ML20140B575
| ML20140B575 | |
| Person / Time | |
|---|---|
| Issue date: | 09/09/1981 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 ACRS-T-1000, NUDOCS 8109140253 | |
| Download: ML20140B575 (58) | |
Text
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i D DA "2 N 05: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS I SUBCOMMITTEE ON REGULATORY ACTIVTTY /-,. i e 's, t.: 1 ( 'iv, . 8 l (kll hi il.(..I f LIJ l o t. l ;-l,t g (,x ,h m 2\\ ' g'j _J "3 j l 1031 u 'O 1 (c,\\ va. m at.,,c o w,, u; C % esrx / i .,i [/f j g Q[ OAS: Sectember 9, 1981 PAGES: 1 - 144 AT: Washington, D. C. / /l~ l / \\ / G i N 60 i l ( RNN O MEM' 'i l 40 0 vi vir.ia Ave., 5.W. Was d.g.=n, O. C. 20024 l O
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I 1 1 UNITED STATES OF AMERICA 2 3 NUCLEAR REGULATORY COMMISSION 4 5 6 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 7 8 SUBCOMMITTEE ON REGULATORY ACTIVITY 9 10 Nuclear Regulatory Commission 11 Room 1046 12 1717 H Street, N.W. 13 Washington, D.C. O 14 15 Wednesday, 9 September 1981 16 17 The meeting was convened at 8:45 a.m. 12 19 ACRS MEMBERS PRESENT: 20 C. P. SIESS, Chairman 21 JEREMIAH J. RAY, Member 22 MAX W. CARBON, Member 23 H. ETHERINGTON, Member 24 25 O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE.,3.W., WASHINGTON D.C. 20024 (2C2) 554-2345
1 1 { 2 l i l l 1 l O i otS1cuirto rtotait eMetortz. l 2 SAM DURAISWAMY i ~ !O i i 4 ALSO PRESENT: l 5 Messrs. Morrison, Sil ve r, Randall, Kiessel, f 6 Richardson, Scarbrough, Baker Wenzinger, Serpan, Cherny, \\ 7 Maskell, Page, Boel4m, and Anderson. l t 8 e i i 9 i l l 10 l i 11 l l J l 13 i O I i' 14 t 15 l 16 [ 17 18 19 20 1 21 22 l 23 24 25 O 1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D C. 20024 (202) 554 2345 .m..
3 1 O nussatus 2 (8: 45 a.m.) 3 MR. SIESS: The meetiLo will come to order. 4 This is a meeting of the ACKS Subcommittee on 5 Regulatory Activities. I a m Chester Sier ;, Subcommittee 6 Chairman. The other ACES Members present a t this time, 7 sta rEing on my left, are Jeremiah Ray, Max Carbon, arid 8 Harold Etherington. Mr. Bender is not going to be here this 9 aorning, and I do not think anybody else is planning to be. 10 If Mr. Shewson is here, he will be in later. 11 The meeting is being conducted in accordance with 12 the prevision so of the Federal Advisory Committee Act and 13 the Government in the Sunshine Act. The designated Federal 14 Empioyee is Mr. Sam Duraiswamy on my right. 15 We will be keeping a transcript, so speak 16 clearly. If you have a mike, try to use it. 17 We have had no requests from the public 'or oral 18 sta tements, and we have had no written statements from the 19 public. 20 The agenda that I have here includes four items: 21 Regulatory Guide 1.33, Revision 33 Revisions to 10 CFR 50, 22 including Appendices G and H; a proposed Reg Guide on 23 Identification of Valves for inclusion in the in-service 24 testing program; snd a proposed Revision 2 to Reg Guide 25 1.105. O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
4 1 We originally had on our agenda proposed Revision 2 2 to Reg Guide 1.13, and that has been postponed. 3 Is that correct, Bill, as far as you know? 4 MR. MORRISON: Yes. 5 MR. SIESS Do you want to take th em up in the 6 order we listed them? 7 MR. MORRISON: Yes. That is fine. 8 HR. SIESS: All right. The first item, then, is 9 Proposed Revision 3 to Regulatory Guide 1.33, Cuality 10 Assurance Program Requirements (Operation). 11 This is a proposed revision. It has been 12 previously looked at by the subcommittee, I believe. You 13 brought it in, and we said send it out and we will look at O 14 i t later. It has been out for comment. It has received a 15 reasonable number of public comments. It is now submitted 16 to us for concurrence by the f ull ACPS. 17 It endorses with come additions an ANS Stande rd, 18 A NS 3.2, which has not yet been made final. Right? f 19 MR. MORRISON: Well, I think it is in the 20 correct me if I am wrong, Tom. Tom Scarbrough is the Task 21 Leader on it and will make the presentation. He has the 22 draft that is being published. So what you have received is 23 the final version. / 24 MR. SIESS: What it says in Carl Go11er's letter 25 is that it has not been apJroved by ANSI, A-N-S-I. Have the O l ALDERSON REPORTING COMPANY. INC, I 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
5 O 1 etenderde been eooreved er AxS? Ie everrthino done exceot 2 the ANSI approval? 3 MR. SCARBROUGHs There is one remaining item that 4 needs to be clarified, and it is more or less an 5 administrative matter. I talked to Marilyn Weber yesterday 6 and she is workir.g on resolving that. She assured me that 7 the change would not affect our endorsement of the 8 standard. She hopes to hav. it approved by the ANSI Board 9 of Review toward the end of this nonth. 10 ER. SIESSs All right, now, I just want to get 11 something clear. ANSI approval of a standard is usually an 12 administrative approval. 13 MR. SCARBROUGH4 Yes. O 14 ER. SIESS: ANSI does not concern itself with the 15 technical content unless there are questions regarding 16 resolution of negative votes. Am I correct? 17 MR. SCARBROUGHs That is correct. 18 MR. SIESS: So this is only an administrative 19 approval that is lacking? 20 MR. SCARBROUGH4 Yes, sir. 21 MR. SIESS: The standards-vriting body has signed 22 of f on this, and has been approved by whatever standards 23 board ANS has. 24 MR. SCARBROUGHs ANS-3, who is in charge of this 25 particular standard, is meeting next week, and they will at O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AV2., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6 () 1 that time be presented for the Guide for formal approval. 2 It has already been through their review process, and it is 3 now in the stage where they will giva '. heir formal approval { 4 so it can submitted to the ANSI Board of Review for their 5 administrative approval. 6 MR. SIESS: So in effect, then, one of my concerns 7 was this business of writing Reg Guides on draft standards. 8 This is a "draf t" only in the sense that it has not had its 9 final administrative approval? 10 MR. MORRISON: That's right. And before we put 11 out the Regulatory Guide as an effective Regulatory Guide, 12 the ANSI Standard will have to be available and published in 13 its final form. 14 HR. ETHERINGTON: Does it ever cet revised at tha t 15 time when ANSI approves? 16 MR. MORRISON: Well, the standard has been through l 17 this ANSI concensus committee, which is NUPPSCO -- 18 MR. iTHERINGTON: So it is only a rubber-stamping 19 operation f rom here on? 20 MR. MORRISON: -- I guess has been checked to make 21 sure that the concensus process has not been violated in any 22 w a y. There should not be any technical changes. 23 MR. SIESS4 The highest ANS Board has not met yet, () 24 b u t that is like a standards board, too. That is looking at 25 procedures; righ t? O ALDERSoN REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
i i 7 O en "oaa1 sos-rae co ce==== oro=> 1= tae "uresco 2 g roup, yes. 3 HR. SIESS: That is the concensus group? 4 MR. MORRIS 0Na Yes, they have approved it. 5 MR. SIESS: ANSI approval is usually a pro forma 6 type of thing. 7 Okay, Jerry? We are going to get some general 8 questions out of the way, and then you just keep them in 9 mind and do not repeat them. 10 MR. RAYa As I interpret your last statement, 11 where this Guide refers to the draft ANSI, or ANS, it will 12 be revised to refer to the approved ANS ANSI before you 13 issue it? 14 MR. MORRISON: That is right. It will be finally 15 ref erred to as -- 16 MR. RAY: As "the standard"? 17 MR. MORRISON: -- ANS 3.2-1981. 18 MR. RAY 4 Wi t ',1 no reference to a draft? 19 MR. MORRISON: No. 20 MR. RAY: That is very desirable, I think. 21 MR. MORRISON: Incidentally, tl.at has always been 22 our agreement with ANS on the use of draft standards; that 23 in the interest of getting the Reculatory Guide <, out in a 24 timely fashion, that we will use their draft standards in 25 the precomment stage, but when we go effective we will O ALDEPSoN REPoRTIN9 COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
8 () 1 endorse the published version of the standard and not the 2 draf t standard. /} 3 MR. SIESS: So you are not using this as a device 4 to push them into what they did not want to do? 5 MR. MORRISON: No. 6 MR. SIESS: They already knew what you were going 7 to put in the Reg Guide when they approved the standard ? 8 MR. MORRISON: Well, I am not sure I can say that, 9 because we ;tave had -- 10 MR. SIESS: I assume anything you have got in the 11 Reg Guide is something you have been pushing on the 12 standards-writing committee? 13 MR. MORRISON: Not completely, in that there are 14 some positions where organizational -- allowable 15 organizational relationships, f or example, whrte we have in 16 effect endorsed what was in the standard, but also provided 17 additional options. 18 MR. SIESS: Oh, okay. l 19 MR. MORRISON: It is not clear to me that we have 20 been pushing them f or tha t. l 2: MR. SIESS: Well, look. I have got another sort 22 of a procedural question. I think it was actually brought 23 u p somewhere in the public comments, which we can get into ( 24 in a little more detail. The title of the standard is 25 " Administrative Controls and Quality Assurance for the l l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9 () 1 Operational Phase of Nuclear Power Plants." The title of 2 the Guide is " Quality Assurance Program Bequirements (} 3 ( Operations )." 4 Now in the first place, they do not agree, which 5 seems to me not to be such a good idea. But in the second 6 place, the Guide does cover administrative controls. It 7 covers things that have nothing to do with O/A programs, as 8 I think you so said in response to the public comment. 9 Now if I am wrong, tell me. 10 MR. MORRIS 0Na Yes, you are wrong. 11 MR SIESSs And I will dig it out and show you 12 where you said it. In your opinion, the Guide does not 13 cover administrative controls? O 14 MR. MORRISON: No, in our opinion administrative 15 controls is included in quality assurance. 16 MR. SIESS All right, let me ask you a simple 17 question s Why would you not use the same title for the 18 Guide as for the Standard when essentially you are endorsing 19 a standard with not a great many exceptions, just as a 20 matter of looking things up? 21 MR. MORRISON: Well, it goes back to the history 22 of how this Guide came out. 23 MR. SIESS: Oh, come on. You have been b) 24 reorganized twice since then. u, 25 MR. MORRISON: If you vould like, I can explain O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
10 () 1why it ended up wi th the title of "Q ua lity Assurance and 2 Administrative Controls" in the Standard, rather than just (} 3 Quality Assurance as we have in the comparable Guide 4 endorsing 0/ A for design and construction. 5 The ANS-3 subcommittee was originally working on a 6 standard that they called " Administrative Controls f or 7 Nuclear Power Plant Operations." This is the only ANS 3.2. 8 When we came out with our Appendix B, the substance of wha t 9 they had in their administrative controls provision was 10 embedded in the quality assurance provisions. In fact, our 11 regu2 ations are not that clear, either, because when we 12 endorsed Appendix B for nuclear power plant operation in our 13 regulations and said that Appendix B will have to be O 14 followed, that section talks about administrative controls. 15 So in our view, quality assurance is this broad 16 program of which part of it can be considered administrative 17 controls. But I cannot say which part is just 18 administrative controls, and which part is not 1 l 19 administrative controls but other parts of the Q/A program, 20 because the line gets very fuzzy. You will notice that the 21 A NS 3.2 standard does not attempt to make this distinction, 22 either. But in any event, the first Guide we came out with 23 for operations endorsed both the N45.2, which is the quality l O %/ 24 assurance standard, and the ANS 3.2 on administrative l 25 controls. s/ l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
11 /% (_) 1 Because of the confusion and the dual-standards 2 endorsement, which some nuclear power plant operators said () 3 they had a little difficulty with the two-standard approach, 4 there was an effort to combine the Q/A provisions of N45.2 5 into the then ANS 3.2. The result was the title that 6 included both quality assurance and administrative controls. 7 Now f rom NRC 's standa rdpoint, or the then-AEC's 8 regulatory staff, we felt it would have been cleaner and 9 less confusing to have a single title -- namely, " Quality 10 Assurance for Operations"; but you had two factions there, 11 and they wanted to have the best of both worlds, and that is 12 how we ended up with quality assurance and administrative 13 controls. O 14 MR. SIESS: I think that is a delightf ul 15 explanation. They are all mixed up, and nobody is quite 16 sure which is which or where is where, and you are not going 17 to help it a darned bit by using a title different than the 18 standards that you have endor~ed. 19 MR. MORRISON: Except the poin t is, our 20 reg ulations are en titled " Quality Assurance Programs," and 21 this is an acceptable way to combine it with our quality 22 assurance criteria. 23 MR. SIESS: You have some regulations that have to () 24 do with how many hours people can work, and I do not believe 25 they are in the rules under quality assurance, are they? lv ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
12 1 MR. MORRISON: I think that you can find quite a 2 bit under the criteria for quality assurance, for example 3 making sure that the people are capable and proficient in 4 what they are doing. 5 MR. SIESS4 I have a very specific example in the 6 8-hour versus 12-hour shift, anc. overtime provisions which I 7 think is a proposed revision; it has not been adopted? 8 MR. MORRISON: That is right. 9 MR. SIESS: That was going to be a rule put out by 10 the Commission, as I recall. Where was it going to be? It 11 was SECY-something. 12 MR. RICHARDSON: SECY 4.40. 13 MR. SIESS: Where was it going? 14 MR. MORRISON Do you have that, Tom? Where was 15 it going? What part of the regulation? 16 MR. SIESS4 I cannot find it in 4.40. "Into Part 17 50" is all it says here. 18 MR. RICHARDSON: I think the intent, Dr. Siess, 19 was to put it into 50.54, which was a condition of the 20 operating license. 21 MR. SIESS: Okay, which would not come under Q/A. 22 I do not know where 0/A is, but it refers to certain 23 Appendix A GDC items, and so forth. 24 Well, I heard your answer, Bill. All I can says 25 is that it seems to me you are propagating the confusion, ) ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
13 1 but maybe a little confusion is good for the business; I 2 don 't know. I am sure the Executive Legal Director has no 3 objections. 4 ( La ugh te r. ) 5 MR. MORRISON: Well, at this point 6 MR. SIESS: I am sure that the Executive Legal 7 Director has no objections. 8 MR. MORRISON: That has been entitled 0/A for 9 operations. I think at this point probably we would end up 10 with more conf usion by changing the title than clarifying 11 it. 12 MR. SIESS: Jerry? 13 MR. RAY: Is there any other NRC document, a Reg O 14 Guide possible, that addresses administrative controls and 15 the operational phase of nuclear power plants? 16 MR. SIESS: Sure. You said Reg Guide? l 17 MR. RAY: Yes. i 18 MR. SIESS: What about -- MR. RAY: I am visualizing myself as being a new 19 20 operator, a new company who just got an OL, or is in the 21 course of getting an OL, and I am concerned about some i 22 administrative control provisions. I do not know where to l 23 look. 24 MR. SIESS: You hire NUS. 25 MR. MORRISON: Mr. Ray, I would be very hesitant ALCERSON REPORTING OoMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 ~ - - -
14 1 to say that there.are ao other provisions in the Regulatory 2 Guides regarding administrative controls for operation, 3 because I can think of ones like 1.47, the status indicating 4 system, where you do have provisions in there for 5 administrative controls of bypass and operable status 6 provisions. 7 MR. SIESS: That is a little different. 8 MR. RAY: The Guide addresses itself to that 9 subject and thereby includes the coverage of administrative 10 controls pertinent to it. I am talking about a guide that 11 has administrative controls in its title, and tha t is its 12 main subject. 13 MR. MORRISON: No, sir. O 14 MR. RAY: There is no centralization? 15 MR. SIESS: You do not have a guide on safety 16 review groups? 17 MR. MORRISON: No, that is in 1.33. 18 MR. SIESS: That is all in 1.337 Okay. It is 19 really a nit, but -- 20 MR. MORRISON: I do not feel very strongly about 21 i t, as far as the title. 22 MR. SIESS: I hope it is something you guys will 23 give a little thought to, because you are in effect writing 24 a great many guides that endorse standards. Although you 25 may think of a standard as being something that goes along O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) E54 2345
15 () 1 with the guide, in reality the guide is something that goes 2 along with the standard. The standard has got 90 percent of 3 the stuf f in it, and somebody takes that standard, modifies ) 4 it according to the guide, and that is what he is committing 5 to when he commits to the Reg Guide. He actually commits to 6 the Reg Guide, not the standard. 7 So just as a ma tter of policy, I think it would be 8 worthwhile looking at those, maybe compiling a list of 9 quides that endorse standards, and see what kind of a 10 relationship you have got between the titles, as to whether 11 or not it would be desirable. Maybe it would be more 12 con f using. 13 Actually, I cannot agree with you that it would be O 14 tha t conf using, because most people think of guides by 15 num bers. So it really is not confusing either way. I think 16 it is worth looking at. 17 I would be interested in knowing just how many 18 guides you now have that endorse standards in whole or in 19 p a r t. That would be of interect. And I think what I would 20 also like to know -- I am not going to ask you now -- is 21 w ha t percentage of the standards you endorse. It is getting 22 to be a higher and higher percentage. I am seeing some nov 23 tha t are endorsing about 97 to 100 percent of the standard. () I think the one we looked at here -- which one is 24 25 it? -- the set points, I think it is about 98 percent. It O ALDERSON REPGRTING COMPANY,INC, 400 VIRGlNIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
16 () 1 is just something to think about, Bill. 2 Okay, are you ready to listen to the formal () 3 presenta tion, abridged as necessary, not to reopen things 4 that we think we might have closed? 5 (Slide.) 6 MR. SCARBROUGH: What I thought I would do is, I 7 have the positions listed in order as they appear in the 8 Guide, and to the right I have a short description of what 9 the change from the previous Guide was. 10 MR. SIESS: First of all, let me say one more 11 general statement. I was very, very pleased at the way the 12 response to the public comments was handled. The numbering 13 system in general was not as good on this one as it is on 14 some of the others, but it is getting to be an awful lot 15 easier to f ollow and I appreciate it. 16 MR. CARBON: Let me add to that, I do not know 17 whether your comments are meant to include it or not, but 18 this key at the back the last couple or three pages are 19 excellen t. Thank you. 20 MR. SIESS4 We have got one where you numbered the l 21 letters and the comments 1-3, e t cetera, and I think that is 22 a grea t idea, even if I did think of it. 23 (Laughter.) l () 24 MR. SCARBROUGH4 Okay, the first reg position I 25 quess we begin on page 8. It is a position which has been ['% l U l l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554 2345
