ML20062D620
| ML20062D620 | |
| Person / Time | |
|---|---|
| Issue date: | 11/01/1990 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1820, NUDOCS 9011140052 | |
| Download: ML20062D620 (173) | |
Text
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ACS!S&I820 now OFFICIALTRANSCRIPT OF PROCEEDINGS op AgeDCy:
U.S. Nuclear Regulatory Commission Advisory Committee On Reactor Safeguards a
l Tide:
Subcommittee on Advanced Pressurized Water Reactors Docket No.
1 l
LOCAMON.
Bethesda, Maryland j
oAm Thursday, November 1, 1990 PAGEs:
1 - 135 4
XR'S~DSe Coay-RET,
$0 File L ife OfIES CO?lnittee i
ANN RILEY & ASSOCIATES, LTD.
1612 K St. N.W Suite 300
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Washington, D.C. 20006 i
(202) 293-3950 ly 3; y
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1 2
-3 4
PUBLIC NOTICE BY THE 5
UNITED STATES NUCLEAR REGULATORY COMMISSION'S 6
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 7
8 DATE:
Thursday, November 1, 1990 9
10 11 12 I
13 The contents of this transcript of the
^
14 proceedings of the United States Nuclear Regulatory 15 Commission's Adviscvy Committee on Reactor Safeguards, 16 (date)
Thursday, November 1, 1990 17 as reported herein, are a record of the discussions recorded at is the meeting held on the above date.
19 This transcript has not been reviewed, corrected J
20 or edited, and it may contain inaccuracies, a
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2 U.S. NUCLEAR REGULATORY COMMISSION i
3-4 5
6-ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 7
'8-
?
9 4
10 SUBCOMMITTEE ON ADVANCED PRESSURIZED WATER REACTORS
.1 I
12 i
.13 47 3 LU 14 Nuclear Regulatory Commission L
15 Conference Room P-110 s
.16 7920 Norfolk Avenue 17 Bethesda, Maryland 18 i
19 Thursday, November 1, 1990-20.
8:34-o' clock a.m.
I
' 21' 4p.
22.
j l2 3 l
l-l 24
\\ l 't
\\
(
% )'
25 1:
2 l'
PARTICIPANTS:
1 l;'('~
^ %s 3
J.. CARROLL, ACRS Subcommittee Chairman 4
C. MICHELSON, ACRS Member S
P. SHEWMON, ACRS Member 6
E. WILKINS, ACRS Member 7
M. EL-ZEFTANY, ACRS Cognizant Staff Member i
8 E. KENNEDY, C-E 9
S. RITTERBUSCH, C-E 10 R. TURK, C-E 11 C. MILLER, NRR/NRC 12 T. WAMBACH, NRR/NRC i,q 13 T. ROTELLA, ACRS Staff Member
- l ' 1,j 14 15 l
I16 o
17 18:
19
- 20 21-22-
- '23 24
!,i O -
'2 5 G
1
- ~
3 l'
PROCEEDINGS
((
2 (8:34 a.m.)
v
~3 MR.-CARROLL:
Good morning.
4 The meeting will now come to order.
5-This is a meeting of the Advisory Committee on 6
Reactor Safeguards Subcommittee on Advanced Pressurized 7
Water Reactors.
i 8
I am J.
Carroll, Committee Chairman.
9 The other ACRS members in attendance are Carl 10 Michelson, Paul Shewmon, and Ernest Wilkins.
I 11'-
The purpose of our meeting today is to discuss the 12 ABB Combustion Engineering Licensing Review Basis document
.f l
-13 and a staff Commission Paper, SECY-90-353, regarding the LRB q7-s
(,)
for the System 80+ evolutionary light water reactor.
- 14
)
L L
15 Dr. El-Zeftawy is the cognizant ACRS staff member,.
1 16-and Tom Rotella is also here, since he will be taking over i
[
17-this project eventually.
L 18 The rules for participation in today's meeting 19 have-been announced as part of the notice of this meeting i
20-previously published in the Federal Register on October 18, l
21 1990.
A transcript of the meeting is being kept and will be
'l 22-made.available, as stated in the Federal Register notice.
12 3 -
It is requested that each speaker first identify 24 himself or herself and speak with sufficient clarify and
',r~ (
^
(
)
25
. volume so that he or she can be readily heard.
s 4
1 We have received no written comments or requests f2 to make oral statements from members of the public.
3 I would point out to the members that Tom and Med 4
have passed out an additional SECY, SECY-90-362, which is 5
pre-decisional and is erroneously titled " Staff Comments on 6
the Continuing Need for a Licensing Review Basis Document 7
for Each Passive Design."
8 Actually, it also discusses the staff's views with l
l-H 9
respect to System 80+,
as well as the staff's views on LRBs 1
h 10 for high-temperature gas-cooled and liquid-metal reactors, 11 but for our purposes this morning, the. couple of paragraphs 12 of interest are those dealing with Combustion System 80+,
f 13 and as I said, this is a pre-decisional document, which is
(()
\\,1 14 available only to the Committee members.
15 With that, unless other members of the 4
16 Subcommittee have things they'd like to bring up at this 17 point, I'd'like to proceed with Combustion Engineering.
j l
18 While Ernie is getting ready, I would mention one L
19' other thing to refresh the Committee's memory:
We were 20 asked by the Commission, cn1 December 15, 1989, in a staff 1
21 requirements document, to -- it says "The ACRS should review 22 both the GE ABWR and the CE System 80+ LRB documents-and.
23 comment on each.
The ACRS should pay particular attention 24 to the-issue of whether the approach taken in the two LRB k./
25 documents is consistent."
I 5
1 We, of course, have mentioned this from time to
.I) 2 time in the past, and I guess the full Committee has 3
indicated that Carl, ABWR, and myself, 80+, as subcommittee
'4 chairmen, ought to deal with this at the appropriate time, l
5 and obviously, if we're going to make this kind of a 6
comparison, we're going to have to wait until the combustion 7
System 80+ LRB document is complete, but that is something-8 we have on our plate, at this time, to deal with.
9 Ernie?
10 (Slide.)
o 11 MR. KENNEDY:
Good morning, gentlemen.
i 12 My name'is Ernie Kennedy.
I am the Manager of p-~
13 Nuclear Systems Licensing for ABB Combustion Engineering 14 Nuclear Power.
15 I have with me today our lead licensing engineer 16 on System 80+, Stan Ritterbusch, and also, we are expecting 17 to arriveJshortly, if the fog lifts, Rick Turk from our-3 18 Light Water Reactor Program Office.
19 We did not bring a large crew-today to go into a 20 lot of technical detail.
We have had some technical meetings with the Subcommittee, but I think, with the people-
-21 22 we have here'today, we can answer the questions you may have 23 on the LRB.
24 (Slide.]
)'25 MR. KENNEDY:
What I would like to discuss today l
[
6 02 1-is that-the System'80+ Licensing Review Basis document, the
[j-
- 2 last major revision we submitted to the staff was last 3
January, January 1990.
That is the version we will be discussing today.
4 5
We did send in a letter in August of 1990 1
6 addressing two or three issues which the staff asked us to l
1 7.
address, which commit to revisions to the LRB on some 8
specific issues, and I will discuss what those are today I
9-with you, i
i 10 The other thing is I would like to discuss what we I
11 expect might change in the LRB as the result of what we
-i 12-understand staff comments to be, and finally, very briefly -
- i/~N
-13
- you-mentioned the-comparison to the-General Electric ABWR N,-
14
'LRB.
I'd like,.very briefly, just to touch on that for the l__
E15 benefit of the Subcommittee.
i 16 (Slide.]
1 17 MR. KENNEDY:
The idea of a licensing review basis
-i
['
18 concept was' initiated generally in '86 '87 timeframe.- It V
t i
19 was initiated by General Electric essentially.
The_ purpose 20 of a licensing review basis document, at that time, was to,
~
i 21'
-document administrative procedures for a review of a design i
H2 2 '
. certification application and the approach to new technical 23~
concerns.
24 In general, an LRB discussed the scope of the i
i 25 design, which would be submitted to the Commission, to the
7 1~
staff, the anticipated review schedule, the administrative 2
procedures under which the review would be conducted by the 3
staff and the applicant and technhal issues beyond those of 4
the existing body of the star.dard review plan and regulatory 5
guides. 'That is what essentially an LRB was intended to do 6
and I must remark that I think LRB's were kind of committed 7
out of the -- you know, invented out of the blue.
There is 8
no guidance that I know of that defines what an LRB should 9
or should have in it.
So, they've been kind of created as 10 the need arose.
11 MR. CARROLL:
To your knowledge, Ernie, is there 12 any requirement -- or maybe Charlie can answer this -- for
-t 13 an LRB in Part 52 -- is it part of the process envisioned by.
14 Part 52?
15 MR. MILLER:
This is Charlie Miller from the 16 staff.
Part 52 has no such requirements.
17 MR. CARROLL:
All right.
18 (Slide.]
19 MR. KENNEDY:
The System 80+ Licencing Review 20 Basis Document was initially drafted and submitted to the 21 staff in July of 1987.
Between the issuance of that draft 22 and the issuance of 10 CFR Part 52 there were, in fact, 23 several revisions which I have not put on the chart here, 24 just to keep the chronology brief.
There were several 25 revisions-in this timeframe.
t 8
1~
The salient point is that in April of 1989 10 CFR
..l- -
Part 52 was issued and we._sMhasquADily revised our LRB in 2
3 3
August of 1989 to reflect our understanding of the Part 52 4
requirements.
This is significant in that,_ prior to this_
5
. time, there were some policy difference with the staff that 6-we were arguing.
In our view, those policy decisions were 7
resolved with the issuance of Part 52 and with this r
8 revision, we believe we no longer had any significant policy 9
disputes with the staff and the Commission.
So, we bellava 10 this LRB was in compliance with Part 52.
11 In. December of 1989, there were two Staff 12 Requirements Memoranda issued by the Commission.
The m
l 13 following month we revised the LRB once again to incorporate l
q0
- 14 some of the requirements of these SRM's.
In particular, the 15-Staff Requirements Memorandum asked for comparison to the-
\\
16 EPRI Requirements Document.
We provided such'a comparison l
17 in this revision of the LRB.
y I
18 This Staff Requirements Memorandum also put in l
l 19 place a process by which the staff would identify policy 1
20 issues and bring those policy issues to the attention.of the 21 ACRS and the Commission for resolution.
We reflected that I
L22 process in this LRB revision in January of 1990.
23 Also in January of'1990 the staff identified p
policy issues to the Commission in-SrnV-94-916.
The Staff 24
)
25 Requirements Memorandum on that was issued this past June of l
9 i
1-1990.
Now, as it turns out, in this revision of the IRB, we l2 correctly anticipated 13 of the 15 policy issues that were 3-included in SECY-90-016, so we did not revise our LRB at 4
this point.
We thought it was still adequate, that we had 5
correctly anticipated the policy issues.
Although, in 1
6 August 1990 we did send a letter, particularly hydrogen
-7 control is the most important technical content of this 4
8 letter, and I'll go into it; committing to revise the LRB-in 9
a couple of specific places.
10 The last bullet here is we're aware that the staff 11 has prepared a SECY paper on the combustion engineering LRB 12-that is not publicly available.
We have not had a chance to 13-examine that yet.
We believe we understand, in general, q, /
\\,_
14 through our discussions with the staff, what is in it; but I 15-would caution we have not yet seen the words in the SECY 16
' document itself.
L 1:
17.
(Slide.]-
18 MR. KENNEDY:
Now, in parallel with the continuing 19 discussions on the LRB, I want to point out to the 1:
20 subcommittee', that we have been proceeding, in parallel,-
21 with completing the-submission of our Standard Safety 22 Analysis Report CESSAR-DC, our Standard Safety Analysis.
23-Report.
We began submittals in November of 1987.
They_ltave 24 continued.
You can see here the sections of the SAR -- the 25 topics which have been submitted and we have discussed much
10 1
of this material with the subcommittee.
2 (Slide.)
3 We just submitted, in fact, although we've given 4
an advanced copy to the staff, we just put in UPS yesterday 5
a'large amendment that includes the general arrangements l
6 which we discussed with the subcommittee at the last t
7 meeting.
It includes the final ECCS and containment 8
analyses and all of.the Chapter 15 safety analyses are in 9
this amendment which is now coming to you.
It also includes 10 all of the Chapter 14 start-up test requirements and
-11 includes the final set of our PRA results.
That amendment p
.12 is now in transit officially to the staff and.they should be j
1 I
l -
~4
. 13
' receiving it shortly.
" ' Q~'1 :
\\
14 MR. MICHELSON:. I wanted to ask Medhat, do-you l'
15-know when I'm going to get a copy of the CESSAR document?
4 1.
16' Amendments don't do me any good.
I mean, I won't.even have i
l L
17-a' copy of the document.
I've asked for some time now for a l=
18 copy.
p 19 MR. ROTELLA:
Yes.=
I just heard about a week ago 20 that it was on its way.
. 21 MR. MICHELSON:
Okay.
I haven't received it yet.
22 MR.! KENNEDY:
We took an action item at the last 23 subcommittee to send a set of CESSAR-DC's to a number of s
24 members of the Committee.
We wanted to fold in this 25 1 amendment in the document before we sent it to you.
W
- +
11 1
MR. MICHELSON:
Oh, it will be in there already?
[J.
b f2 MR. KENNEDY:
Yes.
3 MR. MICHELSON:
Oh, that's fine.
l 4
MR. ROTELLA:
They also had a problem with your --
5 they had a problem with your address also, I believe, and I 6
gave-them a-different address.
-l t
[
L7 MR. KENNEDY:
We intend to file this amendment and i
8 then send you the' set of books, so you don't get a book and 9
then a huge stack of papers.
i 10 MR. MICHELSON:
That's fine because it takes a l-11-secretary a while to file all that.
p-12 MR. CARROLL:
On the next viewgraph, however, he's L13 going to tell you about another -- about the --
4,._%V
't 14 MR. KENNEDY:
We're not going to save you all the 15 work.
There is going to be some more work.
)
16 (Slide.)
17
}m. KENNEDY:- We do plan, by the end of this year, 18 to submit what we hope will be the last planned amendment to L
19 the document. ; Clearly, there will be amendments as we 20 respond to staff review and staff questions, But by the end-21 of this year, we plan a submittal that includes the results 22' of the-seismic methods,'the seismic envelope and the seismic 23 criteria for the design, '"e proposed technical 24 specifications, we will complete.our write-ups on our 5
I) 25 resolution of the unresolved safety issues and generic
i 12 1
safety issues.
We have part of that information in the f2 document now, but we're continuing to update it.
3 We hope to close.out a list of open items which 4
have resulted from the staff review to date, so there will 5
be some miscellaneous amendments to the document.
We will 6
put in our program for environmental qualification and the 7
radiation and shielding assessment.
So those are currently 8
planned for the December 1990 submittal.
L 9
MR. MICHELSON:
A little while back we had a l
10 meeting where you discussed the layout of t.' plant.
Is 11 that layout going to be reflected in this new addition, this 12 Amendment 147 I think it was a 14 or whatever the number
-13 was.
lg-sy V
-.14 MR. KENNEDY:
The October Amendment includes those j
15 general' arrangement drawings.in it.
16 MR. MICHELSON:
Okay.
17 MR; KENNEDY:. And-I have-not.yet seen the print 18
-quality of those documents.. If I th' ink they're not'quite 19 that readable, I believe-we'd be happy to send you some full L
size drawings as well.
20-L 21 MR. MICHELSON:
I'just wondered if that was the 1
22 level, though - 'the whole-document's brought up to that 23 level.
24 MR. KENNEDY:
Yes.
I _)
25 MR. MICHELSON:
Okay.
Thank you.
s N
p
13 1
MR. CARROLL:
Are they going to be in color?
n c (_)'
2 MR. KENNEDY:
No.
3 MR. CARROLL:
I've got colored pencils.
4 MR. KENNEDY:
Let me point out for those of you 5:
who -
you've been following this for some time -- you will 6
note a deletion from this slide, and I should point it out 7'
to you.
In previously showing this slide there was an itgn 8
9 here called Inspections Test Analysis and Acceptance _
i 1
10 Criteria -- the ITAAC required by Part.52.
Given where we 11-stand today and with the Commission still-deliberating on
'I 12 the level of detail issue and whether Tier 1 or Tier 2 7
']
13.
approach that NUMARC has recommended, there is no way that
' 14 -
we can meet a December 1990 submittal date for those 15 inspections tests and analysis.
I removed it from this.
{
16
'It will have to be a separate' submittal to-the; 1
.17 staff,;and-I'm not going to show a schedule of that until I
-18' understand really where we're headed.
So you will' note that-L 19-that is no longer here.
ll-20 That's an important document. It's something we f
L 2 14 need to keep our eye on, but I don't know when to schedule 22; it right now.
23.
(Slide.)
i
'24 Okay.
Let us turn to the licensing review basis
'('~)
. document itself.
It's got seven sections and an appendix.
A_/
25:
~
r t
'(
14 1-There is nothing unique about the organization.
It's fairly l/
.'O 2
straightforward.
The appendix is a list of the design
,EN-1 3-differences that we have identified between the System 80+
i 4
design and the evolutionary requirements document produced i
S by EPRI and under review by the staff.
i 6
And I will briefly go through each of these 7
sections of the LRB and talk about what's in them.
8 MR. CARROLL:
Before you do that, Ernie --
9 101. KENNEDY:
Yes.
10 MR.. CARROLL:
-- answer an even more basic
'll question. LWhat is it called?
Is it called a combustion 12 Eng,ineering System 80+ URB or is it the ABB Combustion
' l.q.
13 Engineering?
()
14 MR. KENNEDY:
It is the. Combustion Engineering, 15 Incorporated System-80+ standard design licensing review 16
-basis document.
18 MR. KENNEDY:
No ABB.
As a matter of legal 19 standing, Combustion Engineering,'Inc. is still a legal L
entity-and is the organization applying for the design i
f 20 I
s 21 certification.
We are still Combustion Engineering, 22
- Incorporated, although we are wholly owned by ABB.
When I 1
L
- 23.
.use the phrase ABB Combustion Engineering Nuclear Power, 2
- 24 that is-the name of a division.
It is not a legal entity.
)
25 MR. CARROLL:
Okay.
1 l
o
15 1
MR MICHELSON:
Just for clarification, as long.as t>"
i 2
there is a short pause, can you tell me how complete your A
3-design's going to be in terms of the -- you know -- what
.4 parts of the design will not be detailed?.
5 (Slide.)
6 MR. KENNEDY:
We are providing an essentially D %-
7 MR. MICHELSON:
Oh, wait.
