARTLOW: I believeLwe asked them to' i i

m.. y W'.

NJ 3 tellmu s ', E by.aptember 30th, have you established..the-j 4: . program'and if not, when? .5 MR.'BERKOW: And from1some of the results ,1 6 'that I've seen, some of them do have portions of the. t A. wM 7 program they stillsneed to e'st'ablish. The dates I've,

}

,,m u 5 ,s alf

.8 seen are mostly in 1991.for-completion.

);; l

i'l/ s

' T,, ' ' '9-COMMISSIONER CURTISS: Okay.. >+ w w.. C ' ?-, ,, 10 MR. /. BERKOW: So this -'is one that we'll: ,1 m i p.l ?[ ' 'D a [ ,. l . - 11 ' - still-have.to track-in many, plants as an,unimplemented! , H. <E s-12'- issue. y,

3,;

,t s jilE," ' ' ' 'l 13' And the final one, 99, was -originally 2 .1'4 -c'oncerned with --inadvertent closing. of the RHR suction-j Y,.m 4 m f .j kb ' valves'when the RHR. system was in use., It was later j {~' '15 c. v 16= . broadened.to. address failures; associated with mid-loop. ~ ~ w/,o The later generic,letterLasks for a group: 3r J17 . operations.. n 18: of expeditious'a'ctions and1some' longer. term programmed: 4 o ~ f4 l' 19i enhancements.. The expeditious actionsLare: essentially l m-j QJ;, 20 complete at' all. plants. The longer term actions?are ; z 21-mostly open for hardware changes that-are scheduled'to; 1 .s y 22 be done between now and the end of-1992 in most-1 f 'c -23 pl an'ts, 24 -( S lide ) May I.have the next slide, i t ,/ l25 please? i NEAL R. GRvSS 1 COURT REPORTERS AND TRANSCRIBERS 4 1323 RHODE ISLAND AVENUE, N.W. .(202) 234-4433 ' . WASHINGTON, D.C. 20005 (202) 232 6600 g i l !,, z' n M.'.a; i . ~ a i ? w h e" '34-a , J. N

1 COMMISSIONER CURTISS:

Herb,:I'm sorry, I i i 1 7 2' 'had one other-question'on the ATWS. In the paper, you ? 4 Y;" ' 3 point.out that-there's a second issue beyond the one 1: '4' that we just discussed on. reactor trip reliabil'ity: { 5 .that may involve a future generic communication. ~ UM ~! E1 6 MR.-BERKOW: Yes. 4 1 p ', Qg 7. COMMISSIONER CURTISS: Can. you-speak to o h' 8 that as well? 7,!h Sl ~ n .9 'MR. BERKOW: Yes. -We did not include that p-fs 4 1 i L. 10-because.we considered by-our definition, we l H 11 considered that unrraolved because-the. original. l' Y l'f / 4 1 if 12' resolution again has been appealed ' b-f the: industry and-11 3 ' the staf f,.is presently-developing a revised l' generic- ~' 4 y letter--which will.give'the industry several additional... s L14 I 15 c ptionso with which ' to : meet-Lthe ~ request that - we had o 1 16 originally -- 1 . - 4. 117 'Is - Faust here? Faust, you ' can.f perhaps; ,,sM 18 elaborate on that?- d a i b 19: MR.' ROSA: Faust' Rosa, Electrical Sys tems - f 2 01 Branch. 21 The three options that'. are going, to be-

A

'22 proposed to the industry: consist of first life testing ~! + p 23 as' origina11y' called f or ;by the generic. letter, and. >c .24 then an ongoing surveillance and reliability L l 25' . monitoring - program

• which would have a reactor-trip l-s NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS

.F 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON. D.C. 20005 (202) 232 6600

f., h,

- G ' ,.is i; 4-

35-breakeri - replaced or - ref urbiathd ' at, say, -500 cycles 1-

.2 ' givenf that.it' experienced two'- f allures. during that. 3

time.

And then we,go on to 1,000 cycles and arbitrary replacement' at that time. If-the licensee insta11's.a-5 diagnostic - recently developed diagnostic equipment

6

.whereby he can' monitor the degradation of the breakers 3 7: continuously, 'every time it's operated under test,. y. 8 then-he can extend the lif e ~ of the, breaker:. beyond? 9. '1,' 0 0 0' cy cle s. - And ' the third option is simply a 10 conservative, replacement, refurbishment 'every l500 ..11. ' cycles ~or' ~ two ' f ailures,- whichever occurs first. In 12 effect, that's what.we propose:to offer the industry. N/ M .And the ball's in. 1 13

COMMISSIONER ' CURTISS :

14-iour1 court on that?- r o ~MR. ROSA:. Right.- 15 3 l16 COMMISSIONER CURTISS :. ' Dra f ting: : the L 17 . generic letter and!the schedule-for that is -- '18 MR.' ROSA:- 'Thatt draft is 'in final =. draf t .19, form about right'now. AE ' 120 COMMIGSION.R CURTIS'S: Okay. o,- 21 MR. ROSA: We intend to send-it -to the' 22 .CRGR f or, :not review, but-for information. 23 COMMISSIONER ~CURTISS: Okay. Thanks. 24 MR. BERKOW: And jus't to clarify one v 25 further point, the fact.that that is opened at-most 'NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS =

C 1323 RHOOE ISLAND AVENUE, hW.

$) (202) 2344433 WASHINGTON, D.C. 20005 (202) 232 6600 >,jp ,I 36~ ( yW '1'.

plants 'is. not, reflected in

the. statistics I showed I

2. yo '.. 3~ COMMISSIONER CURTISS: I : understand, -i 4-because it's not resolved. s 5 MR. BERKOW: .Because we considered that-- { d 6 it-was not' resolved, that's'right. l gw 'COMMI'SSIONER CURTISS:- Okay. ? N e 8 MR. BERKOW: (Slide) 'Okay. Getting back n ^ 9 . to the ' final - chart, in ' summary, about 83 parcent of - 10 the. resolved: generic issues for which we requested 11~ licensee action have been'. implemented. Again, the: t - 1'2 '. ..s taf f believes -that nof plant has an unacceptable s ,y 13 .n' umber of'open; issues,.and the. plans and. schedules-for 7.j s 14 ' completing the remaining actions are acceptable to the g 15:

staf f and the staff is addressing thc,se issues 1

_- 16 trequiring further Laction "or position to reach. final } 17 resolutibn, several of-which we've dis. cussed here this ~ ,.O g ~ 18 morning'. u ' 19 ' A n d,. finally, in ou r opinion., the j y -l 20 remaining open issues do not pose an unacceptable 21 's a f e ty. risk. We are ' generally satisfied with 'the 3 o r 22 plans and. schedules that the 1. licensees.'nve proposed

m.