17 () 1 included to clarify the ref erence of the ANS 3.2 standard to 2 various other quality assurance documents. What we have (} 3 done is include the guides which are app 1'icable for each 4 standard. We have also added a short statement which 5 clarifies the relationship between Reg Guide 1.28, which is 6 O/A for design and construction, and Beg Guide 1.33. 7 Reg Guide 1.28 is being revised to endorse a 8 relatively new standard, NOA-1/1979, and there is a period 9 of transition between the N45.2 series standards, and the 10 N O A - 1. We have included a statement there to c1me '. f y the 11 change. 12 The second position, it is a simple addition of a 13 statement to clarif y the definition of quality control which 14 has been added to the standard since it went out for public 15 comment. Their definition is a little more narrow than the 16 Appendix B to Part 50 definition, and we have included a 17 short statement there to refer the user to Appendix B for 18 the proper definition. 19 Reg Position 3 is where the standard has included 20 some guidance on operational C/A reporting arrangements. 21 They have provided in 3.2 an acceptable reporting 22 arrangement, and wha t we have done in the Guide is state i 23 that that there are others that could possibly be acceptable () 24 als o, to allow some flexibility. That is what the addition i 25 was in that part. O i ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
18 () 1 Further down in the position, the standard was 2 revised to expand the Q/A involvement in activities where 3 personnel not from the 0/A organization were performing { 4 verification functions. We revised the Guide to accommodate 5 tha t change to the standard, and also their expansion of the 6 terms used in their statement allows us to delete other 7 positions in the Guide. So their change was a good change 8 from our point of view because it encompasses more aspects. 9 I will identif y these positions that we have deleted because 10 of this expansion later on. 11 The third po si tio n, which is stated " deleted," is 12 one that is just dashed out. This was a simple addition to 13 the areas of knowledge that had been included in 3.2, so O 14 therefore it is no longer necessary as a guide. 4 ~' 15 Further on down, the next dashed out paragraph 16 here, they have revised their reference to NOA-1 which makes 17it more clear. This position was put into the Guide before 18 i t went out for public comment to clarif y the reference to 19 NO A-1. They have clarified it so that it is now sufficient 20 a nd the clarification in the Guide is no longer necessary. 21 Going on to Position 4, this change in Position 4 22 is basically a change. Previcasly we endorsed the 23 NUREG-0654 Now a Reg Guide has been prepared, and it is in () 24 the final printing process. I do not believe it has hit the I 25 streets yet. It endorses 065u and it is more a ppropria te to O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554 2345 ~
19 () 1 reference the Reg Guide in our guide rather than the NUREG. 2 Number 5, which has been deleted, is the 3 discussion of the Independent Safety Engineering Group. The {} 4 problem that came about there is we had some gujdance in the 5 Guide to clarify the use of the ISEG which had been 6 promulgated through different letters and such. The 7 proposed rule that is out right now pendino license 8 applications addresses the ISEG for pending a pplica tion s. 9 The Guide is applicable to not only those, but also 10 operating plants. So we felt that until that rule is 11 finalized, it would be premature to apply guidance on an 12 ISEG which the Rule has not actually been put in place yet. 13 So what we did is -- () 14 HR. SIESS: Wait a minute. What you are saying is l l 15 t ha t you do not think you should put in something for l 16 operating plants until it is clarified what you want for l 17 near-term Ols? 18 MR. SCARBROUGHs Right. Originally what I was 19 told was there was another proposed rule that would go out 20 in the near future on the 0737 requirements for operating 21 plan ts. From what I understand, that has been tabled for 22 t he time being. So what we hoped to do was wait and get the 23 feedbach and find out what was finalized in the pending ? (h (_) 24 license applications f or this ISEG. And if it goes through 25 as written in the proposed rule, I sould imagine that at O l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON. D.C. 20024 (202) 554-2345
20 () 1 some future date we would revise the Guide to provide 2 f urther guidance if it was considered necessary. 3 MR. SIESS: Has tiie rulemaking on the near-term {) 4 operating license requirements been completed? Is that out 5 as a rule? 6 MR. SCARBROUGHa I believe it is out as a proposed 7 rule. I do not believe it is final. 8 MR. RICHARDSON: It was never finalized. 9 MR. SIESS: So it is not #inalized, either, but 10 the Commission actually backed off on the one for the 11 operating licenses, did they not? 12 MR. RICHARDSON: Tha t is correct. 13 MR. SIESS: They said that had all been O 14 accomplished by orders and there was no need for a rule? Is 15 tha t right? 16 MR. RICHARDSON: I know they disa pproved the staff 17 papers. I am not sure 7f all of the reasons they put behind 18 it. 19 MR. SIESS: I am pretty s' ire that was the reason. 20 So the operating licenses I think have all gotten orders 21 saying, "Do this"? 22 MR. SCARBROUGH4 Not for the ISEG. As I 23 understand the ISEG was not applied through letters to A(_) 24 operating plants f rom my last discussions. 25 MR. SIESS: Was the Independent Safety Engineering O ALDIRSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
21 -(]) 1 Group the thing tha t went along with the shift technical 2 advisors and say, "establis! a group to review your plant," 3 and so forth? (J 4 MR. SCARBROUGH: Certain plants I know that was 5 applied to. Across the board for all operating reactors, 6 f rom what I understand, was not applied to every single 7 operating plant. 8 HR. SIESS Okay. 3 MR. SCARBROUGH: The next one was Position 6, 10 which was deleted. It is a discussion of the meeting of the 11 Independent Review Standing Committee. They have included a 12 discussion in 3.2 on the meeting requirements for having a 13 quorum, and our position is no longer necessary. ( 14 Position 5 was added to the Guide strictly as a 15 flexibility provision for licensees to have a 16 mini-independent review of proposed Tech Spec changes before 17 they submit it to the NBC for review. In this manner, if 18 there is a case where they cannot get the entire standing 19 committee toge ther in a short time, they can have a small 20 subcommittee review it, provide it to the NRC Staff and, at 21 the next scheduled standing committee meeting discuss it 22 there. That was a request to us to allow this 23 flexibility. () 24 (Slide.) 25 Position 6 has been added to clarify the reference G(_) ALDERSoN REiORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
22 ({} 1 to NOA-1, once again in 3.2. They added some words which we 2 felt were a little unclear as to providing the auditing 3 guidance for the use of 1.33, and we just added the 4 statement in there which further clarifies that you should 5 look to Reg Guide 1.28 for auditing guidance. 6 The seventh Position, which was deleted, includes 7a provision concerning auditing in the Q/A organization 8 involvement in auditing. That has been included in 3.2, and 9 our position is no longer necessary. We also deleted a 10 portion which we thought was too proscriptive in auditing 11 techniques to allow more flexibility. 12 The seventh position concerns transfer of 13 responsibility. We have revised it to allow some O 14 flexibility in the performance of the plant tour so that it 15 can performed during the shift, or a designated senior 16 reactor operator could perform it if the shift supervisor is l 17 tied up with different duties which would not allow him th a t 18 tim e. 19 We also made a change to not specify exactly that 20 an oncoming shift must report one-half hour ahead of time. 21 ICE felt tha t with more general words, "a sufficient amoun t 22 of time," would allow them that flexibility to review the 23 plants and make sure that their shifts are reporting in an () 24 appropriate amount of time before he took over. l 25 MR. CARBON: Do you have any knowledge as to wha t O l ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
23 () 1 the utilities consider a reasonable amount of time there? 2 What practice do they follow? 3 MB. SCARBROUGHs Well, from what I understand, 15 {} 4 or 20 minutes I believe on a normal, ordina ry shif t; but 5 from what I understand from some of the comments we have 6 received, it they have more delicate activities being 7 performed they will show up an hour or so early. It depends 8 on what time, what is happening at the plant, and we fel: 9 that to allow some flexibility there would be more useful. 10 MR. RAYS That 20 minutes that you cited is the 11 information exchcnge? That does not include a tour of the 12 plant ? 13 MR. SCARBROUGH4 No, it does not. O 14 MR. RAYS That is on shift after he has accepted 15 the responsibility? 16 MR. SCARBRGUJHs Right. i 17 MR. CAE30Na I take it tha t ICE would still 18 routinely check in their plant inspections, would they not? 19 MR. SCARBROUCH: Right. This would be a very 20 simple matter to check, or the resident inspector could 21 check this very easily. 22 The next position concerns what we just talked 23 abo ut ve ry b riefly, the working hour criterton. From what I () 24 understand, the paper that has presented 81.440 contains 25 criteria very similar to what is contained in ANS 3.2. I () [ ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
24 () 1 think the scope of coverage of the criteria are different. 2 Un it we propose is that once a Commission decision {) 3 has been issued on tha t paper, if directed we will change 4 the Guide appropriately and will inform the subcommittee of 5 any change we have made in this area. 6 The ninth position was revised to clarify the 7 Guide in the area of temporary changes to procedures that 8 are required by technical specifications. The tech specs 9 have specific change requirements for procedures. The stand 10 was a little more general, so we added some guidance to be it consistent with that. 12 The 10th position was simply deleted. It was a 13 rewrite of Position 9 and was no longer necessary. 14 (Slide.) 15 Po sition 10 cencerns equipment control. There 16 were several changes in this position that were incorporated 17 into the standard, so we deleted them and the position 18 became much shorter. The standa rd discussed times when 19 independent verification of system lineup could be performed 20 by other means in cases of significant radiation exposure. 21 The term "significant radiation exposure," we wanted some 22 more specific guidance in that area. So we have added the 23 statement which would define that ca se where verification () 24 could be performed by other means, automatic means or 25 control room sensor readings. In those cases where an ALDERSoN REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
25 1 individual would have to enter a high radiation area, we 2 were trying to ensure that we have some sort of a standard 3 on what was meant i> y "high radiation exposure." g 'w/ 4 The other changes for the most part were 5 incorporations into that expanded section of the standard. 6 We also allowed some flexibility in the qualification of 7 this verifier to allow his qualifications to be documented 8 with respect to his knowledge of the system. Rather than 9 requiring a more narrow operating license provision, we have 10 allowed them to justify the individual's knowledge through 11 documentation. 12 Going on to Position 12, this is a position which 13 I mentioned ec.rlier. By expansion of the 3.2 standard, the /~' 14 verification activities now would include surveillance 15 testing and it made this position basically unnecessary. 16 The provisic.ns for auditing, and procedure review, and 17 selection of personnel, or the involvement of the Q/A l 18 organization in the selection cf personnel, are all 19 addressed in the more abbreviated section of that guidance 20 earlier in Position 3. 21 Reg Position No. 11 has been added to provide 22 consistency with 1.28. Since 1.28 applies to 0/A for design 23 and construction and 1.33 for operation, we tried to include O 24 e couo1e or vo=1tioa= whicn wouta exe use et the accu eat-l 25 easier. They would not have to flip back and forth so much O ALDERSoN REPORTING CotAPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
26 () 1 between the two documents. Now this provision for 2 corrective action and follow up of corrective action can be 3 used, ra ther than looking back into operational records so {} 4 that when an individual uses h0 A-1, and with this 3.2 5 standard, there is a more even split between the design, 6 construction, and operation. 7 Position 13, once again it is an NOA-1 8 clarification position. Because of this changeover that is 9 taking place in the industry, we decided that some 10 additional guidance needed to be for procurement document 11 specification in the Guide itself. 12 (Slide.) 13 Position 14 concerned review of procedures. What 14 we have done is we have revised the position to specify more 15 clearly when the 0/A organization needs to be involved in l 16 the preparation of procedures, which allows the 0/A 17 organization the flexibility to be involved when Q/A i 18 requirements are being undertaken; whereas, it d,ces not get 19 the Q/A organization involved in a chain where it slows down 20 the review process. But it does allow them to be involved l l 21 where there is 0/A functions that need to be undertaken, 22 pull the points, checklists, acceptance criteria. 23 Further, the position was revised to once again be l () 24 consistent with tech spec requirements for approval. The l 25 tech specs require the plant manager to have the final O l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
27 (]) 1 approval of procedures, and we have included that provision 2 here to make the document more compatible with the tech 3 specs. 4 Further on we have clarified when step-by-step 5 review procedures are considered necessary. We have revised 6 it to be a little more clea r as to which procedures need 7 this step-by-step review, and this is consistent with the 8 procedure and test review section of NRR and their plans on 9 step-by-ste p review of procedures. 10 The last thing in that position was we havo 11 revised our guidance to be more clear as to when a revision 12 should constitute an entire review of a procedure to ensure 13 tha t the entire procedure was reviewed in the revision, so O 14 tha t just a small part was not revie wed and the.t counted as 15 a procedural review. Posi' ion was a statement 16 The 15th deleted c 17 concerning calibration intervals for measurement and test 18 e quipmen t. We included this Position in here to receive 19 public comment on these particular intervals. We have 20 provided tha t guidance to the cognizant instrument NRC staff 21 f or their f urthe. action to determine if additional NRC 22 guidance on particular intervals are necessary. 23 MR. SIESS; What kind of " guidance" do you think () 24 that might be? Reg Guide and Standard Review Plan rules? 25 MB. SCARBROUGH: I would imagine that it would O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
28 () 1 either be put into some instrument regulatory guide, if it 2 is considered that numbers similar to these intervals are 3 necessary; or it is possible that 1.33 could be used as a [} 4 vehicle for the operational aspects. 5 I do not believe that that is far enoagh down the 6 road. I believe it is still trying to be determined if 7 additional guidance on the measuring and test invervals is 8 necessary at all. 9 MR. SIESS: The standard does not cover that? 10 MR. SCAR BROUGH It does address measure and test 11 equipment in general for their proper calibration and such, 12 but it does not address the actual intervals themselves. It 13 sta tes more general terns to ensure that they are calibrated 14 en an interval that they do not go out of calibration, but 15 it is not specific intervals such as these-16 The 15th position once again was deleted partially 17 as a result of the expansion of 3.2 in the area of 0/A 18 involvement of verification activities. Further, we have 19 added some guidance to clarify the independence of the 20 personnel perf orming inspections from the personnel actually l 21 perf orming the work. 22 The 16th position, there was no change. 23 The 18th position was deleted. This concerned ( 24 precautions to be reviewed. It was looked at further and it l 25 was decided that the 3.2 standard clarifies when precautions O ALDERSON REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) 554-2345
29 (]) 1 need to be reviewed. It was felt that this small 2 cla rification was not necessary in the Guide. 3 The 19th position is similar. The system 4 procedures checklist, there is a provision in the Guide 5 where complex procedures must have checklists. It applies 6 to all procedures -- system procedures, maintenance 7 procedures -- theref ore, this position was considered 8 unnecessary. 9 The same for 20. Sin:e the ANS 3.2 Standard 10 applies to all procedures for the input of checklists, the 11 second position 28 was not necessary either. 12 (Slide.) 13 Position 17, there was no change in this O 14 position. It is a simple reference to the proper Regulatory 15 Guide. 16 Position 18 was revised to clarify that when we 17 expect the enumeration of immediate operator actions by 1F, plant personnel, the standard is a little general in that 19 area. We have tried to clarify that the title is not 20 necessarily what is important, but actually what is included 21 in the procedure. 22 Further down, much of the position was deleted 23 because of incorporations of this guidance into the standard. l () 24 Position 13, similarly part of it was deleted 25 because of inclusions of the provisions in the 3.2. ALCdRSoN REPORTING COMPANY,ING, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
30 (]) 1 Position 24 was deleted entirely. The reference 2 to Reg Guide 1.101, an earlier position, now makes this 3 particular position of the guido no longer necessary. 4 Reg Position 20, we have included some clarifying 5 guidance to make it more flexible so that instructions for 6 the restoration of the system are only necessary when the 7 systen is altered by the test. If there is going to be a 8 simple visual inspection with no hands-on involvement, there 9 was no need to include it in the instructions for its 10 restora tion. 11 Position 21 has been revised in a couple of 12 manners. It has been revised to delete the procedures which 13 were included in 3.2. Also, to clarify the guidance on 14 making sure that the licensed personnel, once they come back 15 f rom vacation or a long absence, are still proficient at 16 performing their duties. Also, we have included a provision f 17 f or procedures to be used in the training and qualification la of crane operators. 19 Position 27 was deleted in its entirety because of 20 the inclusion of this position into the standard itself. l 21 Position 22 is a new position which is included to 22 address plant procedures for heavy loads. We thought some 23 additional guidance in this area was necessary, and we have () 24 included it in that position. 25 (Slide.) O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
31 () 1 The last position, which is Position 23, is the 2 normal review of the "should" statements in the standards to 3 determine those which are significant enough to safety to be 4 con:. dered as "shalls". We have reviewed this list. Many 5 of the staterents were tied to another statement in the 6 introduction of Appendix A. With the "shall" statement or 7 the requirement in Appendix A, it made these others more or 8 less redundant and it was no longer necessary to include 9 these several other "should" statements in the guide, and we 10 have just summarized it. 11 That is the completion of the Reg Positions, and I 12 will be glad to answer any questions. 13 MR. SIESSs Thank you. O 14 What does an operator do with a "should" 15 statement? I mean a standard has some "shalls." It says, l 16 "Thou shalt do th' That you have to do. And some of 17 them have "may," which says, "If you want to do this, it is 18 all rich t ; there is nothing wrong with it; it is not 19 f orbidden." But what is really the meaning of a "should" 20 statemen t? That it is nice, but it is not necessary? 21 MR. MORRISON: You are talking about the standard, 22 now, not the Regulatory Guide? 23 MR. SIESSs Yes. I am talking about the () 24 standard. How does a person who is following a standard 25 respond to a "should" statement? O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