I see you're there, p
8 MR. KENNEDY:
Well, the slide doesn't tell you 9
much, but I'll try to answer it in words.
L i
10 MR. MICHELSON:
All right.
11 MR. KENNEDY:
You will remember that Combustion 12-Engineering its the 1987 '88 time frame was arguing for a l
I
.13 major portion of a plant.
We started'out with the nuclear 14 steam supply system, expanded that to the nuclear power
'15 module.'/ fart 52 requires an essentially comolete plant,). We i
16 are providing an essentially complete plant.
-17~
If you look at the U1B, there's a1two page listing f
18 of all the systems and structures included in the' plant.- It
~
191
.is a complete plant.
There is a very short listing of 1
20 structures and systems for which a conceptual design will be' i
L 21' provided.
Those are generally the site-specific structures E
L 22 the intake structures, the warehouses, the administrative 23.
buildings and that type of structures.
It is.a complete 24 nuclear power plant.
l: i
-s o,)
25 That argument is over.
We are not arguing that it s
16 1
should be anything less than a complete nuclear power plant.
2.
And the LRB, hopefully, says that.
That we are providing'an 3
essentially complete nuclear power plant.
4 The other thing that the introduction of the LRB 5-discusses is any exemptions which we take to current 6
Commission regulations. _In the January version of the LRB, 7
ge_ identified one potential exemptio E That is the 8
requirement to addr_e_ss 100% zirc/ water hydrogen generation
_/
9-i n __t h e_ d e s i g n._
We were at the time of the LRB supporting 10 the EPRI suggestion that it be 75% zirc/ water reaction.
We 11.
. identified that in the LRB.
^
12 In the August 1990 letter which we.sent in, we
('.13 commit to 100% hydrogen generation as required _by SECY 90 _.
14 016.
That will require us to out igniters in the design.
-15 So.we are currently. evaluating now the type of igniters, the 16 location of the-igniters, but we are.not going to take that 17 exemption at the present time.
18-MR. CARROLL:
In your consideration of the igniter 19 question, are you looking at DC powered igniters?
/
p l
20 MR. KENNEDY:
Yes.
We are~looking at them.
I A
21
.believe -- Stan,.you can correct me -- that the -- right'now
~
22
.it' appears to be that the preference is going to be AC 23 powered igniters, but we are looking at DC powered igniters.
24 MR. CARROLL:
When we talk about powered, I'm
_25' talking about ' ne ultimate power.
l
17
(
I l
MR. KENNEDY:
Yeah.
That evaluation's currently
MR. MICHELSON:
Let me ask, on that failure of 7-~s 14 containment, I'm not sure what kind of failure you are 15 referring to, of course, you could have a direct core 16 release to the containment and subsequent interactions which 17 cause the containment failure.
18 Is that the type of failure you're talking about, 19 or are you talking about spurious opening of isolation 20 valves or whatever?
21 MR. KENNEDY:
I will come back to this, because 22 again, this is-a place where we believe the staff has a 23 comment.
You should be able to give me a
- (~~%
(
25 rather simple answer to what failure of containment -- what l
l
(
45 1
it means.
,r
'S 2
MR. KENNEDY This is any sequence which would 3
result in this release, whether it's through failed valves 4
or a mechanical failure of the containment or that in 5
combination with normal leakage, any sequence which would 6
give you this release result.
7 MR. MICHELSON:
You're looking at closure at 10 to 8
the minus 5 for those.
Is that right?
9 MR. KENNEDY:
For the external events?
10 MR. MICHELSON:
Yes.
11 MR. KENNEDY Ten to the minus six for everything 12 else.
/N 13-MR. MICHELSON:
Yes, but for external events, such
{
s 14 as a fire that might spuriously open a containment-isolation 15 valve, you won't look at it unless it exceeds 10 to the 16 minus 5.
17 MR. KENNEDY:
The intent of this was for the 18 seismic event.
If, because of the we.f we have constructed 19 it, the Committee and the staff conclude that, hey, you do l
20 that; if you do that, you're excluding other events you 21 ought to consider, we're certainly willing to revise this 22 statement.
This was not our intent.
23 MR. MICHELSON:
Really only meant for seismic 24 events.
y^)
v 25 MR. KENNEDY That was our intention.
-=
l 46 1
MR. MICHELSON:
Okay.
4 r
j 2
MR. KENNEDY:
And if, by the way we stated it, we 3
made it a little too global, we're more than happy to adjust 4
the language.
5 MR. MICHELSON:
It is kind of global for the fire 6
case.
7 MR. KENNEDY:
We simply didn't sharpen our pencil 8
enough when we wrote the words down, and I will come back to 9
that briefly a little bit later.
l 10 (Slide.)
11 MR. KENNEDY:
Now, again, in terms of technical 12 issues, the LRB discusses generally, in one or two 13 paragraphs, this list of issues.
14 The significant thing perhaps about this list is 15 if you compare it to the list of 15 technical issues which 16 the staff identified as policy decisions to the commission, 17 the LRB addresses 13 of the 15.
The two that were not.
18 addressed were equipment survivability for severe accidents 19 and in-service testing for pumps and valves.
They aren't 20 addressed in the LRB not because there's any unwillingness 21 to address them, we simply weren't quite astute enough to 22 anticipate that the staff would identify those as policy
- 23 issues and we have.no problem adding discussions of those 24 two events to the LRB, consistent with the discussions in 25 SEcY 90-016.
47 1
(Slide.)
2 MR. KENNEDY The rest of the issues are discussed 3
in the LRB.
4 MR. WILKINS Not just discussed, but you don't 5
identify -- let me rephrase this.
Are there any differences 6
of opinion between C-E and the staff in these 13 areas?
7 MR. KENNEDY:
Let me get into that in just a 8
minute, and I believe the staff later may discuss that as 9
well.
Remember, I haven't seen their SECY paper yet, so I 10 have to qualify what I think the disagreements might be, but 11 let me get into that in just a minute.
12 (Slide.)
j t
13 MR. KENNEDY The LRB also has in it a comparison 14 with the EPRI Requirements Document.
We updated that list 15 in our August letter.
So, if you want to look at a current 16 list, the August letter has our most current listing of what 17 we believe those deviations to be.
18 I should point out that any of the EPRI crit;ria 19 which are related to regulatory compliance we meet, by 20 definition the regulatory requirements.
There are some 21 performance and other requirements in the Utility 22 Requirements Document that we do not meet.
Those are based l
L 23 specifically on our evaluation of our design, the cost, the 24 benefits of meeting those particular ones and we do deviate Li t l
\\-)
25 from some and we have a list of those.
l
l 48 1
1 This is a little gratuitous, I put it on the
]
/~
I 2
slide.
That list is for information and compliance with 3
those EPRI Requirements should not be a staff regulatory 4
requirement.
5 (Slide.)
6 MR. KENNEDY:
Now, let me turn to -- two things.
7 We have the January LRB, we have an August 1990 letter 8
committing to revise the LRB.
The most significant item is 9
to, as I mentioned, change our committment on hydrogen 10 control from the 7S percent generation to 100 percent 11 generation, which will add the igniters.
12 The other point is -- one of the post-TMI f-~
13 regulations right now requires, as we read it, the
('
14 capability to add a containment penetration and a vent.
As -
15 I understand it now, a literal reading of the regulation, as i
16 the staff reads it, implies that'the penetration must be 17 there.
We do not have a penetration.
We have reserved 18 space for penetration, a penetration can be added.
We do 19 not have a penetration.
20 I think the staff feeling is that literally that 21'
. would require an exemption from the regulation.
If that's 22 the staff's position, then we'll probably put in the piece 23 of paper citing that as an exemption from the regulation.
24 We can't add a penetration, we can't add a vent; but the 25 penetration is not in the design at the present time.
So we
49 1
clarified that the penetration is not there.
S) 2 MR. MICHELSON:
Is there some reason why you 3
resist adding the penetration?
4 MR. KENNEDY:
I guess the best reason is it's a 5
steel containment.
It's easy to add it later -- cut a whole 6
in steel and weld in the penetration.
7 MR. MICHELSON:
It's not very expensive to put it 8
in now.
It's probably a lot cheaper than to add it later.
9 So, it's -- and it's a trivial part of the cost of such a 10 plant.
In fact, in your case, it's only the cost of the il pencil on the paper.
12 MR. KENNEDY:
It would not -- it would not take 13 much cost in me arguing to go get out my pencil and paper 14 and put it in.
15 MR. MICHELSON:
Yes.
I just don't see why it's an 16 issue worth elevating to the point of taking exception to 17 the regulation on.
18 MR. KENNEDY:
It may not be.
19 MR. MICHELSON:
It escapes me as to why it's so 20 important to you not to add it.
21 MR. KENNEDY:
Let me make one remark.
In 22 discussions with our utility customers, containment venting 23 is a very sensitive issue to our utility customers.
24 MR. MICHELSON:
Yes, but you're not putting the --
l
'i
\\-
25 you're not adding the system, you're just making the
50 1
provision that if it's decided later it should be added, c
)
2 then you are ready to go.
3 MR. CARROLLt Recall, Carl, that EPRI has taken a 4
strong position that PWR should not have it.
5 MR. MICHELSON:
Yes, but we're not dealing with 6
EPRI here, we're dealing with combustion.
7 MR. CARROLLt But combustion is dealing with EPRI 8
or the facility members.
9 MR. MICHELSON:
It just escapes me why they want 10 to play the game on this, but that's there business.
I 11 think we'll just comment accordingly.
12 MR. CARROLL:
I'd do the same thing, I wouldn't 13 put it on either.
14 MR. MICHELSON:
Well, yes, but we're in :
-15 different position; we're on the other side of the tape now.
16 MR. RITTERBUSCH:
Ernie covered the point when he 17 indicated that we really don't want a vent in the design and 18
. we don't expect to be adding it based on input from 19 utilities.
20 MR. KENNEDY:
Okay, and then the August letter 21 also provided an updated to the comparison with the EPRI 22 Requirements Document.
I should point out that if and when l:
23 the LRB, in fact, is completed, we would probably want to 24 sit down with the staff on whatever day that was and redo
' D(,j 25 this list because this list has changed over time as the l
P 51 1
EPRI requirements document has changed and our design is
(
)
2 developed.
So, we would want to make sure that list is as 3
accurate as we can the day the LRB got approved.
4 (Slide.)
5 MR. KENNEDY:
Now, let me return -- let me discuss 6
what we might expect to do to the LRB in response to what we 7
understand the staff comments to be based on our discussions 8
with the staff.
When the SECY paper is released, we will 9
have a better idea of exactly what the wording is, but this 10 is kind of where we see things we're going to do.
11 We believe that the staff would like to see us put 12 jn there a specific commitment to provide the SRP comparison 13 that's required by 50.34(g) I believe.
We intend to do
,r~}
V 14 that.
Putting such a statement in is not a problem.
15 We've discussed this -- that we would be happy to 16
_put in a commitment to live with the most recent supplement 17 of the USI/GSI Status Report.
We intend to do that anyway.
18 On the subject of the definition of containment 19 failure.
SECY 90-016 has a definition slightly different 20 than what we proposed in our LRB for containment failure.
21 This is the definition out of SECY 90-016.
We have no 22 problem adopting that definition for the LRB, if the staff-23 feels that's the appropriate definition.
In fact, our 24 review of that is that's somewhat easier to meet than our 25 definition.
S2 1
MR. CARROLL Help me out.
What does that first
()
2 bullet mean?
3 MR. KENNEDY:
The first bullet is that 50.34(g) 4 says that the applicant shall provide a comparison to the 5
Standard Review Plan, the extent to which the application 6
meets the Standard Review Plan.
The staff has asked us 7
whether we intend to do that.
The 'nswer is yes.
8 MR. CARROLL:
So that's just paperwork?
9 MR. KENNEDY:
That's just -- yes.
10 Now, there is some history behind that.
There is 11 a footnote, I think, in the regulation that says those 12 people who hold an FDA don't need to retrofit that l
l (^]
13 requirement.
When we started off on System 80+, we said i
\\)
14 we're starting with CESSAR-F and amending it.
I think the 15
-staff just wants some assurance that we're not going to pull 16 that footnote out and try to hide behind it.
We're not, 17 we're going to provide the comparison.
18 All right, the staff can speak for themselves, but 19 I think that's why they wanted it in there.
20 MR. MILLER:
Mr. Kennedy is accurate in his 21 representation.
22 (Slide.)
23 MR. KENNEDY:
To continue, the 10 the minus fifth 24 cutoff on external events, we believe the staff has a
. i.O)
(_
25 problem with and we are willing to work with the staff to
53 1
redefine that in such a way that we accomplish our real qi,,/
2 objective in a manner acceptable to the blaff.
That's, you 3
know, a negotiation that we think can be carried out.
4 There are three writeups in our technical 5
discussion on midloop --
6 MR. MICHELSON:
Let me ask you, why do you have a
]
7 problem with the external events that makes you unwilling to 8
accept the 10 to the minus 6 for the external events?
9 MR. KENNEDY:
The only concern is the large 10 seismic event.
That's the only thing that we need to try to 11 accommodate.
12 MR. MICHEISON:
By large, you mean what, in excess r~
13 of the SSE?
l 14 MR. KENNEDY:
Way in excess of the SSE, the large 15 seismic event that both fails the vessel and the containment 16 at the same time.
Considering the uncertainty on~those L
17 numbers, we don't want to be in the position of redesigning i
18 the plant for this extraordinarily large seismic event and 4
19 that's our only objective.
20 MR. MICHELSON:
Other than that, for all other 21 external events, you're wiling to use the 10 to the minus 6 22 criteria?
23 MR. (ENNEDY:
I believe that's it, and we can get 24 our PRA pecple in to talk about it, but I think we can reach 25 an agreement with the staff.
54 1
There are three of the discussions of the I
)
2 technical issues which we have in the LRB which, if you read 3
SECY 90-016, the staff position uses somewhat different 4
wording than we used in our LRB.
Of course, our LRB 5
preceded our seeing 90-016.
The staff would like for us to 6
revise those words so that they are more consistent with the 7
wording in 90-016.
We don't believe there's any 8
substantive problem here and we think we can reach agreement 9
with the staff on the appropriate wording of those issues as 10 well.
Also, for the two issues that were in 90-016 that we 11 failed to address in the LRB, we believe that they would 12 like to see those addressed in the LRB, and we'd be more i
13 than happy to do that as well.
i e
(
14 Again, I don't think we have any disagreements 15 with what the staff would like for us to write down.
16 (Slide.)
17 MR. KENNEDY:
Very briefly, I know the ACRS does 18 have a request from the commission in one of the SECY papers 19 to perform a comparison-of the CE and GE LRB.
Just for your 20 information and your background, the function or the l
21 original intent of the LRB, as we think, was the same.
l 22 In fact, when we started to write our LRB,- we did l
13 the logical thing.
We xeroxed the General Electric LRB, l
24 struck out General Electric, wrote Combustion Engineering Y
\\
25 and went from there.
It has evolved over time -- the basic l
t
55 1
structure is the same, but the content has differed O( )-
2 significantly because of our own progress in developing the 3
application which we have continued to do in parallel.
4 The issuance of Part 52 -- Part 52 really defined 5
a lot of things that the GE LRB tried to define in advance 6
of Part 52.
Finally, the staff now has the process by which 7
policy issues are being resolved by a different method.
8 They are being identified outside the LRB, taken to the 9
Commission and the ACRS for resolution and that's being done 10 as a separate process.
11 Our LRB has evolved from, if you will, the GE LRB 12 because of those issues.
The reason I bring this up is; l
13 we'd be more than happy to come to the subcommittee and the
,()N
\\.
14 full committee tw talk about such a comparison, but in all 15 honesty, I don't know how much I could add to help you with 16-that.
17 If the committee can make that comparison without 18 the benefit of another meeting, so be it, but there's 19 nothing magic in the differences.
\\
20 (S. '=..]
21 MR. KENNEDY:
Let me conclude, if you will, with a 22 little policy and overview.
We've been pursing the LRB 23 since 1987 and its approval and issuance by the staff has 24 been somewhat elusive.
In our view, the importance of the V
25 LRB has diminished.
. -. -. = - - -.
- -~
v
.__._..._.__..m..m__
..m.
...._.m m
_m.
l 56 1
It is not, in our view, as valuable a document as f
A 2
it~once was.
Part 52 has been issued and that settles the 2
procedural questions that may-have been in question earlier 4
in 1987 and 1988.
Policy issues, many of them have been 5
raised to the Commission and resolved.
We. fully expect that 6
the staff is going to raise several more policy issues and 7
they will go through that process.
8 I don't know that the LRB is a necessary 9
ingredient in that process.. To the extent that the LRB 10 defines a schedule, we acknowledge that the schedules are 11 uncertain and that they are policy issues open that will 12' affect that schedule.
To some extent, any schedule sN 11 3 discussion'in the LRB has to be qualified.
d L
14 We-also have encouraged the staff and we have v
r 15:
supported that the review of CESSAR-DC has been and should
.16 -
continue to be reviewed in parallel with the LRB.
Most of 17 the material in CESSAR-DC isn't really'affected by the 18 discussions in the LRB.
19 Much of that review, under the Standard Review 20 Plan, can continue.
Finally, as we perceive =it, although.
21
.there are some revisions to the LRB that the staff would u
22 like to see, we don't perceive a significant policy 23 disagreement with the staff that-we can't resolve.
l i
24-
- Now, again, I would qualify this again that we 1On U
25 have to look the SECY paper and see if there are any ss L
p
57 1
surprises in it, but based on our discussion with the staff, t(r~y
. 2 we believe we can resolve these expeditiously.
The LRB-1 j.
3 really, in our view, doesn't serve the purpose it might have 4
served two or three years ago.
5 MR. CARROLL:
What do you mean by the second dash 6
up from the bottom, most material is.not affected?
7-MR. KENNEDY:
For example --
8 MR.-CARROLL:
Any material affected?
9 MR.' KENNEDY:
Oh, yes, for example, the LRB talks 10
.about that we will provide an analysis of midloop operation, l.
11 the instrumentation, the design features that address 12' midloop operation.
1 1
But so does SECY 90-016.
a >-~ ) :
k U
14 MR. KENNEDY. Correct.
15 MR.' CARROLL:
Whether the LRB existed;or not, 16 you'd be providing this analysis of midloop operation.
17-MR. KENNEDY:
You are correct.
If I took this 18' sentence and said, most of the material in'CESSAR-DC is 1
19 unaffected by SECY 90-016 and any ocher policy issues that 20 come up, it would be the same statement.
l 21 MR. CARROLL:
Well, on a positive note, what
'22 advantage to Combustion is there to the issuance of an LRB?
23 What do you see it doing for you?
You're going to get the 24
.same question,. Charlie.