~ 23 for. completing them. And, that completes the'GSI portion. 24 1 25 .MR. TAYLOR: Mr.-Wessman now will. continue f L NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE, N.W. [ . (202) 2 % 4433 WASHINGTON, D.C. 20005 (202) 232-6600 Na g. ~ s:- - M, s: Y Olb.- o 1

w., + ~

, (! K g F, 37 ,n i g- -

. i '

i .i ..the/ briefing.'on updated USI implementation status. I 9 J 1 r a, y 'Tw ..2' 'MR.LWESSMAN:. Good : morning, Commissioners. .} in n .3

( Slide ) -

If I 'may have. the -.next ' slide, 4' p1 ease. This slide' displays ' - in gross. numbers the l ~ y C,m .5 's ta ti~s tic s for the unresolved. safety. issues when we

l

?. 56 reported-to you. in February and where they stand j 0' l' 17' currently at' the : end - of. September. (You - may recalli g'}m, 'q " x 8

that the :' process.that we,went'through to establish a-b.Li;

'i N 9'

qualityE database was very similar to ' what Herb ' has-

,., n

t described

toiyou for the GSIs.

You can-see we have'45

l

'10 n. 4 '80 .Lil. + morel USIs that are.now, closed'. 'A couple'of. examples t ) .12 forlyou,:and then-we'll' turn and.look~at what.ue call. i ;> i ? ~ f- - 13 the'" big ~four".in the USI area.- 1 y n 3 w p. ..14 For example,. re cently.' ' at Calvert L Clif f s' o n L15 < Unit1 'the plant 1was - returned - to operation. One of A 16: the' USIs-that-needed-to be resolved' prior. 'to its, w

1..

+ .1 75 ' returning to operation involved low:; temperature over-l X l18; 1 p r e s s u r e.- protect' ion, USI? A-2 6.- This had' to;.be j !L -{ ~ "q W 19 implemented ' f or the s tart-up,'of ; the unit ' and w a s.- j' J! "20

Similarlyn when they'get ready.E o restart. Unit:!2 they-a t

?. D21 will. complete implementation'of that same USI onthat i 4 w d y

22

. unit.

Li(@ t -9 ~ 23 Several.of -the. USIs :. involving the' 24 anticipated transient without scram, USI A-9, have 4 Q^, a i(/ 2'5 - been completed, but'this is the sort of thing that has 2 -NEAL R. GROSS 1 h. COUFU REPORTERS AND TRANSCRIBERS l' j 1323 RHODE ISLAND AVENUE, N.W. -g (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 4600 .l .-:f kl u

l s

s (" ,",O ,i 1 c. y ly u (j

i. Y

} ^ 1

4. g Q

38' i - r 'f ' i2 J& [

1.

foccurred over the-last eight months.' Gradually,;a'few 1 g.' > ;0 'more of-the~USIs have:been: implemented. -2 ' lY 4 -If'we can turn to the next' slide, 3' (Slide)-. g. p:Y,.' N, s 4i I would like"to'focusLyou on the-.' big four'of the USIs s, 'S that sti:.1' remain-unimplemented'at most plants. Thisi .o W, 6 .is the sa ae. big four. that we looked 'at in February' t g. ., N 7' and,' again, in a couple of cases there h'as - been [f. 8 progress on implementation-from the~ standpoint of the 1 b t Q< l 9-numbers. + 'l s t, O s: .10 -In all: cases, there has'been progress from ll ] 11~ thelstandpoint ofLactivity-either by.theclicensees-or' + ^ -12 the staff and I.can briefly' summarize for you. LNotic.e 4 !N,, 13 that' this group of the big four represents about 84 9-- - t, b' ' L14 -percent 'of : all unimplemented USIs, so this is where-

g w

2:\\

• J ) ;:

imost ofithe' activity. remains.to be: completed. -15 i;:.y l anticipated -- 16 In the c a s e. o f! DUSI' A-9 J a 17: transient without; scram, we"had 60hopen.in' February.- y '.18 Nine morei reactors - have implemented this one tand ; we 1 J -19 would expect by ' the 'end.of the ' year another ;nine or

20 ten will'have'probab1'y completed implementation.

21-O f ' t h e 5 1.' t h a t remain l unimplementedL at y %s X'4 (22 this point in; time, 20 - of them-- involve an issue' ; of s A T 23 . diversity where; in ' February there. was a dialogue 'N N J24 between ' the industry and the staf f regarding the .'dfversity of..manuf acture of certain trip system 125 NEAL R. GROSS

..p, '

COURT REPORTERS AND TRANSCRIBERS y,. ;f 1323 HHOOE ISLAND AVENUE, N.W. '(202) 2344 433 WASHINGTON, D.C. 20005 (202) 232 4600 .b a[t ~ I y _~. ^. 8 , ?l. s if a e m

g,; u; n

.h t e t. l ", ? .m 1 ~ components. Now, in' the - case' of those ~20 reactors, q ? c> + a

