ML20125E202
| ML20125E202 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1992 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9212160241 | |
| Download: ML20125E202 (108) | |
Text
_ _ _ _ _ _ _ _ _ _ _
.MSSS44%%%%%%%Wn%%%/6%%%%%%%WpVrij;V;V;ij;(%;(f%fffigg;gg P
Y l'
- At!SMITTAL 70:
'X Occument Control Dest, 016 Phillips g
s f
'0VANCED CCPY TO:
The Public Occument ocem
/4,(([9A CATE:
y 3
FROM:
SECY Correspondence & Recorcs Branen 5
Attacned are ccoies of a Commission meeting transcript and related meeting 2"
3 document (s).
They are being forwarced for entry on the Daily Accession List and placement in the Public Occument Room.
No other distribution is reouested or
&9 c
reouirec.
Meeting
Title:
Nt
[org<v-<./
N cod <E-c,_
e u) hE Meeting Cate:
/ A/7/ 9 A Goen
)(
Closec E
f1 g
3 h
Item Cescr10tien*:
Copies Advanced DCS 3
, 8 it:-
to POR Cooy C
3 s::
- 1. TRANSCRIPT 1
1 g
WNLut hA g-j
.sv g b y
v 2.
E E
[
e 3.
h 5
=s 4
e>
22 4'
1 2
e 2.
=e 2
5 1400 %
e, y
f
- POR is advanced one copy of each document, two of each SECY paper.
[
C1R Branch files the original transcript, with attachments, withcut 5ECf
[
,f0 t
papers.
9212160241 921207 O
s 3
PDR 10CFR NNNNM
_J
1 4
i i
UNITED STATES OF AMERICA 1
NUCL2 EAR REGULATORY COMMIS SION d
4 i
4 SkIi3l BRIEFING ON LICENSE RENEWAL RULEMAKING ISSUES l
i LOCECCT:l ROCKVILLE, MARYLAND f
D3I6l DECEMBER 7, 1992 23963 79 PAGES I
f i
l l
[
NEALR.GROSSANDC0.,INC.
COURT R$ PORTERS AND TRANSCRIBER $
1323 Rhode Island Avenue,-Northwest Washington, D.C.
20005
]
(202) 234-4433
i DISCLAIMER h
1 This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on t
December 7, 1992 in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was 4
- open to public attendance _and observation.
This transcript has not been reviewed, corrected or edited, and it may I
contain inaccuracies.
The transcript -is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or-beliefs.
No pleading or other_ paper may_be. filed with the-Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
4 a
i-NEAL R. GROSS COURT REMMTERS AMO TRANSCRIRIR$
1323 RMo0E ISLAMO AVENUE, N.W.'
(202) 234-4433 WASM4NGToN, D.C.
20005 (202) 232 6600
3 2
1-I-
-1 UNITFD STATES OF AMERICA i
l 2
NUCLEAR REGULATORY COMMISSION' t
4
~
[
3 i= -
t 4
1 5
BRIEFING ON LICENSE RENEWAL RULEMAKING ISSUES
+
i 6
l l
7 PUBLIC MEETING 4
8-i 9
Nuclear Regulatory Commission i
10 One White Flint North 11 Rockville,_ Maryland I
12 i
i 13 Monday 1
i 14 December 7, 1992 2.
i 15 l
l.
16 The Commission met-i n - o p e n - s e s s i o n,- - pursuant to i-
~.
Chairman j.
17 notice,.at 9:30 a.m.,
the Honorable IVAN SELIN, i-j' 18 of the Commission, presiding, j '.
'19 20 COMMISSIONERS.PRESENT:
,i
{
21
..IVAN'SELIN, Chairman of the Commission 1-22 KENNETH C. ROGERS, Member of-the Commission 4
. 23-
-JAMES. R. CURTISS,: Member.of-the Commission
~
24 FORREST J.=REMICK', Member df the Commission-25 i
NEAL1 R. GROSS f-COURT REPORTERS AND TRANSCRIBERS.
7 1323 RHODE ISLAND AVENUE, N W.
}:
(202) 2344433 WASHINGTON. D C. 20005 (202) 2344433 A.-
4
~2
~.
._,.__ n,
...,_.__.2.,
1
-2'
-1 STAFF AND PkESENTERS SEATED AT THE COMMISSION TABLE:
2 SAMUEL J..CHILK, Secretaryl 3
MARTIN
- MALSCH, Deputy General Counsel-for 4
Licensing Regulation 4
5 JAMES TAYLOR, Executive Director for Operations 6
DR. THOMAS MURLEY, Director,'NRR 7
JOHN CRAIG, Director for License Renewal PD, NRR 8
RICHARD CORREIA, Security Chairman, NRR 9
WILLIAM RUSSELL,. Associate Director,. Inspection 10
& Technical Assessment, NRR 11 MARTIN VIRGILIO,.-Assistant-Director, Region IV 12
& V Reactors 13 14 15 16 17 18
-19'-
20 21 22 23 7
.24 25-
=
J NEAL-R. GROSS-COURT REPORTERS AND TRANSCnlSERS 1323 RHODE ISLAND AVENUE, N W l
' (202) 234 4433 WASHINGTON D C. 20005
-(202) 234 4433 e
.... =......... -..-. -.
3 1
sROCEEDINGS 2
(9:31 p.m.)
3 CHAIRMAN SELIN:
Good mornug, ladies and 4
gentlemen.
I'm pleased to welcome members of the staf f to 5
brief the Commission on license renewal issues.
This 6
morning is the first of three briefings that we'll receive 7
this month, on this very important subject.
8 Today's briefing will focus on the Part 54 4
9 rulemaking issues. The second briefing, tomorrow at 9 : 30, 10 will be on Part 51 rulemaking regulatory guidance issues.
d 11 The third briefing will be on industry initiatives and I
12 resources, and is scheduled for December 18th.
13 These briefings are designed to provide the 14 Commission a status report and a summary of staff plans to 15 address issues which have emerged since the publication of I
16 the final license renewal issue.
17 The Commission has now experienced about a 18 year's worth of very intensive effort to implement the 19 license renewal
- rule, however, following the recent 20 decision of Northern States Power Company to delay the 21 license renewal application of its Monticello facility, 22 and given the number of issues which the preliminary 23 review of their possible application has identified, we i-24 believe it's appropriate to take this opportunity to pause 25 in the process to assess our efforts to date.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
1323 RHODC. ISLAND AVENUE. N W.
(202) 234 4433 WASHINGTON, O C. 20005 (202) 2344433
l 4
1 As the decision by Honticello to delay its i
2 application and the earlier decision by Yankee Row to shut l
3 down and demonstrate, there are a number of factors that 1
4 a utility considers in determining whether or not to l
5 pursue license renewal.
5 The commission's obligation -- and I'd like to i
j 7
stress this over and over again -- is to ensure that a l
l 8
stable, predictable, and reasonable regulatory process 1
1 9
exists within which a licensee can consider whether or not j
i.
10 to submit a license renewal application.
i 11 The final license renewal rule adopted by the 12 Commission a year ago was premised on two fundamental 13 principles.
The first principlc is that with the 14 exception of age-related degradation unique to license i
15 renewal, the current and ongoing regulatory process is 16 adequate to ensure that the licensing basis of a currently 17 operating plant is maintained to provide an acceptable i
18 leve'. of safety.
19 That's quite a mouthful but, basically, whM
'e 20 have said is that we are satisfied that the eurrent 21 operation provides for a reasonable level of safety, and 22 the big question is, will the license renewal efforts 23 assure that that level of safety continues in the face of-24 age-related degradation?
-It's not a brand new review of i
25 issues from scratch.
- NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W 4
l (202) 2344433 WASHINGTON. D C. 20005 (202) 234 4433
.n.
5 1
- Thus, the locus of any review for license 2
renewal has to be on any modifications which have to be 3
made to the regulatory process in order to address age-4 related degradation during the renewal period.
5 The second principle is that mechanisms must be 6
in place to maintain the plant licensing basis during a 7
renewal term.
Our review effort over the no;t few days 8
and weeks is designed to help us identify any 9
modifications which may be necessary to our regulatory 10 process, to assure that these two principles continue to 11 guide our efforts.
12 It's not an attempt to review the process that 13 began in the first place.
A great deal of time and effort 14 went into determining that rule. A large number of issues 15 were addressed and settled, and we're talking, at this 16 point, about the implementation of the rule, not a review 17 of it.
18 Copies right off the press, still dripping ink 19 and exuding
- steam, are available, or about to be 20 available, at the entrances to this room.
21 commissioners, do you have any comments?
22 (No response.)
23 Mr. Taylor, would you proceed, please?
24 MR. TAYLOR:
Good morning.
With me at the 25 table, from the Office of Nuclear Reactor Regulation, are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 2344433 WASHINGTON, D C 20005 (202) 234-4433
6 1
Dr. Murley, John Craig, Mr. Correia, and Bill Russell, and 2
Marty Virgilio.
3 The staf f welcomes these meetings thie :nonth 4
that we expect to have with the Commission, and continue.
5 We do believe that the issues and some of the problems 6
that have emerged are solvable.
There are still issues 7
that I noted in some correspondence with the commission 8
that we're working on.
There are some issues of fatigue 9
and environmental qualification, reactor vessel reviews, 10 where the staff has additional work before -oming and 11 bringing those type of issues in front of the Commission.
j 12 But, generally, we believe these issues are resolvable 13 and, with those thoughts, I'll ask Tom Murley to continue 14 the briefing, i
15 DR. MURLEY:
Thank you, Jim.
i 16 As you mentioned, Mr. Chairman, the rule was 17 published a year ago, but we in the staff have been 18 working with the lead plant po: eo&ial applicants for over 19 three years now, on these issues.
20 In light of the experience with Yankee Row and 21 Monticello, I think a natural question arises as to 22 whether there are basic problems with the rule, or the way 23 the staf* has been implementing the rule.
24 CHAIRMAN CELIN:
If you put it to the commission i
25 that way --
NEAL' R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON. O C. 20005 (202) 2344433
l i
7 J
j j
1 (Laughter.)
l 2
DR. MURLEY:
I think we in the staff believe the i
l 3
rule is logical, practical, and it provides a sound basis 4
for safe operation up to 20 years beyond the original J
l 5-license term, and we see no reason at the moment that the i
6 rule needs to be changed.
i i
7 There have been several issues raised with the 3
3 8
staf f's implementation of the rule, including the adequacy 9
of the current licensing basis -- that is, the perception 2
- 10..
that the staff intends to apply - new requirements in l-
- l 11 7!
,.:ertain areas like fatigue. analysis and equipment 4
12 qualification -- and another issue is the scope of the l
l 13 structures, systems, and components important to license 1
j 14 renewal that have to be analyzed.-
15 I am netting-up a senior management review in 16 NRR, to look over these issues and what has been done in I
17 the last -- well, basically, the last year since the rule l
l-18 has been implemented.
This review, I think,- will take i
j 19 probably a few months to do.
20 My sense of looking at this is that these issues i
21 are.not major. They can be resolved in a manner where the i
j 22 staff gets what it.needs to make safety judgments under-l 23 the rule, without imposing unreasonable burden on the 24 applicants.
- 15 In parallel then with this what I call " generic" L
NEAL R. GROSS l
COURT REPORTER $ AND TRANSCRIBERS -
{-
1323 RHODE ISLAND AVENUE. N W--
{-
(202) 2344433 WASHINGTON, D C 20005
_(202) 2344433 L
._,-_.1....
.s,....,,
..,,,,, _,., _,,. -.... _ ~ - - _,.,
..._,,,_.a.,---._.,_.,_.._,~,.,~,..
8 1
activity, generic review activity, by the staff, we have 2
begun working with the B&W Owners Group on another generic 3
program, to resolve technical and regulatory issues for 4
the B&W plants regarding license renewal.
5 In my judgment, I think this effort with the B&W 6
Owners Group promises to be more productive than the 7
plant-specific lead applications, and there are several 8
rrwsons for that.
The first one is that the B&W Owners 9
Group has a proven record of solid technical approach to 10 issues. We have worked with them in these kinds of' issues 11 before. They appear to have committed the resources, both 12 dollars and manpower, to do the job-right.
13 Third is there won't be the distraction in these 14 early years, of license-related issues that can always 15 arise in a plant-specific application. And by that I mean-16 the kind of issues that arose in Yankee that really had 17 nothing to do with license renewal, they had to do with l
18 unearthing a problem that was there in the beginning,;and
[
19 it quickly overshadowed license renewal,
- namely, the F
j 20 vessel-issue.
i 21 There may be some issues that were incorrectly I
resolved by'the. staff years ago, and I'mean ten, 15-years-
-22 23-ago,- but which cannot be overlooked merely:because they 24 were incorrectly ' resolved.
And, here,-I'm thinking-of i
-25 the, 'again, the Yankee vessel and: the weld' chemistry,-
NEAL R. GROSS'-
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W-i202) 234 4433 WASHINGTON. O C 20005
!202) 2344433 i.
.. _. _ _ _. _. _. _ _ - _ _ ~ _ _ _... _. _ _._ _.
1 I
where we thought we knew what-was in the weld chemistry, 2
and we didn't.
I don't view that as a license renewal l
3 issue.
But with the B&W owners Group effort, we think we l
l 4
can maintain the generic reviews without that distraction.
j 5
And, finally, I intend to set up regular senior 6
management review meetings with the B&W Owners Group, to 7
make sure that issues get resolved and schedules are 8
maintained.
9 Now, John Craig will briefly describe the status 10 of our reviews thus far, and then Bill Russell and Rich 11 Correia will talk about the relationships. of the l
12 maintenance rule and-license renewal rule.
13 CHAIRMAN SELIN -.Dr. Murley, at the end, will l
14 you come back and' discuss a little more fully what you 15
-have in mind for the senior review group, and how it will 16 interface, in your mind, with the B&W Group?
17 DR. MURLEY-.Well, I can do it now, yes.
.I 18 expect that I and my senior NRR managers will meet
- 19
.probably monthly or bi-monthly with a steering group from 20
-the~B&W Owners Group, and_that issues that come up on-
~21 scope of review, on technical issues, we can resolve them 22 at least at our level and, if they need to be passed on as
-23 a policy matter, we can do that right away.
So, that's-
'24 all I had in mind.
25 CHAIRMAN SELIN:
Are you aware of policy issues NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS.
1323 RHODE l$ LAND AVENUE. N W.
(202) 2344433 WASHINGTON. D C. 2000$
(202) 2344433-
10 1
that need to be resolved now?
I mean, are you now aware 2
of policy issues that are open, that need to be resolved?
i 3
DR. MURLEY:
Well, yes.
The ones that have 4
arisen in the review so f ar, of Yankee and Monticello, I'm 5
starting right now to do a review, management review, of 4
6 those issues, and I don't want to enter into the B&W 7
offort with those open.
I 8
CilAIRMAN SELIN:
So, your intention is to try to 9
have as many policy issues as have been determined, or i
10 maybe even go a little further, to look for policy issues 11 that ycu consider to be unresolved, and settle those 12 before the B&W people are encouraged to start a major 13 effort?
14 DR. MURLEY: That's correct. And I plan to work 15 with NUMARC to do that, so we can get general agreement 16 with the industry.
17 CHAIRMAN SELIN:
Okay.
18 DR.
MURLEY:
And if there are irresolvable 19 conflicts, we may have.to come to the Commission.
20 CHAIRMAN SELIN:
Yes.
Okay.
21 COMMISSIONER ROGERS:
Well, just on that point, 22 that you have worked -- I mean, as you said, you've worked 23 for three years with the industry, and I assume that that 24 is not only NUMARC, but also Monticello people --
25 DR. MURLEY:
Yes.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4 433 WASHINGTON D C 20005 (202) 234 4433
=.
- --=.
11 l
1 COMMISSIONER ROGERS:
-- Northern States Power, 2
and that my only concern is that many of the issues which 3
have been raised appear to me to be generic iscues, so 4
far, that have come out of the work with Northern States.