25 MR. WILKINS:
I was going to ask it negatively.
.~.
58 1
In-fact, it might be helpful to you to hear my wording of 2
the same question.
3 What difference would it make if someone were to 4
say, as of right now, we're going to forget all about the l
5 LRB?
Just forget it.
That's the same question.
6 MR. KENNEDY:
Is that question addressed to me?
i 7
MR. WILKINS:
You're on the stage, yes.
It's i
8 addressed to you.
I 9
MR. CARROLL:
Charlie gets his shot at it, too, j
i 10 MR. FENNEDY:
My answer is; I don't believe l
11 anything would change.
The issues which are open between us 12
'and the staff would'still be subject to discussion and the
);
q,a-13' LRB would not be a necessary ingredient.
I believe that if l
l L
14 the LRB disappeared tomorrow, it would not change anything.
15 Now, you phrased the question positively.
The 16-real benefit, or the only benefit, I can honestly state, is 17 we'd finish'a long process and get it.done.
That's not much 18
-of a benefit, but it's the only one I can cite right now.
19 MR. WILKINS:
I heard someplace, at one time, that 20 you might anticipate some benefits in your marketing 21 strategy if you could. point to this document.
22 MR. KENNEDY:
Again, I would phrase that.
f 23 negatively. 'Our inability to get~an LRB has, in some j
24 markets, been construed as a negative, not that it has any
, ~)
km, 25 positive benefit, but gee, why can't you get one?
There l
l
59 1
must be something wrong.
q I. _f.
2 MR. MICHELSON:
You could simply point out one is i
s 3
not called for by the regulations.
4 MR. KENNEDY:
- Correct, 5
MR. MICHELSON:
That's one good reason for not 6
issuing a document that isn't required, and nobody seems to 7
have any great deal of usefulness for it.
Why are we 8
issuing it?
It's not required by the regulations.
9 MR CARROLL:
Do you want to deal with that now?
10
'MR. MILLER:
How about if we do this?
Why don't
_ e-let Ernie finish his part.
11 w
12 MR. CARROLL:
I think he's finished, isn't he?
13 MR. MILLER:
Then I'll try to take that one before 14 Mr. Wambach gives the formal presentation for the staff.
15 MR. CARROLL:
Paul, do you have a question?
'16 MR. SHEWMON:
Just out of curiosity, do you have 17 additives, or is_the staff. requiring additives on' 18' containment spray systems now?
There's some corrosive-19 things got put in' plants earlier on -- that is an excuse --
20-and it hangs some on how much iodine you've got to worry 21 about and so on.
22 MR. KENNEDY:
Stan, do you remember what the 23 additive situation is right now?
- 24 MR. RITTERBUSCH:
~Yes.
The staff does not require 25 additives, and we are going through our analysis without 1
- g...
60~
)
1 them.
i
\\_).
2 MR. SHEWMON:
The other question, as you keep.
3 pumping this, you may --
L 4
MR. RITTERBUSCH:
I can't answer the question with 5
pH control.
I was speaking with respect to iodine removal 6
during accidents.
7 MR. SHEWMON:
But Combustion used to have some 8
baskets of salt down underneath the core.
L 9
MR. CARROLL:
That's Westinghouse with trisodium 10 phosphate.
11 MR. SHEWMON:
CE.did, too.
t 12 MR. RITTERBUSCH:
We had an interface requirement.
If~'I.13 The actual-baskets were not in our design.
- l. U 14 MR. SHEWMON:
The stuff that got GPU at TMI-1 in 15 such bad trouble with their. steam generators was a 16-thiosulfate of some kind.
That's different from'what you 17 said, though.
You said a trisodium phosphate.
Okay.
18 MR. KENNEDY:
I was going to simply suggest ---I 19 don't know how long your list of technical questions are.
I 20 am.still expecting Rick. Turk to join us a little bit later, 21 who can go a little bit deeper in your technical questions.
22 If you would like to come back to those after the 23 staff presentation,'we might have a little more information 24 at. hand.
I'd also be some interested in the 1
61 1
labyrinth you have down beneath the vessel, because you have 2
at least two things in here.
One, you've got lots of area, 3
so that anything that comes out of the vessel in a molten 4
state spreads out and has got lots of space to take care of 5
the cooling.
6 MR. CARROLL:
I don't think that's true.
I think 7.
they have got enough space to meet the 0.02.
8 MR. SHEWMON:
That's what I am defining as a lot 9
of space.
10 MR.-CARROLL:
There are some that might argue that 11 that isn't a lot of space.
Well, my concern -- or not a concern 7 %.
13 but the question is more whether, even if you had four times
-Q 14 as much space, it would do you any good.
4 15 It might get some people off your back, but my 16 impression is this stuff is viscous enough that it..wouldn't 17 spread anyway,'but also, more immediately to the question,
' 18.
youLtalk about a labyrinth which would help'you with a DCH 19 accident, and I'am mildly curious to know how you can have a l
20 labyrinth which will stop the gaseous flow of this stuff in 21 one accident but wouldn't sort of.make-the flow of anything.
22
- that came out
- s vessel pretty difficult, too.
23 MR. RITTERBUSCH:
This is Stan Ritterbusch.
I'd like to give a brief response, and if we have to get into
-2 4-1
\\
25 more details, then we'll have to wait until Mr. Turk.
62
)
1 The part about the labyrinth, the-labyrinth is i
rx Q
2-with respect to the event path from the cavity up to the 3
containment.
It's designed to be a complicated path so that 4
material cannot get directly from the cavity.
5 The cavity itself is relatively open for spread-6 out.
7 MR. SHEWMON:
So, that's up off the floor.
l 8
MR. RITTERBUSCH:
Right.
And it has something we l
9 call a debris-collection chamber, intended to keep any i
10 debris that splatters around in the cavity area, but the 11 vent path -- the labyrinth is a vertical vent path.
[
E 12-MR. CARROLL:
From the cavity.
i
- .q -
13 MR. KENNEDY:
Mr. Turk has just joined us.
-tg 14 MR. SHEWMON:
Welcome in from the fog.
-15 MR. RITTERBUSCH: _Ernie, maybe we would like to 16 simply finish an identification-of the issues and then take p
17 a break, and we can talk with Rick.
l i
18' MR. KENNEDY:
Rick, let me put you on the spot, 19 since you just' walked in_the room.
20 Dr. Shewmon asked a question.on the current 21-situation with regard to containment spray additives.
What 22 additives are we currently using for either iodine removal 23 or_pH control?
Do you know the' answer to that offhand?
24 MR. TURK:
I don't know the exact answer at the 25 moment.
I do know that we are not adding any additive for
63 j
1 lodine control. -The pH control question is, I believe, ir) still under review, as to how were going to maintain pH in
- ig-2 3
.the cavity and hold up volume.
4 MR. SHEWMON:
Thank you.
5 MR. KENNEDY:
Any other questions?
6
[No response.)
7 MR. CARROLL:
You're going to stay around?
8 MR. KENNEDY:
Yes.
9 MR. CARROLL:
Let's take a break at this point and 10 reconvene at 10:15.
11 (Brief recess.)
12 MR. CARROLL:
Let's reconvene.
I guess we do have t
13 some additional questions of Combustion.
l f s l
14 MR. KENNEDY:
Yes.
As I understand it, the l-15
-subcommittee might-like some more discussion on the 16 deviations we've' identified from the EPRI utility 17 requirements document.
The most recent list is in our 18
' August 28th letter.
a 19 We can'either^just'go through these items one by
{
20-one, or I could ask the subcommittee if there are particular l
21' items they would like for us to discuss.
l L
22 MR. CARROLL:
I think it is the latter.
l 23 Carl also just raised an issue regarding Table.2 24-of that document.
25 MR. KENNEDY:
Yes, I heard that discussion during
64 1
the break.
'2 Our intent was that that Table 2, those items for 3-which a conceptual design will be provided, we'd intended
[
'l l
4' that to be consistent with Part 52 that we consider those to i
5 be site-specific features which Part 52 didn't require.
'6 There would be interface criteria for those as required by 7
Part 52.
8-If the subcommittee feels, as I think maybe I 4
9 heard some hints, that one or more of those should not 10 simply be a conceptual design, an interface criteria, but t
11 ought to be included in the design, then I think the 12 subcommittee ought to make that comment.
.ry
'13 Our intention was that we considered those to be
-U I
l; 14 either site-specific or far enough removed from safety that 15.
a conceptual design complied with the requirements of Part 16-52, but that's the purpose of this document.
17 MR. CARROLL:
Let's take Carl's specific problem 18 of' potable water-systems in the plant.
19 MR. KENNEDY:
Yes.
~20 MR. CARROLL:
I think you perhaps intended this to 21' mean a potable water system external to the plant.
22 How would you deal with. lines potentially running-23 over switch gear that might break?
24 M. KENNEDY:
Our intention was at the present 25
~ time we did not plan to design the potable water system and
63 g
1 show the pipe routings and all the small piping, that 2
instead our submittal would include an interface requirement 3-that said the potable system supplied by the Applicant for 4
COL shall not -- and you list the design criteria, but for 5-purposes of design certification we right now have not 6
planned to design that system.
17-MR. MICHELSON:
If you look at the Standard Review 8
Plan, Section 361 you are required to do this pipe break 9.
si.ddy and that includes both safety and non-safaty related 10 -
piping, that. contains fluids like water that if they were to 11' fail could cause an interaction with safety-related 12 equipment, i
3 13 Du do that study you've got to know where the
, b 14_
potable' water lines are, I would think.
'i
'5-MR. CARROLL:
Or make a commitment that there are q
l
'16 not going to be or could not have an impact.
17 MR. MICHELSON:
I can make a commitment to build 18-this plant safely; and not do any of this.
That doesn't
-l 19 work. You've got to -- that's the whole object of
(
I 20-certification,.so'you don't have to go back and remove a 21 line-later and so'.forth.
We know where everything is.
It g
22-has been checked.
We have. written off on it.
It is done.
23
~You can't do that if taey start saying, oh, we're
]
going to do this later.
24-p
(,/
25 MR. KENNEDY:
I agree with you and our list of
66 1
laters ought to be very, very restricted.
There'll be some
(
2-laters.
3.
Again, we thought that we could in fact on the 4
potable water system define the appropriate interface 5
criteria, have it designed by the Applicant site-6 specifically at the COL stage, still hayw it closed before
'7 the COL, but not as a part of our design certification.
8 Again, if-the subcommittee feels strongly about 9
that, I think that is,an appropriate comment.
[
10 MR. MICHELSON:
It is deviating from the 11 essentially complete design and I kind of got an impression 12 earlier -- you. agreed to supply an essentially completed ~
l 13 design.
Now we are starting to hear about the exceptions.
14' MR. KENNEDY:.Again, most of the stuff on that
.15 list like warehouses, the intake structures -- clearly site-w 16.
specific.
.I think I have heard one example of a place that j
17
.you feel' uncomfortable.
That-is the. potable and sanitary-
- I 18s water.
I 19 Let me ask, is there anything else on the-list i
20 that makes you uncomfortable?
o 21 MR.~MICHELSON:
That is-the'first one that stands-i 22 out.
Sanitary water can be a real problem too, depending on 23
.how you-lay out your sewer lines.
Sewer lines can really.
~24 interact:with safety-related equipment if not done properly,
(
l 25 including floor drain systems and so forth, which some
67 1
people consider part of the sanitary system.
j 2
They don't specify floor drains and show where 3
they are going to be routed and how you prevent backflows.
4 and all these sorts of things.
You can write rules, but i
5 hell, you can write rules for this whole plant -- and not 6
have to detail anything!
i 7
MR. CARROLL:
You don't mean floor drains under 1
8 sanitary water, do you?
9 MR. KENNEDY:
Floor drains we do intend to route 10 in design.
Floor drains are included.
11 MR. MICIIELSON:
Then-that's not a part of your E
12 sanitary' water system.
It must tie into it somehow.
l 13 MR. KENNEDY:. They tie into-it.
I am not quite 14' sure where the division is but we intend to identify them 15 and: route-the floor drains.
16 MR. MICHELSON:
But up to what point do you. start
- 17-
' writing criteria for interface then?
Where is this
~
i 1) 18-interface to the sanitary' system?. Outside the reactor l:
E-19 building, for instance?-
~
20 Well, I guess you use auxiliary building in that 21 case.
4
-22 MR. KENNEDY:
Yes.
23:
MR. MICHELSON:
So if we know where the boundary
'24 is'and have the details up to that boundary, I think that'is V
25 a good idea but in looking at this list I wasn't sure
l 68 1
whether you were omitting the sanitary system.
,)
i 2-MR. KENNEDY Thit list is meant to be consirtent
%J 3
with the definition of esse.itially complete plant.
If the 4
subcommittee has these concerns, this is what we need to 5
hear.
6
.MR. CARROLL:
Do you have others, Carl, on that 7
category?
8 MR. MICHELSON:
No, I don't.
I wouldn't swear to 9'
it.
I haven't looked at it that carefully but most of the 10.
stuff I'think is a non-problem except, you know, the 11-interface criteria will take care of the non-essential 12 buildings tumbling onto essential structures, that sort of 13 thing I. don't mind but within a vital area like within the j j 3)
!'n 14 control rooms, control buildings,-auxiliary buildings,'you 15
.have got'to know where everything is.
16 MR. TURK:
Well, an interface requirement as 17L c', posed to designing the whole potable water system, an E18 interface. requirement.could be saying that within safety 19:
related structuresLpiping for the' potable water system will 20 be relegated to a certain area.
I think that would address 1
21 your area but:without us requiring to go in and figuring
-22 out, for instance,;what the usage rate is going to be for 3
23' the potable water. system at.that site and then try and size 1
24 tr.e system, which,_you know, you would have to do if you A:
!s,/
25 were going to actually come up with a complete design fer
.~ -.
69 1
.that system.
Q 2
You would need to know the utilities' manning and Q-3 their procedures, so --
4 MR. CARROLL:
Whether you are on an existing site, 5
on a site with an existing potable water system.
6 MR. MICHELSON:
There is no problem with space
[
7 allocation --
i 8
MR. TURK:
So --
9
-MR. MICHELSON:
-- you haven't shown space
.10 allocations yet and I would expect to go that.far.
I would 11 expect beyond that to give me the criteria by which you are 12 going to place pipe within that space allocation.
13 MR. TURK:
In order to satisfy the Staff for line V
14 break-analysis, we are going to have to do that.
L-
.15-MR. MICHELSON:
I thought conceptual design
.16-didn't go that far here but maybe if it does, maybe -- it L
L 17' depends on'how you define conceptual design on this.
18 MR. KENNEDY:
This subcommittee has. raised the i
V
. issue of' potable water with us befcre.
If that'in. fact is p
19 l
. 20-the item on the list which concerns you, we can certain L:
> 21 clarify it to the extent I think we can resolve your 1
L
-22 concern..
23.
MR. MICHELSON:
Sanitary and potablo are the --
l 24 MR. KENNEDY:
We have the message..
q 25 MR. CARROLL:
Okay.
EPRI requirements document,.
70 1
Appendix.
I) 2 MR. KENNEDY:
Yes, and again if you would use the 3
list from the August letter, that is the most up-to-date 4
list.
5 MR. CARROLL:
I am on page A-2 of the August list.
6 MR. ROTELLA: in the staff's report.
i 7
MR. KENNEDY:
It really makes no difference which i
8 one.
If you tell us the issue, we will find it on our list.
9 MR. MICHELSON:
I didn't even bring _that one i
)
10 because it's all in this other --
11.
MR. CARROLL:
Oh, okay, you're right.
You're T12
.right.
i fij(
13-MR. WILKINS:- I have the August letter.
l% /
i 11 4 MR. CARROLL:
A-2 of the SECY is fine, too.
L L.
15 Either one.
It's the same thing.
16 MR. KENNEDY:' Whatever list you're reading from, 17-tell us the-issue._ We'll address it.
j L
l;-
181 MR. CARROLL:
Okay.
Let's go to -- the first one l-
,19L I would like a little more information on is System 80+
l 20' control element drive mechanisms will not have anti-ejection i
21' latches.. What's that issue?
22.
MR. KENNEDY:
Well, it's interesting.
You have g
23 picked one there'which has gone away.
Because the EPRI b.
24 requirements-document has now been changed to remove the-1 J(
\\
25 requirement the CEAs have anti-ejection latches.
Our l
1'
[
71 1
deviation has gone away by virtue of the requirements 2
document having changed.
3~
MR. CARROLL:
Okay.
Let's try it another way.
4 Why did they at one point have this requirement?
Can you --
5 MR. KENNEDY:
Can you address that, Ray?
6 MR. TURK:
No, I can't.
7 MR. KENNEDY:
I believe the incentive was to try 1
8 to get out of-the safety analysis the traditional CEA 9
. ejection analysis by putting in a design feature by which i
10 one could claim that such an event was incredible.
I 11 believe that was the intent.
'12 HMR. CARROLL:
Okay.
L l tf-s 13 MR. KENNEDY:
We still analyze the CEA ejection.
l b)-
~
14 event.
i 15 MR.. CARROLL:
All right.
And the next one, the q
1 16 cross tie between EFS trains, I'm surprised, I guess, that b
17-EPRI didn't do that.
Do you have a comment on that?
L18 MR. TURK:
That EPRI did not require the cross-19 connect?
1 20 MR. CARROLL:
Yeah.
Because I think-it's a very 21 good feature.
I guess PRAs have shown that it's a very a
22
' desirable feature if you can control it.
23 MR. TURK:
Okay.
In the PRA' space it is a 24 significant advantage we found.
So we've decided to do 25 that.
72 1
.I should say that we're having a meeting next week t
,~y
!(,
2 out in Palo Alto with EPRI to go through our exceptions 3.
list, and that's really the first meeting on that subject 4
with the evolutionary plant in quite a while, so in many l
t 5
cases it may be just a matter of us pointing out to EPRI
.6 what we found as we have implemented the requirements 7
document in the design.
So we expect this list will shrink.
8 MR. CARROLL:
All right.
I guess with my 9
WestinghouseLorientation it's not clear to me why you don't 10 have a main steam isolation on pressure rate of change.
11
'MR. TURKi-We have --
12 MR. CARROLL:
You have something that does the 4
13 same thing?
l l {*m.) '
14 MRi TURK:
It does the same thing.
It's, L
15 basically, a variable set point that reduces the low 16
- pressure actuation as you come down in plant pressure during t
l
'17 a cooldown.
The purpose of that signal was to identify L
18
' steam line break events when you're in other than full power-19'
- conditions.
l, 20 MR. CARROLL:
Not on'a Westinghouse plant.
It's L
r
'21 for full power also..