• 4-2

' they' did 'have an : operable system that could get us a g >,e!!; A 3' trip,3however, we were not 'satisfiedLwith the level'of' w p], + ~ 4' [ -diversity of = some of' the-components. The rissue W . 5 'regarding. has been resolved and at this j A4 diversity 6 pointithe' licensees now know the. action they:must take ' s; g and.it.is~to get,a proper diverse compon'ent.and they' '7 .i .o n ,yb. i .1 8~ -will: of. course have to.-Jorder parts a n d - s c h e'd u l e, y @pil s Linsta11ation duri w a refueling outage, 19 W6 s ^s &y ', ' safety evaluation reports ,j 10-of~the other-31, z s s tv 'l Q,p,j o byj the ist:f f ' t. ave.been completed, have'been sent to-11" q N the' licensees snd of; course'they:are now in'a position. j 12 m W 13' ?to= 'do ' procuremer.t of equipment..and; scheduJ.ing so' thel. y x .M my 14 actions 1 can E be, implencented[during - ref uelir.g, outages. >a l15 This means'that'over the< course of the nextstwodyears- '1 64 we'will have seen refueling outages 1on'the Iacilities,- 17- ' ard so ' by that ' time _ this a'ction - should Jbe' all-but > +, 18-completed we would expect. 19 COMMISSIONER ROGERS: Just before'you turn m. 20 away from that,; this diversity. question,1 how'did you- + ~ f 21 finally. define it, :thei satisf ying the diversity; i .22 requirernent? f 13' MR. WESSMAN: -Well, -I may ask Scott c. m A ' 24 Newberry to help me out o'n this, but there was a 25; question regarding certain components in the analogue [ NEAL R. GROSS COURT ASPORTERS AND TRANSCRIBERS

ij-p '

1323 RHODE ISLAND AVENUE, N.W. .(202) 234-4433' WASHINGTON. D.C. 20005 (202) 232-6600 s .I w b I e 2.- -4 40 ) m 1L _' trip. units. l, -3 .At one time, the licensees wanted to une w w -3'

components,- ' I believe, manuf actured by. Rosemount and l*. o-4 we -felt that the identical components in_ certain

-S ' portions of the diverse anticipated: transient without. 6 . scram-circuitry were identical to components in the b ordinary. scram circuitry, and that meant if there:was-i' l.- ~ type of - diode or. l 8: a-common. f ailure or. the same s 91 , something. in' this component ~ had a defect it could be 10; in both systems : and theref ore a trip unit from a .dif f erent' manuf acturer seemed ';to be t'he ' logical-J 11-L12 ' solution.to be.sure that some type of. common failure-r-> manufacturing defect would not - propagate L 13L

• or~ common w&

14 into-the two different systems. '15= COMMISSIONER ROGERS :. Yes. I understand' '16 : .the. concern. .It 's' just a question -of how you really p ;.e I ,17 ' res'olve ' it, because 'justi:_what - do. you really mean'by; 18 diversity? Is it diversity ~of manufacturer, diversity l' 19 o f-design of' the system the dif f erence - between '1 2 0._ redundancy.and diversity? I think these have all been 21 hsues in some sense that have been' involved'here and' Jl l/ 22' (I'm just curious as - to. how you finally settled _ on J 23 that. 24 For instance, if you had ' two redundant .25 ' systems basically the. same design, you would insist: L NEAL R. GROSS ~L COURT REPORTERS AND TRANSCRIBERS l 1323 RHOOE ISLAND AVENUE, N.W. [- (202) 234 4 33 WASHINGTON, D.C. 20006 (202) 232-6600 I. 4 i i.) 41 1, then that1 diversity is satisfied by having a different / 2'

manuf acc.urer,of the basic components?

'Is that where i ~ (, !), 3: i t? "l anded ? Or, would you permit the' diversity l s 4 requirement to-be satisfied only if the designs are 1 c 5 basically different? s.e T 6 MR. TAYLOR: Commissioner, I'd like to ask i m y ~ Scott -- f '7 l 8 MR. WESSMAN: I need help. -9 MR. TAYLOR: -. Scott Newberry. There's a lr j; . ~ think Scott:may be-- 10 -great deal of correspondence,.~but I .l

11 ablejtolgive you'aEcapsulenof where weefinally ended-up'on:this.

12 g'

13 MR. NEWBERRY: I *think oury view on 4 uh'

14 :

<diversityLwas,-as you stated.it, Commissioner Rogers, ) 1 2

15' that '.if the ' f unction --or' the design "was, suf ficiently-E16L

, diverse in 'itself.that would _have.been. an acceptable '17 -alternative,'. or -if, in redundant.scramE systems, a-18 ~differe.nt manuf acturer or. dif ferent Leomponent : woulc a

19 have

t

-20 .been -- 4 NE 21 COMMISSIONER. ROGERS: LThe only way. to 22 .' satisfy it, I take it?' 1 ll

N 23 MR. NEWBERRY:

Yes. In this -case,. both j 24 the alternate route injection system and the s crr.a b ,25 system u eJby-stables or trip units, comparatcis'that' r NEAL.R. GROSS

p COURT REPORTERS AND TRANSCRIBERS e

1323 RHooE ISLAND AVENUE, N.W. L' (202) 234-4433.' WASHINGTON, D.C. 20005 - (202) 232-6600 l' 42 = i 1 are identical. Those are the systems that are -m 2 installed on a boiling water -- virtually I guess it's 3 ~ about 20 boiling water reactors. The only real 4 diffcrence between those trip units as installed right 5 now is one in the ARI, alternate route injection 6 system, is an energized actuate system in the scram system. It's a fail safe design deenergized to 8 actuate. 9 It was our view that that difference was k 10 just not suffiaient and that especially since 11 replacement trip units were reasonably available, L 12 totally different components, manufacturing process, the trip ~~ 13 -that it was certainly reasonable to replace y 14 units with a different trip unit. 15 COMMISSIONER ROGERS: Is there anyplace -16 else that this question of how one interprets the 17 meaning of diversity comes up? b in-terms of the 18 MR. NEWBERRY: I can 19 ATWS, that is one of the' key places where' diversity - . 20 comes up. regularly and it came up rather frequently 21 throughout the past two or three year n as engineerc 22 sat and talked about was the system sufficiently 23 , diverse in - terms of different components, relays, 24 breakers, contactors and those sorts of things. But I 25 don't think it's come up in too many p? aces other than NEAL R.- GROSS COURT REPORTERS AND TRANSCRIBER

• 1323 RHODE ISLAND AVENUE, N.W.