32 () 1 MR. MORRISON: A should" statement in a standard 2 such as ANS 3.2 indicates that it is a recommendation; it is 3 not a requirement. Requirements are indicated by "shalls." (} 4 MR. SIESSa I know, but do you ever go through and f check a licensee, and says Gee, this guy has only followed 6 the "shall" statements; the Licensee A has followed only the 7 "shall" statements, so I will give him a B grade; but 8 Licensee B has followed all the "shall" statements ard the 9 "should" statements, so I am going tu give him an A on 10 performance ? Is that the way you look at this thing? 11 MR. MORRIS 0Na I think the Office of Inspection 12 and Enforcement would have to answer that, but it is my 13 understanding that what they check compliance with is what 14 the licensee has committed to. That is precisely the reason 15 why we have identified some of the "shoulds" 2'. the 16 standards that have some substantive safety importance so 17 that when they commit to the Regulatory Guide, the "shoulds" 18 would be just treated as "shalls." 19 MF. SIESS: I am just trying to understand. Give 20 re a little bit of background. You write a standard and you 21 do not use "should" statements. We put in what people must 22 do, and that is it. And if we think it would be nice but 23 no t necessary, then that does not become a part of the 24 standard. So I do not quite understand how a person uses a 25 standard with "should" sta temen ts. O ALDERSON REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
33 O i NR. M0aRIS0x Some staneerds-writers de11 eve 2 that it is nice to have nonmandatory guidance in their 3 standards. 4 MR. SIESS: Is it the attitude that if I were 5 doing it, I would do it that way, but it is really not 6 necessary for you to do it tha t way? I mean, this is a 7 standards writer, a knowledgeable person who is supposed to 8 know what should be done, and he says: Well, this is 9 something I should do, but it really is not necessary for 10 everybody to do it? 11 MR. MORRISON: No, I do not think that is what 12 they are saying. I think what they are saying is that this 13 represents one acceptable way of doing it, but it is not O 14 necessa rily the only way. Therefore, we do not want to make 15 it a requirement in the standard. 10 MR. SIESS: I read "should" statements; they do +7 not say that, because most of these are proscriptive 18 standards. What you are prescribing is a performance is standard with a couple of alternate ways of meeting the 20 criteria. 21 MR. HORRISON: That is one of the problems that we 22 as rectulators have with it, in that ir most cases they do 23 provide only one alternative. If they provide more than one 24 siternative with "shoulds" and then have a requirement in 25 the statement that says you "shall" do one of these -- OLJ ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
34 1 MR. SIESSa Well, that is not a " shou]d"; that is 2 an "either/o r." 3 MR. MORRISON: We would have no problem with 4 that. 5 MR. SIESSa Bill, you have written standards. You 6 have sat on these committees, haven't you? 7 MR. MORRIS 0Na Yes, many times. 8 MR. SIESS: Wha t are you doing when you say 9 "should"? 10 MR. MORRISON: In most cases where they have 11 substantive safety importance, we impose the "shoulds." 12 MR. SIESS: Yes. So you think "shalls" but you 13 have written standards with "shoulds" in them, and you 14 approva them. 1S MR. MORRISON That is right. 16 MR. SIESSa I do not understand what it means. 17 MR. MORRISON: What means? What the standard ameans? Or why we approve it? 19 MR. SIESS: What the "should" means in the 20 standard. l 21 MR. MORRIS 0 tis It represents one way of l 22 accomplishing a particular activity, but not necessarily the 23 only way. They felt that bccause the standards writers, the O 24 concensus view was that there may be other alternative ways 25 tha t are also acceptable, and theref ore thi s -- O 1 r ALDERSON REPORTING COMPANY,INC. 406 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
35 ({} 1 MR. SIESS: I do not think that is right, because 2 if I picked a particular example you would have to explain 3 to me what that "should" statement is requiring; and if it 4 is saying that you have got to do something, then that is a 5 "shall." 6 MS. MORRISON: It is not r eq uirin g anything. 7 MR. ETHERINGTON: If they do not do a "should," d o 8 they have to explain why they didn't? 9 MR. MORRISON: Not unless we endorse it in the 10 Regulatory Position. 11 JR. SIESS: That makes it a "shall." 12 M :.. MORRISON: That is the whole point of putting 13 it in the Regulatory Position. 14 MR. SIESS: It just gives me a personal problem, 15 because I keep looking at my ACI 3.18 standard, and we do 16not have any "shoulds," and every once in awhile somebody 17 sticks something in the commentary which is like a"should," 18 and if it belongs in the standard we take it out and put it 19 in the standard. I never have understood the "shoulds." l 20 MR. MOP 9ISON: You will dislike Regulatory Guide 21 1.28 which endorses the NOA-1, then, because that has got a 22 whole section called the "Non-Mandatory Appendix." 23 MR. SIESS: I know. Let me ask scruthing else. I I () 24 find the words "important to safety." As of now, I guess 2 25 do not know what "i:n por t a n t to safety" means. I used to, t ALDERSoN REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2343
36 () 1but then somebody raised some questions. Do you know what 2 "important to safety" means? l 3 MR. MORRISON: Well, in our view, "important to (} 4 saf ety" means what our regulations state as general design 5 criteria in Appendix A to Part 50. 6 MR. SIESS: What is the status of the Staff's 7 ef fort to clarify "importan t to saf ety," " safety related," 8 and " safety grade"? I think those were the three terms you Gwere trying to get straightened out. 10 MR. MORRISON: Clarifying the relationship between 11 " safety rela ted" and "important to safety" is still within 12 the Staf f. We are waiting on the concurrence or 13 nonconcurrence from the Office of Fuclear Reactor O 14 Regula tion. 15 MR. SIESS. So in the interim you are using 16 "im po r ta n t to safety" as it has always been used, and that 17 is the Appendix A definition? 18 MR. MORRISON: Appendix A to the Regulations. 19 Right. 20 MR. SIESS: And that is broader than " safety 21 grade"? 22 MR. MORRISON: Some people have interpreted 23 t h a t -- O N, / 24 MR. SIESS: But it does include " safe shutdown," 25 "cooldown"; maintain safe shutdown, mitigate the O ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
37 1 consequences, et cetera? (} l 2 MR. MORRISON: There has been some disagreement as 3 to just what is the rela tionship between " safety related" O 4 and "important to safety," but I think everybody agrees tha t 5 there is a difference between " safety related" and 6 "important to safety." "Important to safety" is in a 7 broader sense. Everything that is " safety related" is 8 included in "important to safety." 9 MR. SIESS: Okay. 10 Eax, do you have a question? 11 MR. CARBONa No. 12 MR. SIESS: Now I would like to go on to another 13 item tha t I think is of some concerns that is, the 14 implemen tation. 15 In the first place, I am not quite sure I 16 understa nd the implementation schedule. In the second 17 place, there were considerable public comments on what was 18 perceived to be a rather short implementation schedule for 19 something that would be fairly comprehensive in the changes l 20 in the 0/A prooram. And in the third place, I have just i 21 finished retding a report from the Office of Inspection and i i 22 Enf orcement poin ting out some of the factors adverse to 23 saf ety that have arisen because of the many, many i () 24 requirements that have been placed on licensees in the past l 25 two years, and sometimes conflicting requirements with very ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345 _e. __m-. m
38 1 short deadlines. 2 As near as I can tell from the implementation, for 3 any new licenses that are submitted whether they are 4 submitted tomorrow or the next day, this applies. Is that 5 right? 6 MR. SCARBROUGH That is correct. 7 MR. SIESS: A new license application when it is 8 filed has to comply with this, as of the time they have 9 filed. So if somebody had an application ready to file 10 tomorrow, let us assume the date this is issued is October 11 1st, I will be generous. Okay? So if someone had an 12 application ready to file on October 2nd, they would have to 13 mee t thiss is that right? 14 MR. SCARBROUGH: It was writtGn with the intent 15 tha t everyone would at least have six months to come back to 1 16 the Quality Assurance Branc.. of NRR and provide a discussion 17 of the diff erent positions and how they were going to meet 18 them. I 19 MR. SIESS: That might be the intent, but let us 20 stick for a moment to what it says. "The method l l 21 described"-- and I am reading at the bottom of page 22-- l 22 "The method described in the Action Guide will be used in 23 the evaluation of the quality assurance programs for the () 24 operation phase of nuclear plants submitted by applicants 25 f or an opera ting license." OV ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 i
39 1 MR. CARSON: Chet, let me interrupt. The last {} 2 sentence on page 23 says, "no later than six nor.ths." 3 MR. SIESS: That applies to applicants that wi21 4 " receive" an operating license within six months after this 5is in place. 6 MR. CARBON: 1 ell, it says " licensees of operating 7 plants a nd". 8 MR. SIESS: I know. Yes. That says if you have 9 an operating plant right now, if you are operating right tonow, this says that you have six months after this is 11 issued. Now let us assume, to get some numbers, that this 12 is issued October 1st. That means you would ha ve until-the 13 1st of April in 1982 to be in compliance, or to file your 14 objections. That is if you have an operating plant. 15 Now the next part of that says that if you get an 16 ope ra ting license between October 1st and April of '82, you 17 will have six months af ter you get it to comply. Right? l 18 MR. SCAR BROUGH s Correct. l I 19 MR. SIESS4 But I am talking about somebody who is 20 going to file an application f or an opera ting license. That f 21 is about two years before you get it, if you are lucky. In 22 Diablo Canyon it was eight. But if you ace going to file an l 23 application f or an operating license, it seems to me this (]) 24 says tha t any time af ter the dite of issuance of this, if 25 you file an application, this applies. O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
40 () 1 So somebody who was ready to file by October 2nd 2 has got to go back to the drawing board and make his thing 3 comply when he files. Am I rig h t ? Is that what it says? 4 Mh. SCARBROUGH Right. They would have to, in 5 that case where they are just now filing their application, 6 they would provide a means with the Quality Assurance Branch 7 of NRR to determine those areas where they needed to change 8 their program to implement this guidance. Where they had i 9 two years, that would be a continuing process. 10 MR. SIESS: That one really does not bother me too 11 much. I just wanted to get it clear. 12 MR. RAY: May I comment in this area? 13 MR. SIESS: On those that are applying. We are O 14 going to get into the operating licensa. 15 MR. RAY: No, it seems to me I am confused as to 16 wha t the status is of plants to whom OLs have been issued 17 but they have not gone into operation yet. They have been 18 issued ; it is not that they are just applying for it. 19 MR. SIESS: That is what I was coming to next. 20 MR. RAY: Okay. 21 MR. SIESSa Now let us take the other extreme, the 22 plant that is operating. Now that I think is clear. 23 MR. SCARBROUGHs Sure. () 24 MR. SIESS: They have got six months after the 25 date of issuance. Right? fS () ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
41 [} 1 ER. SCARBROUGH: Right. 2 MR. SIESS: So if this is issued October 1st and 3 they have got a license, they are to be in compliance by 4 April 1st of 1982. 5 MR. SCARBROUGH That is correct. 6 MB. SIESS: Now I will come back to that one in a 7 minute. Now if they have not got a license but they have 8 got one under r, view, if they have an OL docketed, an 9 application docketed, and they get a license within six r l 10 months after this is issued, then they have another six 11 months to be in compliance. So if this is issued October 12 1 st and somebody gets their license on November 1st, they 13 have to be in compliance by May of next year. 14 If they do not get their license until April of 15 next yea r -- that is within six months of the October 1st they have until October of next 16 period, just barely 17 yea r. If they get their license in May, which is outside of 18 the six-month period, then when do they have to be in 19 compliance? The day they get it? 20 MR. SCARBROUGH: Right. Six months outside of the 21 issuance, af ter the issuance of the Reg Guide they would 22 have to be in compliance. 23 MR. SIESS: So if I got my license in April, I () 24 would have until October to be in compliance. If I got it 25 in May, I would have to be in compliance in May, the day I O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
42 1 got it, which is 6 months from now. [} 2 MR. SCARBROUGH: I would say that six months after 3 its issuance if a plant is going to receive its license 4 between now and April 1st, then they should by that time 5 have provided the input on what changes to their program are 6 going to be made. Anyone after April 1st at the time of 7 their issuance of their license, they would have to be in 8 com pliance. 9 MR. SIESS: So when this is issued you are putting 10 everybody on notice that they have to be in compliance. 11 MR. SCARBROUGH Right. 12 MR. SIESS: But if somebody is coming in right 13 a wa y with their license, where they have got six months to O \\/ 14 be in compliance, if somebody is going to be six months from 15 now, essentially they have sir months, too? But if you 16 stretch it out i om five months from now, you get eleven 17 months ? 18 MR. MORRISON: No, I am not sure. 19 MR. SCARBROUGHs That was not the intent. 20 MR. SIESS4 If you want to go to the blackboard 21 and put some dates up there, you can try it. I have tried l 22 it here. Assume this is issued on October 1st. Six months l 23 f rom that is April 1st.. () 24 MR. MORRISON4 Right. t 25 MR. SIESS: If I get the license on the 1st of () ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
f4 3 i 1 November, I have got until May. I am within that six-month 2 period; right? And I have got six months af ter I get the 3 license. O 4 MR. MORRISON : It is six months after its 5 issuance. 6 MR. SIESS: Yes. If I get my license in November, 7 I have got until May to be in compliance. It says that if I 8 get the license within six months, and I am going to take 9 two dates within the six months, one the first month and one 10 the sixth month. 11 MR. MORRISON: I see what the problem is. The six 12 months af ter its issuance. 13 MR. RAY: That is issuance of the Guide. 14 MR. MORRISON: It is the "its iss ua nce. " It 15 should be the Guide we are talking about, not the operating 16 license. 17 MR. SIESS: In what place? 18 MR. MORRISON: The second-to-the-last line where 19 it says, " implement Revision 3 to Regulatory Guide 1.33 no 20 later than six months after its issuance." The "its" there 21 ref ers to the Guide, not the license. You are getting the I 22 11-month example by reading that "its" to mean the operating l 23 license. 24 MR. SIESS4 So if I apply righ t a way, okay? If I 25 get my license on November 1st, I have got six months after O ALDERSON REPORTING COMPANY, WO, 400 VIRG,NIA AVE., S.W., WASHINGTON, D.C. 20014 (2G2) 554-2345
44 1 the Guide is issued. So th e close-off da te is A pril 1st of 2 '82, no matter when they get it. 3 MR. MORRISON That is right. They have got a 4 six-months ' period. 5 MR. SIESS: It seems to me you could find a better 6 way of saying that. 7 MR. MORRISON: We will clarify what "its" refers 8 to there. 9 MR. SIESS Everyone has to be in compliance six 10 months after the Guide is issued. Why don' t you just say 11 tha t ? 12 Now how extensive are the revisions to somebody 13 tha t is in compliance with the present regulations? Does 14 this require changes in tech specs? It requires changes to 15 operating procedures, doesn't it, shift turnover and all 16 that stuff ? 17 MR. SCARBROUGH: Their tech specs probably would 18 not change, because the changes to the Guide were made with 19 the intent of being consistent with the standard tech 20 s pe cs. 21 MR. SIESSa Take the plant that is not on standard 22 tech specs. You cannot change tech specs in six months, 23 a r.y wa y, can you? The Staff cannot process them. 24 MR. SILVER: I am Richard Silver from NRR. I just 25 vant to clarify whether there may not be -- not all plants O ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $54 2345
I 45 1 have standard tech specs; they do have standardized ) 2 administrative control sections of the tech specs. The 3 areas that are most likely to change, or that are going to O 4 be affec ted, I should say, as a result of this Reg Guide 5 would be the administrative control sections of the tech 6 specs Et Section 6. They a re standaraized. 7 MR. SIESS: Okay. The industry seemed to think 8 that this was going to be a fairly trauma tic and fairly 9 extensive change. They did not think six months was long 10 enough. 11 Now I guess there are two ways to look at that. 12 One is: If this was the only thing the industry had to do 13 in the next six months, how much of a job would it be? 14 The other is more realistic If they have to do 15 this on top of all the other things they are trying to do, 16 which is a fairly extensive list, then it is not exactly 17 sta tic. It keeps changing. There are new ones being 18 added. I understand a letter went out recently telling 19 eight plants to start recomputing a lot of things, and that 20 takes people. 21 So how realistic do you think the six months is in 22 view of all the other things that they have to do within the 23 nex t six months, or the next year, or the next three 24 months? 25 MR. SCARBROUGHs I believe there are many aspects t\\d ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
46 (]} 1 of the Guide which can be incorporated into their program 2 without much problem, since their tech specs would cover 3 that. Other aspects which would take longer because of Os 1 4 either manpower shortages or a more extensive revision of 5the program, we have discussed with the Quality Assurance 6 Branch of NRR will be reviewing these justifications with 7 that intent, that certain aspects would take longer than the 8 six months. So in cases where it was not feasible for them 9 to perform these in six months, they could get extensions. 10 MR. SIESSs Did you say "would take longer"? Do 11 you mean, just take longer for you guys to review it? 12 HR. SCARBROUGH Or take longer for the utility to 13 provide adequate changes to their programs. In certain O 14 cases there may be changes to their program which require, 15 in such a manner as they can perform them, longer than six 16 months and they can supply their justifications to the 17 Quality Assurance Branch for an extension beyond that six 10 months. 19 ER. SIESS: You 'ee, that was their stated reason s 20 for rejecting the comments on that. You are saying: We're 21 saying that you have to be in compliance by six months, but 22 you really do not have to be. You have to tell us what your 23 problems are, if you cannot be in compliance by six months. j () 24 Now that sounds generous, but that is a very 25 legalistic type of approach. This says: For some reason we O I l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 654-2345 -~.