5 And as you move towards working with the B&W Owners Group, 6
if you just cut off from those contacts with Northern j
7 States and those people who have worked with you over the 9
years and from which has emerged generic issues, you may 9
be losing some ground there.
I mean, it just seems to me i
10 that it would be well to continue to work with anyone who i
11 is interested in working with you on these matters, l
12 whether it's the B&W Owners Group or Northern States, if 2
13 they continue to have an interest in resolution of these 14 generic issues, even though they have not said that they d
l 15 have a definite plan for a time to submit an application.
16 DR. MURLEY:
Yes.
We'll work with anyone on 17 these issues.
In fact, I even want to coordinate the 18 issue resolutions through NUMARC so that presumably we're 19 getting an industry view.
20 I must say, I don't know what Northern States' 21 intentions are.
The only communication I've received is 22 what I read in the newspapers.
They've never talked with 23 me, sent-me a letter, or anything.
.So, I, as-I sit here, 24 don't exactly know officially what their intentions are.
25 CHAIRMAN SELIN: Well, that could be a dif ferent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON. D C. 20005 (202) 2b4433
=. -
i 12 1
briefing at another point.
2 DR. MURLEY:
Yes.
John?
3 MR. CRAIG Could we go to slide 1,
please.
4 l
4 (Slide)
I 5
What I'd like to do this morning is go over the 6
background, cover some of the highlights of the rule, the 7
requirements of the rule; give you a status of what we've 8
done to-date, where we are; and provide an overview of the l
9 integrated plant assessment; briefly discuss the scope of 10 systems, structures, and components which are important to 11 license renewal, by definition in the rule; discuss 12 current licensing basis as it's described in the 13 statements of consideration; resolution of technical
)
14 issues is to provide an overview of the review process of 15 a license renewal application; and then we'll shift and 16 talk about maintenance versus license renewal, and some 17 lessons learned.
18 Go to slide 3.
(Slide) 19 The Commission published an Advance Notice of 20 Proposed Rulemaking in 1989, for license renewal, and the 21 Proposed Rule was published in the Summer of 1990.
The 22 key elements of-the proposed' Rule were a conclusion that 23 the current licensing basis was adequate for all plants; 24 that compilation of the current licensing basis was 25 required as was its review. And it's important to note at NEAL R. GROSS COURT REPORTERS AN01RANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON. O C 20005 (202) 234 4433
s i
4 i
13 1
1 this point that that was a necessary action as part of the 2
effort a licensee would have to undertake to identify the j
i l
3 equipment that would have been important to license i
4 renewal under the Proposed Rule, and it required an i
j 5
integrated plant assessment.
6 There were extensive comments on the scope of j
7 the Rule, the equipment that was covered.
A number of i
8 comments addressed the need to completely re-review a l
9 plant to current plant standards.
4 l
10 The ataff prepared and published the Draft f
11 Standard Review Plan, the' guidance for the staff and a i
12 regulatory guide, which.is guidance for applicants on how
+
j 13 to prepare an application, and that was published in l
14 December of 1990, for public comment. And it was based on l
15 the Proposed Rule.
l 16 Slide 4, please.
(Slide) 1 17 The Final Rule was published in December of 18 1991.
The key elements of that Rule were changes in 19 fundamental principles, as has been discussed, a-retiance 20_
on-the regulatory process remaining adequate. to ensure 21' that the licensing basis for plants provides and maintains 22 an acceptable level of safety, as opposed to a-conclusion 23 that the current licensing basis.was-adequate.
24 The addition of a definition of. age-related 25 degradation unique to license renewal, and changes to.the NEAL RiGROSS
- COURT REPORTERS AND TRANSORIBERS
- 1323 RHODE ISLAND AVENUE. N W.
(202) 2344433 L WASHINGTON, O C. 20005 '
(202) 234 4 433'-
14 1
definition of equipment that was important to license 2
- renewal, and the revision that the integrated plant 3
assessment no longer included compilation and review of 4
the current licensing basis.
5 A second draft of the Standard Review Plan and 6
Regulatory Guide have been revised.
They are in the 7
concurrence process now. They will be reissued for public 8
comment at a future date, following the review that was 9
described by Dr. Murley earlier.
10 Slide 5.
(Slide) 11 We've already talked about the philosophy in the
)
12 two principles, and I'll just skip to the second one, and 13 it's the heart of the license renewal process, and that's 4
14 the integrated plant assessment, and it requires a
l 15 detailed and systematic review of aging, to ensure that 16 aging effects have been identified, and that any i
17 additional actions to managa aging will be implemented, 18 and a determination of whether or not current programs are 19 adequate to manage aging.
20 Slide 6, please.
(Slide) 21 This is an overview of the requirements of the 22 rule, and I'll have a flowchart in a minute to talk about 23 the integrated plant assessment.
24 Applicants are required to identify any changes 25 required to their current licensing basis as a result of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON. O C 20005 (202) 2344433
15 1
renewal.
They are also required to report annually any 2
changes made to the CLB after the submittal of their new 3
application.
They are required to describe plant 4
modifications that are necessary to support renewal and, 5
as well, they are required to review exemptions or relief s 6
which have been granted and are in effect, to determine 7
whether or not those exemptions or reliefs should be 8
modified for the period of extended operation.
9 Environmental reports are also required to meet 10 10 CFR 51, and we'll talk a little bit about-that some 11 more tomorrow.
12 Slide 7.
(Slide) 13 This is a simplified flowchart of the integrated 14 plant assessment.
Licensees are required to identify and 15
' list the systems, structures, and components which are 16 important to renewal, and to. identify structures and 17 components that could contribute ia the performance of a 18 function important to renewal and, if they fail, prevent 19 the performance of that function, and to identify any
- 20 etructures or' components that could have age-related 21 degradation unique to license renewal.
22 They are also required, for:each one of those 23-steps, to describe the methodology th'at they used to make 24-that determination.
25 The demonstration that age-related degradation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W
(202) 234 4433 I WASHINGTON, D C 20005 (202) 2344433 L
- - ~
.-L.
,, _. _.... ~ -,...,,,, -. ~...,_,-
t i
l 16 1
l l
1 which could degrade equipment during the renewal term has l
2 to be ef fectively managed, and there are two options. One l
t j
3 is it has to be covered by an effective program described i
l 4
in an application, or a justification that the degradation i
i 5
mechanism would not degrade to the point that the CLB l
jj 6
could be maintained during the renewal term.
I 7
CHAIRMAN SELIN:
Could you put some numbers on 8
these systems, how many systems we're talking about in a
)
9 month or so?
What type plant?
How many could be i
I 10-eliminated almost through observation, without having to i
i 11 do a detailed analysis?
How many need to have a detailed l
12 analysis done just to make sure that there's such a l
13 program?
i 14 MR. CRAIG:
I hesitate to put any numbers on it 15 because it is determined by the approach that a licensee l
16 would take as part of its screening.
The Yankee -- in i
l 17 their screening methodology, they' identify--commodity.
i[
18 groups for pipes or valves, et cetera, and so they divvied
[
19-it up that way.
r 20 Northern States ' has-approximately 107 'of, the 21 systems that they include,-and I believe that's-65-to-70 l
.22 percent of all the - systems, but it depends on how you
-23 define " systems and. structures".-
24 CHAIRMAN SELIN:
But how.many detailed age-l 25-related analyses did we think would have to-be done?
I NEAL R. GROSS COURT REPORTERS AND MANSCRIBERS-1323 RHODE ISLAND AVENUE, N W i
(202) 2344433 WASHINGTON. D C 20005
- (202) 2344433
. ~. - _ _ _.. - - - -,.. - -, _.. ~.. _. -.... _,. _ - - - -. -,.,
~.,-.~,u_,__a.,,_...-.......,..
17 1
mean, of those systems, how many could be looked at and 2
say there's a good preventiv? maintenance program, or it's 3
greatly inspected or, you know, we just -- I assume we're 4
not requiring people to do a detailed analysis if the 5
components are clearly not important to safety, or it 6
doesn't figure high in a PRA.
7 HR.
CRAIG
- Well, the statements of 8
consideration for the Final Rule, on page 64956, address 9
that concept, and some of the comments to the Proposed 10 Rule argued that equipment should be eliminated becausc 11 they are already covered by a claim that they have 12 effective programs today.
And the Commission noted that 13 that approach could result -- and I'm reading from the SOC 14 "such an approach could result in elimination of most, 15 if not all, the structures and components in the plant, 16 from any substantive consideration for age-related 17 degradation. An acceptable technical basis should include 18 a demonstration by appropriate technical arguments that 19 the age-related degradation is not unique to license 20 renewal where programs for managing age-related 21 degradation unique to renewal are effective".
22 Now,- that's not a satisfying answer to your 23 question.
There are some programs in place today for 24 equipment, particularly, I
- think, the safety-related 25 equipment is covered by technical specifications, that you NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISL.AND AVENUE, N W.
(202) 234 4433 WASHINGTON, D C. 20005 (202) 234-4433
i i
18 i
j 1
can look at the programs and look at the degradation j
2 mechanisms that could affect those systems or components, A
i 3
and quickly come to a determination as to whether or not i
4 there are additional degradation mechanisms that would
}
5 degrade it.
So, that would be a low-level review, but the i
6 need to 1cok and make that determination would not be i
7 precluded by the assertion that it's covered by a program i
j 8
today.
The Rule would still require that-look, and it's i
j 9
a matter of the depth of that review.
I 10 CHAIRMAN SELIN:
What about the other part, the l
11 catch-all, about all the equipment that's involved in a l
12 limiting condition of operation or a tech spec.- I mean, 13 that covers an awful lot of stuff.
L 14 MR. CRAIG Yes, sir,'it does, but I should be i-15 quick to point out, it covers a lot less than the Proposed 16 Rule, that required compilation and review.
So --
l 17 CHAIllMAN SELIN:
Well,-my problem is not that l
18 it's covered,.but that -
you know, I read that as saying i
19 that the philosophy was we should look at' a lot of things, f
20 but have a - mechanism to quickly dismiss many. of those i
21 things as clearly not being essential.to license renewal.
22
- And my question has to do with your interpretationi of i
l 23 that, or did-you get to the point of being-.able to-screen r
b 24' that last category of things fairly quickly?
~
25' MR. CRAIG We've taken a position -- actually, NEAL R. GROSS j-COURT REPORTERS AND TRANSCRIBERS 13'3 RHODE ISLAND AVENUE. N W.
(202) 2344433 WASHINGTON, D.C 20005 (202) 2344 433 5
m5
..w.
r w w-e m.,,
w +, w s, -
- n. w [ wnrw w
-q y
m.
,r--er.y' y,3w.,ym--,r...+,.-m-,w.,
--y.,-.-m e e.c eg me
-.y-
%,,-pega,a y
--+
yvn-
. e,e s t
- v. yy - t ar.
+----r---
i 19 1
the Commission took the position in the SOC, about what 2
was included in tech specs and the cascading tech specs --
3 CHAIRMAN SELINr Right.
and we have not tried to develop 4
MR. CRAIG:
5 a screen criteria to say some equipment in tech specs is (l
)
6 more important than others and, therefore, it would not be 7
included within the scope of the Rule.
Rather, we've been 8
consistent with the soc which says, if it's in tech specs 9
and it's necessary to support, then, by definition, it 10 starts at the tc,p.
But as you look at the flowchart, I 11 think what we're really talking about is the third step, 12 and that is, how much effort will be required to determine 13 whether or not these components, this equipment, has 14 degradation unique to renewal, and whether or not it's l
15 adequately addressed today.
And we haven't absent 16 specific components and structures, we haven't approached 17 to get enough information to answer that.
18 CHAIRMAN SELIN:
Okay.
19 DR. MURLEY:
Mr. Chairman, I think that the 20 answer to your question is one of the things that will 21 emerge from our management review.
I intend to look at 22 that very question as, of all the things we think have to 23 be looked at, are there some mechanisms that will allow us 24 to quickly dispose of a lot of the things.
4 25 CHAIRMAN SELIN: I should correct -- Mr. Craig's NEAL R. GROSS COURT REPORTER $ AND TRANSCRieER$
1323 RHODE ISLAND AVENUE. N W..
(202) 234 4433 WA$HINGTON. O C 20005 (202) 2344433
20 1
answer gave me the impression that he misunderstood my 2
view a little bit.
My view of the Rule says that systems 3
should not be excluded from considerations for juridical 4
purposes, they should be excluded for technical reasons.
5 In other words, the net should be thrown quito broadly, 6
but with pretty big loops, you know, so that you don't 7
just say, "Sorry, the Rule does not authorize for us to 8
look at some non-safety transformers", even though we know 9
that those are a major source of challenge.
You're 10 permitted in fact, you're expected to look very 11 quickly, but the quid pro quo for looking at such a broad 12 set of things is, you need a mechanism to quickly get rid 13 of a lot of things which clearly just aren't -- in a PRA 14 sense, just aren't significant.
15 So, don't read me as saying that the Rule 16 doesn't let you look at these things.
In fact, I read the 17 Rule as saying you should take a broad look, but quickly 18 focus on those issues that really have an impact on risk.
19 DR. MURLEY:
Yes, we intend to do that.
And I 20 think we've
' up
'til now, of course, we've been 21 following, and trying to interpret very closely, what was 22 in the statement of considerations and in the Rule itself, 23 and we may want to see what those words really mean.
l 24 COMMISSIONER CURTISS:
Could I pursue this 25 question in a little bit more detail?
If a licensee comes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
{202) 2344433 WASHINGTON, D C 20005 (202) 234 4433 i
y.
_ ~ -, -,
21 1
in, in the license renewal context, and based upon l-2 established and documented experience with its program for.
3 maintenance, or surveillance, or testing of a particular l
l 4
component, a particular system, or let's say the plan as 5
a whole, demonstrates, based upon the effectiveness of 6
that program over time, that it has successfully managed t
7 age-re?.ated degradation, not as that term is used as a 8
term-of-art in the license renewal rule, but it has l
9 effectively monitored-and overseen the functioning of its 10 components and replaced or refurblehed those components as 11 appropriate.
I have two questions.
One, would that 12 demonstration be suf ficient to satisfy the staf f that, for 13 that particular component system, or what have you, that 14 the licensee has done what's necessary to satisfy us in 15 the context of a license renewal application, thereby 16 permitting the licensee to truncate the evaluation of 17 aging degradation mechanisms for 'that component system, or
~ 18 what have you?
And, two, could they do that under the 19
. existing Rule?.
20
- MR. CRAIG Well, it's a qualified "yes". - Thay 21
- could do it'under the existing Rule-, and the-que'stion is'
- 22.
two parts,. with respect to aging' degradation ef fects. : The l
23 first one has to do with the effects that would come into l
play.during-the first..
24 40 years of operation, that 25 experience with which they've'had_ practice or experience l
NEAL-R. GROSS COURT REPORTERS AND TRAN?.CRJBERS 1323 RHODE ISt.AND AVENUE.- N W.
. (202) 2344433 WASHINGTON. D.i 20005
- (202) 234 4433 -
-,1,..,
r-
,vw...,
..w_.-,-fr.
+
re 6
4% -
'e n it se
-e wwi e wnt-r-=e-v
'w w w
+
.e-y 9
- s f e-4
'r w w4 r-
- rre'r-8f-
-v*1-e'w--w'e'
I l
4 22 1
]
1 in managing. Anri for that part, if the programs have been 2
effective, then yes, we would accept that.
4 3
The second question is --
l 4
COMMISSIONER CURTISS:
Without the need to go 5
through the flowchart analysis of specific aging 6
mechanisms?
7 MR. CRAIG:
They would utill have to identify I
8 the degradation mechanisms for the components.
9 COMMISSIONER CURTISS:
And that flows from the 10 Rule, or the special "C",
or both?
j 4
11 MR. CRAIG:
Yes, sir, 12 COMMISSIONER CURTISS:
Okay.
j 13 DR. MURLEY:
I think Bill's going to talk about l
14 that in a second.