(202) 234 4433 WASHINGTON, D.C. 20005 (202) 232 4600 "^ = ., = = 43. 4 - 1 .ATWS. 2 COMMISSIONER REMICK: It comes up, doesn't 3 it, in alternate shutdcwn systems in some of the 4 evolutionary plants?. .l 5-The question isn't one. of redundancy. ) 6 Redundancy is a given. Isn't it' a question of 7 diversity ' versus reliab'lity? In the solution where 8 you're' insisting upon diversity, how are you assuring 9 yourself that diverse syt ns may be less reliable 10 than the one. that 's redundant but has common 11 ' components? How.are you' solving that? That was one i 12 of the arguments, if I recall, that ~ people said, 13 "Well, you requiro us to be diverso. Perhaps we'll be 14 less reliable"." Was that resolved in any. rational.. 15 "way?- ' 16 MR. TAYLOR: Scott? '17 COMMISSIONER ROGERS: Thats~a good point, i 18; yes. 19 MR. NEWBERRY: I think. in all cases the 1 20 objective is' to improve the reliability of the 21 function of concern. In the case-of the ATWS rule, 22 the objective is clearly to improve the reliability of t 23 the rcram function. 24 COMMISSIONER REMICK: But are you 25 convinced that you will have more reliable systems as NEAL R. GROSS COURT REPORTERS AND TRANSCRlRERS 1323 RHODE ISLAND AVENUE, N W. -(202) 2344433 WASHINGTON, D.C. 20005 (202) 232-6600 k.' 44 1 a result? 2 MR. NEWBERRY: Yes, I am in terms of this 1 3 issue and Lne implementation of the'ATWS rule in 4 general. In no case, to my knowledge, were we moving 5 towards replacement of a re'iable redundant component 6 with an unreliable diverse component. In every 7 instance, in fact the rule requires it, that the ATWS 8 systems be reliable in themselves as well as diverse. 9 So, -the ATWS rule requires the plant to install 10 reliable but diverse backup features to actuate a 11 scram or to actuate other systems, turbine trip or '12 . auxiliary feedwater. l t '-13 COMMISSIONER REMICK: Has anybody -14 ~ questioned whether they can get as reliable components-15 as-they had? 16 MR. RUSSELL: Commissioner, 1E I 'could 17 help, this issue was discussed quite extensively. It-i 18 was. appealed. It was appealed-all the way.up through 19. the executive director level, including a CRGR review. . 20 One of the difficult issues you have is how much t 21-reliability' do you actually gain.through. diversity, 22 ' eliminating the potential for common mode failure, 23 which is very dif ficult to:. quantify, as. compared to 24 reliability with, say, a single system that is not 25 diverse. It necessarily relies upon judgment, the NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (2M) 2344433 WASHINGTM. 3 d 2000$ (202) 232-6600 r / 45 1 best engineering ~. judgment you can apply within the 2 context that was outlined in the rule. That's what o 3 the staff did and that review-.went through the entire' 4 process back and forth and we believe that we have ] l 5 achieved the goal of both highly reliabh and diverse 6 within the context of the rule. .\\; .7 COMMISSIONER REMICK: I hope so'too.