47 1 think this ought to be effective in six mon ths. Now we know {} 2 you are not going to be able to meet it, but we are going to 3 say six months and then it is up to you to write us and tel3 .'.us why you cannot do it in six months. 5 Now there is an awful lot of stuff going out like 6 that. I see the letters that are going out. I see the 7 letters that are coming back. And I read the ICE report and 8 the plants taking about how many people are working on how 9 many different things, each one with a deadline. It seems 10 to me that it even takes a lot of skilled manpower time to 11 write the letter telling the Staff they cannot do it in six 12 months and asking for an extension. That is just time that 13 somebody could be devoting to something else that is 14 probably more important to safety than appealing the 15 deadline. 16 Is anybody in Standards, or at a higher level in 17 this outfit, coordinating all of these requests and getting 18 some idea of the manpower estimates? I do not see it in the 19 Value Impact Statement, because the Value Impact Statement 20 1ooks at this particular thing and does not relate it to all 21 the other things that are being done. The priorities are 22 not even there. 23 Is this more important than working on a Technical 3 24 Support Center? Is it more important than working on water (J 25 level instrumentation? I just do not see that anywhere. O ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
48 () 1 MP. SILVER: Richard Silver, again, from NRR. 2 There is some coordination that is being done, perhaps not 3 in the detail you are alluding to there; but when a Reg 4 Guide like this is issued, the next step would be for a 5 letter to go out from the Division of Licensing to the 6 licensees requesting implementation of the Guide, but the 7 Guide does not become effective for implementation when it 8 is issued. It is not like a rule. It is just guidance, and 9 somebody has got to implement that guidance. 10 The Division of Licensing would do that by a 11 letter. Now what that letter states would take into account 12 to some extent what else the Division of Licensing has asked r 13 these licensees to do. f') \\~' 14 MR. SIESS: Is the Division of Licensing the only 15 group that asks people to do things? 16 MR. SILVER: From NRR, yes. 17 MR. SIESS: ICE doesn't? 18 MR. SILVER : ICE would through their Bulletins and 19 Orders ; but from the licensing point of view -- that is, 20 revising licensing reform -- only the Division of Licensing l 21 would do that. 22 MR. SIESS: I am not talking about that. I am 23 talking about something that puts a burden on the licensee () 24 to do something with his skilled manpower. Does an IEE 25 Bulletin and Order require him to devote so many manyears to O ALDERSON REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024(202) 554-2345
49 [} 1 something? I believe some of them do. 2 Whatever happened to the R cubed C that was 1 3 supposed to look st these things and probably did not? 4 MR. SILVER: Well, for NRR there in an equivslent 5 to R cubed C, the Division of Safety and Technology, that 6 has a f ull Branch now that provides the staff work that used 7 to go into R cubed C decisions. 8 MR. SIESS: The trouble is, it is not just NRR. 9 ICE issues Bulletins and Orders. An awful lot of the TMI 10 things were done under Bulletins and Orders. The Commission 11 issues regulations, standards, rules, and those require 12 people to do things. A Reg Guide is not a rule; you are 13 rig h t. It does not require it until the licensee requires 14 it. Br t there is more than one place in this agency that e 15 puts requirements on a licensee. 16 Now I think we have been concerned about this for 17 some time, and that last ICE report certainly emphasizes 18 it. Now I am not complaining about this. This may be more 19 importan t to safety than some of the other things they are 20 doing. It may be more important to safety than installing 21 sirens out for five miles, or it may be more important to 22 saf ety than fixing that wa ter level instrumentation. I do 23 not know. And I do not think anybody here can tell me, () 24 because I do not think there is anybody here who has a broad 25 enough view of it. ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S W., WASHING 70N, D.C. 20024 (202) 554 2345
50 1 Maybe this should be implemented in three months. 2 Maybe it is that important. Maybe 90 percent of it is 3 already done and it is just changing paper, but tha t ta ke s 4 two manyears. 5 MR. MORRISON4 Well, Chet, I have to admit that 6 thare is nothing magic about the six months. Although I 7 think you indicated that industry opposed the six months, I E think we got comments from something like 21 utilities on 9 this Guide, only three of which raised some objection to the to six months. 11 Now the door is open to any of those utilities 12 that have some particular problem to come in and get an 13 extension on it. 14 MR. SIES54 That to me is a cop-out on it, in a 15 vay. It seems to me that the Commission ought to have some 16 g ro up, somebody, some way of deciding what is important and, 17 by golly, if it is important to be done in three months, 18 sa y : Look, we want this done in three months and you put 19 the people on it and take them off of something else. 20 As I sa), I am not saying that it should be 12 21 months and not 6. Maybe it should be 3 months and not 6. 22 M ay be it is more important to safety than anything else you 23 are doing, and the fact tha t only three of them complained-- C 24 again, reading the ICE report -- a lot of them have just 25 gotten to where they are either afraid to complain, or tired O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
51 1of complaining because it has not gotten them anywhere. {} 2 They just go ahead and commit to doing it, and plead for 3 more time. 4 This might be a case where you should accept a 5 plea for more time; I do not know. Who is sitting up there 6 looking at what is really important to safety? And wha t is 7 the probability on something like this that if you do not do 8 it righ t you get into more trouble than if you took a little 9 more time and did it right, or took the people off of 10 something else and put them on this to do it right? This is 11 what concerns me. 12 I am not going to pick on this particular one. It 13 is just that I cannot see anybody looking a t the whole 14 picture. 15 HR. SILVER: Again I might suggest, having been in 16 operating reactors for a number of years, that the judgments 17 may differ f rom plant to plant. The value impact of one 18 requirement or one change versus another may be different on 19 one plant as compared to another plant. You may not make 20 the same decision for each and every plant. 21 MR. SIE55: It is not just operating reactors, but 22 let us take them as a good e xam ple. Under the setup now, 23 there is a project manager for an operating plant; righd? I f^s) 24 He is not very high up in the hierarchy, but that is his s l 25 plant. MERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554-2345 l
52 (]) 1 Does he have somewhere a checklist of all the 2 things that that plant is in the process of doing, or has 3 been required to do? And can he or somebod y else put those 4 in some order of priority? 5 MR. SILVER: He generally would have a complete 6 list of everything that NRR requires that plant to do. In 7 terms of an order of priority, I do not think that that is i 8 too well formalized. 9 MR. SIESSt He does not keep track of what ICE has 10 told him to do? Sometimes ICE' sends out a bulletin that 11 says, "you should stase some calculations" and respond to it 12 in such-and-such a way? 13 MR. SILVER: The project manager is aware of the 14 Bulletins and Orders; but in terms of the manpower impact, 15 but quite honestly, it is highly unlikely that he has a good 16 f eel for the total manpower impact. 17 MS. SIESS: Well, this is a question that I think 18 tha t the ACRS is going to have to keep thinking about. I 19 think we started thinking about it when we wrote a letter on 20 the TMI Action Plan and said something about it being 21 unf ocused and should establish priorities. 22 Do you think you could fix up that implementation 23 so tha t it says what you mean? (m) 24 MR SCARBROUGH: Certainly I think we can. 25 NR. MORRISON: Yes. O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
i 1 53 /'T 1 MR. SIESS: Because I think, from what I V 2 understand now, this is a backfit, It is a retrofit, 3 f orwa rd-fit, all the categories, and everybody is expected 4 to be in compliance six months.fter the date of issuance or 5 give a good reason why not. 1 6 MR. MORRISON: That is correct. 7 MR. SIESS: That should not be hard to say. Did 8 the lawyers write the implementation section for you? Or 9 did you write it? 10 MR. SCARBROUGHa The Editing Section writes that, 11 I guess in conjunction with their knowledge of the legal 12 aspects, and ELD is involved. 13 MR. SIESS You still have not gotten me convinced 14 that you have any editors. They are getting a little 15 better. 16 (Laughter.) l 17 MR, MORRITONs Ted Newman is not down here today 18 to hear that. 19 MR. SIESS4 I still keep seeing " necessity" where 20 "need" is the word tha t could be used, but they are getting 21 better. 22 Gentlemen, are there any other questions? Max? 23 MR. CARBON: Yes. I have a small question I would () 24 like to ask Bill for just my own enlightenment. I have not 25 been involved in the Standa rds writing, and I see here that O ALDERSON REPORTING COMPANY,;NC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
54 (]) 1 the ANS 3.2 vent through about five drafts in about a year. 2 Is that typical? 3 MR. MORRISON4 Is the question concerning th e ) 4 number of draf ts we went through? 5 MR. CARBON: Yes. 6 MR. MORRISON: No, I think, at least based on my 7 own ' experience, that is probably more than the average. I 8 think that -- and maybe Steve has been closer to some of the 9 standard-writing in this pa rticula r standard -- but I think 10 th a t that can be explained somewhat by the urgency in 11 getting this revision out. It was started shortly after the 12 TMI accident, and to factor in all the lessons learned on 13 t ha t on a very rapid timef rame, co tha t I think that there O 14 was more backing and filling under that type of situation 15 than you would have if the ntandard had been developed in 16 the more routine manner. 17 MR. SIESS: How many meetings did they have in 18 order to get the five draf ts? 19 MR. MORRISON: I do not have any idea. 20 MR. RICHARDSON 4 I think there was on the order of 21 five or six meetings. Some involved the Working Group, 22 which is a four-man operation; also, ANS-3, the volume which 23 the subcommittee helped establish marked up the draft around () 24 the table in a somewha t similar f ashion to what we have 25 done. O. V ALDERSON REPORTING COMPANY,INC, 400 VIRGlhlA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
55 1 MR. SIESS: Each one of those was ballotted? (} 2 MR. RICHARDSON: Each one was reviewed at the 3 ANS-3 subcommittee meeting, but not each one of those was 4 ballotted to the Concensus Body, though. I guess two 5 separate sta,dards were ballotted at the NUPPSCO level. 6 MR. KIESSEL: My name is Dick Kiessel. I am eith 7 ILE. 8 Bill, some of the ANSI writing groups issue a new 9 draf t every time it moves up the concurrence chain. In 10 o ther words, the Working Group might be working on Draf t 1, 11 the subcommittee on Draft 2. Is this also true of ANS? 12 Tha t might account for the five drafts. 13 MR. MORRISON: That is true, but the question is 14 whether or not -- what draf t are we up to now? Eight or 15 nine? That is higher than the average. I think the average 16 would be more like draf t four or five by the time we not 17 through the concensus group. l l 18 MR. SIESS: Some outfits will change a draft l l 19 number every time they change a word. 20 MR. MORRISON: Yes. That is the other thing. 21 MR. SIESS. But if you have met five or six times, 22 you have gone through quite a few draf ts. I 23 MR. RICHARDSON: Fome of those were very (]) 24 con troversial, as you can imagine f rom the input. 25 MR. SIESS: That is the best kind. OV 1 ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVd., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
56 (]) 1 Are there any other questions? 2 (No response.) 3 hB. SIESS: The Staff has proposed that we concur 4 in the Position on this. I would propose that we do. I 5 think, though, that we probably need to say something a 6 little more formally to somebody, either Mr. Dircks or the 7 Commission, about this prioritizing of scheduling 8 deadlines. I am not sure that i'. is proper to attach it to 9 this particular thing. I think it is something I would like 10 to bring up to the Full Committee. 11 So I would propose to the Full Committee that we 12 concur in the Position. Is there any objection? 13 (No response.) 14 MR. SIESS: Who would be an appropriate person to 15 address our concerns to? I do not think it is just the 16 Standards people. 17 MR. MORRISON: Are you asking me? 18 MR. SIESS: It is not just Licensing. 19 MR. MORRISON: I think it has to be at least to 20 the EDO level because, as you correctly point out, it is 21 more than one office. 22 MR. SIESS: You see, we just wroto something to 23 the EDO about the water level 131ng, the timing on that. It () 24 does keep coming up, and we cannot get everything done at 25 once and done right. I think that is a fact of life we have O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
57 1to recognize. And if we do not know what is iniportant, I do {) 2 not know who is going to tell people what is important 3 "we" being the Commission. O 4 Thank you, gentlemen. We will take a short 5 break. 6 MR. RAY: da y I make a comment? 2 7 MR. SIESS: Yes, you may. 8 MR. RAY: I would like to commend the efforts of 9 your group, though, for having done what I conceive as a 10 very good job of a very complicated revision. It was not 11 dif ficult to follow, and for me that is quite an 12 accomplishment. 13 MR. MORRISON: Thank you. () 14 MR. SIESSs They are getting easier. 15 We will take 10 minutes, and we vill do CCH next. 16 (Recess.) 17 MR. SIESS: The meeting vill reconvene. 18 The next item on the agenda has to do with changes l 19 in the rules, not a Reg Guide. These are changes -- I guess 20 there is a change in the body of Part 15, and that is l 21 Appendices G and H. 22 I would like to call to the attention of the 23 subcommittee members tha t this has been reviewed by one of f]) 24 our consultants, Mr. Spencer Bush, who I think it is safe to ( 25 say is an expert in this area, at least those par;ts of it f l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
58 1 that pertain to the ASME Boiler and Pressure Vessel Code. 2 Of course he had looked a t the previous revisions, which 3 were looked at in June of 1979. Things move very rapidly 4 these days. 5 Mr, Bush not only had no objection to the 6 revisions in Appendices G and H, he thought they were quite 7 commendable. 8 Now I am sure that Dr. Randall is prepared to make 9 a presentation, and I wonder if you would rather -- How long 10 a presentation do you have? 11 MR. RANDALLs Actually, I do not have any formal 12 presentation. 13 MR. SIESS: Well, good. We will get on with 14 questions, then. 15 MR. RANDALL4 If you want a background and a 16 runthrough of highlights, I can do it. 17 MR. SIESS: Let's first see how much we can do 18 sim ply by questions, if people have any. If not, we will 19 ask you to at least give us a little background on it. 20 Does anybody have any questions? Harold? 21 MR. ETHERINGTON: Did you want to take them up as 22 we are going through it? 23 MR. SIESS: I really did not intend -- h 24 MB. ETHERINGTON: Well, then, I will take them up 25 right now. O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554 234F