33 MR. RUSSELL: ~We're going to talk about that in 16 some detail in just a mi.nuto.
l 17 DR. MURLEY:
If the question is, can we dispose l
18 of looking at things, I would say probably not.
I think 19 we do have to look at them,.but we find a mechanism, and 20 it may be the maintenance rule, the way we implement that, 21 or it may be something else, that will allow us to not 22 require a detailed technical review, but we-don't have 23' that right now.
We don't have those mechanisms in place.
-24 COMMISSIONER CURTISS:
When we get to that 25 point, let.me just raise two questions for'you to think NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE. N W.
-(202) 2344433 WASHING 10N. D C 20005 (202) 234443J.
I
,. ~, -
-,_.y
..~,, _. - -
23 I
about as we go through this.
You are proposing in the Reg 2
Guide, that we permit a five-year period for repair and 3
refurbishment, during which, as I understand what you 4
contemplate, a specific analysis of the aging mechanisms, i
~
5 of the type that you've described in the Rule, would not 6
be required so long as the licensee has a five-year 7
repair / replacement / refurbishment program.
Question:
Why i
8 not ten?
Why not twenty?
Related question:
Is that i
9 based upon what you have in the maintenance rule or 10 existing surveillance?
And, two, 1 guess, for Bill to 11 think about as well, if you were to write the SOC today, 12 now knowing that the maintenance rule is in ef fect, would 13 you have written it differently?
Would you be 14 comfortable, as a technical matter, placing some degree of 15 reliance, at least as you are proposing in the five-year 16 context for the Reg Guide, in making that determination?
17 So, we can come to that when you get to that.
i 18 DR. MURLEY:
Let me say that the Reg Guide is i
19 one of the things that we're going to look at pretty 20 closely in this senior management review.
So, I'm not t
21 prepared today, to say whether five years is right, or 22 ten, or whatever.
23_
COMMISSIONER CURTISS: I thought it was right to 24 open the door.
The question is, having opened the door, 25 does the logic of your argument apply equally well to 20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 -
WASHINGTON. O C 20005 (202) 2344433
4 i
24 4
l 1
years vice five?
2 DR. MURLEY:
Yes, and that's one of the things g
3 we're going to be looking at in the review.
4 COMMISSIONER CURTISS:
Okay.
t 5
MR. CRAIG You're talking about the Reg Guide 6
for license rene%'al?
i j
l 7
COMMISSIONER CURTISS:
- Yes, j
8 MR. CRAIG Well, as we revised the Reg Guide 4
9 for license renewal, we asked the question, if a component i
10 was replaced or refurbished at reguler intervals, then i
i 11 what else is necessary? And we chose five' years based on 12 engineering judgment.
It was that simple.
t 13
-For purposes of discussion, as we went through l
14 the review process and we presented those arguments to the 15 CRGR, at their suggestion, and the comments that that 16 position was not consistent with the Rule, that was 17 ~
deleted, I believe, from the Reg Guide.
I 18 COMMISSIONER CURTISS:
I'm reading. from the If 19 November '92 version but, if it's still going through a j
20 state of flux --
21-MR. CRAIG:
-Yes, it's still under-review, i
~
22 COMMISSIONER'CURTISS:
Okay.
23 MR. CRAIG:
'I want to back up, to explain why I j
24 put a ; caveat'-on my
- answer, and that's that the 25 determination would have to look at ' potential-degradation -
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
.1323 RHODE ISLAND AVENUE, N W. -
.(202) 2344433 WASHINGTON, D C. 20005.
- (202) 234-4433
_.,..,,_...-,,,._,,,;,_.,__e....,,.._,
25 I
1 mechanisms that could come into effect during the period 2
of renewed operation.
So, it's two parts, it's not just 3
that the programs have been adequate.
The question is, a
4 whether or not there is another degradation mechanism that 5
could come into play, and a finding.
But, it's that 6
simple.
7 Cf!AIRMAll SELIll Well, actually it's two parts.
8 One is, is there a new mechanism?
And the second, is f
i 9
there a mechanism that we knew about, but the licensee's 10 plans had only been enough to bind it up and sort of 11 hobble through the first 40 years, and then things would 12 break down in the 45th, and that would require -- I mean, 13 that's what I read in the language about age-related 14 degradation you need for license renewal, that you had to 15 extend it further, 20 years' out, the period in which 16 probably the existing mechanisms would come into play.
17 MR. CRAIG:
That's right.
18 I briefly want to touch on the requirements of 19 an effective program because they are laid out in the 20 Rule. The first one goes _to the technical adequacy of the 21 programs to ensure identification and mitigation of age-22 related degradation.
They also have to contain clear 23 acceptance criteria against which the need for corrective E. i ac. tion can be evaluated.
And they have to be implemented by station procedures of the type that are reviewed by the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. O C 20005 (202) 2344 433 n.
l 4
j 26 j
1 on-site review committee.
1 j
2 Slides 8 and 9 contain a definition of the 3
systems, structures, and components that are important to l
(Slide)
I 5
As I noted, there were early public and industry i
i 6
comments, and a great deal of controversy over the scope i
7 of the Lue, ranging f rom the scope should be limited only 8
to equipment that's safety-related or credit and design l
9 basis action analyses, to the comments that the entire j
10 plant should be re-reviewed.
)
]
11 The first three parts of the definition on slide l
12 8 were largely unchanged from the Proposed Rule.
Slide 9 1
(Slide) the Final Rule added equipment that's l
13 j
14 important to license renewal as including any component
}
15 that's ccaered with operability requirements and technical 16 specifications, and the support equipment necessary for 17 those functions to operate.
18 We noted,.in the promulgation of the Rule, that 19 it was beyond safety-related and that it was not j
20 restricted to a particular mode of operation, power 21 operation, versus shutdowns -- any mode of operation.
22 COMMISSIONER CURTISS: John, can you expand upon 23 how that's being interpreted today, recognizing that 24 you're looking at all these issues.
The question has 25 arisen, in view of the potentially broad scope of this NEAL R. GROSS COURT REPORTERS AND TRANSCR18ERS 1323 RHODE ISLAND AVENUE, H W.
(202) 234 4433 WASHINGTON. D C 20005 (202) 2344433 m -
27 1
provision, that it can't encompass, or shouldn't 2
en'nmpass, nor need it encompass, everything that, with a 3
very liberal reading of this provision, might come within 4
its scope but, instead, what we ought to be concerned 5
about, the argument goes, are those components that are 6
subject to tech spec LCO requirements, insofar as those 7
components are directly required to prevent or mitigate 8
design basis events, to scope in a more narrow way -- in 9
fact, Northern States Power has kind of suggested that 10 this interpretation would, indeed, be a feasible one --
11 but all of the attendant tech spec LCO components and 12 systems, and so forth, which are not required for, say, 13 response to an event, but which-may have restrictions on 14 operations imposed for a period of time, cught not to be 15 encompassed in this provision.
16 Two questions:
How are you interpreting this 17 currently? And how do you view the argument that's being 18 made?
19 MR. CRAIG: Well, as Dr. Murley stated a minute 20 ago, this is one of the issues that we've had under 21 discussion within NRR for a while, and it's going to be 22 re-reviewed.
We are interpreting it to be as close and 23 consistent with the statement of consideration and the 24 Rule as we can. We are constrained by that, I believe, at 25 this point, and it includes any equipment that's in tech NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 2344433 WASHINCTON, D C. 2000$
- (202) 2344433
~.. -. -
28 1
specs within LCO, safety-related or nonsafety-related, to 2
be included in the top of the integrated plant assessment.
3 I recognize that there are equipment included in 4
toch specs, with varying degrees of safety significance, 5
from plant-to-plant.
It was suggested that we use the 6
revised, the improved tech spec criteria, as the basis fcc 7
determining -- for implementing this definition.
And if 8
a plant has equipment in its toch specs that shouldn't be 9
there, then they have certainly the process to clarify and 10 refine their tech specs.
But we didn't view that the 11 license renewal process should be a window to include such 12 a revision, they should make the equipment that should be 13 in tech specs, make those changes before license renewal.
14 There clearly is this difference, t r.ou g h, in 15 safe' significance of equipment in tech specs, but, as 16 you may remember, this issue was discussed with the 17 Commission before the proposed changes at that time became-1b final.
And the question was, whether or not we could 19 develop some sort.of a screen to do just that and, based 20 on the review at that time, the decision was that it was 21 not a viable way to go.
22 COMMISSIONER CURTISS:
Just to be clear here, 23 you are constrained by the SOC, as you read it today, in 24 interpreting this.
provision as-encompassing those 25 structures or components that are addressed in tech spec NEAL R. GROSS COURT REPORTERS AND TRANSCRIBEnS
.1323 RHODE ISLAND AVI.NUE, N W.
(202) 2344433 WASHINGTON, O C. 20005 (202)2344433
,_. - _. ~
1 i
29 3
1
)
1 LCOs and necessary to mitigate or prevent design basis i
2 events? You can't limit it to that under the current SOC?
I
'i MR. CRAIG:
That's correct.
f 4
COMMISSIONER CURTISS:
Okay.
1 5
DR.
MURLEY:
And that's how we've been 4
6 interpreting it.
As you recall, this was intensely 7
discussed at the last
- minute, before the Rule was 8
finalized.
And, so, I think we need to go back and take
)
9 ano*: hor look at just what's involved there, and that's one 10 of the thi.qs we'll be doing.
11 CHAIRMAN SELIN:
I had the benefit of not being 12 part of that group that discussed that at the end, so I 13 can read the material without trying to read between the 14 lines.
And, to me, that phrase was pretty clear.
It 15 basically said for juridical reasons, these parts should 16 not be excluded. They should not be excluded because they 17 don't carry the phrase "important to safety", or what have 18 you, but that it wasn't a requirement that each and every 19 component that had to do with a tech spec or a limiting 20 condition of operation, had to'get the same review but, 21 rather, you know, as I said earlier, to throw the 22 screen them.
.And I think that's pretty clear in.the 23 language, in that it's not that it requires you to look at 24 each of these pieces individually, it's that ir. looking 25 for other components that don't happen to bear the label NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
(202) 234-4433 WASHINGTON. D C 20005
, 202) 234 4433 '
(
~...
I 30 1
"important to safety" or
" safety-related",
that you 2
include as candidates the list that are in the LCOs --
i 3
DR. MURL",Y:
I think that's a common sense 4
interpretation as well because some of these tech specs i
5 have the sprinklers with LCO statements on them and, j
6 clearly, that doesn't make sense to --
. oll, conversely, the rad W
7 COMMISSIONER CURTISS:
8 waste sys' ems have tech spec operability requirements, and
]!
9 one might argue, from a common sense perspective, that it l
10 doesn't make sense in the context of what we're trying to 11 do in license renewal, to subject the rad waste system to 12 an aging analysis of aging effects that might degrade that 13 system, and that strikes me as common sense as well.
14 CilAIRMAN SELIN:
Mr. Russell?
15 MR. RUSSELL: We clearly have a situation where, 16 with a combination of custom technical specificJ 1s and I
17 specifications as they've
- evolved, that thers are 18 significant differences plant-to plant.
j We've just recently completed and issued t.he new 19 l
20 proposed technical specifications under the Tech Spec l
21 Improvement Prograra, using the Commission's interim Policy 22 Statement which looked at essentially design basis events, 23 included another factor, which is importance to risk.
l i
14 That program resulted-in about a 40-percent reduction in 25 the number of LCOs and required actions.
It also --'the NEAL R. GROSS COUAT AEPORTEAS AND TRANSCRIBERS
. W3 HHODE ISt.AND AVENVE, N W.
120?) PM403 WASHN.iTOf4, O C. &000$
(F.7) 2344433
~_
-. - -. _ =
A t
1 31 4
i 1
total volume didn't redure as far as number of pages j
I 2
because we also wrote down succinctly, for the first time, l
3 the reason and the rationale for each of the requirements.
4 So, you've got, essentially, for each standard 5
plant type, two volumes of rattonale and bases and one 6
volume, redone, of the actual limits, and the numbers have 7
gone down by about 40 percent.
So, clearly, a licensee 8
could reduce, within the scope of that program, the number 9
of technical specif1 cations.
And if they were to 10
. implement sequentially, they would reduce a lot of 11 unimportant items.
12 A licensee could also. take advantage of line t
13 item improvements, if they wanted to maintain their custom 14 technical specifications, and amend their license to take 15 things out.
But the approach at this point has not been 16 one to try and define, on a generic or model technical 17 specification basis, the things which would be within 18 scope; rather, take the broad view and then look at the 19 technic 31. rationale for taking things out afterw.srds.
20 CHAIRMAN SELIN:
In a particular plant.
l 21 COMMISSIONER CURTISS:
Yes.
Clearly, the long-l 22 term answer is to make sure the tech specs include things l
23 wo want them to
- include, and not things that are 24-superfluous to what tech specs ought.to include.
- And, 25 hopefully, at some point in this process, we'll reach that NEAL R, GROSS COU47 R&ORTEHS AND TAANSCAtBEAS 4/3 4o0E IS4 AND AVENUE. N W
(?o2) 234-4433 WA$r4WGTOet D C 20')05 (102) 234 4433-
i;-
s 32-1 1
- 1 stage where all the tech specs, in fact, reflect that
-l l
)
1 2
desired objective.
I don't think we -'--
1 3
DR. MURLEY:
Yes, but we have not _ made the a
f 4
standard tech specs a requirement, as_you know --
1 I
5 COMMISSIONER CURTISS:
Right.
- (
6 DR. MURLEY:
-- and we have to face --
l COMMISSIONER CURTISS:
Nor
'line item j
1.
l 8'<
improvements.
9 DR. MURLEY -
Right.
So, we have to face the i
l 10 possibility that the early applications we get will' i
11 prc'cably these old custom tech specs that have all k i
j' 12 of cats and dogs.in them.
1 i
l 13 CHAIRMAN SELIN:
Exactly.
But from a good l
14 management point of view, you end up with a process which
~
15 is logically suit of backward, but still useful.
If you f
16 do what has been suggested, namely, go throughLthe tech i
17 specs, pick out those~ items that-are important from a l
18 safety and-license renewal point of view, pick out a bunch j
19 of l other items and say,
" Gee,- you know, while we're 20 looking-at these. rech specs, we. wonder why.they-were here i.
21 in the first place" = thase would be candidates -for-.the 22 plant : to fix up: reget.ess of license. renewal, but"you L
23 don't hr"e to wait for the:x to do that,- to procecs it.
24.
I have a snmewhat different question.
My l-25 understanding of your experience on maintenance, l
l NEAL R. GROSS-COURT RC 7 Th.RS AND TRANSCRIBERS
+
- 1323 RH.
- ISLAND AVENUE, N W,
>:02p4M33
' WA$
. TON D C 20005 (202) 234 4 33
.~
_~..... -. -
4 33 1
particularly on preventive maintenance,.is that the staf f 2
started out with a highly prescriptive and very detailed 3
component-by-component-need for analysis and, over time, 4
this evolved te saying we could-group these components 5
into much larger systems and assemblies, and look at 6
perforrrance of the assemblies and, if the performance. of 7
the assembly was satisfactory, it wasn't necessary to go
~
8 down to the individual component.
9 Do you read this rule as giving you. the 10 flexibility to doing something comparable in deciding at 11 what level you have to look at essemblies to meet the 12 needs for license renewal, or do you: feel-that the Rule 13 forces you to go down to greater level-of detail than you 14 would like?
15 MR. RUSSELL:
I can cover that.in a moment, but 3
CHAIRMAN SELIN:
No,-you can do it-when you get h
i id '
to it, if you like.
'l 11 9 MR. RUSSELL:
in general', the maintenance 20 rule has two aspects of it.
One is the monitoring, aid we 21 believe, with the work that's been'done thus far, that-22 monitoring.at the train ' level or system level-would be-23-appropriate, and ' then there's some overall balance-of-
-24 plant monitoring that may be effective by monitoring. scram 25 rates or other features.