(

lj 8 MR. TAYLOR: The alternate equipment had 9 to have some evidence of the reliability. 10 COMMISSIONER REMICK: I hope. 11 COMMISSIONER CURTISS: As-I recall,- this 12 issue came 'u p when we were talking about c advanced ? 13 reactors just recently. If memory serves me, isn't- . 14 the staff taking-a'look.and' producing a paper on the 15 definition of diversit3?- I know-Chairman Carr raised 16' that question. I'm ready to go back and take a look 17 'at my notes,. but I thought there was something 18 expressed at one. of, the recent meetings. This is a 19 question that obviously arises in a whole range of 20-contexts. '21 M R. -- RUSSELL: I ' don ' t-recall at that 22 meeting whether it came up. It may have come up'also 23 when we talked about the approach that the British 24 were -using when we discussed reliability based 25 technical specifications because one of the things the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 23d #.? WASHINGTON, D.C. 20005 (202) 232 4600 46 o 1 British are doing is that they. allocate a system l 2 reliability goal and they won't allow you to go with 13 one system beyond a 10-4 reliability. So then you're 4 into diversity because of the concern for common mode 5 failure. So, they'll end up with a digital logic 6 system for one portion of it and a relay type logic 7 system f or - the other. They felt that that was an m 8-appropriate balance between the two in order to obtain q. -9 the~overall reliability that they wished for some of 10 their systems. 11 COMMISSIONER ROGERS: Maybe we ought to i 12 move on. -.13 ~ MR. WESSMAN: Moving on to USI A-44, t 14 station blackout, when we reported to you in February,- E . 15 'we told you that :there were still responses to be 16: received from the industry. .These were supplemental 17 responses to the original generic letter that had been 1 18 issued-earlier. These supplemental responses were. .i 19 scheduled for receipt in March of 1990 and those 20 responses : were received. Reviews are now in progress L l 21 on licensee responses on the station blackout' area.. 22 Thirty-two reactors have complete safety p 23 evaluation reports and I think most of them have been i l '24 sent out to the respective utilities. The review. p 25 process is prioritized to focus on certain facilities l~ i NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS j 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON. D.C. 20005 (202) 2324600 4 4 47 1 that may have particular emergency diesel-generator 2 contigurations or facilities with Mark I containment. [ 3 Our review schedule has us to where we would complete 4 the reviews by early 1992 and the safety evaluations !5 back out to-the utilities by that time. -I 6 After that step, of course, comes the 7 utility's ~ action to procure the necessary components 8 and schedule installation. In some cases, again, this 9 uould. be dependent on a refueling outage. So, we 10 could be a. couple of years away before we see a lot of 11 these unresolved items fully implemented. 12 In the case of USI A - 4 6., seismic 13 qualification of equipment operating plants, again 14 there has been progress from the standpoint.of reviews 15 and interactions with the industry. However,- i' 16 implementation has.not moved forward. When we 17 reported to you in February, we said that there was a .g -18 safety evaluation report that was being developed'by 19 the staff evaluating material.that had b'een submitted 20 'by the industry and that that.' safety evaluation would 21 be issued in mid-1990. That ' safety evaluation was 22 issued in June of this year and shortly thereafter the. 23 seismic ' qualification utility group submitted some 24 supplemental. guidelines for staff review, which of 25 course means that we have an additional review action. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON D.C 20005 (202) 232 6600 e-48 1-There will be yet~ another saf ety evaluation, from the 2 staff on these supplemental guidelines, and at-that 3 point we would expect.the interaction from the 4 standpoint of reviews to be completed-and then the 1 5 . licensees can move forward on implementation of this 6 particular action. 7 Finally, with USI A-47, when we reported 8-to you in February we told you.that responses from the 9 industry -to Generic Letter 89-9 were due in March - of 10 this year. Those responses were received and reviews 11 are proceeding in accordance with the schedule that we 12 all established. As.you can see, 29 of the reactors i 13 do have-full implementation of this unresolved safety 14 issue. There are no substantive issues that have been' q 15 raised in this one and the reviews are proceeding 16 pretty much as we expected. 17 So, you can see that.a total of 38 of the d 18 big four ~have been closed. We still have about 84. 19 percent.of ' the total 381 USIs, that are. involved in 20 this big four, but we believe that we understand, as 21 before, we know where-we are and we-believe that-we L' 22 are proceeding on a reasonable schedule that's l 23 commensurate with the safety. significance of the 24 issues and effectively using the resources that we l '. I 25 have. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N.W. l (202) 234 4 433 WASHINOTON, D.C. 20005 (202) 232 4600 i ~., 49 1-This completes the portion on the USIs and 2 .I think, subject to any further questions, completes 3 the staff's review, unless you have some. wrap-up I 4 remarks, Jim. l 5 MR. TAYLOR: No, I have no further j 6 remarks. 7-COMMISSIONER ROGERS: Other questions? 8 COMMISSIONER REMICK: I have' several 9 questions.. 10 Am I correct? There are no USIs that wait 11 to be resolved at the moment? a -12 MR. WESSMAN: That's correct. 13: COMMISSIONER REMICK: Now, how about in '14 the case of GSIs, to help me put it in perspective? 15 Are there GSIs that are in the unresolved stage' and 16 are there -- how many and are there GSIs for which the 17. priorities are yet to be set? 18 MR. BERKOW: The answer is yes. Perhaps 19 Research can -- yes to both questions. 20 COMMISSIONER REMICK: Do you' have any .21 feeling for the relative' numbers? 22 MR. TAYLOR: Is Research able to give that 23 right now? 24 MR. EMRIT: Ron Emrit from Research. As 25 of the end of FY '90, we show 13 GSIs to be resolved NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4 33 WASHINGTON D.C. 20005 (202) 2324600 g 50 -1 this fiscal year '91. I think it should be mentioned 2 that the cut-off point for Herb's generic-letter that 3 went out, this year was December 1989. Since that n 4 time, we resolved several issues,--about six, but only- '= a -5 two required any action on-the part of licensees and 6 that was issue number 70 and 94. But, I guess', - your. 7 implementation process, next time we'll probably 8 report on licensee. action on those two issues. 9 COMMISSIONER KEMICK: How many are in the 1 i 10 pot, then, for which priorities are being established- .11 and discussions with ACRS and so forth? { 12 MR. EMRIT: Well, if you're referring to-a 13 . issues that are being resolved right now, we have 14 about 27 that are being resolved for which priorities [ 15 have been established. 16 COMMISSIONER REMICK: But, are there any i 17 for which you're trying.to establish priorities? 18 M R'. EMRIT: Yes.. Righ't now, we ' ve ' got ~ 19 about 30 left -- 20 COMMISSIONER REMICK: 'I s e e '. 21 MR. EMRIT: -- to be prioritized. I'think 22 we-reported on the status of that to you a couple i 23 months ago, 24 COMMISSIONER REMICK: And how many come in 25 on a typical year? What's the input? NEAL R. GROSS COURT REPORTERS AND 'RANSCRIBERS 1323 RHOOE ISLAND AVENUE, N.W. (202) 234 4 433 WASHINGTON, 0 C. 20005 (202) 232-6600 51' _a 1 1 MR. EMRIT: Well, the number has come down -2 'over the last few fiscal years. You know, we used to 3 get 20'a. year, about 20, 25 a year, but' the last few 4 years it s averaged ' about three or four per fiscal 5 year. 6 COMMISSIONER REMICK: Okay. Thank you. =7-You now have information from the 8' Commission on implementation of the safety goal and -9 you've: proposed as part of:the regulatory impact study 10 an IRRIS system on enabling licensees to propose s '11 schedule for implementation of things like GSIs. Do 4 12 _y o u - s'e e. any specific impact 'o f safety goal 13l -implementation on GSI resolution? 14 And, likewise, I guess the case of IRRIS 15 is.more ' obvious, because you plan. to provide '16 l'icensee's with the, opportunity' of suggesting 17 schedules and ~ then the staff will approve those or: -( 18 disapprove them. But,ihow'about safety. goals? Do you

19 see'any possible. impact?

It's_not a' loaded question. -20 It's just an open question in my mind.. t 21 MR. TAYLOR: We have'-- CRGR is trying_to 22 keep the measure of safety goal in front of'it. The t i, L 23 recent revisions of their instructions are to apply 24 that. l' 25 Do you want to address it from the staff l NEAL R. GROSS l COURT REPORTERS AND TRANSCPIDERS 1323 RHOCf ISLANti AVENUE N.W. '(202) 234 4 433 WASHINGTON D.C. 20005 (202) 232 4600 l. i ( L. 52 .1 end, Bill? 2 MR. RUSSELL: At least from the staff end, a 3 while we have not seen all the guidance proceduralized 4 as to what additional information may be required to 5 demonstrate that a proposed ' new requirement is 6 consistent with the safety goal, I don't personally 7 envision that that's going to be a lot of additional' 8

