ML20072M588
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N0TATI0N V0TE l
RESPONSE SHEET
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SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM:
C0W4ISSIONER CURTISS
SUBJECT:
SECY-92-037 - NEED FOR NRC-SPONSORED CONFIRMATORY INTEGRAL SYSTEM TESTING 0F THE WESTINGHOUSE AP600 DESIGN APPROVED in part DISAPPROVED in part ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION C0144ENTS:
See attached coments.
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V SIGNATURE RELEASE VOTE
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Apr i 1, in2 WITHHOLD VOTE
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ENTERED ON "AS" YES x
NO
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CORRESPONDENCE PDR
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Commissioner Curtiss' comments on SECY-92-037:
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l I generally concur with the views expressed by the Chairman, subject to the following additional comments and recommendations:
1 1)
Based upon what we know today, I do not believe that it is possible (or, for that matter, prudent) to declare at this point that the results of the testing that the j
staff proposes to undertake will H2t be necessary prior to certification.
I am most uncomfortable endorsing j
such an approach for the following reasons:
4 a)
First, as the Chairman points out, it is simply impossible at this point to predict how good the 1
data from the Westinghouse testing at the SPES
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facility will be in confirming the relevant l
codes.1 q
b)
Second, if anything, the information available to i
us today seems to suggest a very distinct possibility that the test results may well be necessary to permit the agency to render its safety determination.2 1
i Indeed, if we were able to say definitively that the SPES i
tests are going to be sufficient for purposes of certification --
the direct implication of the staff's recommendation (3) (a) in SECY-92-037 -- I would submit that we would'oe hard pressed to justify any additional NRC testing.
2 In this regard, I found Brian Sheron's comments at the Commission's March 31, 1992 meeting, where he discussed what will i
likely happen when the staff gets more deeply into the review, to j
be most illuminating:
What is most likely going to happen is that Westinghouse will run their SPES facility first.
1 They'll run some tests and we're liable to see j
something that looks a little funny.
For example, they l
may have an excessive heat storage problem and some metal mass.
We saw this in Semiscale once the downcomer acted like a geyser.
Due to stored energy, it just blew the water out and we kind of scratched our i
head about that one.
Now it's very likely that SPES or OSU may produce some results that we raise questions about, and what normally happens, we'll have a meeting with Westinghouse.
They'll bring in all their experts and we'll bring in ours and we'll sit down and we'll sit there and we'll argue over whether or not we understand it.
Westinghouse will always come in and i
say, "We understand what happened."
It's just by
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definition.
They can't come in and say, "We don't i
understand our plant."
They'll come in and say they understand it and here's why, and here's why we i
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c)
Third and finally, from a procedural standpoint, ue are limited under Part 52 in what we can do a
with information that becomes available to us after the staff renders its safety determination on the adequacy of the design.
In view of these constraints, I believe that every effort should be made to ensure that all necessary information is available prior to the point when final safety decisions will be rendered.3 I
understand it, and here's what our codes say.
And 4
we'll raise a whole bunch of questions about why we think they're wrong and the like.
And we'll do this and sometimes we'll resolve it.
A lot of times we're gonna, the staff's gonna walk away kinda, you know, with something in our throat.
We're just not satisfied, we just don't have enough evidence to really say, " Westinghouse, you have to go out and spend a jillion Callars and get another test."
A lot of times what the staff does is, we're going to say, " Alright, we're going to run this in our facility.
We're going to see what happens and if this thing does the wrong thing then you guys are in big trouble.
If it does what you said it does and the like then, okay, we'll go
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away and leave you alone."
So most likely what we will
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do is we will watch the SPES facility and if something goes wrong we're going to turn around immediately probably and say we're going to go run it in ROSA where i
we know we don't have those distortions for example.
And we're going to see what the answer is.
If it comes out wrong, then you guys are going to have to go off 4
and fix the problem real quick.
And that's why 4
I'm saying that if we have a facility available that we can turn to, say, prior to an FDA, when all this is going on, that would be very useful to 1.s.
In view of comments like this, I am frankly puzzled by the staff's recomacndation that we should declare today -- more than four years prior to the scheduled date for issuance of the certification -- that this information will not be necessary for our certification decision.
3 In this regard, the finality policy reflected in Part 52, as well as the actual language of 10 CFR 50.109, would suggest that the crucial timeframe for obtaining this information is prior to the issuance of a Final Design Approval (FDA) for the AP-600, since the staff will arguably be bound by the safety decisions that are rendered in the FDA.
l*
I fs For the foregoing reasons, I do not believe that it is prudent to declare, as the staff recommends in SECY ;
037, that the information to be obtained from the high-i pressure, full height testing that the staff proposes to undertake will not be required prior to design certification.
4 2)
I concur in the Chairman's recommendation to authorize the
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staff to pursue the ROSA IV option and to make the necessary
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financial commitments, subject to two additional comments:
(i) in the event that the cost or the schedule for undertaking the testing at the ROSA facility turns out to be j
substantially different from what the staff currently estimates (i.e., $10 million and 24 months), I believe the l
Commission should have the opportunity to reexamine the i
merits of pursuing this approach; and (ii) in any event, staff should seek the commission's approval of the final negotiated agreement.
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gv POLICY ISSUE 1
January 10, 1992 (NEGATIVE CONSENT)
SECY-92-011 For:
The Commissioners From:
James M. Taylor Executive Director for Operations
Subject:
REQUEST FOR PUBLIC MEETING TO DISCUSS THE AGENCY'S POLICY ON ORGANIZATIONAL CONFLICTS OF INTEREST r
Pu_rpo s e :
To inform the Commission of the staff's intention to hold a public meeting to address recent concerns expressed by the nuclear industry regarding the Agency's revised Organizational Conflicts of Interest (COI) policy.
Discussion:
On August 15, 1991, the Commission approved certain 1e
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POLICY ISSUE January 10, 1992 (NEGATIVE CONSENT)
l For:
The Commissioners j
From:
James M. Taylor Executive Director for Operations 4
l
Subject:
REQUEST FOR PUBLIC MEETING TO DISCUSS THE AGENCY'S POLICY ON ORGANIZATIONAL CONFLICTS OF INTEREST i
To inform the Commission of the staff's intention l
P_uroc se :
to hold a public meeting to address recent concerns expressed by the nuclear industry regarding the Agency's i
i revised Organizational Conflicts of Interest (COI)
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policy.
l Discussion:
On August 15, 1991, the Commission approved certain cha tojheA 01 coliev rec
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