- And, so,
-it's. clearly a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W-(202) 2344433 WASHINGTON, D C. 20005 :
(202) 234 4433 -
,a
i i
34 1
= performance-based rule.
2 Thereiis an element that says monitoring is not 4
i 3
required-if you have essentia)1y an effective preventive 4..
4 maintenance _ program.
That is, you are not having 4
i 5
maintenance preventable failures.
That maintenance -
PM 4
i l
6 program is quite broad.
It. essentially covers the entire i=
[
7 scope of the maintenance rule.
'8
.And in establishing that program, if one looked 9
at the kinds of degradation mechanisms that are discussed i-l 10 in-_the PLEX rule,.in the process of going through,-you i
i 11 could establish on a component-specific basis, where i
12 needed, PM programs which would address those degradation i
1 13 mechanisms.
Then,-if you had experience with. time, that 14 you were not getting maintenance preventable' failures, I i
15-think that you.would have the evidence then-to be able to 16
-say, for these components which are covered by'this PM l~
17 program which does address these mechanisms, that this has l, '
18 been shown to be ef fective and, therefore, when you _get to i
[
19.
that point in the screening process, you would be able to i
been satisfied, but you would still have.a-
.i 20:
say-it has i.
2'1 technical rationale to be-able-to-make that conclusion p
.22 based upon the content of the PM program.-
l 23_
So, it's essentially,-as you are going through-1
!5 24 the maintenance program and looking at your _PM activities,
[
-25 ensure that the scope of those activities is suf ficient to i
NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS.
~
1323 RHODE ISLAND AVEWUE, N W (202) 2344433 WASHINGTON. O C. 20005 -
(202) 2344433
_j z,
-a v.--~
i 35 1
address the degradation mechanisms that we are concerned 2
about in the PLEX rule.
4 3
COMMISSIONER CURTISS: Just to be clear here, it l
4 would be -- you cou a satisfy that desire of the staff by 5
pointing to the experience that you have in implementing j
i 6
your maintenance program, or do you still --
7 MR. RUSSELL:
Two facts:
One, that the PM 8
program, when it was initially designed or as it has been 9
- revised, was intended to address that degradation 10 mechanism, and then the subsequent evidence of that based 11 upon performance indicates you're not having failures, 12 would constitute a sufficient demonstration.
13
- Now, that's the approach that we've been 14 discussing and working on.
It would, in essence, be a 15 sequential movement to life extension -- that is, complete 16 the work that is absolutely required under the maintenance 17 rule which goes into effect sooner than most plants would 18 be f acing life extension and, if they did that activity in 19 a planned manner that they could address it now the 20 staff has not developed regulatory guidance which would 21 identify how this could be done in sequence, what kinds of 22 c; edit would be given, what kinds of information we're 23 looking for.
'24 COMMISSIONER CURTISS:
My only observation --
25 this is a quest on we can come back here to -- this really NEAL R. GROSS i
COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE,. N W
,!202) 234 4433 WASHINGTON. O.C. 20005 (202) 234-4433
g.-
1-L f'-
36 1
b 1
goes to-the crux of the issue,f whether you can integrate 2
or' harmonize the maintenance and the license renewal rules 3
beyond what we've done so far.
1 t
4 You are describing. an approach whereby the T
5 management of aging -- and not because of an_ issue unique t,
6' to the extended 20-year period, but simply because of the I
7 continued aging of a component or a structure -- you are.
8 describing an approach where the staff is;saying, "We need i
9-to have-something.beyond what we do for currently:
f 10 operating plants, for plants that are going to extend =
11 their life by 20 years", and that's sorething beyond, in j
j 12 the context of the flowchart and I think in what you've t
j' 13 described, Bill, is some sort of analysis of-the_ specific-14 aging mechanisms for-purposes of license renewal.
1 l-15 And the question-that we can come back to~is, unless - there is something _ unique to the 16
-why is it 17-renewal period other-than the - continued aging of,the 4
of all-of-those
-18 component,Lwhy is it that the analysis 4
?
19:
aging effects is something that the staff wants to l'nsist 20 opon in the contextofflicense renewal, but doesn't need F-21 in the context of the oversight.of the 40-year' period for i
I 22
_all of-the operating plants?
23-We -- _are-perfectly comfortable- :with the 4
f_
24 maintenance regime, I think. The MTI has pointed to th' s.
i i
- -.I think the maintenance rule, when implemented, will move-
?
25 I
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS.
.1323 RHODE ISLAND AVENUE N W (202) 234 4433 1 WASHINGTON l D C 20005
~ (202) 234 4433
..-.l..=-.
37 1
us further in that direction, that the management of aging 2
for the 40-year period is, in fact, a very effective and 3
rigorous process, as a result of the requirements that 4
we've established.
If carried on through the 20-year 5
period -- and, again, here, in the absence of anything 6
specific to license renewal -- why is that not sufficient 7
for purposes of the continued five, ten, 15, 20-year 8
period that a licensee may be seeking to operate?
We'll 9
come back to that question because that may be the heart 10 of the presentation.
11 DR. MURLEY:
Yes, let's move quickly through 12 this and get into maintenance.
13 MR. CRAIG:
The next two slides, 11 and 12, 14 discuss licensing basis and maintaining the current 15 licensing basis.
Slide 11 is just a bulletized form of 16 the definition that's contained in 54.3 of the License 17 Renewal Rule.
(Slide) 18 Go on to slide 12 -- (Slide) -- and note briefly 19 that the regulatory process includes, or starts, with the 20 initial applications and the reviews associated with 21 construction permits and operating license reviews is very 22 broad.
It includes inspections and audits, research, 23 generic issue resolution, et cetera, and has an element of-l 24 compliance both from - the NRC's activities with ongoing i
i 25 inspections and.research, as well as licensee activities NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 234 4433 WASHINGTON. D C 20005 (202) 234 4433
38 1
to look at operating
- events, perform
- audits, and 2
inspections.
3 CHAIRMAN SELIN:
Can I just comment on this?
A 4
Again, reading the rule, not having gone through the 5
history, it's clear to me the rule could be paraphrased as i
6 follows:
That the current activities of the licensee and 7
of the NRC in terms of inspection and operator 8
qualification, et cetera, are adequate to assure that the 9
plant today, and for the foreseeable future, is operated 10-in a suf ficiently low enough risk basis to continue to f
11 operate.
The specific concern is the change in material 12 condition, and has to do with degradation, age-related 13 degradation having impact on the material condition of the 14 plant that would take place in the. time period after the 15 40 years, and that these mechanisms be identified, and 16 that the staff and the Commission be satisfied that steps 17 are in place.
18 But when it comes to.say, well, what'are we 19 talking about, what is the basis?
That automatically 20 suggests that there's a lot in the CLB that's irrelevant 21 to that because the issue is focused on deterioration and 22 material condition of the plant, not that the management 23 is getting old and tired, or that the operators aren't 24 being replaced, but that the steps have to be taken.to 25 keep a post-era or a probability of failure no higher NEAL R. GROSS
- COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVFNUE, N W.
(202) 234-4433 WASHINGTON. D C. 20005 (202) 234-4433
39 4
1 after 40 years than it is in the existent 40 years.
2 So, that would suggest that the part of the CLB 3
that should be focused on in terms of saying what is it, 4
and how do we know that the licensee has taken the action, 5
is no greater than the design basis and maybe some of the 6
tech specs and limiting conditions of operation is 7
probably somewhat less.
So, in the discussion about what 8
do we have to know the licensee could quickly access, it 9
has to be those parts that -- it may be less than this, 10 but it can be no more than those parts of the CLB which 11 refer to the material condition of the plant and the steps 4
j 12 that are taken to maintain the material condition of the 13 plant in the face of intrinsic age-related deterioration.
4 14
- And, furthermore, deterioration that is qualitatively 15 different from that which would impact the plant during 16 its first 40 years, because one assumes that everything 17 else has been taken care of already.
18 And in a discussion of the CLB and where we 19 stand, I didn't.see that focus on saying what does the 20 license rule call for?
That's all that it calls for and, 21 therefore, how do we get to that part of the CLB which is 22 relevant to answering that question?
23 COMMISSIONER CURTISS:
_Could I just add one 24 point there? I agree with the description of the CLB, but 25 on the question of what we have to ensure is maintained --
NEAL R. GROSS 4
COURT REPORTERS AND TRANSCRIDERS 1323 RHOOE ISLAND AVENUE. N W.
(202) 234-4433 WASHINGTON. D C. 20005 (202) 234-4433
40 1
in f act, this is one of my questions -- do we -- are we --
2 put in the form of what our current position is -- is it 3
our current position that the licensee has to maintain 4
that level of safety in year 41 that was maintained in 5
year 39, that the licensee has to maintain the design 6
margin to the code, or to the standard?
7 DR. MURLEY:
No, no, no, no.
8 COMMISSIONER CURTISS:
Okay.
I wasn't clear 9
what the Chairman was saying.
The question is --
10
-DR.
MURLEY:
There's-a distinction between 11 maintaining the current licensing basis and maintaining 12 the current level of safety. And we've been very careful 13 to say that we're going to maintain th'e current licensing 14 basis.
And I'll give just a simple example.
Suppose that the containment, the steel shell of 15 16 a containment -- the Code requires it to be a quarter of 17 an inch thick steel. And the designer puts into it three-18 quarters of an inch initially, at day zero.
But through 19 corrosion and whatever, it goes down'to half an inch.
i
~
20 That's still plenty good for the design purposes.-
- But, 21 clearly, as time goes on and as you-move into the renewal
)
22 period, corrosion will cut that down, so it, in some 23 sense, is not "as safe as it was", but it's still plenty 24 safe.
Sc, that's the rationale that we've used - in 2
-25 requiring maintenance of the current licensing basis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISt.AND AVENUE. N W (202) 2344433 WASHINGTON. O C. 20005 (202) 234-4433
i i
41 1
throughout the --
i 1
2 COMMISSIONER CURTISS:
I recall having exactly i
i l
3 this discussion at the-time that the license renewal rule t
l 4
was up before the commission.
It is not the margin-that 5
exists at a particular point in-time.
Its not the margin 6
to the Code that exists, or what might have existed at l
7 year 39 versus year 41 but, instead, what's required as a 4
1 8
regulatory matter, what is the limit, and which in turn
[
9 ought to be reflected'in the CLB, and that's what the f
10 operative standard ought to be as we look at license 11 renewal.
1 l
12 CHAIRMAN SELIN: That's what I think is meant by -
You can do a j
13 age-degradation unique to license renewal.
l 14 calculation and say, well, in the remaining ten years of 15 the current license, it will only get down to three-
[
16 eighths of an inch, so it's okay.
But then--you have to 17 carry.out the calculation further and say,-if we give them l
18
-20:more years, will it-fall below the.. quarter of_an inch 19 standard?
I 20 DR. MURLEY:
Yes,_we would do-that.
21 Okay,-John?
t 22
- MR'.
CRAIG:
Slide 13.
(Slide)
'This slide
- 2 3 -'
. provides - an overview of - the. renewal application c review
- ~
L.
i-process.
.It starts with the documentation-that would--be 1
25-received ~by the-applicant, and that's contained'in the NEAL R. GROSS COURT REPORTERS AND TRANSCR:BERS 1323 RHODE ISLAND AVENUE. N W,
- (202) 234 4433 '
' WASHINGTON, D.C. 20005 -
- (202) 234,4433 E
,.:._~,,,-.
..-._..__,;._.,-..a.
~
1 i
42 i
1 rule.
As the licensee goes through'an integrated plant 2
assessment, he's required to keep also information on-site i
i 3
and in an auditable and retrievable form, so he doesn't l
l 4
have to ship all of the information to the NRC.
5 As we've explained to the Commission previously, 6
with respect to implementation, we've developed a
l-7 regulatory guide and a standard review plan that's to be l
8 issued on an interim basis, so we can learn from that as
[
9 we gain experience.- ' And they were developed specifically i
j 10
-to focus the reviews on age-related degradation and its l-11 effective management, as opposed to a re-review of plants 12 to current plant standards.
And we've tried to do that, 13 and we've -- as I said previously, those are.in the final i
i 14 stages of concurrence.
They've been revised.
15 We also intend to include a
number of 16 inspections and audits as part of the application review, 17:
which is consistent with - the previous approach, but 1
18 there's a lot of experience with programs and their 19
' effectiveness.- It's documented on-site, and we'll be able 20 to go and relook at the implementation of those, I
21 believe,:.-in an efficient manner.
22 Following-the review, and as.part of it, we're 23-going -to integrate the.results of--' the. license renewal 24 review into the standard inspection. program, and=we.also i
25 intend to have frequent public meetings with the renewal-NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHOCE ISLAND AVENUE. N W1 (202) 234-4433
. WASHINGTON. D C. 20005 (202) 234-4433.
4 w-
,w,-
v.-
-,.,ev-r.,-
,..r,
.---e,.,
em..
.-.-.~e..--e,.e,
43 1
applicant, to discuss the review status, open issues, et 2
- cetera, and ensure that for any sticking points or 3
questions, that they get elevated quickly in both 4
organizationa, both applicant'c as well as ours.
5 With that, I'll turn it over to Bill Russell.
6 COMMISSIONER CURTISS: Could I ask two questions 7
before you turn to maintenance here?
When the rule was 8
originally promulgated, on the advice of OGC, we -- and I 9
think it was correct -- we made a point of saying that as 10 a procedural matter, what we are doing with a license 11 renewal is to,- in effect, grant a renewed or a new license 12 as cpposed to amending an existing operating license.
As 13 I said, I think that's the correct interpretation of what 14 the Atomic Energy Act envisions.
15 My question is really a technical one.
From a 16 technical standpoint, is there anything in that decision -
17
- that is to say, that we are issuing a renewed or a new l
18 license -- that has a bearing on the substantive technical 19 requirements that the staff feels ought-to be imposed?
20 DR. MURLEY:
I think that that issue has come 21-up.
It has had some controversy.
That's one of the 22 things I want to take a look at when we do our review.
23 So, I guess, today, I'd have to say I really don't have a 24
' good answer for that.
I want to come back to that in'our 25 review.
NEAL R. GROSS COUAT REPORTERS AND TRANSCRIBERS 1323 AHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON, D C. 20005 (202) 234 4433
i 44 1
COMMISSIONER CURTISS:
Okay.
On that point, I
2 I've heard the concern and the comment has been expressed, 3
that on various technical issues, as you get into the 4
detailed technical review, the fact that we are issuing a 5
new or a renewed license is viewed in some fashion as the 6
justification from a technical standpoint, to take a 2
7 particular approach. And, indeed, this has come up on two 8
of the most controversial questions, AQ and fatigue.
9 I went back and I pulled out the OGC memo that 10 we received, and I would encourage you to go back -- this 1
i 11 is available, I think, generally -- but as I re-read that 12 memo, the relevant paragraph in the attachment. to the 13 January 13th,
'89, memo -- "We wish to emphasize that the 14 form of the license with respect to life extension does 15 not af fect the substantive issues raised by life extension l
16
-- that is to say, whether and under what technical 17 conditions, restrictions, prerequisites, should life 18 extension be permitted for nuclear plants.
This 19 determination should be made without regard to the purely 20 legal question of-the form of the license".
21 In my view, what we said at the time--- and-I 22 think it's consistent with what OGC said - -in it's '89 23 analysis -- is that strictly as a procedural matter, the 24 Atomic Energy Act requires us, or the better reading of 25 the Atomic Energy-Act is that we will issue a new or a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISt.AND AVENUE. N W.
(202) 234 4433 WASHINGTON. D C. 20005 (202) 234-4433
_. _ _ _ _. _ -_ _. ~
3 i.
i 45-I I
renewed license as opposed to an amended license, but that i
I 2
determination, that basis for:this rule, only af fected the 3
procedural question, and was not to have any bearing on 4
. the technical question, as to whether additional or f
~
5
- current methodology, standards, what have you, ought to be i-6 used.
b 7
And, so, I look forward to what you have to say i
j 8-when we get into that.
l j
9 DR. MURLEY:
Yes.