59 1 MR. SIESS I do not really see any need to go (} 2 through it item-by-item, except to take up questions that 3 you might have about items. O 4 MR. ETHERINGTON: Then I have an item on 5 definitions. The 30-foot pound level for determining the 6R ndt 7 MR. SIESS4 Have you found that, Neil? 8 MR. RANDALLs Yes. 9 MR. ETHERINGTON: Appendix G of the Code, ASME 10 Code, is based on an R which is the highest of the ndt 11 drop-weicht ndts, the 50-foot pound tempera ture minus 60 12 degrees, and the 30-mil lateral expansion minus 60 degrees, 13 isn ' t it ? ( 14 MR. RANDALLs Yes. 15 MR. ETHERINGTON: Now they give a curve based on 16 their R with a 30-mil expansion, or, no, a 30-foot ndt 17 pound level, and you have a different R and their curve ndt 18 would not apply. 19 MR. RANDALLs No, we continue to use the ASME Code 20 T definition of R for the unirradiated material. 21 NDT HR. ETHERINGTON: All right. That will be fine, 22 then. 23 How do you get the shift when your original () 24 material was tested for the 50-foot pound reading? 25 MR. RANDALLs '4 hen they got that tect, they were ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASMNGTON. D.C. 20024 (202) 554 2345
60 {} 1 required to v't a full sharp energy curve. 2 MR. ETHERINGTON: So they have to go back to it 3 and get 4 MR. R A ND A LI,a They have to go back to it and be 5 precise, and the 30-foot pound level is the measure of the T 6 delta 3 that gets added to the initial. NDT 7 MR. ETHERINGTON: So this 30-foot pound shift 8 refers back to the 30-foot pound shift -- the 30-foot pound 9 level that they get from going back to their old curve? 10 MR. RANDALL: Tha t is correct. 11 MR. ETHERINGTON: Okay. 12 MR. SIESS: They all had that curve? 13 MR. RANDALL: They all had that curve. They got 14 it in the process of doing their surveillance. 15 MR. ETHERINGTON: Well, now, let me suppose that 16 ur. der the old scheme the most conservative of three 17 determinations was the level -- wait s moment. Then they 18 will just neglect the old definition of the Code for the 19 R ? You are making, in effect, a new definition f or ndt 20 R different from tha in the Code? ndt 21 MR. RANDALL: No. 22 MR. ETHERINGTON: Well, the definition of th e 93 R in the Code is the most conservative of the R ndt () 24 drop weight, a 50-foot pound temperature minus 60 degrees 25 f or a 30-mil lateral expansion minus 60 degrees. That gives O ALDhRSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $5' 2345
i 61 1 them T for a reference ndt. O-ndt 2 MR. RANDALLs Correct. 3 MR. ETHERINGTON: Your reference ndt will be 4 necessarily different. Supposing, for example, their most S conservative value was derived from their 30-mil 6 determination? 7 MR. RANDALL: Well, as I have said 8 (Mr. Randall goes to the chalkboard.) 9 MR. SIESS: You can erase all of that if you want 10 t o, Neil. It is left over from last month. 11 MR. ETHERINGTON: I am not really quarreling with 12 this. I am just trying to establish that we do have 13 something less conservative than the ASME, and that may be 14 all righ t.- 15 MR. RANDALL: For unirradiated material the CvT, 16 energy curve versus tem pe ra ture, is ob tained -- and in 17 addition, drop weight test results are obtained by 18 f ollowing those Code paragraphs of nd x what you are looking 19 a t (drawing on the chalkboard). I 20 Following those paragraphs, an initial R NDT 21 l 1s obtained, and we invoke the Coda on that. We have not 22 changed tha t. However, for an operating reactor one has to 23 t T O' 24 h a ve R for the end of the next service period, say NDT 25 the next two years or five years. And for that, this is per the Code, R for an operating plant is the sum of the NDT ALDERSON REPORTING COMPANY, INC, f l 400 VIRGINIA AVE., S.W WASHtNGTON, D.C. 20024 (202) 564-2345 l 1
62 T (') 1 initial and a delta R which we call in the techs the A/ NDT 2 adjustment of reference temierature. 3 It is the delta which is obtained from an 4 unirradiated curve and an irradiated curve at the 30-foot 5 pound le vel. That operation you see is not covered in the 6 curve. They do not tell you how to account for radiation 7 damage. The regulation sa ys4 Add the delta to the initial 8 T to get R for the end of the service period they have 9 NDT in mind. 10 MR. ETHERINGTON: Well, in (F), then, am I to 11 T 12 understand that this means by adding to R as NDT 13 determined by MB, whatever the hell it is? 14 MR. RANDALL: Yes. 15 MR. SIESS: That is defined in (E). 16 ER. ETHERINGTONs That means the most conservative 17 of three. 18 MR. SIESSs Yes. i 19 MR. ETHERINGTONs Then you add on the shift as 20 determined f rom your old curve and your new curve at the 21 3 0-f oo t pound level? 22 MR. RANDALLs Correct. j 23 MR. ETHERINGTON Don't you think you should say () 24 t he R Well, does it define in your definition tha t ndt 25 it is -- MR. SIESS: That is in "(E)," Harold. ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
63 (]) 1 MR. ETHERINGTON: Does it define it as referring 2 back to the MB number? 3 MR. SIESS: Yes. 4 MR. RANDALL: Yes. 5 MR. ETHERINGTON: Where is that? 6 MR. SERPANs (E) does that now. T 7 MR. SIESS: Harold, in (E) it says that R NDT 8 is defined in the ASME Code. 9 MR. ETHERINGTON: Okay. 10 MR. SIESS4 Now, Neil, I think what is confusing 11 here a little bit in (F), the last phrase which says, 12 " measures at the 30-foot pound level," okay? That refers 13 only to the temperature shift. O 14 MR. RANDALL Cctrect. 15 MR. SIESS: And tne way it is written in there, it 16 could apply to the whole sentence. 17 MR. RANDALL: I see. 18 MR. SIESS: Now let me try something. Suppose it 19 T said By adding to R the temperature shif t, 20 NDT measured at the 30-foot pound level in the average sharp 21 curve for the irradiated? Would that help? 22 MR. ETHERINGTON: I think the discussion has 23 helped. Now I am not clear whether it is the wording that () 24 bothered me or -- 25 MR. SIESS: But it is the temperature shift that O ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 5E4-2345
64 () 1 is measured at the 30-foot pound level; right? 2 MR. RANDALL: Yes. 3 MR. SIESS: And, you see, when you put that at the 4 end of the sentence, that could refer back to -- T 5 MR. RANDALL: R itself. Fine. I can do NDT 6 tha t. 7 MR. SIESS: It is a minor thing. It may not be 8necessary, if everybody understands it after it is 9 explained. Do you understand it af ter it is axplained, 10 Har old? ,1 MR. ETHESINGTON: Yes. 12 T MR. SIESS: R is the AFME Code value, 13 ND1 {} which is the lesser of whatever. It is only the temperature shift that you are now switching to the 30-foot pound 15 level. 16 MR. RANDALL: Tha t is correct. 17 MR. SIESSs If everybody understands it, don't 18 louse up the thiag with tha t. 19 MR. ET HER IN GTON : I have another one. Shall I go 20 on? 21 MR. SIESS: Yes, go ahead. I 22 MR. ETHERINGTON: Section IV, Item 2, " Methods of 23 A na ly s is. " () 24 Now Appendix G of the Code really only gives a 25 true analysis for the shell with the quarter thickness ) t ALDERSON REPORTING CoMFANY,INC, I 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 I
65 {~ } 1 crack, and it give an indication of how to proceed from the 2 point of discontinuity. This is intended to cover both, I 3 suppose? O-i 4 MR. RANDALLs Yes. 5
- 33. ETHERINGTON:
The whole of the Code. Now you 6 add on this item, which I think is quite important, that you 7 should -- because you have to bolt the flange down tight, 8 you have to do that when it is a cold, in effect, or you 9 must protect tne things there. 10 Now when we come on to three, you say that it 11 should be Item 2 plus 40 degrees, isn't it? 12 MR. RANDALL: Yes. 13 MR. ETHERINGTON: Supposing the flange conditions 14 were controlling. Do you want to add 40 degrees onto that, 15 too ? 16 MR. RANDALL: Yes. 17 MR. ETHERINGTON: Then I do not understand the 18 purpose of the f urther statement, "nor lower than the 19 minimum permissible temperature for the in-service system 20 h yd rosta tic pressu re test. " That would be your T of ndt 21 the flange region, plus 160, wouldn't it? 22 MR. RANDALL4 Are you talking about for PWRs? 23 MR. ETHERINGTON: I am talking PWBs. () 24 MR. RANDALL4 Yes, which do use the minimum 25 permissible temperature of in-service system hydrostatic Oa ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
66 1 pressure. 2 MR. EIHERINGTOE If that were controlling, that 3 would now become T plus' 160 degrees. Is that what you () ndt 4 intend, if that were controlling in the non-critical 5 condition? 6 MR. RANDALL: Yes. That's correct. 7 MR. ETHERINGTON: I did not think you intended to 8 do that. Do you intend to add on 40 to that, as well? 9 MR. RANDALL: Yes, I did. I am a nswering without 10 being sure I understand your question. Let's be sure I do. 11 MR. ETHERINGTON: Okay. Then what does it mean by 12 "nor lower than the minimum permissible temperature for the 13 in-service system hydrostatic pressure test"? That would be 14 on the ndt plus 120, wouldn't it? Under what conditions 15 would that second phrase apply? I can't conceive any 10 condition. 17 MR. RANDALL: For a PWR 18 MR. ETHERINGTON: Yes, we are talking PWRs. 19 MR. SANDALL: The minimum permissible temperature 20 for the in-service system hydrostatic pressure test is 21 calcula ted using the Code's Appendix G. 22 MR. ETHERINGTON: All right. But when would this 23 have any significance? If the flange condition is () 24 controlling in the noncritical condition, you add on 40 25 degrees, or 60 degrees? What is it? 40 degrees? O ALDERSON REPORTING COMPANY,INC, 400 VinGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
67 (]) 1 MR. RANDALLs Let's see if I can draw it up here 2 with a diagram. 3 (Mr. Randall goes to the chalkboa rd. ) 4 This is a pressure-temperature diagram (drawing on 5 the chalkboa rd ). Following the rules of Appendix G of the 6 Code, one gets this upsvept curve for noncritical. And the 7 rules say you add 40 degrees to that for critical 8 operation. C Now before I get any further with that, at a 10 pressure of -- in the previous paragraph we were talking 11 about, paragraph two says -- at a pressure of .2, I will 12 call it PSSH, the pre-service system hydro, we ask that-- T 13 this (indicating) is R for the flange material-- (^] NDT 14 t h a t when they get to this (indicating) pressure, they 15 should be at least at 120 degrees. 16 HR. ETHERINGTON: I was not concerned with the 17 hea tup; I was just looking at -- well, let's suppose we are 18 right up at critical temperature. You are right up at 19 operating pressure. 20 MB. RANDALL: Well, let me go through it a little l 21 bit. So that instead of this curve (indica ting) governing, I 22 there will be a step like so (indicating) in the noncritical 23 curve. () 24 Now f or critical opera tion, they have to be at 25 least 40 degrees above this. And for PWRs, they also have O ALDERSON REPORTING COMPANY,INC, W VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
68 /~) 1 to exceed the pre-service hydro temperature -- I am sorry, (, 2 the in-service hydrostatic service temperature as described (y3 3 there in the end of the first sentence of paragraph three. 4 MR. ETHERINGTON: Maybe I am not getting 5across-- 6 MR. RANDALL And that might or might not be 7 higher than that, depending on how much radia tion damage 8 they have had and how much shift this is. That (indicating) 9 might govern, or that might be less than this. 10 MR. ETHERINGTON: No. I have not gotten my 11 problem across. I am finding it difficult to express it. 12 Supposing we are at f ull pressure and opera ting conditions. 13 Supposing the shell is controlling. O 14 MR. RANDALL: Right. 15 MR. ETHERINGTON: Then the hydrostatic pressure 16 does not enter into it. You just add on 40 degrees. 17 MR. RANDALL: Then vou would be a t a location like 18 tha t (indicating). Yo u j ust add -- 19 MR. ETHERINGTONs You just add 40 degrees onto the i 20 shell, and the flange condition does not enter into it. It 21 is not there. We have said Let's suppose that the shell l 22 is controlling. 23 MR. RANDALLs Yes, which means in effect that you () 24 have a sensitive steel and a fair amount of radia tion l 25 damage. ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345 L
69 i 1 MR. ETHERINGTON: Yes. 2 MR. RANDALL: In a modern plant which is low 3 copper, insensitive velds, and not too much age, this pair 4 of curves (indicating) will be displaced to the left 5 (indicating). Do you see where I am looking here? 6 MR. ETHERINGTON: I am trying to find out whether 7 the minimum permissible tempera ture for in-service 8 hydrostatic pressure tests means anything at all. It is my 9 f eeling that it doesn't mean anything. 10 Let me just start again. Supposing the shell is 11 controlling. 12 MR. RANDALLs All right. 13 MR. ETHERINGTON: Then by hypothesis the minimum 14 permissible temperature for in-service hydrostatic pressure 15 tests does not enter into it, because that is not 16 con trolling. 17 MR. RANDALL: Yes. That controls at low ( 18 p re ssures. 19 MR. ETHERINGTON: Oh, I see. At low pressures? 20 But then we are talking about being critical. You are not l l l 21 critical at low pressures, are you, in the pressurized water l 22 rea ctor? l 23 MR. RANDALL: In general, they do not go O 24 critic t-25 MR. ETHERINGTON: Then it has some significance O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
70 1only if you are critical but at low pressure. ) 2 MR. RANDALL: That is correct. 3 MR. ETHERINGTON: If you are critical at high 4 pressure, this phrase has no meaning at all. 5 MR. RANDALL: If the beltline is controlling, a 6 PWR curve would look like that (indicating). 7 MR. ETHERINGTON: I can see that, if we are 8 talking about a critical condition which is below operating 9 pressure, all righ t then I will buy that. But it is the to most improbable kind of a condition, isn't it? You are not 11 running the reactor below operating pressure. 12 MR. RANDALL: I am not enough of a systems man to 13 say, though, that they would never do that. 14 MR. ETHERINGTON: Okay. Then you definitely mean 15 tha t if the flange region is controlling, you want to add 16 the 40 degrees on? 17 MR. RANDALLs Yes. 18 MR. ETHERINGTON: Is tha t righ t? 19 MR. RANDALL: Right. l l 20 MR. ETHERINGTON: At full operating pressure? At 21 f ull operating conditions? 22 MR. RANDALL: Yes. Nov if the flange is 23 con trolling, we come back to the other diagram. If you have () 24 a case where the flange is controlling, that really means 25 that -- and I have to d ra w this out of scale -- that the 120 l O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.O. 20024 (202) 554-2345
71 1 degrees is there. And because there is not much radiation {} 2 damage, the curves from the code are to the left of this 120 3 degree step (indica ting ). O 4 MR. ETHERINGTON: Yes. This doesn't bother me. I 5am not interested in the diagram. I understand that very 6 w ell. 7 MR. RANDALL: In that case we would add the 40 ~ 8 degrees to the 120 for the criticality line. 9 MR. ETHERINGTON: You see, my problem is: Here it 10 says ""nor lower than the minimum permissible temperature 11 for the in-service system hydrostatic pressure test." Nov 12 if we are only talking in terins of an operating reactor, 13 then it should read "nc t lower than the animum permissible 14 temperature for th e in-service system hydrostatic pressure 15 t es t plus 40 degrees," if that were controlling at full. 16 pressure. Au long as it did not say 40 degrees there, I did 17 not know if you wanted to add the 40 degrees on if it were 18 con trolling. 19 MR. RANDALLs We do not add the 40 degrees. 20 MR. ETHERINGTON: You do if it is controlling in 21 ' h e full operating condition. 22 MR. PANDALL: There are two cases here. 23 MR. ETHERINGTON: Yes, there are, and you have not (]) 24 really separated them. 25 MR. RANDALL: Well, we went through it on the O v ALDERSON REPORilNG COMPANY,(NC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