22 MR. TURK:
All right..Well, we use just a 23-straight pressure set point, but that set point is then
~
24 reduced as plant pressure comes down and that meets the
.( 7 25 intent.
73 1
MR. CARROLL:
Okay.
Let's see -- I'm flipping
)
2' back and forth between lists here.
3 MR. WILKINS:
Well, since you're paueang, can I --
i 4
MR. CARROLL:
Go ahead.
Jump in.
5 MR. WILKINS:
Why don't you want to use what has 6
been described as realistic source terms instead of --
7 MR. KENNEDY:
It's not a question of why we don't i
8 want to use them, but in reality considering the schedule 9
which we're trying to achieve, we simply did not think that i
10 the staff would be in a position to approve any other source 11 terms for us to use in a time frame to support our schedule.
12 So our rationale was we would perform our safety analysis l ". i g-
.13 using the traditional source terms.
L
(
.14 If the staff and the Commission approved new more 15 realistic source terms, we certainly would seek that 16 relaxation and modify our safety analysis, but rather than-f 17 take the chance of proceeding.with something different.and i
18-having that in.the final analysis not-be acceptable to the 19 staff or the Commission we just didn't feel it was prudent
)
20 to do that right now.
21 Certainly we would much prefer to use a more 22-realistic source, but there's one not really available to us 23' now.
24-MR. WILKINS:
The containment design leak rate --
'I~
f
~ \\.
25 I'm not sure I understand these words.
Not that I question i
74 i
1 your judgment here.
I just want to make sure.I understand
- 2 them.
3 You're saying the Systems 80+ safety analysis will 4
demonstrate that NCFR 100 limits-can be met with containment 5
of.3% leak rate versus.5% per leak rate per day in the l
6 requirements document.
What I think that means is that i
7 you're not as safe as you would be if you had.5 of a 8
percent.- Am I wrong?
9 MR. TURK:
No, that's not what it means.
It means 10 that we're more conservative, but the testing acceptance.
11 criteria that will be placed on the plant will be somewhat I
12 more stringent than a.5% per day.
13
-- MR. WILKINS:
So you're going to demand that the
~O 14 leak rate not exceed.3%?
.15 MR. TURK:
As opposed to the'EPRI requirement
~
i 16 which, essentially --
17-MR. WILKINS:
Which was permitted.to be.5%.
.l
~ 18 MR. TURK:
That's right.- And that was predicated 19' upon acceptance of the reducea source terms.
Both of those 20 are'a considerable improvement over current practice which 21 might be as low as.1%.
f
'22 MR. KENNEDY:
That does tie'in to your source term 23 question.-
If we were using more realistic source terms, we 24 could dsmonstrate acceptability to.5 weight percent.
So, 25 again, if the source term is relaxed, we can come back to
75.
i l'
'this criteria and relax that one as well.
But with the n
2 traditional source terms,.3% is about all-we feel
(
~
l 3
comfortable in demonstrating right now, and that is a.
4 threefold relaxation over current practice.
5 MR. CARROLL:
How about the one of RVLMS?
I 6
MR.-TURK:
I believe that one also becomes a non 7
noncompliance in that EPRI is going to. remove their 8
requirement that you eliminate the vessel level monitoring 9
system.
i 10 MR. MICHELSON:
They're going back to it again.
11 MR. TURK: - Correct.
12' MR. MICHELSON:
Gary's going to do the same thing..
r u
MR TURK:
They never left it.
j L.r g
-13' V
14 MR. MICHELSON:
Oh, that's right.
Excuse me.
115-MR. CARROLL:' Again, can.you give me some insight' i
16 as:to what theyTwere thinking?'
17 MR. TURK: lWell, their insight was that the system-l-
l' 18 was:a complication and the operator could infer the same 19 information from other sources and, therefore, by 20 eliminating it it was a simplification to the-plant.
21 MR. CARROLL:-
Like they:did at TMI?
22 MR. WILKINS:
Yeah.
[
23 MR.' CARROLL:
That's called a rhetorical question.-
~24-MR. WILKINS:
Because your explanation of the
(_)
25 reason they didn't want to comply just strikes me as i
76 1
absolutely unassailable.
If there's an NCFR 50.34 and so on
- )
i 2
-- I didn't go look it up -- NCFR 50.34 (f) (2) -- what's that t
3
-- 28?
4 MR. KENNEDY:
We had a choice of noncompliance 5
with an EPRI requirement or noncompliance with a Commission 6'
regulation.
7 MR. WILKINS:
You don't have any choice.
8 MR. KENNEDY:
We chose noncompliance with EPRI.
9 MR. CARROLL:
Cowards.
10 MR. WILKINS:
Well, I guess you could ask for an 11 exemption.
]
L 12-
.MR.. CARROLL:
Okay.
I'll ask one for Paul here.
1 L.7--
13 What'sithe issue.about the use of 690 and pressurized-i
--V 14 reheater sleeves and instrument welds?
15 MR.. KENNEDY:
If you've been following current g
L i
16' events in some of our older operating reactors, we have had l
l..
' material cracking problems withLour pressurizer heater l
18 sleeves.
19-MR. SHEWMON:
The alloy 600.
20 MR. KENNEDY:
That is alloy 600.
We believe that l
l 21-it would be better in our--future designs to use alloy 690.
22 If you look at the.EPRI requirements document, they say you 23 can-alloy 690 in the steam. generator tubes, but they don't 24 want'it elsewhere.- That was written before we had that
)
25 experience, and we think it's prudent to go to 690 for these k
77 1
other applications.
l 2
MR. MICHELSON:
Why didn't they want it elsewhere?
3 MR. TURK:
I am not really sure.
It may be-4
'because of the way the requirement ended up being written.
5 In the requirements document, there's lists of materials and 6'
lists of applications.
As I said, in part of our 7
discussions with EPRI next week, we'll be talking about why 8.
We want to use 690 in the heaters.
9 That may result in some revision to the.
l 10 requirements document, or at least an ackr.owledgement.
11L MR. SHEWMON:
I was wondering; the 690 will cost 12.
you more= presumably, but I wondered if there was any r-).
.particular problems with it being more prone to cracking or 13 L
' _/
- (
14 welding problems or anything that makes people want to --
15 MR.' TURK:
No, I believe EPRI's reasons were i
16-basically cost and just not being aware of plans to apply it 17 in that application.
'18 MR.-SHEWMON:
.Certainly, primary side' stress b
19 corrosion cracking come up'in enough places now that.I would 20' think they'd change the requirement.
21 One other thing that I'll ask for Jay is, the
-22 first item on some list I have here, whether it's the one 23 you have or-nott.it talks about reducing the hot leg 24-temperature to 615.
What is it now?
25' MR. TURK:
Palo Verde and the Korean units operate l
l
?
78 1
at a TH of 621.
)-
2' MR. SHEWMON:
Okay, so you're coming down there 3
and EPRI had suggested coming down to 600?
4 MR. TURK:
That's correct.
5 MR. SHEWMON:
That was primarily because of 6=
corrosion concerns?
7 MR. TURK:
Correct; that was EPRI's concern, yes.
8 MR. SHEWMON:
It might be that you could get away 9
with 600 there.
Certainly, that' corrosion problem is 10 temperature' dependent.
Okay.
11 MR. CARROLL:
Other issues from this list?
i 12.
MR.'MICHELSON:- Yes, I've got a question.
What is 2
v ^s l13 the purpose now in System 80-Plus of the atmospheric. dump
(
14 valves?
15 MR. TURK:
The atmospheric dump valves provide-the-
)
16 safety grade means to remove decay heat through the steam 1
i L
J17' generators'whentthe condenser'is unavailable.
18 MR. MICHBISON:
That's-the onlyfpurpose?
19 104 fURK: -- -And achieve cold. shutdown conditions as L2 0 -
oppoted to the safety valves which would removc the~ decay-21'
' heat, but remain hot.
22 MR. MICHELSON:.That's the only reason that the 23
. atmospheric dumps are in there?
24 MR. TURK:
That's correct.
'N 25 MR. MICHELSON:
I guess then that they could be
1 l
79 1-
. manually operated?-
)
2 MR. TURK:
Yes.
3 MR. MICHELSON:
Now, why did we have them pressure 4
actuated with variable setpoints in the past?
5 MR. TURK:
It was a control issue, I believe.
6 MR. MICHELSON:
Was it protection --
1 7
MR. TURK:
There was also some use of the-valves 8
to prevent secondary safety valve lift.
9 MR. MICHELSON:
But you're-not even claiming that 10 anymore?
i 11 MR. TU:RK:
No.
12 MR. MICHELSON:
You wan't be able to claim it if
.O
'13'
-you don't have it automatic.
.G% )-
14 MR. TURK:
Right.
We have.never done that at Palo 15 Verde and other. units.
Essentially for any overpressure 16' situation where the condenser is available, the turbine 17 bypass' system,. steam-bypass control system is going'to
-\\
18' prevent secondary safety valve lift.
l y
19
.If the condenser is not available, if you are i
?
20 going to have to relieve to atmosphere,and you have a 21-significant overpressure, probably the dump valves, of and 22 by themselves, are not going to be sufficient.
They're 23 about five percent each.
24 MR. MICHELSON:
They're pretty small.
l(
l.
25f MR. CARROLL:
Is the unit designed to accept a
80 1
full load rejection?
f2 MR. TURK:
The unit is designed to accept a full 3
load rejection.
4 MR. CARROLL:
That's through bypass to the 5
condenser?
j 6
MR. TURK:
That's bypass to the condenser in 7
conjunction with a reactor cutback.
~8 MR. CARROLL:
You don't even use these atmospheric 9
dumps in that?
10 MR. TURK:
That's correct.
11
-MR. MICHELSON:
Why can't you use the condenser
.2-Lbypasses to take care of.the other heat,.the kinds of. heat _
1 t
(/~)
~13 :
removal that you made the atmospheric dumps.for?.Why are
,g 11 4 they needed at all?
l15 MR. CARROLL:
Because on loss of power, --
16 MR TURK:
You wouldn't have the condenser.
17 MR MICHELSON:
Well,-you don't have to.
You can l
18~
' blow the condenser diaphragm at such an outside event, j
19 MR.' CARROLL:
I don't think you want to do that.
20 MR. MICHELSON:
You may not want to do that.
21 MR. TURK:
That requirement has to meet safety
.i 22 grade requirements-which would mean taking safety. class 23 piping all the way out to the condenser.
24 MR. MICHELSON:
To avoid that sort of thing, you (s
25 just provide -- what is just two atmospheric dumps?
-~ _..
81 1
MR. TURK:
There are two per steam generator.
O
?s j/
2 MR. MICHELSON:
Right.
That's the only function 3
then?
Okay, okay.
That doesn't have to be done for thirty 4
minutes or so?
Is that the kind of times we're talking i
5 about?
6 MR. TURK:
With the emergency feedwater system and 7
just the secondary safety valve, you could sit a hot 8'
standby, removing decay heat to atmosphere as long you had a 9
feedwater supply, i
10 MR. MICHELSON:
Why the atnospheric dumps then?
.i 11 MR. CARROLL:
So you car. cc.'l down.
12 MR. TURK:
So you can cool down.
The dump valves; (t '(
e 13 you've got to maintain hot conditions.
V L) ^
-14 MR. MICHELSON:
You wouldn't want to just do that
-15 until you got power back'to the condenser?
16 MR. TURK:
You probably would in most cases.
I
.17 think, rather-than lift the spring-loaded safety valve, 18 tnough, you'd probably take the atmospheric dump valves.
l I
19-MR.' MICHELSON:
You're just trying to-meet the Q
20 regulation that says you've got to do'this in, what 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> D
'21.
or something?
'2 2 -
MR. TURK:
Correct.
l 23 MR. CARROLL:
What's the issue on the fans and L
l; 24 filters in the control room boundary, control room pressure
(
25 boundary.
82
~1 MR. TURK:
You may have hit one that I'm not --
=
2 Stan,-do you want to address that?
3 MR. RITTERBUSCH:
This is Stan Ritterbusch.
One 4
of the issues has to do.with leakage.in the HVAC.
We're 5
removing a leakage concern.
6 MR. CARROLL:
By putting them inside the pressure 7
boundary?
8 MR..RITTERBUSCH:
Correct.
9 MR. CARROLL:
EPRI thinks they should go outside?
We'd have to review that.
11 MR. KENNEDY:
That's one I don't think those of us
~ itting here at the table are not that familiar with.
12 s
i(~1 13 MR.' MICHELSON:
Okay.
Could I ask a followup on U
14
.that question?
li-
-15 MR. CARROLL:
Sure.
t 16 MR. MICHELSON:
It's my understanding -- and 17l correct me if I'm wrong -- that you1do not have any normal lv L
1 L
18'
. ventilation' systems that serve more than one defined area of s
. 19 the plant.
By defined,-I.mean one division or so forth?
That's correct.
1 i
21 MR. MICHELSON: :There are no common ventilation
. 22 systems' in this plant that are pumping.from two or three t
- 23 different divisions?
24' MR. TURK:
Correct.
25 MR. WILKINS:
Are you comfortable with not
=>
83 l'
requiring separate switch yards for main and reserve offsite I
2 circuits?
I mean, it see.ts to me that one could contemplate 3
'an event in which you'd ' cake out that switch yard.
That's 4
the very last.
5 MR. TURK:
I think this requirement, again, 6-because the switchyard is on the list of issues that are not 7
part of the certified design, all we're doing is making our
)
8 design general enough that, depending upon the site, it 9
could be applicable if a given utility decided that, at 10 their: site, they.did not want to conform with the EPRI
~ 11 requirement of physically-remote switchyards, the.t that 12 wouldn't~ preclude this design.
It does.not really enter f
13~
into the application.
l
(..
t L
-14 MR. CARROLL:
When you're talking to EPRI about j
.15 their-requirements document'and your design, where you-i 16 comply.with the EPRI requirements is with respect to 1-E
-17 pow s, two emergency diesel generators for two divisions, 18 one for aach of your two divisions of safeguards. equipment, d
19 plus the non-safety-grade onsite power source.
'20 In view of the-Vogtle event, concerns about 21
. accident sequences and other-than-power operation, I guess I 22
.would ask you to ask yourselves and EPRI whether an "n plus 23 2" design might not~be a better approach, a full "n plus 2" 24 design extending back into the electrical might not be a
?!
25-better approach.
R
84
)
1 Do you understand my concern?
r 2
MR. TURK:
Yes.
3 MR. CARROLL If you did that, I am not sure you 4
would really need th onsite generation non-safety-grade, l
5 other than because of a dumb requirement in the station-6 blackout rule.
I think it's an issue that should be aired, 7
in view of Vogtle and similar events, because you are going 8
to have diesels out during outages, and you also are going 9
to have accidents during C,utages.
10 MR. MICHELSON:
I had a couple more, mostly for my 11 own edification, I guess, but let's do it.
12 Why do the containment purge valves have to close 13 in 15 seconds?
14 MR. TURK:
Essentially to meet criteria for the 1
l 15 spfaty analysis.
I should point out here this I think the 16 difference with EPRI arises because the EPRI requirement is 17 phrased in generic terms to say that automatic valves should 18 not have to close faster than 30 seconds and then lists some 19 necessary exceptions, and it lists the main steam stops and 20 the main feed stops, and we just believe the purge valves 21 weren't really considered when they listed that.
4 22 MR. MICHELSON:
There must be some real good 1
23 reason why you chose this, 24 MR. CARROLL:
That also ia,Ource-term related.
p 25 MR. TURK:
Correct.
By not looking at the lower
85 1
source term, yes.
rk,)
2 MR. MICHELSON:
So, you think that if you looked m
3 at a realistic source term, you might go back to --
4 MR. TURK:
We might be able to relax that time, 5
yes.
6 MR. CARROLL:
A few hours.
7 MR. MICHELSON:
Well, it's hard to believe it goes 8
from 15 seconds to hours, but maybe it does.
9 MR. CARROLL:
You don't need to close them until 10 you have released the radioactivity into the containment.
11 MR. MICHELSON:
Well, that's the given, though.
12 That's how you decide how fast they have to be.
('
}
Another question:
The diesel start time, you're 13 14 talking about a sequence here of 20 seconds, which I gather 15 is to reach all immediately-needed loads, must be on in 20 16 seconds.
Is that the way you interpret it?
It says start 17 and load in 20 seconds.
What do you load in 20 seconds.
18 MR. TURK:
The first element of the sequence chn
'19 be loaded onto the diesel starting at 20 seconds.
20 MR. MICHELSON:
That's a lot different answer, of 21 course.
In other words, ready to load the first element in i
L 22 20 seconds.
l 23 MR. TURK:
Right.
24 MR. MICHELSON:
As opposed to being fully loaded.
I 25 MR. TURK:
If the diesel's started up to speed --
86 1
MR. MICHELSON:
That's not the way that the bullet 7m
\\)
2 is worded, but maybe it needs to be reworded when this thing 3
is reissued, then.
It's start and ready for loading in 20 4
seconds.
Is that what you meant?
5 MR. TURK:
That's what I believe it is.
I'll have 6
to verify that.
7 MR. MICHELSON:
I would have no problem with that.
8 I would have quite a bit of problem with -- I'd like to know 9
what you're going to load and get up in 20 seconds.
10 Apparently, then, EPRI says 40 seconds, but you've 11 got to sea what EPRI's criterion is.
12 MR. CARROLL:
Again, that's source-term related.
y'~x 13 MR. MICHELSON:
No, not necessarily.
14 MR. TURK:
As far as coming up with the criteria -
15 16 MR. MICHELSON:
This is mostly ECCS-related, how 17 fast you've got to get all the water flowing to prevent 1
18 exceeding 2,200.
19 MR. TURK:
Correct.
l 20 MR. MICHELSON:
I don't'know.
I don't have any L
l 21 problem, but I didn't understand what was here.
I would 22 think you'd have to tell me more about it, if you're going 23 to be fully loaded in 20 seconds, and then I wondered what 24 did EPRI say?
25 MR. TURK:
We're not trying to complete the
87 1
sequence.
)
2 MR. MICHELSON:
Is EPRI's such that you just start 3
loading in 40 seconds?
4 MR. TURK:
I believe the two numbers are 5
comparable numbers.
The numbers were generated in the 6
requirements document when we first started the requirenents 7
document 3 or 4 years ago.
8 Forty seconds was picked, at the time, as a goal 9
to relax the demand on the diesel.
When we actually started 10 completing our Chapter 15 analysis, we found we naeded 20.
11 I think you're right; I think most of that reasor,was 12 thermal hydraulic and not source-term related.
. / 'N 13 MR. MICHELSON:
Well, 20 wculdn't even be too bad i d 14 a time in which to be ready to load.
15 MR. TURK:
That's what we folt.