Yes.
We'll be looking at 1
10 that.
-I, too, have re-read that document, but.we have to -
11 keep in mind that there was a-slightly.different version l
12 of the rule-contemplated in 1989.
And I don't know i.' -
13 whether that makes any.dif ference or not, but I want to go 14 back and chat with'.OGC staff and so forth.
15 Bill?
1 E
l 16 MR. - RUSSELL:. Let me-set the stage a little bit i-l 17 before I get into the similarities between the two rules, i
18 with some background.on maintenance because I-think it i
- 19 will be relevant'to our-responding to your questions.
20
'At the time = the staff came forward.to the
.21 Commission, we proposed that there-not be a maintenance-22-rule that is:~a process-based - rule.
In ' fact, the-
-23 maintenance team inspections.that we had done to that time 24-
!1ookedLat' essentially the procedures for controlling and 25-conduct of: maintenance.
And' we concluded' that, - in '
b NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
=
1323 RHOOE ISLAND AVENUE. N W.
(202) 2344433--
WASHINGTON. D C. 20005 (202) 234 4433 1
r 7-
'-+,'e
= ra*
e-4 -e e-
,re-g-we-
+--+e
- +=++
r e,,in w-c-+=r*w e-=+wo--=er==---wwe'--e=-rw---*is
-w+
---w 4,-v-
=-
U a
46 f
1 general, there were good maint'enance programs at the-p I
2 facilities that had the appropriate scope.
{
3 There were,- however, three areas that were l
4 identified as weaknesses. They were essentially the areas
+
5 of root cause analysis, consideration of risk and conduct
}
6 of maintenance activities, and trending, in particular l
7 with respect to potential for repetitive _ failures.
8 These elements have now been captured in the new 9
performance-based maintenance rule and in the regulatory l
i 10
. guide that'sIbeen developed.
But I characterize that l
l 11 these issues are not fully resolved and effectively being 12 implemented at all-plants yet.. In fact, in some cases we
[
13 found that 20 percent, or more, of the facilities were i
j 14 characterized as doing-a poor job in some of these areas, 15 at the time we-did the maintenance team inspections.
f 16 That's important because the perf ormance-based -
17
- that is, the assumption that things are performing well' 1
[
18
-- has--to be based upon what you have been doing in the 19 past.
If-you have not been looking or trending'and.you b
20 don't have' data,'it may not be sufficient to say that you i
i j
21-
.have an adequate PM program.
l 22-Given,- however, that we are looking at 'a-23 transition period L under E the maintenance rule, with-the r
24:
- regulatory; guide being out'for a three-year period prior 25 to, we expect that an effectively implemented maintenance NEAL R. GROSS 1
COUN BEPORTERS AND TRANSCRIBERS
-)
1323 RHOOE ISLAND AVENUE. N W.
(202) 2344433 WASHINGTON, D.C. 20005 (202) 2344433 i
4
- m..
o
- -. -. - - - ~..
i 4
4 47 1
1 program that met those guidelines would address root cause.
1 j
2 analysis where there are
- failures, would adequately-l_
r 3
address risk and ensure that the more risk important items 4
are trended and monitored, and that repetitive failures, t
5 were they to occur, would, in f act, be evaluated and would i
6 kick up into the A-1 category under the maintenance. rule i
7 and, in fact, require trending.
l 8
So that we did not propose a procese rule, and i
9 that is a fundamental dif ference, I think, between what we a
j 10 have in the plant life extension activities, and that is, f
11 we have a process rule that has a broad initial scope and i
j 12 a screening process to go through.
f 13 If I could have slide 15.
(Slide.)
j 14 There are some similarities between the' rules.
=
i
-15 Clearly, the scope of structures, systems, and components l'
16 are very close to each other. There -'are some-dif ferences, 17 and I will go into those in just a moment.
The objectives
[
18 of the rule, they have similarities. ' one -is the technical l
19 adequacy:to maintain aging that is unique in their license I
20 renewal period, and ties into the adequacy of the current 21 licensing basis and how it's maintained over the 20-year 22 period of renewal, and the objective of-the maintenance-
~
i 23 rule is to assure that equipment-reliability. and:
p l
24 availability is as assumed
'in ' the
- analyses, and j
25-
. essentially-to prevent failures.
NEAL-R. GROSS i ~
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENVE, N W.
. (202) 234-4433 -
WASHINGTON, D.C. 20005 (202) 234-4433 y
e w r ~*
- ~e-e s4.ee-e,e.-
erw,,=*.we-e.
1--ex se w y voru-v-
a-w-w - e+
-w+-d
-wwv,,wg e
1 I
48 I-j
- 1 There are review and feedback mechanisms-in e-2 both, however, one rule is performance-based, looking at 4
3-results, and the other is process-based,Eso that there are i.
l 4
clearly -- while there are feedback and review mechanisms, I
5 they have different content.
a 1-1 6
And both rules allow the use of existing l_
7 programs, with one exception.
In the life extension f
8 activities, you would need to re-review those programs to j
9 show that they_are acceptable, in a. process-oriented way.
I 10 And in the maintenance rule, there is not a need 'to review i
11 if you are not having failures or adverse - equipment 12 performance.
13 Slide 16, please.- (Slide) l_
14 This is a side-by-side comparison of the scopes i-15 of the license renewal rule and the maintenance rule.
I 16 Both cover safety-related equipment._
Nonsafety-related-
-17 I equipment whose failure -could -prevent -satisfactory
[
18 accomplishment of the safety-related function:ia covered l-19 under license _ renewal. Similarly,. itiis covered under the 20 maintenance-rule.
- Slightly different words,.
but i
' 21-essentially { identical scopes.
j__
F 22 Under license renewal, we've explicitly included :
23l
-anticipated transients withoutoscram,-station blackout, t
[
_ 24 which are both part of ' emergency operating - procedures,-
-25
-.which is covered under maintenance, - but under license i-i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE hw
.(202) 234-4433.
WASHrNGTON. D C. 20005 (202) 234 4 33 f
r c
.w,
,i.-ir -r m
y-..,--...v.---v m.
.,,,.~...,,,,,,,...,y.-,,
..-.m,e...,+w,w,
.v..
.,.e.,.~.,.
+.m.+,.v..s-,..
49 1
renewal we've also included equipment qualification and 2
fire protection.
Ale >,
the scopes may be slightly 3
diffe;ent.
4 The license renewal technical specificaticens are 5
covered to the extent it involves limiting conditions for 6
operation.
In the maintenance rule, the scope is those 7
structures, systems, or components whose failure could 8
cause a
scram or an engineered safeguards feature 9
actuation. So that while there is significant overlap and 10 these may result in a large congruence between the lists 11 that are generated under the two rules, there are some 12 differences between the two.
13 COMMISSIONER CURTISS:
Bill, could I ask you a 14 question on that?
We have, in the two rules and I 15 think this flows from the SOC on each of them the 16 license renewal rule emphasizes to a much greater degree 17 the use of deterministic methodologies to identify SSCs 18 that are encompassed under the rule, with the maintenance 19
- rule placing much greater emphasis, in relative terms, on 20 a risk-based.or probabilistic methodology for separating 21 out what you need to look at and'what you don't need to 22 look at.
l 23 With the experience that we're now getting on 24 the V & V program in terms:of how they are applying the 25 risk-based methodologies to scope SSCs in the maintenance NEAL R. GROSS COURT REPORTERS AND TRANSCA18ERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON O C. 20005 (202) 234-4433
1 50 1
context, is there a basis for perhaps allowing greater 2
latitude in the context of license renewal, to employ g
3 those risk-based methodologies in scoping license renewal 4
SSCs?
5 MR. RUSSELL:
Let me describe first what we are 6
doing in the maintenance area because you could take a 7
very narrow construction, from the standpoint of could 8
cause a scram or an ESF actuation, and you could have a 9
chain of logic that would cover essentially everything in j
10 the plant.
So, it would throw a rather. wide net.
11 We are looking at a scope which would say has 12 caused in the
- past, from an operating experience 13 standpoint, as a scope to include, and then if there were i
14 a failure that would trigger, that you would see at a 15 plant level based upon an event identifying a particular 16 component which failed, that component would then be 17 looked at more. explicitly.
18 So, we're, rather than getting into a. broadening.
19 of the scope in the process of going through, we are 20 trying to narrow it more, and look it using operating 21 ~
experience, since we are talking about things which are 22 performance-based, and while you might ' conclude that 23 something could cause a scram if it were to occur, if it's 24 never occurred, that would be something which would be 25 more a theoretical type review rather than a performance-NEAL R. GROSS
- COURT REPORTERS AND TRANSCRIBERS j
1323 RHOOE ISLAND AVENUE, N W.
_ 202) 234 4433 WASHINGTON, D C. 20005 (202) 234 4433
(
- +.
0 J
51 1
based review.
2 So, we are looking at modifying that slightly, 3
and that's part of what we'll be discussing in the V & V 4
process.
So, it's more on an experience-base, not only 5
could, but has --
6 DR. MURLEY:
Could I comment on that question?
7 I think that there is a role for risk-based insights and 8
things to play, a broader role than we have up to now been 9
using in license renewal.
10 I think, though, to be fair, or to be honest, 11 Commissioner, part of the problem in dealing with these o
12 two rules, is that the staff has, in the back of our 3
13 heads, the keen knowledge that these rules were put out 14 contemporaneously, and the thinking behind the:m was going 15 on contemporaneously, but --
16 COMMISSIONER CURTISS:
I'd like to suggest that 17 the thinking was coordinated, but they were i
18 contemporaneous.
19 DR. MURLEY:
I said contemporaneous.
20-COMMISSIONER CURTISS:
Okay.
You selected that I
21 word carefully.
22 DR.
MURLEY:
- And, so, when we see in the 23 statement of considerations word differences, that I think 24 has played probably an inordinate role'in our minds up 25
'til now, and just reading from it says in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W..
(202) 234M33 WASHINGTON. O C. 20005 (202) 234 4 33
4 1
52
-I statement of considerations for the license renewal rule, i
-2 "In view of the PRA limitations discussed" -- and these-1 3
are limitations in the fact that we don't have aging
(
j 4
- models, for
- example, very well built into PRAs 1
l 5
"probabilistic assessment alone is not an acceptable basis i
i 6
for the exclusion of SSCs to be evaluated as part of the 1
7 IPA".
i.
j 8
COMMISSIONER CURTISS:
Yes.
1 9
DR. MURLEY:
So, that, I think, has played a key i
10 role.in the staff's mind.
But now I think we've got some
~
h
}
11 experience.
We've spent some time on - developing the 12 maintenance rule.
And I think it's -- I will make this l'
13 part of the senior. review that we do to try to find better
}
l 14 and broader uses of risk-based methodology.
~
f 15 COMMISSIONER CURTISS:
I raise that question-l 16
-because in the nature of the mid-course review that we're 17 going to undertake now, of the' license renewal. rule and-18 the work that's been done on the maintenance rule, it does j
l-19 seem to me that we've got an opportunity-to take a look at i
20 potential interactions,
- overlaps, opportunities for 21 harmonization here, with the significant work that's gone 1
22 on in the maintenance context.
23
_It would be interesting, as you look at-that
- 24' question,-first, to reflect upon the extent to-which you f
25 are comfortable with methodologies that are being used in l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON, D C. 20005 (202) 234-4433 1
=
~
4-., -
s-,-
6,.-y--e-,
,,w..-,
w-e re-y v -
-y - is + --w r+
-v+ v---w ~ + v -ev- -*W t-r t v
- 7 m, < y e
+-W=
4 53 1
the implementation of the maintenance rule;
- secondly, 2
focus on whether the different methodologies, more 3
deterministic in the license renewal context, more risk-4 based in the maintenance context, are contributing to some 5
of the differences that you see in the scope of the SSCs.
6 And then, of course, make a recommendation on whether you 7
believe that's greater infusion of risk-based 8
methodologies in license renewal might serve to close some 3
9 of that gap and be useful in the context of how we look at 10 SSCs in both rules.
11 CHAIRMAN SELIN:
I'd like to build a little bit 12 on that, Dr. Murley. You know, the Constitution has stood 13 for a long time, but people don't go back to Federalist 14 papers and say, " Gee, this is what they meant in 1789, 15 when they did this".
Considerations change, even though 16 the rule itself is written, and it's important that you 17 learn from experience and not sort of say "The Commission 18 must have known exactly what they meant when they said 19 these two things". Maybe we did and maybe we didn't.
But 20 it would be very important that, as you do.you senior 21 group, not only do you look at that, but you come back to 22 us and say, "Here are some questions.- Do you want us to 23 do it this way, or this way?"
Both are consistent with 24 the rule, although-one might be more or less consistent r
25 with the statement of considerations because the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASMINGTON. O C 20005 (202) 234-4433
1 54 1
considerations do change over time, and we're anxious for 2
the chance to participate in the results of your po) 4.cy 3
review, as you look at these pieces before, say, the B&W i
4 Owners Group go off, because of a legalistic reading of 5
the document, as opposed to coming back and saying "How i
6 does this compare with what the real objectives of the two 7
rules were?"
8 DR. MURLEY:
Yes.
9 MR. RUSSELL:
The reasoning behind giving the 10 example I did'in maintenance is essentially that we are 11 not trying to increase the scope of existing preventive 12 maintenance programs to the extent they are ef fective, and 13 we've been using the philosophy that a single maintenance 14 preventable failure would only be the basis for doing an 15 in-depth analysis of that failure, potentially modifying 16 the PM program, and not necesrarily shifting it into a 17 formalized tracking valuation procea under A-1.
6 18 If I could have slide 17, please.
(Slide) 19 I'm going to try and highlight some additional 20 differences between the two rules.
I' think we've covered 21 some of these already, in the course of the discussion.
22 The maintenance rule clearly
-focuses on 23 operation and the.results of operation, in systematically 24 gathering and evaluating operating experience, mair.tenance 25 experience with that operating experience.
1he license NEAL R. GROSS CoORT REPOMElG AND TlW4LCfhEEAS 1323 PHO9E ISLAND AVEtatJE, N W.
(202) 234 4433 WASHINGTON. O C 200Ci (202) 23444?3
~ -.
+
i
I 55 1
renewal rule focuses on the licensing basis and how that 2
licensing basis will be maintained into the renewal 3
period, and whether there are any unique aspects that need 4
to be re-addressed.
5 Clearly, the maintenance rule is a performance-6 based rule, where the license renewal rule is a process-7 based rule which is quite prescriptive.
8 The maintenance rule focuses on reliability, 9
availability or, in fact, capability to perform, of l 10 sr.ructures, systems, and components within the rule.
And 11 there is, within the
- rule, an e:nphasis on risk 12 significance.
Those are the things that, within scope, l
1 l
13 get pulled out for special treatment and review, will 14 likely be the things which are monitored at the more l
15 senior management or executive level within a utility, to feeling for how well the program is functioning.
i 16 get a l
l 17 The license runewal rule, however, focuses on maintaining l
18 a
licensing bacis for all. structures,
- systemn, and 19 components within the scope, and does not have this more 20 focused approach to a liuited set based upon risk 21 significance.
22 The maintenance rule does not require submittal i
23 and review of progtams or documentation, it relies upon t
l 24 inspection activities to be conducted on-site.
The 25 license renewal rule requires a _ substantial bulk of NEAL R. GROSS COURT REPQ51TERS ANO TRANSCFUBERS 1323 RHOOE ISt#4D AWNUt!.N W
[
002) (M4433 WASHINGTOW, D C. 2"J005 poh 2344433 l
4 56 1
information to be submitted, both describing methodology, 2
2 detailed asseusment results, and will result in the 3
developtr.ent of a safety evaluation.
4 Notwithstanding these two differences, I
5 indicated earlier that we believe it's possible that both 4
6 could be implemented ef fectively, and that there is an 4
7 interaction between the two rules.