2 72 {~} 1 bla ckboa r.'d. 2 MR. ETHERINGTON: You have not separated them in 3 the wording. You took exception to my statement, I think. 4 MR. RANDALLs I will put the PWR back up. It says 5 that here is a noncritical curve from the Code 6 (indica ting ). Here (indica ting ) is the 40 degree delta. 7 But for a PWR, the criticality line in this region is 8 determined by that temperature for in-service hydros. And 9 it is not that tempera ture plus 40. This is the 40 10 (indicating ), but this (indicating) is the in-service 11 tempera ture. 12 MR. SIESS: So for the -- 13 MR. ETHERINGTON: In other words, if the flange f% 14 condition is controlling, then according to your statement 15 you should add 40 degrees onto it regardless of when it 16 happens, unless you specify otherwise. Your opening 17 sta temen t isa "When the core is critical for other purposes 18 other than low-power physics tests, the temperature of the 19 reactor vessel shall tot be lower than 40 degrees above the 20 minimum permissible temperature in paragraph 2." 21 Well, then if the flange condition were 22 controlling, then you would have to add the 40 degrees onto 23it in accordance with the sta temen t. If you do "at mean () 24 t h a t, you have got to say it in diff erent words. 25 MR. RANDALLs Well -- wl ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
i 73 1 MR. ETHERINGTON: Do you understand wha t I am 2 trying to say, Chet? 3 MR. SIESS: I am not sure. Where is the 40 0 4 degrees? Is that in 27 5 MR. ETHERINGTON: That is in 3. 6 MR. SIESS: That is in 3, but the controlling is 7 in 2; right? 8 MR. ETHERINGTON: But then 3 is referring to the 9 condition in 2, to MR. SIESS: You add 40 degrees above what is in 11 27 12 MR. ETHERINGTON: That is right. 13 MR. SIESS: And when the flange controls -- 14 MR. ETHERINGTON: If the flange controls, you have 15 to add 40 degrees to it, and that is agraed to be the 16 intention. 17 MR. SIESS: And that is already 120; right? 18 MR. RANDALL: Let me try once more. l 19 MR. SIESS: What you need is a logic table. t 20 MR. RANDALL: Yes. There are several cases. 21 MR. ETHERINGTON: You really need to separate the 22 two cases, I think. 23 MR. SIESS: I think you have a logic problem 24 here. If you make yourself a logic table, see if you always 25 come out in the right place. O ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
74 1 What Harold is postulating is that you are at 2 operating pressure and the flange controls, which is not 3 likely but it is not ruled out. O 4 MR. RANDALL: We have done both cases, but let us 5 tak e that one. 6 MR. SIESS: Is that right, Ha rold ? 7 MR. ETHERINGTON: Tha t is right, or even at any 8 pressure, for that matter, but let's stay with the operating 9 pressure. 10 MR. SIESS: Under 2, what does 2 state for that 11 case? 12 MR. RANDALL: You want one where the flange 13 controls even for operating pressure? () 14 MR. SIESS: Well, in 3 we saw what happens when 15 the flange controls; right? 16 MR. RANDALLs Right. If that is true, there is 17 operating pressure (indica ting ). T 18 MR. SIESS: And -hat is 120 f 40 from R ? NDT 19 T l MR. RANDALL: That is right, from the R 20 NDI all that flange material. 21 MR. SIESS: The 120 comes out of two, and the 40 22 comes out of three? 23 MR. RANDALL: Yes. Now that is at operating (]) 24 pressure. 25 MR. SIESS: That is for anything above.2? ) l ALCERSON REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
75 ("s 1 MR. RANDALL: Yes. Now they also have to check, (_) 2 however, in this pressure range -- Well, you asked what 3 happened to the criticality line down in here (indicating), O v 4 just to complete the diagram. 5 In this region (indica ting ) for this ca se, it only 6 has to meet this phrase in the middle of paragrah three, the 7 minimum permissible tem pera ture for the in-service hydro. 8 MR. SIESS All righ t. Now where would that be? 9 MR. RANDALLs Now for this case, since there isn 't 10 much radiation damage, that would almost certainly be over 11 here (indicating) somewhere. 12 MR. SIESS: So what Mr. Etherington was saying, 13 t ha t that would hardly ever govern, is true. O (/ 14 MR. RANDALL: I agree that PWRs do not generally 15 go critical in that region, but we have covered the whole 16 diagram is what I am saying. 17 MR. SIESS: If you are above the.2p in critical. 18 MR. RANDALL: And the flange is controlling all '9the way. 20 MR. ETHERINGTON: It seems to me that you could l l 21 take out "nor lower than the minimum permissible tempera ture 22 f or in-service system hydrostatic pressure test" and you 23 have not lost a thing. ('J i 24 MR. SIESS: Under what cases would that control? l 25 Only if you were -- O) u. ALDERSON REPORTING COfdPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
76 (} 1 MR. RANDALL: Only if a PWR -- 2 MR. SIESS: -- critical below.2p? 3 MR. RANDALLs -- vanted to use nuclear heat below 4.2p. 5 MR. ETHERINGTON: d controlled then, you would i.ecause that is part of the 6 have to add the 40 degrees m 7 system, by the wording. As long as it is controlling at any 8 time, you add 40 degrees onto the section under paragraph E two temperature. 10 MR. SIESS. Only when you exceed 20 percent, isn't 11 it, Harold? 12 MR. ETHERINGTON: Yes, only when you exceed 20 13 percent, but you would not be critical under 20 percent. 14 MR. SIESS: So the in-service system pressure 15 would not have 40 degrees added to it below .2. 16 MR. ETHERINGTON: Yes. That I would concede. 17 MR. SIESS: Your point is that you do not think i 18 this really puts an additional limit on. 19 MR. ETHERINGTON: It does not put an additional 20 limit on; that is correct. 21 MP. SIESS: Does this not apply to BWRs, also? 22 MR. ETHERINGTON: Yes. I was leaving the BWRs out 23 because we are talking mostly about FWRs. () 24 MR. SIESS: The next sentence goes on to make an 25 exception for BWRs. I would assume tha t everything ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
77 1 preceding that sentence applied to BWRs. {} 2 MR. ETHERINGTON: Yes. 3 MR. RANDALL Yes. O 4 MR. SIESS4 Your point is that it does not add 5 anything, but it does not subtract anything? 6 MR. ETHERINGTON: It does change something, 7 really. If the Staff position is in this: For whatever 8 tha t applies to, you don't add 40 degrees on? 9 MR. RANDALLs That is correct. 10 HR. ETHERINGTONs What it applies to, I really 11 cannot say. 12 MR. RANDALL It applies to a PWR that chooses to 13 go critical. 14 MR. ETHERINGTON: Below 20 percent pressure? 1 15 MR. RANDALLs Right. 16 MR. ETHEP.INGTON: I think that is so hypothetical 17 t ha t the water is kin;t of muddied here a little. Okay, if 18 tha t is the intention, and if people will understand t r.a t, I 19 have no further comment. 20 MR. RANDALL: The exception for EWRs is an 21 exception to that clause which says that ir. tha t ( 22 low-pressure region they only need to be 60 degrees above T 23 the R of the flange. NDT () 24 MR. ETHERINGTON: You see, it was this phrase that 25 left me in doubt whether you really wanted to add the 40 O l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
78 1 degrees on when it was the flange that was controlling. I 2 agree with you that it is logical to add it on, but this 3 phrase, where there was no 40 degrees, made me wonder O 4 whether you really wanted to put the 40 degrees on. 5 MR. SIESSs Okay? 6 MR. ETHERINGTON: I think it could be improved a 7 lot. 8 MR. SIESSs It could be clearer. 9 MR. RANDALLs Let me think about the wording and 10 see if I can improve that. 11 MR. ETHERINGTON: Now let me pick up one more 12 ite m, then, V(B), "shall be designed to permit a thermal 13 annesling treatment to recover material toughness properties 14 of ferretic materials in the reactor vessel beltline." 15 The committee has always asked applicants: Will 16 you be able to anneal the vessel? And the applicants have 17 said: Yes -- 18 MR. SIESS: I'm sorry, Harold? Which section? 19 MR. RANDALL IV(B). 20 MR. ETHERINGTON: V(B). 21 MR. SIESS: I am reading V(B), and -- 22 MR. RANDALLs It is IV(B). 23 MR. ETHERINGTON: I am reading from old one. Is 24 that not the same? 25 MR. RANDALLs Look on page 11 on the clean copy. O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554 2345
79 1 MR. ETHERINGTON: Oh, yes, I see, "IV." I thought 2 the (B) was -- all right. 3 MR. SIESS: Yes. It is IV. O 4 MR. STHERINGTON: "Shall be designed to permit 5 thermal annealing". The committee has always asked 6 applicants, "Can the vessel be annealed?" And the 7 applicants have said "yes," and the Committee has not probed 8 any further. 9 MR. SIESS: It was a commitment. 10 MR. ETHERINGTON: Yes. 11 MR. RANDALLs It was meant a s a warning s If some 12 d ay we get to the place where we jnsist that you anneal, do 13 not tell us that you were not warned. () 14 MR. ETHERINGTON: I understand. But now two 15 temperatures have been mentioned f airly prominently in the 16 literature for stress relieving, or annealing, 650 degrees 17 Fah renheit and 750, These are quite different animals. 650 18 you would get to by pressurizing the reactor and letting it 19 reach saturation temperature up around 600, 650, without any 1 20 great modification as long as the rest of the system, the 21 seals, the pumps, and so or., were no t an y problem. l 22 MR. SIESS: What pressure would that be? 23 MR. ETHERINGTON: Wha t is 650? About 2200? ([) 24 MR. RANDALL: It would be right a t design. 25 MR. ETHEhINGTON: So you can just get up there-- l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
80 () 1 ER. RANDALL: 2250. 2 MR. SIESS: 2250 and 650? Ch, that is saturation, 3 that is righ t. The 550 is subcooled. 4 MR. ETURRINGTON: So you can get up there that 5 way. But there is little evidence, really, that this is 6 going to do very much good at all. When a vessel has been 7 operating at 550 degrees for 30 years, it is not going to be 8 very impressed by taktng up another 100 degrees for a month, 9 or whatever. 10 It is true that the 650 has been shown to give 11 good stress relief on material that has been irradiated 12 cold, or even hot, on an accelerated basis. But we are 13 getting substantial annoalino at 30 in normal operation O 14 over 30 years. What does another 100 degrees do to you for 15 a month, or whatever period you want to stress relief? 16 There is a big question there. 17 Now 750 is the other tem pe ra ture, and that is a 18 dif ferent animal which almost surely will do you a lot of 19 good. To go to 750 you have to do it differently. You 20 would have to put in an electric heater, and a convection 2 fan, and use it like a Jonvection furnace to bring it up to 22 temperature. This requires a good deal more preparation. I I 23 think it is a wholly practical operation, but you have some ! () 24 decisions to make. 25 MR. SIESS Did you sa r " wholly practical"? O ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $54-2345 l.
~ 81 1 MR. ETHERINGTON: Wholly practical. I think you 2 have to decide where you cut off your heat. Do you let it 3 penetrate into the nozzles? You probably would have the O 4 bottom head go there. Do you want the top head to go 5there? You have to make some preparations and some 6 thinking. 7 So I think that to be meaningful, we should 8 mention a temperature here. Everybody will says Yes, we 9 can anneal. And they are thinking 650. We might just as 10 well leave it out if that is all. I am inclined to think we 11 should mention a temperature like 750, for example, so as to 12 push them beyond just running up to saturation temperature. 13 MR. SIESS4 Now this doesn't really have any w 14 meaning for an existing reactor. 15 MR. ETHERINGTON: That's right. 16 MR. SIESS: It says, "shall be designed." If you 17 are already in existence, it has already been designed; 18 right? 19 MR. ETHERINGTON: If it is in existence, you are 20 stuck wi th what you have got. 21 MR. SIESS: So this is an admonition for future 22 designers; right? 23 MR. RANDALL: Correct. (]) 24 MR. SIESS4 Now with some control over the weld 25 metal, is anybody likely to design anything that is likely O l i ALDERSON RdPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 [
82 1 to have a 200 degree NDT shift? 2 MR. RANDALL: In general, they come out below 3 that, that's correct, for modern material. O 4 MR. SIESS: But in effect you are giving them the 5 choice here to design it be annealed, or design it to have a 6 less-than-200 degree shif t, because it is predicted. You 7 are designi ng the thing. You do not know what the shift is; 8 right? It is a predicted value of the 200. 9 MR. RANDALL: Correct. 10 MR. SIESS: Given that choice, isn't somebody 11 going to choose to predict 200 or less? 12 MR. RANDALL Yes, he is; but you have about 20 13 plants out there now that have -- ) 14 MR. SIESS: This doesn't apply to them. 15 MR. RANDALLa Well -- 16 MR. SIESS: This says "shall be designed." Do you 17 mean to tell me that if I take one of the old plants, they 18 now have to go back and redesign them to be annealable? 19 Wha t are they going to do? How do you design it to be 20 annealable? l 21 MR. RANDALL: No, we do not contemplate that. 22 MR. SIESS: How old is this requirement? When was 23 this put in? (]) 24 MR. RANDALL The regulations became effective in 25 '73. O) \\. ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WAS'ilNGTON, D.C. 20024 (202) 554-2345
83 (]) 1 MR. SIESS: In '73? And n
- of the plants we 2 talk about that have high copper
.I are likely to go over 3 200 predate '73. 4 MR. RANDALL Their <essals were built by that 5 time. 6 MR. SIESS: So just what does this regulation 7 mean? It tells a future designer thats You don't choose a 8 high co per weld material. It sayss You either design this c 9 thing to stay well under 200 because the staff is going to 10 challenge you if you come up with 200, you've got to have 11 less than 200 predictable conservatively; or, you could come 12 in and say: Well, I don' t care about it; I've got to design 13 f or annealing. Right? I can see what the choice is. I 14 ca n ' t conceive of anybody that -- Am I correct? 15 It is easy now to design f or something that will 16 have a lot less than 200 degree shift? 17 MR. RANDALL No. I think maybe that is the 18 point ; that the number of technical surprises we have had 19 influence estimates and in the effects of chemistry are such 20 that we would not totally believe a statement from them that 21 they predict only 180 degrees. 22 MR. ETHERINGTON: And someone could goof on a weld 23 wir e, or something lik e tha t, too. () 24 MR. SIESS This says " predicted." That does not 25 take into account mistakes. O ALDERSON REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
84 I L 1 (Laoghter.) 2 MR. SIESS: What would you accept as a 3 prediction ? Let's say you make the prediction. You put in 4 all the conservatisms you want. What would you shoot for? 5 MR. RANDALL: You mean, what value would we 6 predict and let them say we don't think we can anneal; we 7 are not providing for annealing ? 8 MR. SIESS: Yes. You're giving them an 9 alternative here. You are sayings Come in with a design 10 that can be annealed; or, come in with a design that has a 11 predicted NDT shif t of less than 200 that is acceptable to 12 the staf f. I will put that in. 13 What have you been doing since '73 on that very 14 issue? 15 MR. RANDALL: Well, there has been a lot of work 16 among research people on the annealing. 17 MR. SIESS: What has been the SRP conclusion on 18 plants since '73? 19 MR. RANDALL Plants have uniformly -- the FSARs 20 have uniformly had a paragraph or two describing the fact 21 tha t they could anneal, and briefly saying what they would 22 d o. 23 MR. SIESS: Did they say what temperature? 24 MR. RANDALL: The last one I looked at was for 25 Diablo Can yon, and they said 750 dry anneal with electric O ALDERSoN 9EPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
85 (} 1 heaters and just a few technical specs. 2 MR. SIESS: What Mr. Etherington is saying is that 3 you really ought to say in here, "can be annealed at a level 4 of 750." 5 MR. ETHERINGTON: Yes. That is what I feel. But 6 I would buy, "to permit an effective thermal annealing 7 trea tmen t," which I wo uld thi.k flags it that we are not 8 going to accept 650. 9 MR. CARBON: It flags it, but sort of lightly. 4 10 MR. ETHERINGTON: 750 is what I think it should 11 be. 12 MR. RANDALL: Even higher is being talked about 13 no w. 14 MR. SIESS: Does the SRP give any guidance, the 15 standard review plan ? 16 MR. RANDALLs I don't think it does. Do you mean 17 as to what a nnealing -- 18 MR. SIESS: What annealing would be acceptable. 19 MR. RANDALL: I am sure it does not. 20 MR. SIESS: The S taff has been accepting 750 as a 2, commitment? 22 MR. ETHERINGTON: I did not know tha t. 23 MR. SIESS: Diablo came in with 750 as a scheme. () 24 MR. RANDALL: Well, th e sentence ends with the 25 statemen t, "to recover material toughness properties." ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 4345