We felt that the 16 20 seconds was a significant relaxation over some of the 17 current demands.
18 MR. MICHELSON:
From 10 to 12 right now.
19 MR. CARROLL:
It's also related to leak before 20 break.
21 MR. MICHELSON:
I'm not sure.
In ECCS, you don't 22 talk about leak before break.
You talk about the design-23 basis breaks, and that's what all this is based on, 24 irrespective of what the credibility of a design-basis break
.n-k-
25 might be, which is when you get into leak before break.
But 1
88 1
this is based on the hypothesized Appendix K specified size
)
2 breaks.
3 MR. CARROLL:
The fast start time on the diesels 4
was driven by the large-break LOCA.
5 MR. MICHELSON:
That's right.
6 MR. CARROLL:
Which has been --
7 MR. MICHELSON:
It's still a large-break LOCA.
8 MR. KENNEDY:
Leak before break is only used, as 9
we use it, in support and internals design and analysis, or 10 ECCS analysis, Appendix K.
We are still required to use the 11_
full double-guillotine break.
12 MR. MICHELSON:
That's what drives this thing so i )
13 fast, and perhaps maybe we should revise the postulated 14 breaks for ECCS.
That's been thought about from time to 15 time, too, but right now, it hasn't happened.
You will 16 clear up the wording a little bit eventually.
17 MR. TURK:
Yes.
18 MR. MICHELSON:
Okay.
19 MR. CARROLL:
What is the one about initiation of 20 feed-and-bleed mean?
Don't you presently initiate feed-and-L 21 bleed at the time of steam-generator dry-out?
22 MR. TURK:
Operationally, yes.
What this was was 23 to attempt to define a measure of the plant's capacity to
(
24 essentially absorb heat; in other words, how long could the 7,
25 plant sit there if you did not initiate feed-and-bleed?
89 1
So, it's essentially a measure of the heat
()
2 capacity of the steam generators and the primary coolant and 3
the like, and again, early on, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> was picked, if that's 4
the one you're looking at, as a general measure.
When we 5
actually got in an looked at the inventories that -- coolant 6
inventories that we wanted to have in the system, it is 145.
7 There is also need for some discussion with EPRI 8
regarding how you actually calculate that, whether it's 9
best-estimate methods or not best-estimate methods.
But 10 that's not meant to be an operational restriction.
If you 11 will, it's a measure of margin.
12 MR.. CARROLL:
Okay.
Maybe that ought to be re-13 worded, because it made it sound to me like you're going to 14 wait 30 minutes after dry-out to initiate.
I guess I was l
15 wondering what the basis was.
You started a stopwatch when 16 you dried out?
And you're telling me you will.
Your 17 emergency operating procedures envision initiation of feed-18 and-bleed upon dry-out.
Okay.
19 EPRI did, apparently, come up with a 60-mi.
1 20 requirement, and you can go 30 minutes, but you're not sure 21 whether it's best-estimate or what.
So, this one could also 22 be revised for that reason.
l L
23 MR. TURK:
Numerically, yes.
24 MR. CARROLL:
All right.
l 25 Anymore?
l
-~
90 1
MR. MICHELSON:
Let me ask, just so I've go the 2
background I don't know much about this requirement for 3
hand-holds at every tube-sheet or every tube-support.
Is it
{
4 just a matter of the cost of putting in the extra hand-5 holds?
Is that the concern?
or is there something else?
t 6
MR. TURK:
I don't have all the information L
7 either.
It has to do, I think, also, with maintenance 8
history.
I 9
I think there were instances on other vendors' 10 steam generators where they found it was desireable to be
{
11 able to get up into upper ends of the tube bundle.
We have, 12 historically, had adequate access.
( }
13 We have a man-way in the upper area which allows 14 access to the upper ends of the tube bundles, and with the 15 access that we have, we have alternate access at the tube-16 sheet level to get in at different angles.
17 MR. MICHELSON:
But not at the separator, not at 18 the supports through the generator.
19 MR. TURKt Right.
20 MR. MICHELSON:
Just at the top and at the bottom.
21 Perhaps I'm just speculating.
I thot ght the 22 reason that you might like these, of course, is if you've s
23 got a problem with tube dinning at the supports and so 24 forth,.that you can get in and wash the debris out and that i
25 sort of thing, which is what you do, I think, at the bottom E
wi-.-:_-.msmmt
.m__m__--_.._.--mm__m.m-_-.mm-ma.
.mm
_-2-m.
._.w,__,
- ___m, mmma-m_
l 91 1
tube-sheet now.
vm I,)
2 Is there any reason to believe that it's a 3
worthwhile investment?
j 4
MR. TURK:
I do not have that evaluation with me 5
and don't recall it.
I imagine that was probably the basis, 6
but we can go back and take a look at that.
7 MR. MICHELSON:
It could be that was -- I just 8
don't know.
I was curious.
It is though an item that 9
didn't look like that big a problem, but -- so why -- why 10 take exception to what the customers think they want.
11 MR. CARROLL:
Let's see.
One other comment.
I 12 notice that combustion knows how to spell polyvinyl but the k
af}
13 staff doesn't.
There's no "e" in the end.
But you're April G
14 whatever document was correct.
15 MR. KENNEDY:
Thank you for the compliment.
16 MR. CARROLL:
All right.
Anything else on this --
17 or for combustion?
18 (No response.)
i 19 MR. CARROLLt All right.
Let's move to Tom L
20 Wambach of the staff for his presentation, or Charlie, you l
l 21-were going to lead off, weren't you?
l 22.
MR. MILLER:
You wanted me to make some remarks to 23 respond to the question that you had.
24 MR. CARROLL:
Yes, yes.
25 MR. MILLER:
I'm going to flip a slide-up there
1-92 1
but I'm going to talk from here.
2 (Slide.)
3 MR. CARROLLt Okay.
4 MR. MILLER:
You've seen this one before.
I 5
thought it might be worth while to kind of give a quick 6
history of LRB.
Ernie covered sort of the genesis of LRB's 7
in his discussion.
8 At the time that we embarked upon doing the 9
reviews and planning the reviews for the ABWR and the CE i
J 10 System 80+, the staff felt that it would be good to try to 11 sit down and get some general ground rules laid out up-12 front.
I think Carl called it a " gentleman's agreement" in 13 the past, and that might be a good term.
14 At the time that the ABWR LRB was issued, it was a 15 staff document -- an NRR document really, that Tom Murley 16 issued to General Electric.
17 MR. CARROLL:
Is that right --
18 MR. MILLER:
That's correct.
19 MR. CARROLL:
-- or did he just write a cover 20 letter --
21 MR. MILLER:
Well, okay.
22 MR. CARROLL:
-- attaching GE's LRP?
23 MR. MILLER:
Yes, yes.
It's a very -- it's a very 24 sordid history.
In reality, the vendor prepares the draft O
25 of the LRB, they dialogue with the staff, we come to
93 1
agreement on what it should look like and then the staff
.s p
(
2 issues it to the vendor.
Okay.
I didn't mean to imply that 3
the staff developed this whole thing on their own.
That 4
would be selling the vendors far short.
The bulk of the 5
work was prepared by the vendors.
6 As we proceeded through the ABWR review and the 7
Commission started to focus more closely, which was about 8
the time that Part 52 was coming into being and reached its 9
final stages of com%ent form and was about to be 10 promulgated, the Commission said, ah-hah, staff, you're down 11 there setting policy, and the Commission is the body which 12 sets policy.
Some of the things that you have agreed to in 13 the LKb as the way you're going to proceed, should have been l
14 raised as policy questions.
15 At that point in time, the staff and the 16 Commission entered a dialogue through several meetings and 17 what resolved was some guidance that the staff received last 18 December.
At that point in time, the staff tried to take 19 the guidance in its various forms as it was issued and try j
1 20 to put it together in some logical format.
This monstrosity 21 was the -- that I have up here on the slide, is the result 1
22 of that.
l 23 MR. CARROLL:
That's a logical format by 24 definition?
?
k_/
25 MR. MILLER:
Yes.
In looking at the guidance that
94 1
was given, we tried to see if there was any illogical steps
(^T l
(_s/
2 in the process, but from a logic standpoint, it tracked.
3 MR. CARROLL:
Okay.
4 MR. MILLER:
So, the staff developed a Commission 5
Paper 90-065, where we basically said this is our 6
understanding of the guidance that you've given us in the 7
various forms commission and that went back to the 8
Commission.
9 At that time, the Commission then asked the staff 10 to make suggestions concerning how the process might be 11 streamlined.
The staff then prepared a SECY 91-46, which 12 was more of a streamlined approach to how we would conduct l
13 these reviews.
14 The Commission, by a vote of 5 to 0, rejected th 7
75~
streamlined approach and told us to basically follow.the 16-process as it was outlined in SECY 90-065.
17 If you look at the first column there of events, 18 what we basically had done is we've raised the LRB to a 19 level that it was not to be a staff-issued document, but it-1 20 was now to be a Commission-approved document.
L 21 As a result of that iterations and the additional l
l 22 preparations that we had to make, it's caused some delay I-23 think in probably -- where we were trying to get to.
As a 24 result of that,.I think it's fair to say that it's led to O
25 some frustration on the vendors' part because I think it's
95 1
felt that the lack of issuance of the LRB has held up 2
getting on with the review in its full ernest.
3 Nevertheless, at this point in time, the guidance 4
that we have received from the Commission is to issue an 5
LRB.
They haven't retracted that guidance.
So, that's the 6
main reason that we're here today.
7 If you look at that -- that sequence of events and 8
the steps -- one of the things that we're supposed to do 9
along the way is to report to the commission on the staff's 10 comments and recommendations concerning their review of the 11 LRB.
The SECY paper that you have before you is exactly 12 that step.
t 13 Now, I should go on to say that accompanying this 14 was a schedule of how the LRB would proceed, as best as we 15 could guess.
We developed that schedule, I think, with the 16 thought in mind of not that this is System 80 or the ABWR, 17 but this is about what it would take time wise to develop an 18' LRB for some un-named design certification application.
19 In reality, although we're at the comment and 20 recommendation stage, I would basically agree with Ernie 21 Kennedy's comments earlier, that I don't think that there's 22 any large disagreements at this point and time between the j
23 staff and Combustion Engineeringt at least nothing that I 24 don't think could be handled through just sitting down and 25 rewriting some words in the LRB and issuing it.
1
96 1
However, the Commission is the approving body for A.
2 the LRB at this point in time.
What we have to do is to 3
send our comments and recommendations, as we've done in this 4
paper to the Commission, get their okay or any other 5
guidance that they wish to give and proceed to finalize the 6
LRB.
In our paper, we basically made the recommendation 7
that we didn't see any significant impediments in doing 8
that.
We thought that we could finalize it in a much more 9
timely manner than had been earlier anticipated in the 10 schedules in 90-065.
11 Given all of that rhetoric, the one thing that I 12 don't want to see happen, and I'm speaking for Charlie l [ )
13 Miller, personally, in my role in all of this, is that the 14 LRB become an impediment to getting on with the review.
If 15 it turns out that that's the case, then I would personally 16 question whether it's really worth doing in full ernest.
I i
17 think it was at the time that we set out.
l
.18 MR. CARROLL:
This particular LRB?
19 MR. MILLER:
This particular LRB, yes.
If you'd l
l 20 like, I can expand my comments concerr.ing LRB's in general.
21 I didn't know if you wanted to get into that in this forum 22 or not?
23 MR. CARROLL:
Yes.
I think it's one of interest 24 to us --
l
.g 1
25 MR. MILLER:
Okay.
l
97 1
MR. CARROLL
-- if you can do it in about 30 k
2 seconds?
3 MR. MILLER:
I guess what we basically concluded 4
is that -- that we were far enough along with the CE LRB and
]
5 they had put enough effort into it and the staff had put in 6
an effort to it and it looked like we could reach closure j
7 pretty quickly, that it was worth finalizing.
Also, we 8
haven't been told not to finalize it at this point in time.
9 What the Commission has asked us, more j
10 specifically, is, gee, given the fact that we have told you 11 for passive plants that we want you to resolve all matters, 12 in the context of the EPRI Requirements Document, before you 13 proceed with the formal review of the passive plants, are 14 LRB's of any use anymore?
15 I think we concluded that given the fact that 16 we're going to resolve those major issues in the context of I
i 17 EPRI first, that there are some values to an LRB that would
~
l 18 still be there, but the cost / benefit of really doing one 19 just isn't there anymore; and we recommended to the i
20 Commission that we not proceed with formal LRB's for ths 1;
I 21 passive plants.
22 MR. CARROLL:
And that recommendation.is --
23 MR. MILLER:
And that recommendation is separate.
24 MR. CARROLL:
-- 90-362 --
t J r i
25 MR. MILLER:
Right.
~s i
I
nw 98 i
MR. CARROLL:
-- which we handed out aarlier to 2
the Committee members.
3 MR. MILLER I should also say that for the more 4
exotic designs that we've yet to faces the liquid metal and 5
gas reactors, we've reserved the right to maybe revisit it 6
again and maybe we would want to put something like an LRB 7
out, depending upon where we stand, because there is at this 8
point is no EPRI Requirements or other vehicle for visiting 9
some major issues.
10 Now, even given where we've gone, for th) 11 evolutionary plants, the Commission has told us to review 12 the EPRI requirements and the vendors' designs in parallel.
13 So as policy issues are identified either through EPRI or 14 through the individual designs, we've got to get them to the 15 Commission right away.
16 We're not going to be resolving them necessarily -
17
- can't be sure that they'll be resolved in EPRI before 18 they're resolved with each of the evolutionary applications.
19 So, we still felt it was important that -- you know, the LRB 20 be some document that give kind of a -- in one spot, a 21 general understanding of the waiver proceeding.
22 One thing that I should state is that the LRB has 23 no legal standing.
I think that's_important for everyone to 24 realize.
25 MR. CARROLL:
I think Murley made that very clear
99 1
with the caveats he put into the cover letter to the GE ABWR 2
LRB.
3 MR. MILLER:
Yes.
So, we basically have agreed 4
with the vendors that, I believe, that's the case.
I'll let 5
CE speak for themselves.
But, at this point in time, we 6
have not had the vendors come back and say, staff you said 7
this here and now you're doing it different and you can't 8
make us do it.
We have not had that whatsoever.
In fact, 9
at this point it has been a fairly cooperative dialogue.
10 But I think the most important thing --
11 MR. CARROLL:
So, given, Charlie, that the
'12 decision is made by the commission to proceed with this LRB 13 and it does get finalized, what are you going to do with it
.,O 14 then?
What value does it have to the staff?
s 15 MR. MILLER:
I think the value that it has to the 16 staff is that we will then have, with combustion 17 Engineering, kind of a general agreement as to the way they 18 are proceeding and, to the extent that 90-016 issues have 19 been identified, Combustion Engineering will have, if you 20 will, in some minimal form stated their commitment that they 21 understand that that's the way they are proceeding to meet 22 those in their design.
Which, by the way, we have not yet 23 gotten to with the EPRI review.
EPRI wants to continue the 24 dialogue on some of those issues.
25 But, the LRB document shcWs that there is some
...~
100 1
ut.dcratanding there as to the way that we are proceeding.
I 2
think that is the biggest salue and the fact that it has 3
transcended the evolution of Part 52 and some of these 4
policy issues.
It kind of ties a knot in where we started 5
and where we are today.
6 Now, if the commission were to decide -- I think 7
one of the reasons that the Commission is looking at it, 8
fcom my understanding of some of the dialogue I've had with 9
their staffs, and one of the concerns that the industry has, 10 is that the schedules that we laid out for the development 11 of an IRB can take up to two years.
I think there is a 12 general feeling of, well gee, if it's going to take two
(
}
13 years to develop this thing before we can start with the 14 review, is it really worth holding everything up for that 15 length of time in order to get this document.
Could we make 16 schedular savings by eliminating it?
17 MR. CARROLL:
And resources savings --
18 MR. MILLER:
Resource savings, yes.
19 MR. CARROLL:
For staff, for applicants, their 20 ACRS.
21 MR. MILLER:
Stan can tell you.
He has put in-a 22 fair amount of time in dialoguing with my staff, debating, 23 arguing the language in the LRB and we have gone round and 24 around.
.O 25 The other thing I should note in the CE LRB -- and
101 1
I'll just make this statement generally -- is that there is
)
2 a difference in the CE LRB and the GE LRB in that, at the 3
time that we issued the GE LRB the Commission had not made 4
the decision that they were going to desire essentially 5
complete designs.
So, I think you are going to see the CE 6
LRB addresses that where the GE LRB -- although GE has 7
committed to do it -- does not reflect that.
8 So there is a difference in the timing difference 9
in the issuance of the two documents.
But, in summary, I 10 guess it is our conclusion that we were far enough along we 11 thought it would be good to finish it and get it done.
12 Now to the extent that -- I don't plan holding i
13 Combustion Engineering hostage to this document and saying 14 that we are not going to do a review unti' it has been 15 issued.
I think there was a time where the staff had that 16 intention and hoped to use the LRB as the first step of the 17 process before we would embark upon a review.
But, in the 18 case of the System 80+ I no longer have that aspiration.
19 I guess that's what I wanted to say.
20 MR. CARROLLt Okay.
Do you have questions on this 21 issue?
22 MR. MICHELSON What do you envision to be the 23 form of a Commission approval, which is a step in your block 24 there.
Is that some kind of a formal Commission letter to a
25 the applicant, or what does it mean, Commission Approval?
I
102 1
guess that says approval if I can make it out from here.
f) 2 MR. MILLER:
I guess it could take one of two 3
forms.
It could take the form of the commission decides 4
that they are the body that wants to formally issue it, so 5
they would put their name on the line rather than Murley, or 6
-- I hate to make this comparison, but it would be similar 7
to issuing an operating license where, you know, you go 8
through the commission really to get approval before it's 9
issued, but actually Tom Murley who puts his name on the 10 license itself.
11 MR. MICHELSON:
There is no Regulatory basis for 12 doing that sort of thing, nor would you want to generate one i
13 without a Regulation to do it.
14 MR. MILLER:
I think that's a very valid comment.
15 The one thing that I personally would not want to see happen 16 and, to a certain degree has happened already, is that the 17 darn thing gets so institutionalized that we treat it as a 18 bigger document from a Regulatory space than it was 19 originally intended to be.
20 MR. MICHELSON:
One might envision, of course, 21 simply doing as was the case for the GE, for Murley to 22 transmit it with one paragraph, a mold, which in my opinion 23 it just says we've got a gentleman's agreement, looks like 24 we're heading in the right direction, now we'll see what you 25 do, i
i
103 1
MR. MILLER:
Well I think, from a practical
()
2 standpoint, what we were likely to do is once we get the 3
guidance back on our comments and recommendations to the 4
Commission, if they say go forth and finalize it, we'll go j
5 forth and finalize it and probably send something that looks 6
like that and say we plan on issuing this thing and we need 7
your okay to do it.