effort, so I would not expect that it would take 9

additional time once the guidance is developed and '10 we're into a process for doing that. There may be ~11 some where it's difficult to quantify and we'll end up 12 relying on judgement, but I don't see that process-i ' 13 ' impacting!the resolution portion of getting it through-14 a CRGR review. There may be some start-up delays the paper and'the 15 associated with that, with getting 16 inf ormation and - presenting it, but once that's done I 17 see that~ steady state it should not have a significant 18 impact. - 19 As it relates to the IRRIS program and,the 20 integrated regulatory requirements implementation-21 schedules that licensees would be developing, because 22 there may be plant-r,pecific differences that cause the 23 worth of a p:rticular item to change v.h en we-go j 24 through generically we look at it on a best estimate i 25 It may be that an issue would turn out to have a lower NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON. D.C. 20005 (202) 232-6600 53 ( 1 value cost benefit'to a licensee and we've indicated 2 that 'that may be prioritized low, and. then when you _g 3 look at that on a continuing basis that may in fact 4-result in a determination that it's not necessary to 5 implement at all. And that was the approach that we n _ 6 had. proposed for handling on a plant-specific basis, 7 because we could not really. effectively address 8 . cumulative requirements other than generically with an ~ 9 idealized plant. 10 So, I don't believe that there would be 11 significant impacts from the safety goal. In fact, .12 the process that we think-about in going through and 13 developing requirements I ~ think is consistent with 14 .that and it's just. formalizing something ' which. is 7 15' . going on informally in judging the need for 16 requirement using the cost benefit analyses type of 17 approach that we have in the value-impact guidelines. 'j 18 COMMISSIONER REMICK: The backfit. rule? 19 MR. RUSSELL: Yes, sir. 20 COMMISSIONER REMICK: Thank you. 21 COMMISSIONER. ROGERS: C o m m i s s'.' o n e r -22 Curtiss? 23 COMMISSIONER CURTISS: I actually just had 24-one question. This is very thorough. I appreciate-25 the update. It covered a lot of ground that I_had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RH00E ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON, D C 20005 (202) 232-6600 54 1 questions about. 2 In USIs, given the definition, Dick, of 3 'USI on your chart here that involves condition not r 4 likely to be acceptable over plant lifetime, have. ' we 5-given any thought to how we will treat USIs in the 6 . context of those plants seeking license renewal where t i 7 'the USI is outstanding? 8 .MR. WESSMAN: I'm not sure that we've 9 looked specifically at that, but I think our belief is 10-by the time a plant reaches the license renewal phase, 11 the USIs would have been fully implemented. As we s .12 indicated ~and we looked at the big four, most of these 13 have.been implemented in the next two or three years, 14 ' depending on the refueling outages and the procurement i l-15 . of ' components. That only ' leaves: about 60 that are 16 -scattered amc. 7st - the other USIs. But,I think from 17 our ' knowledge of where the USI. is or the licensee 18 schedules, these 'should be fully implemented-by. the 19 time we have to deal with the license renewal 20 situation and I would expect that that will not be a 21 consideration at that' time, i 22 MR. TAYLOR: That would be true for those i L 23 USIs we now know and have in our inventory. We have 24 to keep our mind open. That experience could bring 25 others. We hope not, but that's a possibility. Then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 4600 c.- .55 1 ) I we'll have to deal with that. l 2 MR.- PARTLOW: I think to the extent that 3 implementation of something based upon some future USI 4 is really_ needed. f or adequate protection, why, it's 5 going to have to get done. If that USI and its 6 resolution surfaces at the lith hour of license '7

renewal, I don't know that at - this point we would 8

adamantly say that that would.have to be implemented 9 before the license was. renewed. But certainly there i -10 would be some kind of reasonable schedule worked out, e ,11 just as there is today. 12 MR. TAYLOR: We would have to evaluate-- 13 clearly.in any of them, they're implemented by order 14 as a condition to it. We could do that. 15 COMMISSIONER CURTISS: Okay. That's all I 16 have. 17 COMMISSIONER ROGERS: That's all? l 18 Commissioner Remick, I think - you had 19 another? ? 20 COMMISSIONER REMICK: Going back to, Jim, 21 what you proposed in the beginning, the possibility of 22-consolidation and changing schedules,_I support that i 23 now that we have a much better feeling of theLstatus 24 of implementation. But looking ahead, do - you feel-25 that to keep yourselves updated and us updated on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 2324600 1 N, 56 l 1 impl'ementation it will be necessary to go out with a 2 generic' letter again or will your database in the SIMS 3 system be suf ficient to. enable you to do that in a 4 realistic way? 5 MR. BERKOW: We. did not anticipate the 6 need for another generic letter. I think - we have .i 1 7 systems in place now where we can -- now that we have L-8 a good base line, we should be able to keep it up to 9 date. 10 COMMISSIONER REMICK: Good. 1 11 That's all, Ken. 12 . COMMISSIONER ROGERS: You just touched on 13 this question of the SIMS database. Wha t. -is the 14 advantage of maintaining these two databases, SIMS and 15 the 0933 separately? There's a distinction there 16 between the -- 17 MR. ' BERKOW : ' Yes.- 0933 tracks the 18 research activities basically.. in the prioriti'zation 19 and resolution of the issues. The SIMS database.goes 3 20 further than that. It's.the status of issues that-are 21 in the implementation stage as well as those that are 22 completed. So, it really goes further. than the 0933 23 database does. 24 MR. PARTLOW: This 0933 is organized; by 25 issue. Our databases are more oriented towards plants NEAL R. GROSS COURT REPORTERS ANO TRANSCRIBERS r 1323 RHOOE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON. D.C. 20005 (202) 232-6600 i 57 l 7 1-Land the-issues'within those plants.

i '.