86 (} 1 Clearly they would not go tnrough the effort of annealing if 2 the management did not think they would buy a good many 3 yea rs. 4 HR. ETHERINGTON: If we think that the applicant 5 is sufficiently self-interested to protect himself, we do 6 not even need this c,lause at all. 7 ER. RANDALL: All right. 8 MR. SIESS: He is going to be shut down. 9 MR. ETHERINGTON4 Of course he will put us on the 10 spo t, though. It is difficult to shut a reactor down. 11 MR. SIESSa You say all the FSARs that have had a 12 commitment to annealing have described their procedure? 13 MR. RANDALLs Yes, very briefly. (~s) 14 MR. SIESS: You remember Diablo. Do you remember 15 any others around 6507 16 MR. RANDALL: Most of them do not mention a 17 temperature that I have seen. 18 MR. CARBON: No. 19 MR. RANDALL: It is a very short paragraph simply 20 sayings Yes, we meet this paragraph. 21 MR. ETHERINGTON: We will figure out a way to do 22 it when we come around to it. That is really what they 23 me a n. () 24 ER. SIESS4 It seems to me that as a minimum the 25 standard review plan ought to implement this regulacion by O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
87 1giving the reviewer some guidance that somebody that commits {) 2 to 650 is not likely to be able to prove it. 3 Don't you think that would be a good way to handle s.] 4 it, Harold? 5 MR. ETHERINGTON: Yes. 6 MR. SIESSs Then people would know that they have 7 to justify what they can do because, as you said, there is a 8 big difTerence between 650 and 750 and what they will have 9 to do. Why do they have to use electric heaters? Why not 10 gas? 11 MR. ETHERINGTON: They can use gas. I think the 12 electric is a little easier to control. You can't see; you 13 don 't have any peepholes. If you have a peephole, gas is 14 fin e. 15 MR. SIESS: Are we getting some more input 16 the re ? 17 MR. BAKER: When I get a chance, I want to talk to 18 him about something. 19 MR. SIESS: Talk to "him," not us? 20 MR. BAKER: Right. 21 MR. SIESS: Okay, Harold. 22 MR. ETHERINGTON: I have a minor one a little 23 further down, (C)(1). I wo uld suggest we transfer that 100 () 24 percent to the first line, "A 100 percent volumetric 25 examination of a beltline ma terial tha t do not satisfy the ) ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
88 (]) 1 requirements of Section V(B), including e 7,sociated welds." 2 If you put the 100 percent down on the third line, people 3 will kind of wonder "what about the beltline itself ? ~ 4 Isn't that 100 percent volumetric, or isn't it? 5 MR. SIESS: Not by this, it isn ' t. 6 MR. ETHERINGTON: But is it? 7 MR. RANDALLs You mean the normal inspection? It 8 is only the weld mat. There is a strip on each side of the 9 weld. I believe it is 1 TY. 10 MR. SIESS: What does this mean, then, "a 11 volumetric examination of the beltline materials"? That is 12 everything. That's weld, plate, right? Weld material. 13 Wha t percentage? O 'l '~ 14 MR. RANDALL: When you say "everything," it is of 15 the materials that do not satisfy the requirement. 16 MR. ETHERINGTON: But supposing 17 MR. RANDALL: If there is a certain forging, 18 normally -- 19 MR. SIESS: Suppose there is a plate that doesn't 20 satisf y that requirement. What percent? 21 MR. RANDALL4 Only that plate is involved. 22 MR. ETHERINGTONs It is the whole plate, then, 23 isn 't it? () 24 MR. SIESSs 100 percent of it? See, the only 25 pla ce you men tion the amounts is on the velds O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WAShlNGTON, D.C. 20024 (202) 554-2345 -. -. ~ - - -. -.. -.,. - -
89 (} 1 MR. RANDALL: Well, that's true. I guess that's 2 not clea r. 3 MR. SIESS: Did you intend that the plate be O 4 examined 100 percent? 5 MR. ETHERINGTON: If it doesn't meet the 6 MR. RANDALL: Actually, the thought in our mind 7 was that it would be the weld tha t is controlling. 8 MR. SIESS: I know, but that is not wha t you 9 said. 10 MR. RANDALLs I think we have a weak spot there. 11 MR. ETHERINGTON: If it doesn't satisfy the 12 requirement, it should be 100 percent inspected even if it 13 is the plate? O 14 MR. RANDALL: Correct. 15 MR. ETHERINGTON: Then you do want to move that 16 "100 percent" up, if that is what you mean. 17 MR. RANDALL: Fine. I will accept that. 18 MR. ETHERINGTON: Shall I go on? 19 MR. SIESS: Yes, sir. l 20 MR. ETHERINGTON: The next section, C(2), the last 2111ne says: "From results of supplemental fracture toughness l 22 t es ts. " Are these defined anywhere, what "sup pleme n tal" 23 is? Or should you give an indication of what is meant? () 24 MR. RANDALL: N they are not defined. There is 25 under III a statement that such supplemental tests have to O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
90 1 be approved by us. I guess that is what ties it in. 2 MR. ETHERINGTON: That ties it in? 3 MR. RANDALL: It ties it back to something that is 4 controlled. 5 MR. ETHERINGTON: That is all I had, Mr. 6 Chairman. 7 MR. SIESS: Thank you, Harold. 8 Does anybody else have any questions or comments 9 to make? 10 (No response.) 11 MR. SIESS: I would like to make a comment in 12 response to public comments. 13 On page 12 of your response to public comments-- 14 and it does not make any difference what the commen t is in s-15 this case-- right in the middle of the paragraph it says: 16 "Perhaps the misunderstanding was caused by the phrase...". 17 Why do you have to speculate as to why somebody 18 misunderstands? I noticed somewhere else in here, over on l 19 p ag e 14, it says " Comment 13-5 as explained by telephone l 20 conversa tions with the office." Can't you just call these 21 guys and ask them what they misunderstand and why? 22 MR. RANDALL: In the case of Comment 13, I did. i l 23 MR. SIESS: I mean, if the commen t is important O 24end you thinx the guy you cen t sust eseume he is stupid, 25 because sometimes they're not. O ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
91 1 (Laughter.) 2 MR. SIESS4 Don't you usually check back with them 3 if it is not a clear comment? 4 MR. RANDALLs Yes, no rmally I do. 5 MR. SIESS: There is no restriction on such 6 communication, is there? 7 MR. RANDALL: No. 8 MR. SIESS There is one thing you do get back in 9 the comments. You get substantive -- you get criticism, but 10 f requently the comments just tell you that wasn't written 11 clearly. 12 MB. RANDALL4 Right. 13 MR. SIESS: Call in the editors, and he picks it 14 u p. 15 Gentlemen, this one is proposed for committee 16 concurrence. From Harold's discussion, there has been 17 agreement to change the 100 percent. 18 On the other item, are you satisfied that at least 19 if it doesn ' t a pply it doesn't hurt anything? 20 MR. ETHERINGTON: Yes, but I would suggest lookino 21 it over. In view of our conversation, I would suggest 22 taking a look at the wording. 23 MR. SIESSs Yes. As a minimum, it is not clenr. O 241.ou1e oro,ose thet.e recommend to the ru11 Cemmittee thet i 25 this receive ACRS concurrence, subject to the one revision l l O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 5L4345
92 () 1 which the Staff has agreed to, and consideration of some 2 language changes which are really not a substantive change. 3 Is there any objection? l 4 (No response.) 5 MR. SIESS: So ordered. 6 Okay, the next item I have on the agenda, then, is 7 a proposed Regulatory Guide on the identification of valves 8 for inclusion in in-service testing programs. And again I 9 will remind the subcommittee members that Dr. Bush, our 10 consultant, did review all these Guides, and he has some 11 comments on all of them, including this one. His comments 12 were favorable. 13 I would like to mention at the beginning, on this O 14 one I found that the way the comments f rom the public were 15 handled was especially convenient. That was about as neat a 16 job as I have seen. 17 I also noticed "important to safety" here, but I 18 think we have taken care of that. 19 I again prefer to handle this initially on a sort 20 of questioning basis. If you want to tive a short 21 in troduction, that will be fine. 22 MR. MORRISON: Which Reg Guide are you talking 23 about? () 24 MR. SIESS: I misread my comments, excuse me. 25 What I wanted to applaud was that the items in Part B and in O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
93 (]) 1 Part C are numbered in a one-for-one correspondence, which 2 is the first time I have seen numbers in Part B, and it is 3 almost the first time I could relate every item in Part B 4 clearly to an item in Part C in the five years I have been 5 working on that. 6 (Laughter.) i 7 MR. SIESS: It helped. If you want to give us a 8 very brief introduction, you can. If not, I've got a lot of 9 little items hece, and I am sure a lot of other people do. 10 How would you like to do it? 11 HR. BAKER: I will give a brief introduction. 12 MR. SIESS: Okay. Just give us the objective, 13 generally. 14 MR. BAKER: The Guide started about three years 15 ago with a request from DDR. They were using guidance very 16 much similar to this, issuing it on a case-by-case basis to l 17 the licensees. The licensees came back and more or less l 18 asked for it to be placed in a Reg G uid e f o rm. So at that 19 time it was started in a Reg Guide form and it has taken 20 about th ree years to get it ready for presentation. 21 NRR is still using the same guidance that DOR was 22 using, so this really is not a new requirement. It is just 23 formalization in the format of a Reg Guide of the things, () 24 that they were already using. 25 MR. SIESS: Does it increase the number of valves ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
94 1 (} 1 that have to be tested, or decrease, or unchanged? 2 MR. BAKER. It really depended on the case. There 3 were cases where a licensee would come in and have 12 valves D G 4 in their testing program, *.nd another case where they would 5 come in with something like 700 valves. So it more or less 6 standardizes it so they would all come in with the same 7 number. 8 MR. SIESS: Which is it closer to? 12, or 700? e MR. BAKER: I don't know. Joel? s MR. PAGEa 700 would be closer. My name is Joel 11 Page, NRR. 12 MR. SIESSa You said the 700 would be closer? 13 MR. PAGE: Yes. 14 MR. SIESS: So that means there will be more 15 people testing more valves than there will be testing f e we r 16 valves? 17 MR. PAGE: Yes. 18 MR. BAKER: Only to the extent that in the past 19 N RR would ask for an increase in the number of valves, that 20 when they come in with an application or a testing program 21 they would only ask for 12. So there would then be some 22 discussion on how many, and it usually ended up with more 23 than 12; but it is more to standardize the number when they () 24 com-in initially than what it actually ended up as. It C5 v'.id cut down the amount of time spent in discussion as to l l ALDERSoN REPORTING COMPANY,INC, 400 V:RGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
95 n,a 1 how s any valves in each system should be done for which 2 systems. 3 MR. SIESS: Okay. Does anybody object to sort of 4 going throuch this page by page, and if-you have comments we 5 will take them up? If you don't mind, I will lead off, and 6 then we can go on from those. 4 7 On page 1, the introduction which usually is the 8 part that gives the rele van t rules and regulations, in the 9 bottom paragraph it says: " Identify valves for inclusion in to the licensee's in-service testing program." As I read A and 11 B of this, I get the impression that the in-service testing 12 program we are talking about is the Section 11 Code 13 program. But when I get to position C-3, there is a 14 ref erence on page 4 in line 5 that says, " Requirements 15 stipulated in Appendix J." 16 MR. BAKER: You mean the Regulatory Position C? 17 MR. SIESS: Page 4 of the Guideline, line 5, there 18 is a ref erence to Appendix J. And Appendix J is not 19 ref erenced anywhere in the introduction as being something i 20 that this As implementing. And the whole impression in the 21 introduction and in the discussion in Parts A and Parts B is 22 that this is a Guide. to implement ASME Section 11 23 requirements. () 24 And then I get over into Reg Position C-3 and see 25 something about -- it suggests to me that it is implementing l l ALDERSON REPORTING COMPANY,INC, 400 VIRGIN'.A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
96 1 Appendix J positions. 2 Now when we get to that section, would you explain 3 how Appendix J gets into this? 4 MR. BAKER: Yes, I will. 5 MR. SIESS: Is there anything else on page 1? 6 (No response.) 7 MR. SIESS: Incidentally, I var pleased to see in 8 the second paragraph the reference to structural and 9 loop-type integrity. 10 On page 2 on line 12, is that a typo where it says 11 " K" ? 12 MR. BAKER 4 Yes, that is a typo. There is a 13 button they have to push on the machine to get the little s 14 paragraph symbol, and they didn't push it. There is also a 15 mistake on line 2 of the first page. Since we were 16 reo rganized, it should be "MS-901-904," standing for 17 Mechanical Structural Branch. 18 MP. SIESS: Sam, will you note that so we can keep 19 track of this one, since that is our only key? 20 MR. DURAISWAMY: Yes, sir. 21 MR. BAKER: It is correct in the cover letter, but 22 the Guide wa s prin ted before that. 23 MR. SIESS: In line 25 on page 2, it says, O 24 seiateia tue reector 1a e eere enutaova coaattica " 1te 2 25 just before that says "a cold shutdown condition." Now that O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 554 2345
97 (]) 1 gives me three kinds of shutdown: cold shutdown, hot 2 shutdown, and safe shutdown. Do you want to explain what we 3 are talking about here? 4 MR. BAKER: I think the difference is that it says 5 " maintain." In other words, over the long-term period, the 6 valves would have to stand up to -- l 7 MR. SIESS: Would a " safe shutdown" mean a " cold 8 shutdown," or a " hot nhutdown"? 9 MR. BAKER: I guess in this case you're really 10 talking -- well, it would be both, really. 11 MR. SIESS: Not at the same time. 12 MR. BAKER: Not at the same time, no, but you 13 could have a long-term cold shutdown, and you could have a 14 lon g-term ho t shutdown. 15 MR. SIESS: Now there has been some argument about 16 whether cold shutdown or hot shutdown is the best. There 17 was an argument once that it is a lot easier to keep the 18 plant in hot shutdown; you don't have to move nearly so much l l 19 water around through so many big pumps. The point had been l l 20 made that eventually you're going to have to get to cold 21 shutdown ; you can't just leave the thing in hot shutdown l 22 f or ever. 23 But does Item 3 mean that either hot shutdown or () 24 cold shutdown, but that you want to be able to maintain it 25 there for a long period of time? O \\_/ I ALDERSON REPORTING COMPANY. INC, e,00 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
98 1 MR. BAKER: We don't want the valves to leak 2 excessively in that condition; that's correct. 3 MR. SIESSs Now is that absolutely clear to O 4 everybody? There are diffecent valves involved. In the 5 discussion, does the position make it clear? This is 6 Position 1. It talks about systems, Appendix A. Are you 7 satisfied tnat the systems listed in Appendix A cover both 8 hot shutdown and cold shutdown tiequately? 9 MR. BAKER 4 Yes. 10 MR. SIESS: Is the term " safe shutdown" that 11 standard ? Or do you mean, " maintain the reactor safely in a 12 shutdown condition"? Is " safe shutdown" a word like " cold 13 shutdown" or " hot shutdown" that has a specific meaning? ( 14 MR. PAGE: Joel Page from NRR. Could you restate 15 the question, please? 16 MR. SIESSs " Cold shutdown" is a term that is 17 defined, a certain tempera ture for a PWR and a BWR. I think 18 one of them uses " hot standby" and the other one uses " hot 19 shu tdown," if I'm no t mistaken, but those are terms that are 20 defined. 21 MR. ETHERINGTONs They make a distinction, too, I 22 believe. 23 MR. SIESS: Yes. BWRs and PWRs have a different () 24 definition of " hot shutdown" and "ho t standby"; right? 25 MR. ETHERINGTON: And I think even BWRs make a O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 k.