They may just give the okay and then 8
Murley would do exactly what you said.
9 MR. MICHELSON:
If you add a high degree of 10 formality then one has to be much more careful this.
11 When I look at -- just doesn't seem like the thing 12 that I would recommend at least.
I would do it just like 13 the ABWR.
That's about as far as I'd go with it.
~~
s 14 MR. MILLER:
I think we found that the staff found 15 that to be a useful document and so has GE.
But remember 16 that, at the time that document went out lots of things that 17 have now -- a lot of water has gone under the bridge since 18 the time that was issued.
19 MR. MICHELSON:
In a larger part it has.been 20 preempted by those things.
21 MR. MILLER:
Yes.
And, in fairness to Combustion,-
22 they've been trying to get one issued now for quite some 23 time.
24 MR. CARROLL:
All right.
Tom, you're up.
25 MR. MILLER:
Now I'm going to ask Tom Wambach to l
t
104 1
give a formal presentation.
r(_))
2 MR. CARROLL:
I cut into your time considerably, 3
Tom, partially on the basis that you indicated that 4
Combustion had sort of stolen your thunder earlier.
I 5
assume that where there is agreement or no problems, just 6
slip through the slide and focus on the things where there I
7 are issues.
8 MR. WAMBACH:
Yes, sir.
9 (Slide.)
10 MR. WAMBACH:
I'm Tom Wambach from NRR, project 11 manager for CE, System 80+.
This may be the only slide that 12 gives you some information that you haven't heard already.
13 (Slide.]
v-~g)
(
14 MR. WAMBACH:
This is the schedule.
I put this up 15 mainly to address this issue, because there seemed to be 16 some confusion with the subcommittee as to what they were 17 going to be meeting on today.
I think Mr. Miller has now 18 addressed that in his introduction.
J 19 (Slide.)
20 MR. WAMBACH:
This slide takes 'the 15 issues from 21 SECY 90-016 and shows us the sections in which they were 22 addressed in the LRB.
As pointed out in the CE, two of the 23 items were not included because nf the timing of the 24-previous documents and the SRM3.
25 The asterisks by the other items also indicated l
l
-.,~.
105 1
where there was either some modification that the staff p)
(
2 wanted to the LRB or some additional information.
3 (Slide.)
4 NR. WAMBACH:
This is SECY 89-013, which had the I
5 other technical issues which were addressed in the LRB and 6
on these, as you see, there are no asterisks.
Because of 7
the timing of that issuance, those issues had all been 8
resolved in the LRB previously.
9 (Slide.)
10 MR. WAMBACH:
The LRB, as amended on August 28th 11 identifies the one exemption on the OBE being one half of 12 the SSE and deleted the other exemption that was identified i --
13 in the previous LRB.
However, as indicated by Mr. Kennedy, f
14 the staff feels that a verbatim reading of the rule states 15 that a containment penetration shall be provided.
16 Later on in the rule at the bottom of the section, 17 it says that the intent of this is to not preclude the 18 addition of a vent.
Those words are what CE feels then they 19 wouldn't have required an exemption because they do not 20 preclude the potential for adding a vent.
21 But we feel that they should either propose the
-22 penetration or ask for an exemption.
Again, I don't believe 23 that at this point it's a technical issue.
It's just making 24 the paperwork right.
)
25 MR. CARROLL:
The first item, the OBE/SSE issue,
S 106 1
the Commission has agreed with the position you took that it i/
2 didn't have to be half SSE, right, in 90-0167 3
MR. k'AMBACH:
That is correct.
4 MR, CARROLL:
That's an non-issue, really.
5 ML. WAMBACH:
Right.
6 F.R. MILLIR:
Except for the fact that there's a 7
current effort evolving into changing the regulation.
Until 8
such time that the regulation is changed, although we may 9
agree in principle, we would have to treat it as an 10 exemption to the regulations.
11 MR. WAMBACH:
We'd have to issue an exemption.
12 MR. MILLER:
Current regulations provide for
()
13 something different than I think where we are today.
l 14 MR. CARROLL:
I've got you.
15 MR. MILLER:
That's the issue.
16 MR. CARROLL:
Yes.
-17 (Slide.)
i 18' MR. WAMBACH:
Now, one of the items that we 19 indicated we needed some fine tuning on; midloop operation -
20
- the CE proposal did talk about the fact that they would do l
21 an analysis.
They would consider design features and/or
~22 operational restrictions.
23 Then as the example, they proposed an operational 24 procedure to provide venting to the reactor coolant system
(
25 so that there would be no pressure buildup during midloop L
py e
s s
107 1
operation.
r.
()
2 We, the staff, feel that the issue is broader than 3
that; that it should propose design features to minimize 4
loss of shutdown cooling flow, not just pressure buildup.
5 You do this, ir addition, by showing the reliability of the 6
shutdown cooling system, the instrumentation that's provided 7
to the operator for reactor vessel level and pressures and 3
8 temperatures and procedures for rapid containment closure.
9 (Slide.)
10 MR. WAMBACH:
On fire protection, the CE proposal 11 is the same as what the staff had in SECY-90-016.
The 12 Commission, in their SRM, approved the staff position, but
(~
13-as supplemented by our response to the ACRS comments in our i
14 April 27th memorandum.
So, that is what we will do in this 15 exercise, is match it up with our response to the ACRS.
16 MR. CARROLLt If I remember correctly, the ACRS 17 comments were included in the-Commission directive on mid-18 loop, also.
19 MR. WAMBACH:
That's right.
20 MR. CARROLLt On the previous slide.
21 MR. WAMBACH:
Yes.
I think that the four items 22 that were listed are the ones that ACRS wanted us to add, 23 specifically, rather than in a general statement.
24 MR. MICHELSON:
Do you know, in the case of fire
/~T
'(_)
25 protection, whether there is any problem with CE taking care
108 1
of the ACRS commento?
f(
2 MR. WAMBACH:
No, I don't believe there.
The HVAC 3
you discusred with them earlier.
l 4
MR. MICHELSON:
Maybe CE would like to confirm 5
that, and then there would be no doubt.
6 MR. KENNEDY:
We don't believe there's a problem.
1 7
(Slide.)
i 8
MR. WAMBACH:
The intersystem LOCA, the CE 9
proposal discusses the fact that there is no low-pressure 10 safety injection and that they are increasing the design 11 pressure of tne shutdown cooling system to 900 psig.
12 The SRM from the Commission included -- again,
)
13 there were some ACRS comments about all the components in 14
.the low-pressure system, the pump seals, valve bonnets, heat 15 exchanger tubes and so forth, and that all of those things 16 should be addressed, and then all high-and low-pressure 17 interfaces should be addressed.
18 The LRB, as written, just addressed, really, those 19 two and then made a statement that the PRA shows that all 20 the rest are insignificant contributors.
21 MR. MICHELSON:
What PRA shows that?
i 22 MR. WAMBACH:
I guess the PRA for System 80+.
23 MR. MICHELSON:
Maybe it should be said the-PRA 24 will have to demonstrate that, and then we'll look at the
,.~,
25 PRA and see if it, indeed, demonstrates it, and then we 1
~.
109 l
1 would agree, I think.
I don't think there is a PRA written 1
,-k) 2 right now that we've reviewed yet.
3 MR. KENNEDY:
This is Ernie Kennedy.
Not one that 4
you have reviewed.
5 MR. MICHELSON:
- Yes, 6
MR. KENNEDY:
We claim it's demonstrated.
I guess 7
that is open for discussion.
8 MR. MICHELSON:
What your approach is going to be 9
is to simply show on a probabilistic basis that it's so low 10 as to be discounted?
11 MR. KENNEDY:
It will be a combination of 12 deterministic design criteria, supplemented and confirmed by
(N 13 the FRA.
It will not be simply relying on the PRA to say N
14 it's not important for other low-pressure-connected systems.
l 15 MR. MICHELSON:
If you aren't able to provide a 16 reasonable basis, then you would fix it.
17 MR. KENNEDY:
Correct.
18 MR. MICHELSON:
Is that the approach?
19 MR. KENNEDY:
Correct.
20 MR. CARROLL:
On the subject of your PRA, are you 21 interpreting the Part 52 requirement for a PRA as meaning i
22 that you need to look'at potential accident sequences in l
23-modes other than power operation?
l 24 MR. KENNEDY:
The PRA which we have submitted only 1
e s
25 looks at full-power sequences.
It does not look at
.~, -..
110 1
sequences initiated for less than full power.
p
(
2 MR. CARROLL:
Do you have any plans to supplement 3
it?
l 4
MR. KENNEDY:
We know right now that that is a 5
subject of active discussion between the staff and EPRI in 6
the context of the requirements document and the EPRI ground 7
rules.
Right now, we are watching that very closely.
8 Right now, we have no plans to do anything other 9
than the full-power event.
We are encouraging EPRI that in 10 their discussions with the staff, to the extent they can, if 11 EPRI can demonstrate generically with some generic analyses 12 as to why that approach is acceptable, it would preferable 9 ^)
13 than having the individual applicants do that.
Whether or V
14 not they will take our suggestion, I do not know.
15 MR. CARROLL:
All right.
16 (Slide.)
17 MR WAMBACH:
The next issue is the core concrete 18 interaction.
The CE proposal, as you noted this. morning, 19 was 0.02 square meters per megawatt thermal of cavity floor-20 space and an in-containment refueling water storage tank for 21 flooding.
22 The staff prefers the more general, rather than 23 agreeing in advance that that is sufficient floor-space, to 24 go back to the more general requirement that sufficient O
(_s/
25 reactor cavity floor-space to enhance debris spreading and
.~
111 1
provide for quenching debris in the reactor cavity; in otner i,.
)
2 words, some demonstration that those two may or may not be
!s 3
acceptable.
4 MR. CARROLL:
Okay.
But how do we get out of this 5
dual loop?
It's very important that this be resolved, 6
because particularly with a spherical containment, like this 7
design is and some others, if the 02 is doubled or 8
quadrupled or whatever, it just blows the whole containment 9
design out of the water.
I mean this has got to be 10 resolved.
11 MR. WAMBACH:
Yes.
12 MR. CARROLL:
What's the staff's schedule for i
13 doing that?
We've got to fish or cut bait.
f 14 MR. WAMBACH:
Well, that's why we're going to this l.
15 more general requirement, so that they will then have to
.16 prove that that does this.
17 MR.-CARROLL: 'EPRI thinks they have.
When is the 18 staff going to tell them we agree or. disagree?
19 MR. WAMBACH:
How it's going with EPRI, I don't 20 know.
21 MR. CARROLL:
Charlie, Brad, can you add anything 22 to this?
23 MR. HARDIN:
I'm Brad Hardin from the staff.
24-This is one of the outstanding items, as you know,
)
25 in the various documents that have been generated on severe 1
ll
- -.. ~
112 l'
accidents, and there is an experiment that's been ongoing at
)
2 Argonne now, which EPRI and the NRC and the vendors are all 3
involved in doing cooperatively, and we hope that we get i
4 some information from that that will help resolve this 5
question of debris coolability, which will help settle this 6
coolability criteria, but it's a difficult experiment, and
.7 they haven't gotten any results from it.yet, and I don't 8
know what their schedule is right now.
I haven't talked to 9
them recently.
10 But I think a worthwhile comment to make is that 11 the staff has felt.that this has been an issue where we
- 12 could not really look at it withcut some conservatism, and I
so, for GESSAR, for example, we had to use the more
)
' 13
.i 14
. conservative approach that the staff has used traditionally 15 on debris coolability and to look at what does that mean in 16 terms of the' license-ability of the design,:and I would just I
17 offer the thought,.because I don't think we have any real 18 definitive information on this particular design yet, but 19 generally,. the result of not allowing the more rapid cooling 20-that EPRI has used in their' analyses is that we-have larger 1
21 loadings on the containment, and yet, those have been 22-acceptable fram a licensing viewpoint.
-23
.This was true for GESSAR.
I think that that's an L.
.24-alternative, if we have to fall back on that.
That's i
25' probably what wi.11 have to happen.
t
~
113 l'
MR. _ CARROLL:
In other words, if somebody designed f) 2 a cavity based on 02 and you wanted to apply conservatism, 3
your view is that -- and the design was fixed and they've b
gone ahead, and you know, it was very expensive to recover 4
5 from it, your approach would be to look at the margins that
(
6-containment had, as opposed to saying, okay, tear up all
[
7 that paper and start over again?
8 MR. HARDIN:
That's right.
I think, again, I have 9
to be careful that I don't overstate this, but I don't think 10 there is any information that would cause us a great concern.
r
=
11 that there would have to be a major re-design of the 12 containment.
I think it just wouldn't look as nice.
It would have some loadings that would be higher
-13 14 than otherwise, if-it was coolable, and yet, our information 15 indicates: that those loadings would be acceptable.
Those
~16 would be' included in the staff's final SER for the severe-17 accident response of the design.
18 MR. CARROLL:
Thank you, and you just have no 19 insights, Brad, as to how long this Argonne work is going to 20 go on?
21 MR. HARDIN:
If we had realized this was coming 22 up, we could have checked, but we can get back to you on 23 that.
24 MR. CARROLL:
Well, you'll be coming in on this 25 presentation next week so maybe you can have an answer,
---mm-m-um m
mme
114 1
MR. MILLER:
Maybe we can get an answer for the
(,.
2 full committee meeting next week, okay?
3 (Slide.)
4 MR. WAMBACH:
The Containment Performance Goal, 5
the definition'of containment failure, as Mr. Kennedy, 6
explained this morning, that we prefer this definition 7
rather than the dose-based definition of containment 4
8 failure.
9 This I believe is the same one that is in 90-016.
10 Again, the external events with frequencies less i
11-than ten to the minus fifth should not be disregarded.
l 12 The criteria for_ evaluating external events is jf )Y 13
'being worked out with EPRI on the ALWR requirements document
\\.
= 14 and when the resolution is gotten it will be transmitted to 15 the vendors.
.16 MR. MICHELSON:- Before you' leave that slide, on 17.
the first bullet, Containment Failure, you are thinking here 18 in terms of the classical failure in which something happens 19' that the core-has gotten into the containment I guess, and q
20 then the-activity is leaking out of the containment.
12 1 -
How about the case wherein you have an 2'2 intersystems LOCA in which the core never gets into the 23-containment perhaps.until extrememly late'in the game but
-s that early-on-you have got substantial leakage of the core 24
\\,)
25 directly outside of containment?
How does that fit into our m
115 1
definitions of containment failure?
)
-2 Is that a containment failure, to have an 3
_intersystems LOCA and dump the activity outsider of 4
containment?
5 MR. CARROLL:
It's a containment bypass.
6 MR. MICHELSON:
It certainly is a bypass but they 7
use the word " failure" and not the word " bypass" and I never 8
know when I see the word " failure" which kind of failures 9
they are talking about.
I wish they would be more careful 10 with the words but what was meant here in containment 11 failure?
Did that include a bypass type failure?
12 MR. WAMBACH:
I would have to assume so.
13 MR. ' MICHELSON:
So if I ever see the words 14
" containment failure" I always automatically assume that if 15 the' Staff is saying it it.means, it includes the bypass 16' possibility.
17_
MR. WAMBACH:
Part of the containment is the, you 181 know, the closed system boundaries.
19 MR. - MICHELSON :
Beg pardon?
20 MR. WAMBACH:
Part of the containment is the' 21 isolation valves in the closed system boundaries --
22 MR. MICHELSON:- Sure.
Sure, I think that it can 23 be easily defined that way but it's certainly an 24 uncontrollable leakage and it's substantially greater than a f
25 design basis leakage but the containment is not leaking.
I i
116 1
It-is not a loss of containment integrity except
!i )
2 in the sense that you have lost the integrity of piping 3
outside of containment and were for whatever reason unable 4
to isolate it.
That's how you got into that.
5 MR..WAMBACH:
I would say that is part of the 6
containment boundary at that point 7
MR. MICHELSON:
Okay, then that is a containment 8
failure then by your definition.
i 9
Now your second bullet in your previous slide also 10 gave me some trouble because it is not worded the same way 11
. as: CE's.
You are talking here about any external event 12 which is greater than ten to the minus five?
Or are you 1
79 -- -
13 talking about external events in which the results'are loss
,I
(
L 14 of containment.
Yes, that is what is meant.
i 16 MR. MICHELSON:
Shortened;it up?
'17 MR. WAMBACH:
Yes, I shortened it up.
p 18 MR. MICHELSON:
You left out an important part of l
L19
.it, i
20 MR. WAMBACH:
Yes.
21 (Slide.]
22-MR._WAMBACH:
Equipment survivability.
23 MR. WILKINS:
Are you willing to put any number in i
24 that sentence?
External events with frequencies, say, less
.(
(_,/
25 than ten to the minus six per year can be disregarded?
-a-m,-
w ~
117-1 MR. WAMBACH:
Does anyone on the staff want to
'2 answer that?
3 MR. ROTHMAN:
Bob Rothman from the staff.
4 At the present time the staff is looking at that.
l 5
As a seismologist as far as earthquakes is concerned I am 6
hesitant to putting bottom line numbers on those, having 7
absolute criteria, because of the fact of the uncertainty in 8
the seiemic hazard.
You have got such a wide range of 9
uncertainty I think you'are really fooling yourself when you g
10-put some probabilistic~ goal _ ten to the minus five or ten'to i
- 11-the.minus six.and try to reach it with the uncertainty 12
' involved in the seisimic hazard, at the input end of it, but_
pq 13 the' staff is still looking at that.
~Q
-14 MR. CARROLL:
What sort of alternatives to a I
15~
. quantitative cutoff'-.
16 MR. ROTHMAN:' 'What we prefer to do in the PRAs i
17' that we have looked at in the past and.the hazard studies is-18 look at relative, look at sequences relatively and see what 19' dominates in the accident space rather thanLputting some 20-number and saying you have to meet that, because we'run into.
21 problems'with the way the. hazard.is.done and thingc like
~
22 that to meet the numbers.
23 We feel that from plant to plant or sequences 24 within_a plant you are better off using a standardized i
25 metnodology and then comparing things relative to each other a
118 1
to.see where you may have problems.
()
2 MR. MICHELSON:
Well, how are you viewing other 3
external events and by that, other that seismic?
t 4
MR. ROTHMAN:
You mean --
5 MR..MICHELSON:
The disagreement I gather is only 6
on seismic.
Does that mean on all the rest of them it 7
should be ten to the minus six?