It would be a l
8 sequential or concurrent implementatic.n, but i f a licensee 9
- chose, in reviewing the scope of their preventive 10 maintenance
- program, to address the age-related 11 degradation mechanisms that are identified in the renewal 12 rule, and show that they were being ef fectively addresaed 13 now, and that they were not having maintenance preventable f
14 failureu, that that would constitute sufficient evidence 15 to conclude that they had an ef fective program, and that, 16 therefore, the degradation. mechanisms were not unique to-17 the renewal period.
In fact, they were being effectively
\\
18 maintained during the current licensing period.
19 Areaa that may be difficult would be areau where i
i 20 they do not have a
preventive maintenance program 21 currently addressing the compc.nent or the equipment -- for j
22 exanple, cabling.
Thnre generally are not curveillant:e J
23 programs which addrer the adequacy of cabling and the 1
\\
24 effect of age en that cable.
~
25 i
So, there may be a need thnn to-addreas Sow they
.NU.L A GROSS 1
JNFIT rEPOATERS AND TPANSCFoT/93 1323 FM)OE $lA*:D AVENttE. NW C02) 2H 44%
WSWNGTON D C. 2000$
1202) ZM4t13
-.s-x.
,~
m
. J
1 4
57 2
I would develop such a preventive maintenance program, and j
2 it may include periodic testing of the cable to 3
demonstrate that it has not degraded, that it has the 4
insulation rcoperties that were assumed.
As an example, l-5 we believe that this type of an approach to the 4
6 maintenance program would allow it to be used in an 7
effective manner with the current plant life extension j
8 review, and it may be one that it would be appropriate for 9
the staff to lay out in more detail how these could be 10 used, what types of things we'd be looking for in an f
11 effective PM program, from the standpoint of tie scope of 12 the PMs, or what the PMs are intended to preven by way of 13 degradation mechanisms, or detect, and than the experience i
1 14 -
under that that shows that there are no failures.
15 That activity has only been discussed at what I 16 will. characterize as a conceptual level, over the last 17 several months.
We have.really not gotten into the 18 details of looking at particular components which wraald be e
3 19 within the scope of both rules, - what are the typical 20 preventive maintenance programs ther exist today, how well 21 do they addrees the - degradation mechanisms that are 22 identified in the rule, are they sufficient, 'what are the 23 I differences. Thet activity has not been done. That's one 2+
of the things we'll'be looking at, as to how to proceed 25 with this more senior group relooking at these two NEAL R. GROSS cot)RT REPORTERS AND TAAN$CPOERS I
15 3 AHOOE ISt.AND AWNUE. N W.
(232) EM 4433 WASHitlGTOt( D C. 2tW5
' (2t?2; 2344433
~.
i 50 1
approaches.
2 CHAIRMAN SELIU t Try to spend a little t'me f rom 3
the licensee's point of view, when you do that, so that i
4 you don't have guys in blue who are doing preventive 5
maintenance for the ntaintenance rule, cond guys in red who 6
come around and do preventive maintenance for the 1
l 7
licensee.
I mean, there rhould be one maintent.nce program 8
- and, as far as
- possible, it should satisfy both 9
objectives.
l 10 MR. RUSSELL:
Yes, sir.
11 COMMISSIONER CURTISS:
. Bill, what -- I ' m s o r ry.
l 12 Go ahead, Forrest.-
13 COMMISSIONER REMICK:
Juet a com:nnut, Dill, and 14 not to detract from what you just said because I think 15 it's very reasonable, but you keep using the word "and 16 they are not having maintenance preventable failures".
i 17 I look at the analogy of my car.
I try to take
~
l l
18 good care of my car, but f ailuras do occur.
Now, one way 19 to prevent my tires or my engine or my transmission from 1
20 failing, would be to change them every 10,000 miles, and l
21 naybe I wouldn't observe any failure.
22 So, it ueems to me that people, if they do have 23 a good maintenance program, are still going to have some 24 failures, and that judgment of not. having any maintenance 25 preventable faileres is a crucial one, I think, NEAL R. GROSS COf Ar AEPORTEP$ AND TRANSCROCAS C23 RHODE ISLAND AVENUf, N W.
va;n 234 4433 -
WASHINGTON. O C. 20u05 M02) 234 4423 f
4 59 1
MR.
RUSSELL:
I agree, and let me try and 2
characterize le answer a little bit better.
We expect 3
that the PM programs, which are under the A-2 portion of 4
the maintenance rule, wi'.1 cover, in f act, the bulk of all 5
the activities.
And there will not be mary components i
6 which are trended, it will more be trains-and systems 7
which are trended, or overall plant perfort..ance which is 8
trended, under A-1.
)
9 And, so, an item can remain under A-2 -- that 10 is, an assumption that the preventive maintenance program 11 is effective, provided you are not having maintenance i
12 preventable failures.
If you do ha;e a maintenance 13 preventable failvre, you need to evaluate that and see if 14 you revise the program. And we've said, one failure, that 15 you can stay in the PM pogram provided you take 16 appropriate corrective action. Two, or more, would be the i
17 basis for moving to a trending-monitoring program, more 18 formal program under A-1,,
So, when I say if there are not 19 maintenance preventable failures,. that would be the basis 20 for taking the bulk of the items, the large majority that 21 would be covered under A-2, and say, that's sufficient 22 evidence that you don't need to go further.
]
23 Clearly, some fallures are acceptable, and you
]
i l
24 may establish a goal which indicates that for particular
.that some failures to perform is acceptable.
l 25
- systems, l
NEAL R. GROSS COURT REPORTERS'AND TRANSCRIDERS f 323 RHOOE (SLAND AVENUE. N W.
)
j een $433 WASWNGTON, D C. 20005 m & MD
60 1
That doesn't mean that it's not meeting its performance 2
goal, it's not consistent; with the safety analysis, it 3
just means that if you are having failures and you are 4
trending them, you come under A-1 of the maintenance rule, 5
not A-2, the PM program.
And, so, you may need to do a 6
different analysis for something which is coming to A-1 7
from A-2.
8 COMMISSIONER REMICK:
Yes, I see.
9 MR. RUSSELL:
I was focusing only on what we 10 assume was the bulk of the equipment that would be in A-2 11 under a PM program.
12 COMMIEA10NER REMICK:
Thank you.
13 COMMISSIONER CURTISS:
Bill, the approach that 14 you've laid out, essentially, if I understand it, would 15 have a licensee that is interested in pursuing license 16 renewal, do the kind of analysis of aging mechanisms, on 17 a
component-by-component
- basis, either under the 18 maintenance rule or under the license renewal rule.
If 19 you strip it. of all its general description, is that what 20 it comes down to?
21 MR. RUSSELL:
Well, it's not required to be 22
_ performed under the maintenance rule.
You can wait for 23 performan::e to cause you to need to re-evaluate. What I'm 24 suggesting is that if they were to, as a part of 25 implementing the maintenance. rule, do a
review and NEAL R. GROSS COURT REPORTERS AND TRANSCalDERS 1W3 HHODE ISLAND AVENUE. N W.
(202) 2M-4433 WASHINGTON, O C 20005 (207) 234-4433 W,
-.--_----.---__*_.______-_-.--.a---_a
.--m_
=
l 1
l 61 1
consider the kiuds of information that would be needed to I
2 support a renewal application, that doing that one time 3
and doing it early would then provjde a period of time 4
when you would have some experience under that program, 5
from an implementation standpoint, and would constitute 6
then, with the review that was done of the scope of the PM 7
program and the intended actions to mitigate the effects 8
of particular types of age-related degradation, that would 9
be a
technical review.
Then you would have some i
10 experience under that for a period of time, and then those 11 two would constitute a sufficient basis to meet the 12 requirements of the life extension rule.
l 13 COMMISSIONER CUnTISS:
And, of course, it would i
14 he a matter of discretion for-a licensee to do that.
15 MR. RUSSELL:
It would clearly be a matter of 16 discretion.
That would not be required under an 17 implementation of the maintenance rule alone.
18' COMMISSIONER CilRTISS:
The suggestion has been 19 made and I think that's a reasonable step the 20 question is whether it goes far enough in harmonizing the l
21 two rules.
The suggestion has been made, and let me 22 outline it as I understand it, that if you are able to 23 establish that you have an of factive program, I don't know 24 as that term is used in license renewal, but if you have 25 a program that includes surveillance, tests, compliance NEAL R. GROSS COURT REMRTERS AND TRANSCRIOCRS 1323 AHODE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON, D C P0005 (202) 234 4433
-....c
j j
62 I
with the maintenance rule, everything that the licensees 4
1 2
are doing today, plus what they will be doing under the i
3 license renewal rule, and an experiential database, some 4
data that indicate how effective that's been in avoiding a
5 maintenance preventable functional failures, that that 4
(
i 6
alone ought to be sufficient for a licensee then to say,
}
7 in the context of license renewal, "We don't need to go in i
8 and evaluate every one of the aging mechanisms that might 9
af fect a particular structure or component, on the ground j
1 1
j 10 that we have a sufficient database-period of time over i
11 which we've had positive experience, as we've adjusted, 12 fine-tuned,
- modified, supplemented, our existing l
13 maintenance program" -- and I use that in the general 14 sense -- "and, therefore, can essentially truncate the 15 review of individual aging mechanisms".
f 16
- Now, going back to tne Reg
- Guide, and 17-recognizing that the CRGR - has advised you.that the i
18 approach is not consistent with their reading of the rule, 19 or the Soc, your initial thinking on that score which, as 20 I understood it, said, yes, we would be comfortable with 21 that approach up to five years -- that is to say, if you 22
. have.a repair-replacement-refurbishment program, which is 23-essentially what the maintenance rule and the attendant 24 aquirements contemplate, we're comfortable with that up.
25
-to a five-year period..
NEAL R. GROSS I
COURT REPORTCRS AND TRANSCRIBERS 1323 RHODE l$ LAND AVENui, N W (202) 2,4 4433 WASHit4GTON,. D C. 20005 f?o2) 2344433
63 1
liow, my question here, and it's the question I 2
raised earlier, is two-part.
11 umber one, if you're 3
comfortable with that for a five-year period, does the 4
same logic apply to a program like that for the full 20-5 year period of license renewal?
Why not simply say, if 6
you have an effective repair-refurbishment-replacement 7
program, that can be sufficient in and of itself to make 8
the requisite showing.
9 And, secondly, to what extent is your lack of 10 comfort with extending it beyond five years, a result of 11 the fact that you don't think the rule permits you to get 12 there?
13 MR. RUSSELL:
I must admit, the five-year issue 14 I find interesting, and I'u glad the CRGR took it out.
15 DR. MURLEY: We're going to answer that question 16 as part 7f our review.
We will keep it in mind, that it 17 is a key aspect.
But I guess I would not feel comfortable 18 today, giving a staff answer to that, until we go through 19 the review and really look at it.
But we're quite aware 20 that you're interested in that, and I think 1 9 a good 21 question.
22 MR. RUSSELL:
In f act, the approach we're taking 23 under the maintenance rule is not dependent upon that, and 24 I would characterize it as-different, substantively, in 25 that under the maintenance rule we are looking j
NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON O C 20006 (202) 234 4433
64 1
specifically under A-3, for what I will characterize as an 2
optimization between performance and unavailability that 3
may occur as a
result of potentially excessive 4-refurbishment
- overhaul, and that we are aware that 5
excessive maintenance can introduce equipment 6
unavailability and cat introduce failures because of 7
potential problems in the conduct of the maintenance.
8 And, so, the concept of balancing the two which 9
is embodied in the maintenance rule is also embodied in 10 the regulatory guide, from the standpoint you are trying 11 to maintain when needad, trend monitor the condition, and 12 use a condition basis for going in and effecting your 13 corrective action, rather than a straight periodic repair-14 overhaul-refurbishment which may be excessive, and may 15 itself introduce failure mechanisms.
So, there is a very 16 different philosophy, I think, in the maintenance rule.
17 DR. MURLEY:
Could we have some final words on 18 lessons that we've learned so far, and Rich Correia is 19 going to discuss them.
20 MR.
CORREIA:
Would you turn to slide 19, 21 please.
(Slide) 22
- First, to give you some background on our 23 interactions with the industry, in this case NUMARC, on 24 the implementation for the guidance of the maintenance 25 rule.
First of all, our goal was to encourage industry NEAL R. GROSS COURY REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON. D C 20005 (202) 2344433
65 1
j 1
leadership in development of a guideline, and then for us 2
to, in turn, endorse this guideline in a regulatory guide.
3 The first meeting between NUMARC and the staff f
j 4
was last August, of '91, at which time the NRC and NUMARC i
5 steering groups agreed that HUMARC would take a lead in 6
developing an industry consensus document, and that the 7
NRC staff would also develop a regulatory guide in 8
parallel with the NUMARC effort.
2 9
During the year, the two steering groups met 10 f airly frequently, to discuss development and progress of I
]
11 any issues that came up, to try to resolve them as quickly 12 as possible.
13 By June of L d W ><
tja steering group, NRC 14 steering group, determined that the NUMARC guideline was 15 acceptable enough, provided taree key areas were addressed i
~
16 and resolved and, at that time, decided that a task force 17 between NRC and NUMARC would be developed to resolve these 18 key areas.
19 By June and July following, the two working i
20 groups held a series of meetings in which they resolved 21 these issues.
NUMARC subsequently revised the guideline, 22 and the NRC steering group determined that their guideline
-23 formed a suitable basis to go forward with their V & V 24 program.
25 In August of this year, the NUMARC V & V program 3
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON, D C 20005 (202) 234 4433
,.~_
66 1
began.
It was participated in by nine nuclear units from 2
eight utilities, and they are listed there grouped by IJSSS 3
vendor type.
4 The program is almost over.
Currently, the 5
licensees are finalizing their V & V reports, which 110 MARC 6
will compile in a summary report and submit to us about 7
mid-January of this year.
8 11 ext slide, please.
(Slide) 9 Some of the lessons we've learned from our 10 interactions with liUMARC, first of - all, the steering 11 groups ensured a consistent oversight of the guidance 12 development process, a timely resolution of issues during 13 the meetings, a schedule adherence, and a dedicated staff 14 on both sides, to develop the guidance details.
15 liUMARC provided the leadership rule in 16 development of their guideline.
That facilitated general 17 acceptance of the guideline by the industry.
18 We've also learned, because the maintenance rule 19 is performance-based and results-oriented and allows 20 licensees flexibility in utilizing their existing programs 21 to implement the rule, that it reinforced the need for the 22 guidelines to be comprehensive to allow licensees to use 23 their programs to implement the rule.
24 Our
-interactions during the guideline 25 development process stimulated open exchange of ideas and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WA$HINGTON. D C. 20005 (202) 2344433
- - - _ - = _ _ _ _ _ _ _ _ _ _ - _. - _
\\
67 1
- thoughts, and provided NUMARC with an ongoing staff 2
opinion of the acceptability of their guidelines.
3 Similarly, ehe NUMARC V & V process allowed for 4
an open discussion between staff and the V
V 5
participants, on rule requirement, so their plans to-f 6
implement the
- rule, potential inspection enforcement 7
issues that they had questioned well in advance of the 8
- implementation date of the rule.
.9 Next slide, please.
(Slide) 10 Some specific examples of what - we've learned-11 from the V & V program, first of all, the scope of SSCs 12 covered by the rule.
We've determined that additional 13 guidance in the Reg Guide would be needed to better 14 describe which SSCs, nonsafety-related SSCs, use the EOPs, 15 or that could cause a. scram or safety system actuation, i
16 needs additional clarification.
In the case of EOPs, for 17 example, some licensees pointed out that some SSCs are 18 included in EOPs strictly for economic teasons.
They 19 would wish to isolate them from potential damage from the 20 accident, and have no b' earing on the safety consequence of 21 the event.
22 They've alsoLpointed out that-because - of-the 23 uniqueness of U.S.. plant design,Ohat no two lists of SSCs -
24 from similar plants will necessarily be identical. AE and -
25 utility-specific design preferences have showed themselves NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 234 4433 WASHINGTON. D C 20005,
(202) 234 4433 -
,.-..;....._.-,_,a_...,_,,.,._-.-;_.-..-....