2 MR. BERKOW: Right. And _ of course the 3 SIMS has more in it than just GSIs or USIs. It's'much '4 broader. It's got all of the licensing activities in i 5 it. ( -[ 6 COMMISSIONER ROGSRS: When SIMS gets-I ~ 7 updated, does that update 0933 or not? .i 8 MR. BERKOW: Well, we do have a dialogue t 9 with Research and.-- 10 MR. WESSMAN: Here's our database guru. 11 MR. SCHOLL: My name'is Raymond Scholl and: -3 12 for the' past_ two-years I have served as the safety 13. information management system coordinator'for NRR. 3 14 The-databases that we've ~ been talking 'j 15 about' to a'large extent are the same. The Office of 16 Information, Management within the NRC maintains a very 17-large series of. interlocking databases-at NIH, one of 18-which is GEMEX,- which is related to 0933.. 0933,_as 19 you've=been briefed before by Research'several times, 20 is a NUREG which outlines the problems, possible. 4 21 solutions and costs. And when an ~ issue has been 22 resolved, that-is we know what we want to do about=it, 23 it defines that resolution. It may define it in terms 24 of_saying generic letter umpty-scrunch was issued. 25 Another part of the system, the SIMS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 4600 9lN 58 1 . system itselfj is a reporting system which is designed 2 .to extract the definition of the problem and the i. 3 solution to the problem and supply plant-specific data 4 where a plant has been required to do something. The 5 data there is detailed data such as when the licensee 6 responded, when we wrote an SER or a memo to files-or 7 some other way., administrative 1y closed out - NRRs 8 review. It includes information as to whether or not .9 the licensee had to implement something and,-if~ so, 10 when. It includes information on verification. 11 There are lots of SIMS reports out. Each j 12 one of these reports only contains a small amount of a 13 very large. volume of. detailed data which.isLavailable 14 from the computer if you should ask it the right 15 questions. Included ~in the system, for instance, are 16 inspection report numbers, dates-when inspections were 17 conducted, information on whether or not-verification i 18 is required, information on the relationship between 19 .that particular SIMS issue and other related issues. 20 It contains some costing information and 21 it also includes some history of the review path in-22 some cases. In a lot of cases, the data is ir. complete 23 because it-has not been-of interest to the staff or to - 24 the Commission as other aspects such as the 25 implementation we've worked on for the last two years. NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS K d RHODE ISLAND AVENUE, N W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 4600 -i i ,.O 59 l-COMMISSIONER ROGERS: Okay. I - guess 2 there's still a lot of questions that I'd like to hear i q 3 about, but not today. Thank you very much. l i 4 Can you give us a little bit of' assurance -3 5 or. reassurance - on the station blackout issue? There 6 is not a single plant that has implemented the closure j

- j 7

on the station blackout issue. Is that correct? ] 8 MR. RUSSELL: Let me start with that first 9 and then ask, Faust Rosa to cover it. 10 We're prioritizing the reviews. We 11 clearly want -to do those reviews where staff approval j 12-is needed before hardware can be implemented. -So, j 13' we're generally doingt the reviews-where an additional 14 AC. supply is being proposed for'the station or where i 15 they ' re -proposing to add additional - diesels or 16 turbines. We are doing the reviews where facilities 17 are ' basically proposing to cope with a station 18-blackout for a period of time using existing equipment j 19-is ' on a lower priority. So, we've developed that 20 scheme to do those first which would impact the-21 implementation schedules of licensees. 22 I believe we've completed approximately 30-23 reviews for sites and a number of those, on the order 24 of about a third, I believe it's nine or ten, we've t 25 found do not conform to the rule. So, we are in an NEAL R. GROSS COURT REPORTERS AND TRANSCRipeno 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C 20005 (202) 232 4600 s g ,i. 60 ..y 1 -iterative mode waiting-for the licensee to propose an 2 alternate scheme which would be in conformance with 3.- the rule. I .4-So, there has been significant work going 5 on. It's being locked at at the highest' levels. In 6 fact, 'we're preparing a status report for the EDO 7 which would provide the detailed schedules f or - the ' 8 . reviews, what's been completed and what has not been 9 completed, such that this issue is getting visibility. 10 Overall an to-how we're doing it. was the subject of 11 -the last program review with the EDO, at which time we - 12 ' committed to a priority to do. those reviews first 13-where we felt they would either not meet the rule and ~ 14 something elsechad to be proposed by the licensee, or . here there were significant modifications for which 15 w 16 staff-approval was -on the controlling. path for 17 implementing those modifications. i 18 COMMISSIONER' ROGERS: Well, could there be 19 a -- you're setting your priorities by. looking at 20 those proposals that involve hardware additions or 21 changes' as distinct f rom a coping approach. Is it 22 conceivable'that some of those coping approaches that 23 have been proposed are really quite unacceptable and 24 that not reviewing them carefully right now is leaving 25 something to a later date that perhaps ought to be NEAL R. GROSS COURT REPORfERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232-6600 .4 61 1-flagged and paid attention to? 2 MR. RUSSELL:

Well, that's clearly the 3

case. In fact, the latest Commission paper that we sent forward on emerging technical

issues, we a

5 identified the reactor coolant pump seals issue and 6 what is the leakage'that you would expect from a seal u 1; l 7 as' a significant issue, Generic Issue 23. Depending l 8 upon the resolution of that ' issue, it may be that 9 facilities wou~cd not be able to cope during a blackout k 10 condition. This affects four boiling water reactors 11 tisat do not have the turbine-driven makeup capability, 12 isolation condenser-type facilities, and pressurized .13 water reactors. 14 That issue is presently in the review 15 process. We-are proposing a generic letter to alert l4 16 those utilities. This was considered, by the way, at i 17 the time we promulgated the rule when we made the L 18-assumptions about leak rate f rom these seals and 3 l 19 identified that the leakage could be higher. So, yes, 20 'there's an example where coping may not be appropriate 21 so that that aspect of coping is important. 22 The other aspect is for dual, unit sites 23 where - they '.re proposing to use excess capacity from 24 the unaffected unit to provide AC power to the unit 25 that has the blackout. We've had quite a bit of NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE, N W. (202) 2344433 WASHINGTON, D C. 20005 (202) 232 4600 1 .u,' 62 jjf l 1 dialogue back and f orth with industry on that issue, s 2 The staff does not agree with what I would call heroic [ t '3 measures, that is removing systems from service on the 4' unaffected unit in order-to. provide power. We'd like t 5 that to be done using the normal systems that are 6 required for shutdown for a loss of off-site AC power. / 7