8 MR. ROTHMAN:
I don't think that number has been 9
accepted by the staff yet but I think the uncertainty in 10 some other external events are less than in the seismic and 11' they would more-easily be quantified.
12 MR. CARROLL:
So you don't think the staff has 13 accepted ten to the minus sixth as aLcutoff for non-seismic 14 external events?
15 MR. ROTHMAN:
I don't think the staff has accepted 16 a quantitative number, personally.
17 I know:in.the IPEEE program we are still.looking.
18 The staff has recommended that there not be a bottom line 19 number that a plant should reach but rather to look at 20 sequences and look at -- as far as IPEEE is the benefits of 21
-- fixing dominant sequences rather than setting some 22 number, to me.
23 101. -MICHELSON:
Does'that' sort.of comply with the 24' safety goal policy?
I thought the safety goal policy kind 25 of zerced in on numbers.
119 1
MR. ROTHMAN I'm not sure about that.
['
( _
2 MR. MICHELSON:
And they covered external events 3
as well, I assumed, so it doesn't seem like the staff is 4
quite following what guidance the commission has issued on 5
safety goals.
6-Maybe I didn't read it carefully enough.
7 MR. ROTHMAN:
The staff -.we're really having a 8
problem with wrestling with this and I am just telling you.
9-MR. MICHELSON:
Oh, you're thinking about that 11 0 part.
11 MR. ROTHMAN:
Yes.
We are still thinking about 12' that.
Ly 13 MR. MICHELSON:
-You may go back to the Commission X
'14 and ask for a clarfication?
15 MR. ROTHMAN:
I am not sure what the plan is.
16 MR. WAMBACH:
The next item is equipment 17 survivability,'which again CE didn't address because of the 18-timing of the papers.
19 The Commission approved the staff position is that L
20 mitigation features designed for reasonable assurance to l'
operate in severe accident environment for the time needed 21 L
22 but not-requiring EQ to 50.49 requirements or. Appendix B l'
l 23 requirements.
I:
l 24 MR. MICHELSON:
There were some reliability 25 requirments,-some magic words about high reliability or l
l
F
^
120 1-something like that, so it's more than just -- I just that's 2
part of assurance to operate.
_3 MR. WAMBACH:
Reasonable assurance to operate in 4
severe accident environment.
5 MR. MICHELSON:
Yes.
There were some pretty good 6
words in there, which fell just short of full-blown 7
treatment, it would appear.
~ 8.
(Slide.]
9 MR. WAMBACH:
IST pumps and valves, the CE b
10 proposal said they would have an IST program; however, that 11-didn't take into_ account the additional requirements that 12 were in 90-016 for considering piping cesign to incorporate 13' full flow' testing _of pumps and check valves designed and 14 incorporate provisions to test motor-operated valves under.
15 design basis differential pressure 16 MR'. CARROLL: 'And/or flow.
17 MR'. WAMBACH:
Yes..
Check valve testing should 1
- 18 incorporate the use of advanced non-intrusive techniques and 19 a program to determine the frequency of' disassembly,.
20 inspection of pumps and valves to detect' unacceptable
- 21 degradation.
22 MR. MICHELSON: =There is also'in there a -- one 23-now -- has to determine these -- I forgot the term at the 24 -
moment, but it's essentially the valves that can go into 25-n*.her positions and have to be returned to the right
121 1
position.
That return must be assured.
That was a part of
,m
(
2 89.10.
Of course, that means CE would want to do an 3
analysis to determine what the name or the most adverse 4
conditions on the valve and assure that it operates under
[
5
- those conditions.
I think it is all understood.
Compliance 6-with 89.10 is the answer.
7 Did CE take any -- do you know yet if you're l
8 taking any exception to 89.10 for future planto?
9 MR. KENNEDY I don't believe we are.
No, sir.
10 (Slide.)
t 11 MR. WAMBACH:
This slide has sort of miscellaneous
- 12 '
items on it.
The source term for severe accident evaluation L( -
13 is being developed with EPRI and ALWR vendors.
The USI and
' N,)
14-GSI resolution, as Mr. Kennedy said this morning, they are t
15 using the most updated supplement.
16 Conformance with SRP 10 CFR 50.34(g) -- that's I
L
-17
- again, Mr. Kennedy said that they plan to do that.
18 MR. MICHELSON:
Refresh my memory.
What is that I
'19 one?
'20 MR. WAMBACH:
That's the one -- 10 CFR 50.34(g)
L
'21-requires that applicant to identify deviations from the SRP.
l' f
22 MR. MICHELSON:
Okay.
Well, there are several p.
23 other things besides deviations from the SRP that are j
24 required-by Part 52 and I thought that was even flagged'in 25
. Part 52 along with several other items that had to be sure
.1
122 1~
to be in the application.
Maybe I'm wrong on that.
I
~ /~
l
\\
2; wouldn't be at all surprised if I were, but I --
3 MR. WAMBACH:
I think Part 52 has a general 4
requirement that you meet Part 50 and this is part of Part 5
50.
I guess --
6 MR. MICHELSON:
Maybe that was the way you backed l
7 into it,-yes.
I guess that was it because I went back and 8
searched.
Yes, I guess that listed them somewhere -- what 9
all they were.
Yes, physical security plan safeguards, all i
10 that stuff.
That was backed into it.
Okay.
I.got it.
'11 Thank you.
12
.MR. WAMBACH:
The. comparison with the ALWR l
t j
13
' Requirements Document.
The staff did sort of a screening 14 review on that only.
The SECY paper includes the-caveat 15 that if we identify any other potential policy issues.during 1
16 our review, that we will quickly bring them to the attention
-17 of the Commission., One that we flagged at this time was the 18 possible prototype testing for the.NUPLEX 80+.
'19 MR. CARROLL:'
Now, you're: saying that's an EPRI y
20-Requirements. Document issue?.
21 LMR. WAMBACH:- No -- pardon me.
No,.this was 22 identified ih their comparison'to ALWR requirements, they
-23 pointed:out that they did not have the single station, they had, you know, disbursed stations.
They didn't have one 24 1.
\\
25 single station from which the operator could do everything.
.. A.
t-T-W
-gir e f
123 1
It was in that context then that we said, well, we better
()
2 warn them that there may be the requirement for prototype 3-testing.
That --
4 MR. CARROLL:
An NRC requirement, not ar.-EPRI 5
requirement?
6 MR. WAMBACH:
Right.
7 HMR. CARROLL:
Okay.
8 MR. WAMBACH:
The same issue could come up on 9
other-advanced control room designs.
10 MR. CARROLL:
What's the basis for the NRC's 11 requirement?
Is it in a regulation, or it's just somebody's 12 idea of how to deal with these advanced control rooms?
i
'13 MR. MILLER:
It is premature to say that it is a-
~
14-policy issue.. What we wanted to: identify was that it may be 15
-- smerge as a policy issue.
We have staff here from Human
.16 -
Factors that can talk to that in some more detail, if you 17' Ldesire, as to where are thinking is today.
I-think there's
-18:
ls general-thinking on advanced control rooms,'in; general, 19 we're not-just-picking on CE.
20-MR. CARROLL:
I would~like to-hear a couple of 21 minutes of1that discussion.
22 MR. MILLER:
I'll ask Rich Correia to come to the 23 microphone and maybe he could gJno you where our thoughts 24 are at this time.
25 MR. CORREIA:
I'm Rich Correia from the Human
---i--,---
124 1
-Factors Assessment Branch.
2 As Mr. Miller stated, the concern isn't 3
necessarily just the CE advanced control room, it's all i
4~
advanced reactor control rooms.
Concern being that they are 5
so different than today's control room in the way that 6
they're laid out,-the type of displays that the operator 7
will be using, how the information is processed, coming _from 8
the plant to the operator and back again, basically, digital 9
control _versus analog control.
All of those issues together 10 combined-raises the question, well, will it really work?
11 The issue or prototype testing is a method of determining 12 whether or not the operators will indeed have the 13 information they need to perform the tasks they need to 14 control'the plantLunder.all conditions.
15 MR. CARROLL:
What would you envision such a 16 prototype to be; a simulator-driven control room?
17 MR. CORREIA:
That would be, I suppose, one
~18 extreme and then you would back down from there -- from a 19 full scope simulator, back'down to possibly dynamic mock-ups 20 of a control station.
We're. struggling with that right now.
21 MR. SHEWMON:
What's the dynamic mock-up that's 22L different from a simulator?
23 MR. CORREIA:
I would say a dynamic mock-up would 24 be a part-scope simulator, if you will.
It wouldn't have O
'25 the full capabilities of a simulator.
1 l
125 1
MR. CARROLLt So, it may just be one component of i(N)}
2 this like feedwater' control or something like that?
3 MR. CORREIA:
Right, with partial capabilities to-L 4-replicate plant system interaction with the operators.
-i 5
MR. MICHELSON:
I appreciate your concern about s
6 the newness of such control systems, and I have a particolar 7
concern about them, but from a different viewpoint, and that i
8-is the potential exposure of these types of systems to 9
extreme environments in local areas or perhaps even in the 10 control room, depending upon what thu event is you wish to 11 name.
Eventually we have to understa.3d the response of 1:
l 12 these. systems to-such events well encugh to know that it vN 13~
doesn't interfere with safe shutdown of the plant.
Is that d
14 going to be a part of this, or is it going to be a part-of L15 '
some other examination?
16 MR. WAMBACH:
,I guess that would be part -- more 17-the ISCB-type review.
Those are the Human' Factor's Staff --
[
'18-MR. MICHELSON:
This is mostly a Human Factor's
.19' review. -Okay, but somewhere else in the staff you will be 20-reviewing carefully the -- what you think is the 21'
. vulnerability of uds type of equipment to such adverse 22 exposures to assure that it doesn't really jeopardize safe-23-shutdown.
24-MR. WAMBACH:
Yes, sir.
1r i
(-
25 MR. MICHELSON:
I would think that that would be
126 F
1 something we would want to pursue with you and would expect N
2 to pursue.
3 MR. MILLER:
We would have to look at that as part 4
of our safety review in order to be able to draw a 5
-conclusion.
6 MR. MICHELSON:
Well, we'll'see.
7 MR. MILLER:
Yes.
8 MR. MICHELSON:
It may even require a test program 9
before CE gets through with it, i
10 MR. WAMBACH:
As far as our test program goes, s
11 then finally, on the' schedule there's not too much that can
.12 be'said.
We did intend now to go to a complete Integrated 13 Draft Safety Evaluation Report which will require more 14 informal type communications and keeping everybody up to 15 speed with the direction that everything is going.
16 I wanted to point out that the review has 17 commenced.
The discussion this morning had to do with 1
18 whether-the LRB would hold up the review or not.
It has
=
19 commenced.
We-have, back through '87 and '88, we issued 340 RAIs, and the Appl'icant has responded to about two thirds of
'20 those and we have been having meetings.
We had visits up to 21 4
'22 tha plant to see'the lockups of their NUPLEX 80+ and so on.
23' So, just to make the point that we are moving.
24
-forward on the review.
The schedule will, as you know, is 25 pending the Commission decision.
127 1
MR. MICHELSON:
I don't recollect that Charlie you
- (
2 showed earlier,-the one with.all the reviews _and all that 3
going on.
But my vague recollection of that chart was that 4
ACRS became involved long before the issue of a final SER, 5
but maybe I'm wrong.
6 MR. MILLER:
Yes.
Do you want me to put it 7
back up?
8 MR. MICHELSON:
It might not hurt to put it up.
~9 Right.
10 MR. MILLER:
Okay.
11 MR. MICHELSON:
The concern I have, of course, is 12 from comments I heard earlier and our discussion earlier i
1 13-wasn't real clear, how we were going to get integrated into 14 the process.
Maybe if you think that this chart is what 15 will be continued to be followed, we can be more specific 16' about where and.at what point we become integrated.
It
'17 looks like it is well before the final SER.
- 18 My concern, again, is-trying to get a leg up on 19 this thing so we don't end up at the end of the game trying_
-20 to do our own review.
We'd like to be reviewing along with 21 you somehow, so that we can close on it quickly when you're 22 done.
What kinds of things do you anticipate now sending to 23 us for possible-comment?
24
'MR. MILLER:
Let me show you.
25-(Slide.)
128 1-MR. MILLER:
This is what we're doing today.
()
2-MR. MICHELSON:
Right.
3 MR. MILLER:
So the ACRS will be involved as we 4
proceed through the LRB if the Commission decides that they 5
want us to complete it.
We will finalize the LRB and again 6'
you will see what we've come up with.
You'll be involved.
7 As we proceed through the Design Certification 8-Review.
9 MR. MICHELSON:
When the policy issue shows up, 10 for instance, we will be involved.
But what else will be 11 involved in besides that?
12 MR. MILLER:
Okay.
As the staff completes its i
13 review and drafts its --
14 MR MICHELSON:
That's a final SER there.
15 MR. MILLER:
It's a draft.
That's a draft SER, 16 yes.
Integrated SER.
-17 MR. MICHELSON: ' I mean, that's the integrated SER.
- 18' Okay, so that's the first time we'll get back in again.
19' MR. MILLER:- Well, first time. officially on the
. 20 diagram but, as Jay said, I anticipate-during this process
- 21 that we're going'to be having meetings along the way.
22 MR. MICHELSON:
But, as far as this process, we 23 don't really get involved until that DSER issued.
24 MR.-MILLER:
Right.
Well, at the time that the 9
25' draft SER was sent to the-Commission and we put them on
139 1
notice that we plan on issuing it, we would send it to the 2
. Committee.
3 MR. MICHELSON:
Now that might be a couple of 4-months' lead time at least.
5 MR. MILLER:
It is not the staff's intent to try 6
to hold it back for two months before it's given to the 7
vendors so that they can start working on the open issues 8
that are still identified and formally see where we are.
9 That period then would be used to get it to the Committee so 10 that we can start airing it with the Committee and get your 11 concerns and those concerns can get factored in while we're 12 closing _open issues and before we prepare a final SER.
j 13 MR. MICHELSON:
How many months do you think it 14' takes to get the DSER issued after it's a draft SER?
You've 15 got a draft SER there and then you do some things and then 16 you issue.
17 MR. MILLER:
It-is our intention that this Draft 18 SER would be submitted to the Commission.
I anticipate that
-19 we would try to issue that thing to the vendor as soon as 20 possible.
I don't even know if it_would be a matter of 21 months.
s 22 MR. MICHELSON:
Okay.
But then our clock starts
-23
.when you issue the DSER?
24 MR. MILLER:
Right.
25 KR. MICHELSON:
In this scheme of things.
130 1
MR. MILLER:
Right.
()
2 MR. MICHELSON:
We might see the Draft SER a 3
little earlier.
Whenever the commission sees it I would 4
hope we would see it I would hope we would see it, too.
5.
MR. MILLER:
Yes.
That is our intention.
6 MR. MICHELSON:
But apparently not much time 7
transpires before our clock starts because you think you're 8
going to issue the draft almost as soon as you give it to
~9 the Commission?
10 MR. MILLER:
Because of the mechanism that your 11 Commission has set up, their desire is to have policy issues 12 identified and resolved before we --
13-MR. MICHELSON:
Now, I how much -- I know you 14 don't know where we're talking about yet, but that Draft 15 SER, which is the integrated one, must be a year more from 16 now.
17 MR. MILLER:. Absolutely.
18-MR. MICHELSON:
Eighteen months, maybe.
.So, for
- 19?
the'next eighteen months.
We can pick and choose things 20 we'd to talk about but.we won't see any SER material, as I 21-
-understand it, until that Integrated Draft SER is issued.
22 MR. CARROLL:
To the extent new policy issues --
23 MR. MILLER:- To the extent that we identify any 24 policy issues,.we will have to write a paper on it.
And i
25 when that paper is written then it will come to you so that
131 1
you have an opportunity to comment to the Commission it rO
'()
2 before they pass judgment.
3 MR. CARROLL:
And to the extent we have a meeting 4
on selective issues, Carl.
5 MR. MILLER:
As we did yesterday, for example, on 6-the ABWR where you have some things that you really --
7 MR. CARROLL:
We might, for example, do what we've 8'
done on an ABR.
We might write a letter to the EDO saying, 9
hay we had a meeting with the staff and the applicant.
We i
i 10 have these concerns and we get some form of written response
.11 back from.the'EDO, as to how the' staff views our concerns.
l L
12
. MR. MICHELSON:
I'm just trying to understand the 13 extent to which we'd better start leading ourselves and not 14 ask the staff to be doing it.
-151 Traditionally in some cases you wait for the SER 6
L 16L and'then you start churning up your; staff.
17 MR. CARROLL:
No.
I think'we've got to be L
- 18
_proactive on this to some-degree.
-l l
19 MR.. MILLER:
Yes, we'll have.to be very proactive
-20 on this thing to get ahead.
' 21.
MR. CARROLL:
But as an example of our being 22-proactive1we, for example, -got. scheduled in --- what is it, i
23 Tom,-January -
the meeting on --
24' MR. EL-ZEFTAWY:
February.
b
^ /
,25 MR. CARROLL:
In February?
Okay.
The meeting on
~-
i
132 1
computer base control systems, to start us down this path, i'_ ls A/
2 It is not just with combustion, because it is an issue
-l 3
common as with all new plants, but Combustion is one of the 4
participants.
So, we will be getting a head start on that.-
S-MR. MILLER:
There are several other areas that 6-we're going to pursue like fire protections.
l 7
MR. MICHEISON:
I'm just trying to make sure I 8
understand the way we will have to play the game to come out 9
without an'. unreasonable delay at the end of the system.
10 But after a DSER is issued, then that gets turned
-11 around-quickly'and a final SER approval is conjured up.
4 12 Then the7 certification is something-that we don't know that i
)
13 much about yet, I guess.
a b
14~
MR. MILLER:
Right..
15 MR. MICHELSON:
Okay.
I think I appreciate it.
16 Thank you.
- 17L MR. SHEWMON:
I have two questions for CE before' L18 we quit.
One, could.you tell me what the end of life
(
19 fluence, fast neutron fluence, thatithe core midpoint is-l 20
'after sixty years with this?
You people used to hava kind 21 of a.high value even at 40' years, and I wonder if you've-22 changed the geometry much.
1
+
23 MR. KENNEDY:
I believe when we were here in 24 September we had those numbers with us, anticipating that 4,;ss 25 you would-ask those questions, and I didn't bring them l
5 133 l~
today.
Could I possibly pull that information out and send
)
2 it to you separately?-
3 MR. SHEWMON:
Yes.
s 4-MR. KENNEDY:
I don't have it with me today.
5 MR. CARROLL:
Or, just give it to him next week.
t 6
MR. SHEWMON:
Okay.
A different question, then.