. w...
.....-,....._,..._._.__--_..w-.-........_._,_.,
i 68 1
1 in the list of SSCs, that the licensees are determined to 2
be within the scope of the rule.
4 3
We've also found that over time, due to plant 4
j 4
modifications or design changes, that certain SSCs may be i
{
5 added or eliminated from the scope of the rule, simply by l;
6 their function.
J 7
One area that HUMARC V & V and the staff spent l
8 a lot of time on was PRA and determining risk-significant i
9 SSCs.
There are approximately three, three and a half, 1
j 10 methodologies, if you will, that they've come up with are 11 determined risk-significant SSCs, but these, or this f
12 information that's derived from the PRAs, would be fed l
13 into an expert panel, plant-specific expert panel, to i
14 review and determine which ones are, for their plant, 15 risk-significant, rather than just rely on strict 16 interpretation of the PRA.
l 17 The licensees have also realized the benefits by 18 evaluating maintenance on a system or train level.
Right l
19 now, they basically focus on the component level, but 20-stepping back and looking at the overall effect of 21 component performance as it relates to train or system l
22 performance, they see as a definite benefit.
23 As Bill mentioned, one of the findings from the l
24 MTIs was the root-cause determinations were generally not 25 adequate.
The licensees in the V & V program have also 4
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 3
1323 RHODE ISLAND AVENUE, N W
(?O2) 254 4433 WASHINGTON. O C 20005 (202) 234 4433 mw.-
y -
4 g -me
-o e-
.+-v
,m
-rm-:
. =.._
I 69 1
found that some of their past maintenance failures didn't 2
have a sufficient cause determination associated with 3
them.
They realize that area still needs strengthening.
4 They've also realized that many of the data 5
systems that they use on-site now are not adequate to 6
support their needs for the maintenance rule.
They have 7
the information available, but they're not all focused on 8
the needs for the maintenance rule.
9
- And, finally, one other issue that they've I
10 generally agreed on is the need to refine the process that i
11 they have in place now, to determine overall plant safety l
12 before they take the system, structure, or component out l
13 for maintenance.
Right now, they rely on control room 14 operators'
- judgment, training, as well as tech spec i
15 requirements, to make that call, but generally they feel l
16 they need a more refined process to make that happen.
17 That concludes my presentation.
18 MR.
TAYLOR:
That concludes our formal 19 presentation today.
We'll be continuing tomorrow.
If 20 there are further questions --
21 COMMISSIONER ROGERS:
Before we leave, just-a 22 couple of questions on this last matter. Are you going to 23 review these lists of SSCs from these dif ferent plants, to 24 see whether there really is somehow a difference in point 25 of view that is not shared,.and if that's responsible for NEAL R. GROSS COURT REPORTERS ANO TRANsmiOERS 1323 RHODE ISLAND AVENU(
'L (202) 234 4433 WASHINGTON. D C,20005 '
(202) 234 4433 '
70 1
an item being on the list or not on the list?
In other 2
words, I wonder if there isn't something that might be 4
3 learned a little bit from looking at these lists done by 4
different plants, and to see when they don't overlap, 5
whether there's something that we can learn from that.
6 MR. CORREIA:
I think the uniqueness of-the 7
differences in U.S.
plant design is what is highlighted 8
there.
What they have done is --
9 COMMISSIONER ROGERS:
No, I understand that's 10 what we would ascribe it to, but I-wonder-is there the 11 possibility that it's not just that the plants are 12 different, but -that actually the analysis is a little 13 different, that has led to identification of an SSC in 14 each of these plants.
15 MR, CORREIA I don't believe that's the case.
16 It's a matter of focus on the function,_ and it's just-that 17 each plant has unique descriptors, or that the way they've 18 configured 'their systems caused it to list them dif ferent, 19 but I believe they are consistent in their approach.
20-
--MR. RUSSELL:
I would also point out-that in the 21-event that something is missed, with the period of time of-peration, it's a self-correcting-process. -
And if you 22 o
23 have a maintenance f ailure that does occur, that causes an 24 ESF actuation or a plant trip, and it wasn't previously in -
25 your program, you are required-to evaluate that, determine -
NEAL R. GROSS -
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 2344433 -
WASHINGTON, D.C. 20005 (202) 234 4433
i 1
i j
71 l
1 what type of maintenance is needed in the future, and if 2
you have a second or.e for that same cor.iponent, it goes
}
3 into the formal trending process. And, so, with time, the i
4 performance-based rule, if the equipment does not perform a
j 5
well, it becomes a part of that rule and gets tracked and j
6 evaluated with all the subsequent reviews.
l, So, if the PM program is effective and failures 7
8 are not occurring, that 's - the end result that we're 9
looking at.
So, we were not intending to review in-depth 10 the list, or how the lists were generated.
Rather, we are i
- intending to review the results of whether that program is 11 12 effective.
l 13 CHAIRMAN SELIN:
I'll save my general wrap-up comments for tomorrow, and just turn to my colleagues.
_I 14
-15 just have to point out that I have found in_my year and 16 some time here, that - having-read Darwin ~and Steven J.
17 Gould-on evolution turns out to be more relevant than my 18 engineering training sometimes, in ' understanding these 19 pieces.
-- 2 0 Commissioner Rogers?
21
_ COMMISSIONER ROGERS
- Well,
.many of my que'stions, I-think, reallyiwill.have.to come out of--your 22 23 review process, that there's no'l point..in raising them 24 again, until you.have carried that out.
What do you see-e 25 as the implication,- or what. implications for level of NEAL R. GROSS COURT AEPORTERS AND TRANSCRIBERS 1323 AHODE ISLAND AVENUE, N W.
- (20?) 2344433 L
. WASHINGTON, D C. 20005 --
'(202) 2344 433
.__--...--,..b'
i i
ij-72 2
i
~
1 staff resources do you see coming up now, in this new work 4
2 that you'll be doing with B&W, and perhaps there is a i
l 3
calvert - Clif f s application in the offing as well, I
i 4
understand, so that do you feel that new resources - are
(.
5 going to be required? Do you think that -- there has been 6
a question of whether there's adequate resources available l
7 now.
I guess we didn't get into the EPRI documents yet, 8
and I guess that will come up tomorrow,-that we haven't l
9 had a chance to review those adequately, at least in their l
10
-view, whether there is a resource question that's arising-i
)
11 now?
l 12 DR. MURLEY: That's one of the things that we're i
13 going to be looking at in this review as well.
I'll give l-14 you my honest sense now, I think we're probably going to i
i 15 have to put more resources into this area, yes.
i 16 A few months ago, I would have thought just the 3
17 opposite.
I saw a lot of interest declining.
- NUMARC, 18 however, wants us to write safety evaluation reports on-
~
l 19 their industry documents.
The staff did not think that l
20 that was a productive of fort because they were so general-21 that we-wouldn't learn very much.
Nonetheless, NUMARC i
l 22 wanted it.-
They've put many _ millions _ of dollars into 23 producing;them.
So, I committed that we will write SCRs,-
[
24 so we've got that. activity going on.
i 25 We now have B&W coming-in-and, as I said, my NEAL R. GROSS o
COURT REPORTERS AND TRANSCRIBERS
' 1323 RHODE ISLAND AVENUE, N W.
h (202) 2344433 WASHINGTcN. O C 20005 (202) 2344433 c a
~ -
73 1
experience with that group is they do very good work, and 2
they'll be prodnelng things for us to review fairly 3
quickly.
In addition, there is some activity with i
]
4 Northern States -- I don't know what their plans are --
i 5
and then, also, with Calvert Cliffs, Baltimore GSs.
And 6
with all that coming, it depends on the timing, is the 7
reason I can't give you a clearcut answer, but my sense is l
8 we'll have to put some more resources in.
9 CHAIRMAN SELIN:
Commissioner Curtiss?
3 10 COMMISSIONER CURTISS:
I've asked all my 11 questions that I have for today.
Let me just make two or 12 three observations.
First, I'd like to commend the staf f 13 for what I thought here today, and I assume tomorrow, will 14 be a pretty thorough presentation of the issues, laying 15 them out as they currently stand.
Obviously, we have a 16 lot of work ahead of us in terms of working through the 17 detailed policy implications of these issues, and that i
18 really leads to my second comment, which I think -- which 19 I should say is I think the decision to establish a high-l 20 level senior group within the agency is exactly the right 21 thing to do at this point in time.
Clearly, there's a lot of interest on the part of those outside of the agency, to 22
'23 have clear, more stable guidance on some of. these 24 important issues. And I think the quicker we get on that, 25 the better off we'll be.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON, O C. 20005 (202) 2344433
_..._._._ _.___~._..._ _ _ _. _._
.. _ _ _ _. _ ~ _ _ _ _ _. _..
4 74 1
In that regard, I have one suggestion.
You do 2
have, as I took notes here, you do have several issues 3
that have to do with interpretation of the SOC and/or the i
4 rule, and I encourage you, as I'm sure you probably
)
5 intend, to solicit active and continuing interaction by 6
OGC on that question because those.are --
7 MR.-TAYLOR:
That hasn't been lacking.
+
8 COMMISSIONER-CURTISS:
If it has, fill in the 9
gaps, but if it hasn't, continue that, because I do think 10 many of these issues, which I've thought about but haven't 11 got any clear positioning on either in terms of-whether 12 they can be done within the context of the current rule, 13 or the SOC, or both, I'd sure-be interested in hearing 14 what OGC's input is throughout this process.
15 I'm going to reserve judgment on_ the question of 16 resources and the B&W effort until I have an-opportunity 17 to hear from you tomorrow, and B&W on the 18th.: I will 18 just raise, at this point in_ time, a question for you to 19 think about.-
I agree with--everything that's been said 20 about the B&W initiative, and I think, in fact, we can 21 expect that-effort.to-be a-first-rate effort supported
'22 fully.by__the B&W people,_ andLI say that not meaning to
=23-comment _ in any way _ on the ef forts that we've had.to date, 24 because I think those have been supported quite actively, l too.
NEAL R GROSS
. COURT REPORTERS AND TRANSCRIBER $
- 1323 RHODE ISLAND AVENQ N W-(202) 2344433
' WASHINGTON, O C. 20005 -
(202) 234 4433
i l
I 75 l
i i
1 The-question that exists in my mind, and the i
2 thing that I'll need to reflect upon come the conclusion 4
l j
3 of this series of briefings, is whether it makes senss to l
1 1
j 4
embark upon a f airly active and resource-intensive offrart i
5 with B&W at this point in time, in parallel with the work i
j 6
that you've got going on, to address and resolve these i
7 major policy questions.
We do have limited resources in 8
this area.
I know John Craig has been busy doing a lot of l
9 things, including but not limited to license renewal, and i
10 I think the priority at this point in time ought to be i
11 placed upon ensuring that these several policy issues that 12 we'll dincuss today and tomorrow, are resolvea in the most i
13 comprehensive and expeditious fashion.
If you believe 14 that some interaction with B&W will inform-your i
l 15 discussions in a productive way in that regard, that would l
l 16 be interestingfto hear _either tomorrow or on the_18th, f
i 17 If, on the other hand,_ the_ B&W ef fort - has -the potential:
l 18 for absorbing a lot of resources and to the point perhaps
[
19 of distracting from the. kind of - high-level management i
20 attention that you've outlined.here, - Tom, I think : th'e 21-priority ought to'be placed upon resolving these_polley 22.-
questions.-
i 23
.And, so, as. we talk' about the resources _
l l
24
- tomorrow, and_ the B&W effort on1 the
- 18th, I'd' bei 25-interested in your further reaction to the coordination of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
- 1323 RHODE ISLAND AVENUE. N W.
-(202) 234 4 433 WASHINGTON, D C. 20005 (202) 234-4433 l--
. -,..,a._- _. _
- . _. a.. - -..._.
.w - ; c
.. -, ~ _
. -. ~...
-- ~.--
1 i
a 76 1
the two.
It's the question the Chairman raised at the 2
outset.
I think it's an important question.
j 3
DR. MURLEY:
Yes, I agree.
My intention is to 4
resolve these issues in the next couple months, if we can, 5
before we start into heavy interaction with B&W.
I 6
CHAIRMAN SELIN:
Commissioner Remick?
7 COMMISSIONER REMICK:
I also found the meeting 1
i 8
extremely useful.
A number of the questions I have, I i
(
9 think, must await the additional briefings we're going to i
7 10 have this month, and also the outcome of the high-level 11 management group review.
And I certainly applaud, Tom, 1
j 12 your undertaking that effort, because I 'think it is 13 warranted.
i 14 Two questions that I might have at this point, i
15 in your interaction with Yankee Row and Northern States 16 Power people, did you come to the point to determine 17 whether that fourth definition in SSCs important to i
18 license _ renewal contributed anything to the process of 19 major significance that would not have been covered under 20 the first three parts of that definition?
21 MR. CRAIG:
We've had limited interaction with l
22 Northern States -on that particular issue, and :I don't 23 think we have a database to respond to that question in'a 24 rAcaningful way.
Clearly, added a number of systems, but
'25 they hadn't subinitted the list, the final list, for us to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234-4433 WASHINGTON. D C. 20005 (202) 234-4433
77 1
take a look at.
We have not done that, so I would 2
hesitate to answer that.
3 COMMISSIONER P.EMICK: Okay. One of the concerns 4
I have, I kind of see that the rule develops kind of like 5
a coffee grinder with a big funnel, where a lot of things 6
go in and, through various processes, some things are kind 7
of spit out.
The hulls are spit out, or the cats and 8
dogs. And you end up with the more significant SSCs.
But 9
if I understand it properly, those things that you spit 10
-out would still be subject to challenge-and, therefore, in 11 answering that challenge,-both the-licensee and the staff 12 would have to expend considerable amount of resources in 13 justifying the fact that they were spit out of the coffee 14 grinder.
So, I still have that concern.
15 I have another question, which you don't have to 16 answer today, but I throw it out-because it's come to mind 17 a number of times-but, _ while '-eing a Commissioner, I've 18
' observed a couple major rulemaking processes, and the 19 question I have in mind is not in any way criticism of the 20 people developing the rule, or the criticism of NRR, but 21 I can't help but wonder if NRR~is not being impeded by the 22 process where we have one _of fice develop some major rules 23 which NRR must implement -- it certainly wc,uld apply also, 24~
I guess,-to NMSS -- and I realize there's a concurrence 25-process, but.there's nothing -- like facing the questions J
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
.- 1323 RHODE ISLAND AVENVE, N W.
(202) 734 4433 WASHINGTON. D C. 20005 :
(202) 2344 433"
78 1
that do arise when you're intimately involved with the 2
writing of the rule itself.
3 So, I just throw it out as a general question, 4
it need not be addressed unless you want to today.
The 5
question, does our current system of having rulemaking 6
development in one office separate from the office which 7
ultimately has the responsibility from implementing, if 8
that presents us with particular problems like we're 9
facing today, where we are addressing problems at a late 10 date and, at the same time, I realize at the time one is 11 writing these rules, one can't possibly anticipate all the 12 difficulties that we run into -- Part 52 and Part 54, and 13 so on.
I throw it out as a general question.
14 MR. TAYLOR:- It's a reasonable question.
As I 15 recall back during the time when we were getting the ideas 16 together for a license renewal rule, both offices were 17 very, very much involved at the management level, and that 18 certainly on the importance of this rule, I would say it 19 was a cross-office effort, and whatever happened was the 20 best at the time, that we knew we could do to make this 21 rule.
I certainly -- Tom, would you agree with that?
22 DR. MURLEY:
Yes.
23 MR. TAYLOR:
But there are you know, your 24 question is a reasonable one.
It's been addressed before 25 in our organization, but let me -- this one, I think, had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLA*JD AVENUE, N W (202) 234 4433 WASHINGTON. O C 20005 (202) 2344433
)
79 1
both offices tightly involved.
2 CO!GiISSIO!1ER ROGERS:
Well, I think, you know, 3
the companion questicn to that is not just whether it's 4
different offices, but different groups of people.