Then, if they do indeed have additional capacity y

l q 8 available, to consider that. So,- those types of l t 9 reviews where they're proposing to use ~ the other. unit 10 on site's diesels is also getting priority. l 1 11 So, this is a complicated

review, 1

L 112 ' depending upon what solution response to the rule has 13 b'e e n. p r o p o s e d by the licensee. We are giving them- -i 14 h'igh priorities. We've done the best we could in q 15 allocating. resources t o' do: that, and we have had a I 16 number. that. we-have ' concluded the proposal does not l 17 meet' the-rule'and we're trying to get through. those. -i d' i, L 18 So, we're not going back and forth with Qs and. As -, t .u 1 l 19 trying to get resolution to agree on.each one. If we- ~ 20 find that the proposal does not meet our requirements, . '21 we're informing the licensee of that and moving on'to '22 - -the next one to get through'them as quickly as we can. 23 The schedules have slipped. some and we're giving i-24 management attention to that fact, but it's a 25 complicated process for us. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 4600 l 63-a 1-COMMISSIONER ROGERS: In closing, I'd like 2 to urge continued progress towards implementation of 3 the' resolved USIs and GSIs because even though we use 4 the terminology " resolved, " the job is not really 5 completed until the implementation is carried out at y 6 all U.S. nuclear power plants, t '7 If in the future staff identifies any 8 bottlenecks to the timely in.plementa tion of these 9 - issues, they should advise the Commission promptly and-10 should seek any necessary guidance. 11. In~ addition, Agency's programs,such as the J '12 .IPE program or some of'the staff's proposed activities 13 in, response;to the regulatory impact survey currently 1 14 under Commission consideration may also affect the 15 schedule for iniplementation of closure of these issues '16 and the Commission ' wil'1 want to be kept apprised of 17 such matters'. In any event, staff'should continue to 18 keep the Commission advised of> the status of F is implementation of the closure of the USIs and GSIs. 20 I'd' like to thank' the staff 'f or an 21 excellent job in briefing us this morning. 22-If there are no further comments from my 23 fellow Commissioners, we stand adjourned. 24 (Whereupon, at 11 : 21 a. m., the above-25 entitled matter was adjourned.) NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. 7 (202) 234 4433 WASHINGTON. D.C. 20005 (202) 232 6600 CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the United-States Nuclear Regulatory Commission entitled: TITLE OF MEETING: ' PERIODIC BRIEFING ON INDUSTRY IMPLEMENTATION OF GENERIC SAFETY ISSUES i FLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING: OCTOBER 25, 1990 were transcribed'by me. I further certify that said transcription is accurate r.J complete, to the best of my ability, and that the transcript is a true'and accurate record of the foregoing events. d'L cd4 t ~ V j 4 Reporter's name: Peter Lynch .4 l l, i NEAL R. GROSS COURT REPORTER $ AHO TRAN$CRl0ER$ 1333 RHODE ISLAND AVIHUf. H.W. I (202) 234 4433 WASHfMOTON. D.C. 20005

202) 232 6600

l il i de v l o m s 'm g es e, n Reu i A f f s o3l e o w

• x s

w i n 0 r si M. B uy w wa 9 f W ~4 om 9 Av i o c tt k s 1 n a lt r n ae a e e 5 r s P" o ntf P B W 2 n ioSa t r sr a s S mba o eed e w p% r b s n r aeh t oc JHi c c yei %g i e i R O mi t r mtae s n o n e C eG Lo m + e -m l ~ p w m ww i m e. v _i i l PURPOSES

• To Provide:

(1) Curren't implementation Status of GSis (2) Implementation Status. Update of USis

• Is implementation Completed?

e if Yes, When? i

• If No, What Remains to be Done and When?

t l ^*"t w ~-'W ~~- ~ a ~y ~ ^ ~. .1 ... y j BRIEFING OUTLINE

• Chronology of GSI Task Effort
• GSI Selection Process
• GSI Database Development
• Summary of GSI implementation Status
• USI Status Update i

.~ 1 - ~ i DEFINITIONS GSI

• Affects a Number of Plants
• May Have Potential for Safety. Improvements USl
• Affects a Number. of Plants
• Questions Adequacy of Existing Safety Requirements
• Final Resolution Not Yet Developed
• Involves Conditions Not-Likely to-be Acceptable Over Plant Lifetime l

_ ~ ~ .s ~..j '? 6 GSI SELECTION PROCESS T

• Starting Point -TGeneric issue Databases l

l

• Elimination
• Staff involvement / Concurrence i
• Result-- 32 issues' & Subissues j

i 1 l i I l DATABASE DEVELOPMENT

• Response.to GL 90-04
• Independent Staff Status Deterniination a Staff QA/ Concurrence
• SIMS Database Entry

--"-*--"l -' - - "' ^ - " " " ' "* -- -"'-" '- '' .__h___.._ r GSI IMPLEMENTATION STATISTICS Total Applicable GSI Actions at 111 Reactors 2662 Total implemented 2211(83%) Total Unimplemented 451(17%) No. Unimplemented at Individual Plants 1-8 i GSis UNIMPLEMENTED AT MOST PLANTS i i NO.OF i .GSI PLANTS OPEN 43 Reliability of Air Systems 61 51 Improving the Reliability of 108 Open-Cycle Service Water Systems i 67.3.3 improved Accident Monitoring 86 1 75 Salem ATWS Item 2.2.2, Vendor interface for Safety-Related Componenis 108 99 RCS/RHR Suction Line Valve Interlock on PWRs 60 TOTAL 423 4 ) EVALUATIDN OF GSI IMPLEMENTATION STATUS 1 1

• About 83% implemented a No Plant Has Unacceptable Number of Open issues
• Acceptable Plans and Schedules for Completing Remaining Actions; Staff is Addressing lssues Requiring Staff Action or Position to Reach Final Resolution

USI IMPLEMENTATION STATISTICS 2/90 9/90 Applicable USIs to be implemented 1927 1927 USis that are implemented -1501 -1546 Unimplemented USis 426 381 ~N- 1 i i 1 USis UNIMPLEMENTED AT MOST PLANTS 1 i PLANTS OPEN PLANTS OPEN a US! 2/90 9/90 l A-9 Anticipated Transient Without Scram 60 51 i i l-A-44 Station Blackout 116 116 l A-46 Seismic Qualification of Equipment in Operating Plants 66 66 i A-47 Safety implications of Control Systems 116 87 l TOTAL 358 320 i or s.e,, n ,}}