7 What is the temperature drop across your core at full power, 8
the difference-between T-in and T-out?
i 9
MR.-CARROLL:
Temperature rise.
10-MR. SHEWMON:
Temperature rise, all right.
l 11 MR. KENNEDY:'
We will' check the number and give it 12 to you.'
I don't know the number off hand.
We'll check the 13 --
number.
I don't want to quote a nunter and be wrong.
-14 MR. SHEWMON:
Okay..Because, as_the outlet L15 temperature.comesidown at full. tower, the inlet temperature 16
.goesldown, too,'which means the vessel. temperature goes down 417:
as it=is radiated and so my meal interest is in what is the 18 temperature of the inlet at full power.
19 MR. KENNEDY:
Okay.
We-will give you those-l' D'
20 numbers.and also --
lt 21 MR. CARROLL:
Also, I think you're interested, L
22;
' Paul,.in what the impact of coast down would be because U
~
23 that's. going to drop T-in also.
H24 MR. KENNEDY:
We have also, I think, we have the L \\
25 numbers, we've calculated the end of life RT-NDT shift and l
}
134 i
- 1' we will give you those numbers and based on the material 2
specs.1 3
MR. SHEWMON:
Fine.
4 MR. KENNEDY:
We have that material available and 5
we'll get it to you.
6 MR. CARROLL:
It does, of ;ourse, depend on 7
whether you use a strategy of end of live coast down each i
8 cycle.
That's going to have an impact.
9 MR '. KENNEDY:
Understand.
i 10 MR. SHEWMON:
Okay, that's it.
11.
MR. CARROLL:
Does anyone else have anything else?
12 MR. MILLER:
Can I bring something up, if you are i
Lv- ;
13 getting ready to close.
l
$s, -
14~
MR. CARROLL:
I gueba so.
15 MR. MILLER:
Okay, thank you.
I appreciate that.
't 16
-Next week.we will have a full Committee meeting, I
--17
-guess on the same subject.
To that extent, are there any 18-insights'you want to give the staff-with regard to --
19 MR. CARROLL:
I was --
l
\\
l 20 MR. MILLER:
Do you want to give the same l.'
21 presentation, a different presentation?
22 MR. CARROLL:
I was' going to go off the record and 23 discuss _these things.
All right, we can do that, then.
s
-25 MR. CARROLL:
Okay.
We are off the record.
l l-l l
t 1
1 135 1
l 1'
(Whereupon, at 12:05 p.m.,
the meeting was ifN" Q.
2 adjourned.)
3 4
5 6
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n REPORTER'S CBRTIFICATE This is to certify that the attached proceed-ings before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: Advance Pressurized Water Reactors DOCKET NUMBER:
PLACE OF PROCEEDING: Bethesda, Maryland were held as herein appears, and that this.is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and trereafter. reduced to typewriting by me or under the direction of the court report-ing company, and that the transcript is a true and accurate record of the foregoing proceedings.
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CONTAINMENT PERFORMANCE....
u ROBUST DESIGN VIA NORMAL DESIGN PROCESS l
FOR SEVERE ACCID.ENT CONDITIONS THE CONDITIONAL FAILURE PROBABILITY WILL BE l
LESS THAN 0.1 BASED ON:
O, l
l (1)
CREDIBLE CORE DAMAGE SEQUENCES WITH A FREQUENCY GREATER THAN 1.0E-6 PER L
YEAR, EXCEPT FOR EXTERNAL EVENTS IAIICH BOTH DAMAGE THE CORE AND FAIL THE CONTAINMENT t
(2)
CONTAINMENT FAILURE WHEN DOSE IS GREATER THAN 25 REM AT ONE-HALF MILE.
V 1
^ SYSTEM &&
L
4 14.
L
',o CONTENT OF LRB...
I o
OTHER SPECIFIC ISSUES:
i COMPARISON WITH EPRI REQUIREMENTS i
PHYSICAL SECURITY AND SAB0TAGE SITE ENVELOPE COMPLETENESS OF DESIGN DOCUMENTATION QUALITY ASSURANCE MAINTENANCE, SURVEILLANCE & RELIABILITY SAFETY GOAL POLICY STATEMENT 60-YEAR LIFE l-FIRE PROTECTION LO STATION BLACK 0UT LEAK-BFFORE-BREAK SOURCE TERMS OBE/SSE-CONTAINMENT LEAK RATE HYDROGEN GENERATION E
CONTAINMENT VENTS MID-L.00P OPERATION.
4 INTERFACING SYSTEM LOCA ATWS ELECTRICAL SYSTEM DESIGN DEGRADED CORE BEHAVIOR SYSTEM $$#
'-e,ra.
-'ev-*n-W.-
cce
=d%+m 4, e ym-ee,g'.w,e me-y- -, * > -w
-*e-r w
w.
i 13 l
I l
15 " TECHNICAL'! ISSUES
- 1.
PUBLIC SAFETY GOALS
- 2.
S0uRCE TERMS
- 3.
- 4.
MID-Lo0P OPERATION
- 5.
STATION Bl.ACKOUT
- 6.
FIRE PROTECTION
- 7.
INTER 5YSTEM LOCA L
- 8.
HYDROGEN GENERATION AND CONTROL.
- 9.
CORE-CONCRETE INTERACTION.
- 10. HIGN-PRESSURE CORE MELT EJECTION i'
- 11. CONTAINMENT PERFORMANCE
- 12. "ABWR" CONTAINMENT VENT
- 13. EQUIPMENT SURVIVABILITY c
- 14. OBE/SSE
.15. IST FOR PUMPS AND VALVES CURRENTLY ADDRESSED IN LRB b
sysrw8@+"
._.m-,
... - - -. -. - - - -. -,,,.-~.--,,,,m--
,,m...-,-,..,,.-.-,.5-_-,,,
...,.+.-m-_ - _, -,,.. _,. - - - - - - - - -. -, -,,, - - - -
16 -
- 'O i
i CONTENT OF LRB...
o COMPARIS0N WITH EPRI " REQUIREMENTS" MEET EPRI CRITERIA REQUIRED FOR REGULATORY COMPLIANCE 0:
DEVIATIONS BASED ON ABB/CE EVALUATION SPECIFICALLY FOR THE SYSTEM 80+ DESIGN.
FOR STAFF AND C0144ISSION INFORMATION, NOT COMPLIANCE REVIEW.(12/89 STAFF REQUIREMENTS MEMORANDUM).
SYSTEM $$#
. m.
,.__m..,
,,...,_-..yr,..,,,
,__.-,..__,,,,,y_7.__
.c.
l 17 e
I i
AUGUST 1990 COMITHENTS 4
TO REVISE THE LRB o
MEET 10 CFR 50.34(F) ON H2 CONTROL i
o CLARIFY " CAPABILITY" TO ADD A CONTAIl04ENT PENETRATION AND VENT BASED ON SEVERE ACCIDENT ANALYSIS O.
o UPDATE COMPARISON WITH EPRI UTILITY REQUIREMENTS DOCUMENT L
SYSTEM $$#
-... - ~..
l 18.
I io l
\\
L l
l RESPONSE TO STAFF C0044ENTS l
o ADD EXPLICIT STATEMENT ON PERFORMANCE OF SRP DEVIATION REVIEW o
IMPLEMENT MOST RECENT SUPPLEMENT TO THE USI/GSI STATUS REPORT (NUREG-0933) lO
.o DEFINE CONTAINMENT FAILURE BASED ON SECY-90-016 (UNCONTROLLABLE LEAKAGE SUBSTANTIALLY GREATER THAN DESIGN BASIS LEAKAGE) i 3
SYSTEM $$#
,.....,..,,_,.-._.%.m_,
l-19 l-Y~
i l
1 F
3 MESPONSE TO STAFF COMENTS...
o RE-DEFINE "CREDI6LE EXTERNAL EVENTS" o
REVISE WRITEUPS FOR "MID-LOOP", "INTERSYSTEM' LOCA",.AND " FIRE PROTECTION" g.
ADD WRIT'UPS FOR " EQUIPMENT SURVIVABILITY" E
o AND " INSERVICE TESTING 0F PUMPS AND VALVES" l
l:
sysreu8@+~
..-a,
.--..w----.-,.----
-.--n... -, -,.., - -..,, -.~. _.. - - - - -. ~... - -,
20.
f LO l
i i
l 4.
COMPARIS0N 0F ABWR AND SYSTEM 80+
l r
r
[
LRB STRUCTURES o
ORIGINAL FUNCTION OF BOTH LRBs WAS THE SAME o
BASIC STRUCTURE OF THE SYSTEM SO+ LRB
[
REMAINS, BUT MUCH OF THE DETAIL HAS CHANGED DUE T0:
i O DESIGN PROGRESS AND CESSAR-DC PUBLICATION ISSUANCE OF 10 CFR, PART 52 l
IDENTIFICATION OF POTENTIAL POLICY ISSU.ES RELATED TO NEW TECHNICAL CONCERNS I
s O
sysrm8@+"
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a,v.,.,.. -,,,,.,, -,..,,...,,,,,.
,r,,,.e,
,,.--,.,,,,.,.,n-+
21,
[
l
).
CONCLUSIONS l
o STAFF APPROVED AND ISSUANCE OF LRB HAS BEEN r
ELUSIVE h
IMPORTANCE OF LRB HAS DIMINISHED o
p 10 CFR, PART 52 HAS BEEN ISSUED POLICY ISSUES HAVE BEEN DOCUMENTED IN SECYs AND SRMs SCHEDULES ARE UNCERTAIN CESSAR-DC REVIEW CAN, AND SHOULD, PROCEED IN I
PARALLEL'..
MOST MATERIAL IN CESSAR-DC IS UNAFFECTED BY LRB ISSUES NO-SIGNIFICANT DISAGREEMENT WITH STAFF l
k i
system $$#
t
... ~. -
- NRR STAFF PRESENTATION TO THE O
SUBJECT:
LICEtiSING REVIE)/ DASIS DOCUMENT FOR THE COMBUST 10f4 ENGINEER!flG, INC. SYSTEM 80+ EVOLUTIONARY llGHT WATER REACTOR,SJ_CY-90-353 DATE:
ll0VEMBER 1, 1990 PRESENTER:
THOMAS V. WAMBACH O
PRESENTER'S TITLE / BRANCH /DIV: PROJECT MANAGER STANDARD 12AT10N PROJECT DIRECTORATE DIVISION OF REACTOR PROJECTS - 111, IV, V AND SPECIAL PROJECTS PRESENTER'S NRC TEL. NO.:
(301) 492-1103 SUBCOMMITTEE:
ADVAHcED PRESSUR17ED WATER REACTORS 9
6
_ - - - _ _ _ - - -. - -. _ _ - - -. - - - - - - _ _ _ _ - _ _ - - - _. - - - - -. - - _ - - - _ _ _ _. - _ _ - -. -. _ _. _ - - - -. - - - - _. ~ -. - -. - - -. - - - _ _ _ _ -
O CESSAR DC LICENSING REVIEW BASIS (LRB) l 1987-1988 CE SUBMITS DRAFT LRB'S CE SUBMITS PROPOSED LRB JANUARY 22, 1990 l. i)
JUNE 22, 1990, DIRECTS STAFF TO IMPLEMENT STAFF REQUIREMENTS MEMORANDUM (SRM) DATED
,c~s.
s-PROCESS PRESENTED IN SECY-90-065 I
SRM DATED JUNE 26, 1990, ADDRESSES STAFF POSITIONS SECY-90-016 l
CE SUBMITS MINOR REVISIONS ON AUGUST 28, 1990 1
1 SECY-90-353 SENT TO COMMISSION OCTOBER 12, 1990 1
l C- 'sj
(_)
SECY-90-016 LRB SYSTEM 80+
(1) PUBLIC SAFETY 60ALS SEC 7.7 & 6.5 (2) SOURCE TERM SEC 7.12 (3) ATWS SEC 7.19 (4) MID-LOOP OPERATION SEC. 7.17' (5) STATION BLACKOUT SEC. 7.10 (6) FIRE PROTECTION SEC 7.9' (7) INTERSYSTEM LOCA SEC. 7.18' (8) HYDROGEN GENERATION & CONTROL SEC. 7.15 (9) CORE-CONCRETE INTERACTION SEC. 7.21' (10) HIGH PRESSURE CORE MELT EJECTION SEC. 7.21 (11) CONTAINMENT PERFORMANCE SEC. 6.5.3*
.p uJN/
(12) AEKR CONTAINMENT VENT SEC. 7.16 (13) EQUIPMENT SURVIVABILITY l
(14) OBE/SSE SEC. 1.2.1 (15) IST PUMPS AND VALVES l
l l
ADDITIONAL INFORMATION NEEDED TO CONFORM To SECY-90-016 l
-n
G
's /
SECY-39-013 LRB SYSTEM 80+
TECHNICAL SPECIFICATIONS SEC. 7.6 RELIABILITY ASSURANCE SEC. 7.6 LEAK BEFORE BREAK SEC 7.31 TYPE C CONTAINMENT LEAKAGE RATE SEC. 7.14 PHYSICAL SECURITY SEC. 7.2
,2,,
60 YEAR LIFE SEC. 7.8 ELECTRICAL SYSTEM DESIGN SEC. 7.20 t
I-
6 O
REGULATORY COMPLIANCE EXEMPTION TO 10 CFR 100, APPENDIX A REGARDING OBE BEING ONE-HALF SSE STAFF IDENTIFIED EXEMPTION To 10 CFR 50,34( f )(3)( iv )
t (m
CONCEPNING A DEDICATED PENETRATION FOR CONTAINMENT r
\\
VENT 1
r
- l
(
l l
1
\\
i I
l
()
MID-LOOP OPERATION I
l CE PROPOSAL j
t
- ANALYSIS
- CONSIDER DESIGN FEATURES AND/OR OPERATIONAL RESTRICTIONS l
- CONCERN LIMITED TO PRESSURE BUILDUP IN l
RCS nV COMMISSION DIRECTIVE
'l 1
l l
- PROPOSE DESIGN FEATURES TO MINIM 12E LOSS OF SHUTDOWN COOLING FLOW r
1
- RELIABILITY OF SHUTDOWN COOLING SYSTEM 1
- INSTRUMENTATION i
i
- CONTAINMENT CLOSURE i
l i
I
9 O
FIRE PROTECTION CE PROPOSAL
- SAME AS SECY-90-016 COMMISSION DIRECTIVE O
- AreRovco sTaee eosiTio" 18 secv-90-ois
- AS SUPPLEMENTED BY STAFF RESPONSE DATED APRIL 27, 1990 TO ACRS CONCLUSIONS REGARDING EVOLUTIONARY LIGHT WATER REACTOR CERTIFICATION ISSUES O
e Ih INTERSYSTEM LOCA CE PROPOSAL
- NO LOW PRESSURE SAFETY INJECTION
- INCREASE DESIGN PRESSURE OF SHUTDOWN COOLING SYSTEM TO 900 PSIG l
COMMISSION DIRECTIVE
)
- ADDRESS ALL HIGH/ LOW PRESSURE INTERFACES WITH THE RCS AND ALL COMPONENTS OF LOW PRESSURE SYSTEM l
t
- ADDRESS THE REQUIREMENTS FOR VALVE LEAK TESTING, l
VALVE POSITION-lNDICATION, AND HIGH PRESSURE
]
t-L ALARMS WITH OPEN ISOLATION VALYFS AS DESCRIBED IN I
l SECY-90-016 1
1 l
i l
O COPE-CONCRETE INTERACTION CE PROPOSAL 2
.02M /MwT CAVITY FLOOR SPACE
- RWST IN CONTAINMENT FOR FLOODING COMMISSION APPROVED STAFF POSITION
()
- PROVIDE SitFFICIENT REACTOR CAVITY FLOOR SPACE TO ENilANCE DE9RIS SPREADING
- PROVIDE FOR QUENCHING DOBRIS IN THE REACTOR CAVITY O
CONTAINMENT PERFORMANCE G0AL CONTAINMENT FAILURE - LOSS OF CONTAINMENT INTEGRITY RESULTING IN Ah UNCONTROLLABLE LEAKAGE SUBSTANTIALLY GREATER THAN THE DESIGN BASIS LEAKAGE EXTERNAL EVENTS WITH FREQUENCIES LESS THAN 1.0E~5/RY SHOULD NOT BE DISREGARDED
([)_
CRITERIA FOR EVALUATION OF EXTERNAL EVENTS ARE BEING DEVELOPED IN THE REVIEW OF ALWR REQUIREMENTS DOCUMENT l
l.
L l
l l
l O
l e
.(]
v.
EQUIPMENT SURVIVABILITY CE PROPOSAL i
.NONE i
i COMMISSION APPROVED STAFF POSITION
- MITIGATION FEATURES DESIGNED FOR REASONABLE p-d-. '
ASSURANCE TO OPERATE IN SEVERE ACCIDENT ENVIRONMENT FOR' TIME NEEDED l
1.
'j 1
1:
L l _.
j i
' h I-t af
t y.
hJ l'
.IST PUMPS AND VALVES CE PROPOSAL
- IST PROGRAM
. COMMISSION APPROVED STAFF POSITION-
.l L
- PIPING DESIGN SHOULD INCORPORATE FULL FLOW TESTING OF PUMPS AND CHECK VALVES W
- DESIGN SHOULD INCORPORATE PROVISIONS TO TEST MOTOR OPERATED VALVES UNDER DESIGN BASIS DIFFERENTIAL PRESSURE E
1
- CHECK VALVE' TEST.!NG SHOULD' INCORPORATE THE USE OF
' ADVANCED NON-INTRUSIVELTECHNIQUES
'i l
- A PROGRAM.To DETERMINE THE FREQUENCY OF DISASSEMBLY AND INSPECT 10N OF PUMPS AND VALVES TO DETECT UNACCEP-TABLE DEGRADATita NOT DETECTABLE THROUGH NON-INTRUSIVE TECHNIQUES i
=
I 1'1a IO SOURCE TERM FOR SEVERE ACCIDENT EVALUATION
- BEING DEVELOPED WITH EPRI AND ALWR VENDORS USI a GSI RESOLUTION
--VERSION OF NUREG-0933 CURRENT 6 MONTHS PRIOR TO COMPLET10N OF APPLICATION CONFOR,iANCE WITH THE SRP 10 CFR 50,34(g )
COMPARISON WITH ALWR REQUIREMENTS DOCUMENT
- ONE' ISSUE IDENTIFIED AS POTENTIAL POLICY ISSUE -
PROTOTYPE TESTING OF NUPLEX 80+
0 SCseDULe
- COMPLETE DSER TO BE ISSUED NOT SECTION BY SECTION
- REVIEW HAS COMMENCED
- SCHEDULE,PENDING COMMISSION POLICY ON LEVEL OF DETAll O
,