I 5
mean, the difference between the maintenance rule and the 6
license renewal rule being developed concurrently, I
7 think, in retrospect, we probably just didn't think about 8
those together in the right way.
None of us did.
9 MR. TAYLOR:
We didn't think of the overlaps.
10 COMMISSIONER ROGERS:
So, even though you may 11 have had people from both offices involved in both rules, 12 they were different people, and none of us really saw the 13 importance and the virtue of perhaps th3.nking a little bit 14 more about how consistent or inconsistent they were with 15 each other.
It was an issue that I know came up a little 16 bit, but I don't think we really thought about it very 17 deeply at the time.
18 CHAIRMAN SELIN:
Thank you very much.
See you 19 tomorrow.
l 20 (Whereupon, at 11:18 a.m.,
the meeting was 21 adjourned.)
22 23 I
24-l l
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHCDE ISLAND AVENUE N W.
l (202) 234 4433 WASHINGTON. D C 20005 (202) 234 4433
s.3--#.T.e-h.4.A w D 4 M JW W'
$M h+ 4s,.+,L.A-
'aMA4 iJhis, s 4544I,
=45.4.1-M42 -'
**NA2 X
-haS.4d44aWAd.eA=+4ES'
- 4 s
-EJA4-4-Lh4 4h 3 6.h A 4km. M--M m a w e-en
.h--
_h w a -
be
-A, I
e 6
i e
l 9
D k
P f
5 I
h 4
I.
?,
m.,..
..m..-....,,,,-.,,..-;m-c--a r..y,y,,2.r,.
.m.,
4-w-
.,#,,,m,
,.,,..,,..,%-4y..,#.
- ,,7 v 3
..,.,-e,,.
,-mw...,%p.,9 i
CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting I
of the United States Nuclear Regulatory Commission entitled:
l l
TITLE OF MEETING: BRIEFING ON LICENSE RENEWAL RULEMAKING ISSUES PLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING: DECEMBER 7, 1992 were transcribed by me. I further certify that said transcription is accurate and complete. to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
I aklCEMtL 0
0 Reporter's names.
l l
l HEAL R. GROSS COURT R890GTIR5 AND TRANSCRIS6tS 1833 AM00618 LAND AY3MUE, N.W.
(302) 234-4433 WASHINGTON, D.C. ' 20005 (702) 237 4 000 '
REVISED AGENDA LICENSE RENEWAL ISSUES BRIEFINGS FOR THE COMMISSIONERS DAY 1 -- RULEMAKING ISSUES o
l
- PART 54 l
-- Background
-- Scope of SSCs 12 /7/Q
-- CLB
- Definition
- How to Maintain CLB
-- Resolution of Tecnnical lasues
-- Maintenance vs License Renewal rules
-- Maintenance rule lessons learned DAY 2 -- PART 51 SULEMAKING & REGULATORY GUIDANCE ISSUES o
- PART 51 Environmental issues i
l
-- GEIS and " states rights" lGg/92-l
-- Refurbishment Activities and Waste Disposal
- Standard Review Plan & Reg. Guide
-- Staff Reviews
-- Aging Research
-- Industry Reports DAY 3 -- INDUSTRY INITIATIVES AND RESOURCES I
o l
- Lead Plant Activities
- B&WOG Generic License Renewal Program W
92~
- Staffing and Resource Needs 1
December 2,1992 ENCLOSURE l
-)
e
- .u t
"D ct) g Q' %,k; 8
a e
i 3:
s-
/3 one,
ly" G li s i i s c '
LU a
w r
u,l
[D i pi LLJ 2
\\*>o' n y#F#r=-s 3
\\4 CC w
&n i O
\\ kufv.ts @b'/
4 N
W f
co Z
LUO 5
4
.a.---m
.-_m--m_m-o
i
,i
[
L AW EN E
S R
E L
E U
D D S R
E N N N
A E S
L R
SC E
A A
S AE ML U
W E
I S
E L
D U E O S
N S
S T
NS S T E
N i
EI YT L
R S
- G SN A
O I
,A S
C E
S S
S N
AI ST A
I N
N E
R B
E. O K
H E
L P
1 A Y M UP G
C C
E N
E I
TM L
L AE Ci S
s T
U I
L DU US N
n F
v R
RT E
a O
E E
i R
D TN C
n N
C C
t N
S E I
U L
a O
N N
i FN A
A TnM O
OO o
T N
N I
P Nio U
R.
t E
E G
E Eit L
M n
T T
K P
Riw O
N N
C O O Reo S
f I
I A
C C UDH E.
A A
B S
C R-M M
~
x s
~
l
'i i~.
j i
j
s l5 a
.g O
N C
O ITA LU G
k E
45 R
T L
R A'
A W
P E
R N
F E
C R
O 0
E 1
SNEC IL E
H
.T g
n LIlllllII1!ll L:!
OVERVIEW OF Pr..lT 54 ACTIONS ADVANCE NOTICE OF PROPOSED BULEMAKiNG - 1989 PROPOSED RULE PUBLISHED - JULY 17,1990 Key elements include:
- Conclusion that current licensing basis was adequate at all plants
- Compilation of current licensing basis
- Integrated plant assessment DRAFT STANDARD REVIEW PLAN AND REG. GUIDE PUBLISHED FOR PUBLIC COMMENT - DECEMBER 4,1990
- Based on Proposed Rule 3
JVERVIEW O= PART t.. ACTIONS (CON-Q
~
FINAL RULE PUBLISHED - DECEMBER 13,1991 Key elements include:
- Regulatory process is adequate to ensure that the licensing basis provides &
maintains an acceptable level of safety
- Age-related degradation unique to license renewal
- Integrated plant assessment without cornoilation of current licensing basis 2ND DRAFT OF SRP-LR & REG. GUIDE IN CONCURRENCE PROCESS NOW TO BE ISSUED FOR PUBLIC COMMENT 4
LICENSE RENE W,1L PRINCIPLES
~
PHILOSOPHY. FOUNDED ON 2 KEY PRINCIPLES:
1.: REGULATORY PROCESS ASSURES THAT LICENSING. BASIS PROVIDES:& MAINTAINS
?AN:' ACCEPTABLE LEVEL OF SAFETY
-:WITH THE POSSIBLE EXCEPTION OF. AGE-RELATED DEGRADATION UNIQUE TO THE PERIOD OF EXTENDED? OPERATION
- 2. CURRENT LICENSING BASISLMUST:BE MAINTAINED-DURING THEtRENEWAL TERM
- THEilNTEGRATED PLANT ASSESSMENT-(IPA)
IS6ALDETAILED:SYSTEIVIATIC REVIEW OF AGING
&:lDENTIFIES ADDITIONAL AGING MANAGEMEN'l ACTIONS S
~
10 CFR PART 54...-QUIREMENTS L
i INTEGRATED PLANT ASSESSMENT (IPA)
)
CLB CHANGES REQUIRED BY LICENSE RENEWAL l
PLANT MODIFICATIONS FOR LICENSE RENEWAL EXEMPTIONS AND RELIEFSLGRANTED & IN EFFECT i
ATTIME OF APPLICATION THAT ARE RELATED TO SSCs (MPORTANTTO. LICENSE RENEWAL OR l
[
CONTAIN. TIME-DEPENDENT ELEMENT:
+
r
' ENVIRONMENTAL REPORT L
i h
i 6
l
i INTEGRATED PLANT ASSESSMENT (IPA) 5 6
IDENTIFY AND LIST SSC's ITLR' IDENTIFY STRUCTURES AND COMPONENTS (SCs) THAT:
- 1. CONTRIBUTE-TO :THE PERFORMANCE OF' A FUNCTION IMPORTANT TO LICENSE RENEWAL
- 2. COULD, IF THEY FAIL, PREVENT AN SSC ITLR FROM PERFORMING lTS FUNCTION 1DENTIFY SCs THAT COULD HAVE DOCUMENT BASIS AGE-RELATED DEGRADATION (ARD)
UNIQUE TO LICENSE RENEWAL' DEMONSTRATED ARD UNIQUE TO LICENSE RENEWAL j
EFFECTIVELY MANAGEDL
[
Y
- t
.on
' EFFECTIVE PROGRAM :
- -JUSTIFY NOT HAVING l
AN EFFECTIVE PROGRAM p
i DESCRIBE AND'JUSTIF- 'THE EFFECTIVE PROGRAM FOR'EACH SC Y
1 1 --
-l l
7
..t
~~
,c
1 OYSTEMS, STRUCTUF, S, & COMPONENTS f
j
- IMPORTANTTO LICENSE RENEWAL (SSCs ITLRy I
3 l
- FOUR PARTS OF DEFINITION (10 CFR:54.3)
)
I
- 1. SAFETY-RELATED SCs L
- 2. NONSAFETY-RELATED SSCs WHOSE FAILURE COULD DiRECTLY. PREVENT SATISFACTORY PERFORMANCE OF SAFETY-RELATED EQUIPMENT i
- 3. SSCs RELIED UPON.TO MEET:
I
- 10 CFR:50.48 FIRE PROTECTION L
- 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION i
I i
- 10 CFR 50.61 : PRESSURIZED THERMAL SHOCK
- 10 CFR 50.62 ANTICIPATED TRANSIENT W/O SCRAM L
l
- 10.CFR 50.63 STATION BLACKOUT l:-
i j
L 8
- L"
]
--- a
SYSTEMS, STRUCTUR. S, & COMPONENTS IMPORTANT TO LICENSE RENEWAL q'SSCs ITLR)
- FOUR PARTS OF DEFINITION (10 CFR 54.3)
)
- 4. SSCs SUBJECT.TO OPERABILITY REQUIREMENTS CONTAINED IN THE FACILITY TECH SPECS
)
LIMITINCTCONDITIONS FOR OPERATION
- SSCs SPECIFICALLY IDENTIFIED
- NECESSARY SUPPORT SYSTEMS FOR OPERATION SlSCs REQUIRED TO ASSURE SPECIFIC VALUES ARE MET l
- lNCLUDES. A MAJORITY OF THE PLANT'S SSCs; q
JGOES BEYOND SAFETY-RELATED SSCs 9
-j
3 CURRENT LICENSING BASIS AND REGULATORY PROCESS 1
l 1
i t
S t.
T 6
I a
i 10 L
f k
y i
CURRENT LICL aSING BASIS
.NRC REQUIREMENTS FOR A SPECIFIC PLANT lNFORMATION ON THE PLANT DOCKET lNCLUDES:
- NRC regulations
- Orders
- License conditions
- Exemptions and reliefs
- Technical. specifications
- Design bases contained in updated FSAR
- Commitments.made in response to:
- Bulletins
- Generic Letters
- Enforcement; Actions
- Commitments contained in:
- NRC safety evaluation reports
- Licensee event reports 11
M. 4NTAINING THE CURL._ NT LICENSING BAS.j
~
REGULATORY PROCESS INCLUDES:
- Inspection activities
- Inspection Program
- Audits and investigations
- Research
- Generic Safety issue. Resolution
- Operating experience evaluations PROCESS IDENTIFIES NEW ISSUES AND ASSURES NRC EVALUATION DOCUMENTATION OF REGULATORY PROCESS INCLUDES:
- New or revised regulations
- Orders or confirmatory action letters
- Safety evaluation reports
- Inspection reports
- Bulletins and Generic Letters
- NUREGs BACKFIT PROCESS (50.109)
COMPLIANCE
- Licensee activities
- NRC activities 12 O
g
Y REST _UTION OF TECHNICA.
ISSUES DURING reb lW 4
4 i
=
DOCUMENTATION
- Application Information onsite.in auditable and retrievable form (54.37)
IMPLEMENTATION i
Regulatory Guide i
Standard Review Plan Inspection and audits i
i f
INTEGRATION.OF LICENSE RENEWAL INTO I
NRC INSPECTION PROGRAM i
FREQUENT PUBLIC MEETINGS WITH RENEWAL l
~
APPLICANTS TO DISCUSS REVIEW STATUS, I.
OPEN ISSUES, ETC.
l 13
i i
l 4
I i
i 1
l I
k i
1 i
3 i
i l
COMPARISON OF THE MAINTENANCE RULE 1
v i
AND THE l
l
- d..
LICENSE RENEWAL RULE i
9 l
I l
t
(
{
t i
i l
I ll i
14 O
9
M,..NTENANCE AND LIC ASE RENEWAL RULL j SIMILARITIES 1
d SCOPE OF STRUCTURES, SYSTEMS AND COMPONENTS OBJECTIVE 'OF THE RULES REVIEW AND FEEDBACK MECHANISMS l
USE OF EXISTING PROGRAMS 15 i
SCOPE OF S Cs,1N THE i
LICENSE RENEWAL & MAINTENANCE RULES l
License Renewal Rule Maintenance Rule c
-o Safety-related
- Safety-related i
- Nonsafety-related whose
- Nonsafety-related whose failure failure could directly prevent could prevent safety-related I
satisfactory accomplishment structures, systems, and components of the safety-related function from fulfilling their safety-related function l
- Nonsafety-related relied upon to e
Fire Protection, PTS and SBO-mitigate accidents, or transients, or rules used in EOPs e
o Addressed'in technical
- Failure could cause scram l
specification LCOs or ESF actuation o
L
-16 i
p l
i
M,..NTENANCE AND LIC._NSE RENEWAL RULt__J DIFFERENCES APPLICATION
=
- Maintenance rule focuses on operation
- License renewal rule focuses on licensing basis
. TYPE OF RULE
- Maintenance rule is. performance-based r
--License renewal rule is prescriptive i
=
FOCUS OF RULES
- Maintenance rule focuses on reliability and l
. availability of all SSCs within the scope, l
.with emphasis' on risk-significant SSCs j
i
- License renewal rule focuses'on maintaining licensing basis for all SSCs within scope DOCUMENTATION t
- Maintenance rule does NOT require submittal l
and review of' programs - relies on inspection L
- License renewal rule requires submittal of
{
methodology and detailed assessment of-l age-related degradation unique.to' renewal e
L i
l 17 iw
4 i
i 1
]'
i STAFF INTERACTIONS WITH INDUSTRY ON i
IMPLEMENTATION OF THE MAINTENANCE RULE a
p i
i a
}
l f-I i
I i
l I
f l
18 i
-l
~
~
t i
[
ST, F/ INDUSTRY INTERAC JONS ON MAINTENAl JE i
BACKGROUND i
^
o NRC STAFF GOAL:
ENCOURAGE INDUSTRY LEADERSHIP i
& ENDORSE GUIDELINE o
AUGUST 1992:
NUMARC V &.V PROGRAM BEGINS WITH 9 PARTICIPATING PLANTS:
i i
- Haddam Neck, Callaway, Comanche Peak (W)
- Crystal River & ANO Unit 1 (B&W)
- Fermi 2 & Grand Gulf (GE) l
- Calvert Cliffs & ANO Unit 2 (CE) o JANUARY 1993: SCHEDULED COMPLETION OF NUMARC V&V I
PROGRAM 19
L ST/
F/lNDUSTRY INTERAC
.ONS ON MAINTENAN,E NRC AND NUMARC STEERING GROUPS e
t NUMARC LEADERSHIP ROLE 4
.i COMPREHENSIVE IMPLEMENTATION GUIDANCE NEEDED NUMARC V & V PROGRAM FOSTERED FRANK-DISCUSSIONS f
20 i
i f
1
~
ST/
F/ INDUSTRY.INTERAC
'ONS ON MAINTENAI JE
- EXAMPLES OF RESULTS FROM V:& V PROGRAM SCOPE OF SSCs COVERED BY THE MAINTENANCE RULE h
PRA INSIGHTS EVALUATE: MAINTENANCE EFFECTIVENESS AT THE SYSTEM / TRAIN LEVEL REFINE PROCESS TO ASSESS OVERALL PLANT SAFETY WHEN TAKING EQUIPMENT O.UT OF SERVICE FOR MAINTENANCE 21
Y f
s=s a
4 a
9 x\\\\x\\
xx