99 1 distinction, don't they? " Hot standby" is ready to go right [} 2 back up, maintain operating temperature; and " hot shutdown" 3 can be some lower temperature. Is that right, or not? f_ (m) 4 MR. SIESS: But does " safe shutdown" have a 5 defined meaning? Can you give me a definition of " safe 6 shutdown" as a phrase? 7 MR. PT.GE s " Safe shutdown" can include the hot 8 standby, the ho' sh u td o wn, or the cold shutdown, either 9 one. It is commonly used with the safe shutdown 10 earthquake. 11 MR. ETHERINGTON: Do you make a distinction 12 between " hot standby" and " hot shutdown"? 13 MR. PAGE: Do we make that distinction? 14 MR. ETHERINGTON: Yes. 15 MR. PAGE: No. The " safe shutdown" cludes-- the 4 16 reason it is used, in the context of this Guide here it 17 means that any of the valves used for any of those sequences 18 are to be included in this program. 19 MR. SIESS: In other words, " shutdown" means-- 20 MR. PAGE: Hot standby. 21 MR. SIESS: No, not really. " Shutdown" means, 22 "no t critical"; righ t? 23 MR. ETHERINGTON: Right. () 24 MR. SIESS: Wouldn't this be better phrased to 25 s a y, "m.intain the reactor safely in a shutdown O l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
100 {} 1 condition"? 2 MR. PAGE: I 'jelieve either one of those would be 3 correct. f~g V 4 MR. SIESS: Because it just seems to me that " safe 5 shutdown" as a phrase doesn 't mean anything like " cold 6 shutdown" and "h o t shutdown" and " hot standby" do. If you 7 really mean " maintain it safely in a shutdown condition," 8 noncritical condition, I understatd what it means. 9 Would you buy that? 10 MR. BAKER: Sure, I don't have any problem with 11 tha t. 12 MR. SIESS: Okay. Anything on page 2 from 13 o thers? I") L' 14 t(No response.) 15 MR. SIESS: On page 3, lines 14, 15, and 16, I 16 guess really it is from there on out, but it starts off: 17 "Where it can be identified that such valves perform both a 18 pressure isolation f unction and a containment isolation 19 f unction" and I got completely lost trying to understand 20 t ha t and to relate the discussion of that to the Position. 21 Position 2 simply refers to valves that perform a pressure 22 isolation f unction. And Position 3 relates to valves that I 23 perform a containment isolation function. And Discussion I 24 B -2 talks about valves that perform both. 25 I just have trouble relating the discussion to the ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
101 {} 1 position. It seems to me that the position is those tha t 2 have a pressure isolation f unction, Position 2. So why is 3 there any discussion of a containment isolation function in 4 B-2 7 5 MR. BAKER: The problem you run into is that some 6 of the valves do do both. 7 MR. SIESS: That doesn't make any difi ence. You 8 don 't make that distinction in the Position. 9 MR. BAKER: In other words, it does make a 10 dif ference what they are tested for. 11 MR. SIESS: Then that ought to be in the i 12 position. You've got one position for pressure isolation 13 and one position for containment isolation. And if a valve 14 does both, I would say both positions apply. If it does 15 only one, only one position applies. In your discussion 16 you 've got them mixed. 17 (Pause.) 18 MR. SIESS: Do you see what I mean? Position C-2, 19 " valves tha t perform a pressure isolation f unction"; 20 Position C-3, " valves that perform a containment isolation 21 f unction " only. If they perform a containment isolation 22 function together with a prensure isolation function, then 23 they need to be under C-2, don't they? () 24 MR. BAKER: Excuse me? 25 MR. SIESSs Then they come under C-2. C-2 applies O ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
102 1 whether they perform pressure isolation alone, or pressure 2 isolation together with something else -- throttling, 3 containment isolation, or whatever. The Position is clear. O 4 It is the discussion that is confusing. 5 MR. BAKER: We can change the discussion to 6 reflect th a t. 7 MR. SIESSs You see there Appendix J comes in for 8 just the containment isolation function; right? 9 MR. BAKER: That's right. 10 MR. SIESS: Do you see wha t I'm getting at? 11 MR. BAKERS Yes. 12 MR. SIESS: I think in Discussion 2 you are 13 anticipating 3, and you see in line 19 you reference ( 14 Appendix J. 15 MR. BAXER: That's right. 16 MR. SIESSs Which again is not cited back in A. 17 Now again I am assuming something. Usually in A you have 18 stated your authority of what this intended to implement. 19 It looks like this is intended to implement a t least in part to Appendix J. 21 MR. ANDERSON: That wasn't our intention. So that 22 in Position 3 what we are really trying to sa y is, you do 23 not have to apply Section 11. Rather than saying you should (]) 24 apply Appendix J, because Appendix J has carried its own 25 weight and it is under revision. ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
103 1 MR. SIESS: But under " containment isolation," 2 this Guide doesn't apply. 3 MR. ANDERSON: Essentially that's what we are 4 saying. 5 MR. SIESS: I think you have lost it up in 2. 6 Well, think about it. This is going out for comment, 7 anyway. I have a number of suggestions for your editor. I 8 will give you my copy. I assume he has worked on it? 9 MR. BAKER: It has been submitted to him. 10 MR. SIESS: Is this the result of editing? 11 MR. BAKER: No, your comments also go to editing. 12 MR. SIESS: I just wanted to know if I am ed ting 13 the editor, or editing you. 14 In line 30 -- 15 MR. BAKER: Which page? 16 MR. SIESS: -- Page 3 - "where systems are 17 required to penetrate the containment boundary" wha t do the 18 words "are required to" mean there? I would think that 19 where systems penetrate the containment boundary, whether 20 they are required to or not.. l 21 MR. EAKER: That's fine. 22 MR. SIESS: Is there anything from the rest of the 23 committee on page 3? O 24 <No response.) 25 MR. SIESS: Now on page 4 on the top part, this is ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
104 1 the containment function only. You say they have to meet (~} 2 Appendix J and need not be further leak tested to Section 3 11. Now that is what Bill was just saying what your intent 4 was here. 5 Now then you've got a "should," a Standards type 6 "should", not a Reg Guide type "should". "In some cases it 7 would be desirable to perform Type C tests as defined in 8 Appendix J and individually leak-test each valve." I 9 thought that Appendix J required Type C tests there? 10 MR. ANDERSON: I believe Appendix J allows you to it leak-test the whole containment, valves and all. 12 MR. SIESS: It's got A, B, and C. A-B is the 13 integrated leak-rate test; B is the stuff on hatches, doors, 14 seals types of things; and C is everything else, I thought, 15 penetrations -- whoever wrote this must know wha t a Type C 16 test is. Type C does not require an individual leak-ra te 17 t es t ? 18 MR. BAKER: No. 19 MR. SIESS: In Appendix J7 And why are we fixing 20 u p Appendix J in the Reg Guide? l 21 (Pause.) 1 22 MR. PAGE: May I respond to that? 23 MR. SIESS : Sure. () 24 MR. PAGEs The reason we don't give them relief 25 f rom doing them individually is that on an operating plant i l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
105 1 particularly we ask them to trend the valve and take ) 2 corrective action in accordance with IWV24.20, if that 3 requirement is still there. We do want them to trend the O 4 valves. 5 MR. SIESS: My question was Does Appendix J 6 require -- let 's see, what are talking about? A system that 7 penetrateu the containment boundary and communicates with 8 either the primary reactor coolant system or the containment 9 atmosphere. Okay, this is something where the primary 10 system goes through the containment boundary, or you've got 11 like a purge valve. Right? Section 11 doesn't apply, but 12it would be desirabl? to perform Type C to Appendix J 13 tests. 14 My question wass Doesn't Appendix J require that 15 there be leak-rate tests made on things that penetrate the 16 containment ? l 17 MR. BAKEE: But that says the centainment as a 18 whole. 19 MR. SIESS: What do you mean, "the containment as 20 a w hole"? 21 MR. PAGE: Then you add them all up and you have a 22 total requirement 23 Mh. SIESS: There are three kinds of tests in () 24 Appendix G. Don't tell me I know more about Appendix J than 25 you do. That will be the first time it ever happened. O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
106 1 Somebody get me a copy of Appendix J. Sam has gone for it. 2 But suppcse Appendix J doesn't' require it? Wouldn't it be 3 better to fix up Appendix J than sneak it into a Reg Guide O 4 that saysa Don't do it? 5 MR. ANDERSON: Appendix J has been under 6 revision. We have had a high-priority revision underway on 7 Appendix J for three years. It keeps losing its priority, 8 and we are picking up a large "NS standard tha t goes into 9 much more detail. 10 MR. SIESS: Type C tests mean tests intended to 11 measure containment isolation valve leakage rates. 12 Containment isolation alves included are those that provide 13 a direct connection to the inside and outside a tmospheres 14.under normal operations such as purge and ventilation, 15 vacuum relief instruments. Valves that are required to 16 close automatically on receipt of a containment isolation 17 signal, required to operate intermittently under 18 post-accident conditions or in the main steam or feedvater 19 pipes and other systems which benefit containment. Those 20 are Type C tests in Appendix J. 21 22 23 24 25 O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554-2345
107 (" 1 MR..3ILVER: I don't know exactly how Appendix J V) 2 is written now, but at one time I believe it allowed you to 3 pressurice between two valves in series. So you weren't 4 testing each valve irdividually; you were testing the 5 penetration as a whole. But I am not sure whether it is 6 still written that way. So the distinction would be testing 7 of penetration versus testing valves individually. 8 MR. SIESS: Well, the thing that bothers me most 9 is that you've got a Reg Guide on identification of valves 10 f or inclusion in the in-service testing program. Basically 11 you are saying that if they are in the Appendix J list, they 12 don ' t need to be in this list. If they do nothing but 13 con tainment isolation, that's somebody else's business; 14 tha t's Appendix J. 15 And then you go on to suggest what seems to be an 16 addition to Appendix J, but I am not sure it is an addition 17 to Appendix J. And I don't know the difference, and you 18 don 't know the difference, so I would simply suggest that 19 you get it straightened out. 20 If this is a lackdoor method of taking care of 21 Appendix J, fine. 22 MR. CHERNY: Let me try and answer that one. 23 Frank Cherny from Mechanical Engineering. We do in our () 24 Branch the Section 11 review. Typically what we get quite 25 of ten f rom licensees is a request for relief from Section 11 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554 2345
108 () 1 testing. What they sa y tha t they will do instead for 2 containment isolation valves is that they will do a Type C, 3 Appendix J type test. 4 We typically approve that kind of a relief 5 request, but the actual review of how that particular test 6 is doae af ter that point is done. That review is done by a 7 different Branch. 8 MR. SIESS: I think you have answered my 9 question. Let's say you have established the validity of my 10 question. There is something a little strange here. It may 11 be right, but it doesn 't seem righ t on the surf ace. 12 MR. ANDERSONs We will take another look at it. 13 MR. SIESS: I am going to take this by sections. O 14 Is there anything else on Section 3 and B? 15 (No response.) 16 MR. SIESS: Section 4 I have no problem with. 17 Does anybody have any questions about it? 18 (No response.) 19 MR. SIESS: Section 5, you know I have a very 20 simple observation here. I thought the position was quite 21 cle a r, and the discussion confused me completely. I might l l 22 remind you that I read these things by reading the position l 23 first, and then reading the discussion, because the position ! () 24 is important and the discussion is supposed to explain it. 25 You have got some scenarios in 5, and they are not O l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
109 1 clea r. The two at the top of page 5 I thought were pretty 2 clear, but you have a whole series of scenarios, and they 3 are all mixed up in there. I think if you took them out and 4 sort of isolated them, paragraph by paragraph, it would be a 5 lot easier to read. 6 The ones at the bottom of page 4 I just found 7 confusing. You see, the whole thing goes around " valves 8 that when exercised under certain conditions can put the 9 plant in an unsafe condition," and then you have listed some 10 exa mples. 11 The one that says, "For example, there are valves 12 whose f ailure to close during cycling tests would result in 13 a loss of containment integrity. This is the case in which Os 14 the redundant valve has failed to open and exercising the 15 remaining valves during plant operation would breach the 16 containment. " There are words like " failed" in one case, 17 and " exercising" in the other. I would just suggest that 18 you read tha t through and see if you cannot isolate th ese 19 and say a little more clearly what you mean. 20 MR. BAKER: Well, in the case you just cited 21 MR. SIESS: I am sur; you can explain each one of I 22 these, but you do not go along with the Guide. 23 (Laughter.) l () 24 MR. SIESS: I think if the scenario were a little t 25 bit clearer -- you have four scenarios, I think, in here. () l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (2C2) 554-2345
^.s0 {} 1 There are two on page 4 and two at the top of page 5, and 2 maybe some more. You have two paragraphs, and th-3 paragraphs do not divide the scenarios into the categories. 4 I think some examples are good, but there is just 5 no point in having a discussion that is more confusing than 6 the position. 7 MR. BAKER: We can reformulate it so that the 8 examples stand out by themselves. 9 MR. SIESS: Yes. I think it would help. You 10 might reconsider whether you really need so many examples. J 11 Sometimes if you put too many in the people begin to think 12 it is an exhaustive list. Maybe you could explain what you 13 mean clearly enough to let the people think up their own 14 exampes. 15 Are there any other comments on that item? 16 Harold ? I 17 MR. ETHERINGTON: Yes. I have a concern about the l 18 second sentence in that section. What it says is: "In l 19 almost all cases where a valve has been exercised under a 20 certain condition, fader has occurred." Is that true? Is 21 tha t what it means? You don't get a fader every time. 22 MR. BAKER: What it is referring to is when -- 23 MR. SIESS: Let me try something for you. I have (]) 24 rewritten that sentence, Harold. I think I had the same 25 problem. Let me read the first two sentences the way I've O ALDERSON REPORTING COMPANY. INC, l 400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554-2345 L
111 {} 1got the second one rewritten. 2 The first one says: "There are valves that when 3 exarcised under certain conditions can put the plant in an 4 unsafe condition." I changed the following sentence to 5 reads "In almost all cases, such conditions would involve 6 f ailure in a redundant system or failure in the valve 7 itself. " Those are the "certain conditions" that are 8 ref erred to. You have two conditions there, and one of them 9 os ht to be fixed up. 10 I think what you mean is that the "certain 11 conditions" under which this can happen are those which 12 involve failure in a red unda n t system, or failure of the 13 valvo itself. .4 MR. BAKER: That is correct. 15 MR. ETHERINGTON: But you need the condition, 16 "also an unrela ted failure in some other component," don't 17 y ou ? l 18 MR. SIESS4 This is part of this whole problem; 19 ye s. The example is not -- What you are trying to say is i 20 tha t if the valve fails while you are exercising it, or if 21 there is a concomitant failure in another system while you 22 are exercising it, or if there is a concomita;. failure in 23 another system while you are exercising a valve, this could ! () 24 put you in an unsafe position. But right now, the second 25 sentence is wrong. It implies that every time you exercise i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
112 1 '. t -- 2 MR. ETHERINGTON: Yes. 3 MR. SIESSs Do you see what I am getting at? 4 MR. BAKERS Yes. 5 MR. SIESS: Is there anything else on Item 5? 6 (No response.) 7 MR. SIESS: In lines 11, 12, on down, the Staff's 8 position has been that: " Routine exercising of [I've got} 9 such a valve should not be performed unless a reliable 10 method exists to detect leakage." I think you mean "a 11 rel.i.able method to detect the position of of and/or a 121eakage past the check valves." 13 It is not just a leakage past the check valves, 14 unless you assume that open is leakage, I guess. To me, an 15 "open valve" is not quite the same thing as a " leaking 16 valve." 17 Anyway, let's go on to Item 6. In line 25 it 18 says, "A balanced judgment between the hardship and the 19 compensa ting increased level of safety must be explicitly 20 j ustified." Who makes the judgment? The licensee, or the l 21 Staff? I am not quite sure who has to do the balancing l 22 here. Usually a balancing between hardships and safety is 23 something that the Staff has to do, isn't it? l 24 MR. BAKERS Well, the licensee would have to make 25 the presentation as to what he thought they were, and the O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
113 {} ' Judgment would be up to the S ta f f. 2 MR. SIESS: Well, do you usually write a Guide 3 that tells the Staff they have to do something? Usually the 4 Guide is addressed to the licensee. You see, the '* judgment" 5 does not have to be justified. A balanced judgment has to 6 be made as to whether you are going to take an exception to 7 the testing level because of increased exposure, or 8 something of that sort. 9 Really what you mean to say here for the applicant to is that an exception must be justified in terms of hardship 11 versus something else. So I think you should fix the 12 language. It is not the judgment of the Staff that has to 13 be justified. You justify your judgments before a Hearing 14 Boa rd. The applicant justifies their judgment before you. 15 Is there anything on 6 from anybody else? 16 (No response.) 17 MR. SIESSa On 7, this might be strictly edito rial 18 b ut my comment here is that the first two sentences say the 19 same thing. The first says: "The concerns of the Staff 20 with a reviewer's insufficient information," and the second l 21 one says that in the past there has not been adequa te 22 inf ormation. I think one of those could be omitted. 23 In line 12, it says: "If all necessary l ' () 24 inf ormation is provided." Now is the "necessary l l 25 inf orma tion" that that is defined in Position C-77 Is that l O l ALDERSoN REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
114 [} 1 the intention to say that C-7 is a complete list? It says, 2 "as a miaimum" in C-7. It says that if I submit what is in 3 C-7, I do not get Q-1s. O 4 MR. BAKER: That is what is intended. If they 5 submit everything that is in 7, they should be all right. 6 MR. SIESS: You could say that. 7 Shall we go on to the Regulatory Positions? On 8 page 6, the first item, the first sentence needs to be fixed 9 up. You have got "some valves are needed" and "some are 10 req uired," a nd I do not think you wanted that distinction. 11 Eve rything you required is presumed to be needed. 12 In lines 20 and 21, it sayss " Requirements of 13 ASME Section 3, or some other voluntary standard." You must 14 have had something in mind. 15 MR. BAKER: " Voluntary," as f ar as voluntary 16 concensus. / 17 MR. SIESS: I know what a voluntary standard is, 18 but do you have one in mind? 19 MR. ANDERSON: Yes. A lot of valves under P-16 in 20 the older plants, and one of the concerns there is that 21 people come in and saya Well, this wasn't built to Section 22 3.30 so we don ' t have to test it to Section 11. 23 MR. SIESS: But it is sufficiently open that you () 24 would just like to leave it open? 25 MR. ANDERSON: I think there migh t be some MS O l l l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
115 1 specs. ) 2 MR. SIESS: Is MS a voluntary standard? 3 MR. MORRISON: What is "MS"? 4 MR. SIESS: I do not think milita ry specs are 5 voluntary standards. I really think what you san, when you 6 get right down to it, is as a regulatory agency I think you 7 mean any ather acceptable standards. Because I think 8 non volun tary standards -- 9 MR. CARBON: "Or not." 10 MR. SIESS: If somebody can point to a standard, 11 tha t helps. If they can't, you might as well start over. 12 B ut what you mean, you don't want the manufacturers spec 13 sheet. That is not a standard. ( 14 MR. ANDERSON: They may have been done just to 15 that standard. 16 MR. SIESS: If you put "acce ptable," a t least 17 somebody knows they have to submit it. l 18 MR. CARBON: I think this refers to past tensa, 19 whether they were constructed to ASME Section 3, or whether l l 20 they were not. 21 MR. SIESS: No. 22 MR. CARBON: I believe that is what it does. l l 23 MR. SIESS: Well, actually, if that is true, you (]) 24 could put a period after "Section 3." 2 MR. CARBON: Or you could say, "Section 3 or O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
116 () 1 not." 2 MR. SIESS4 Let's put it this way. Suppose they 3 were not constructed to any standa rd. You are not going to 4 lea ve them out? 5 MR. BAKER: No, we just want them tested. 6 MR. SIESS Why do you have to say that at all, 7 what Mr. Carbon said? 8 MR. BAKERa What if we just said, "or not" at th e 9 end of Section 37 10 MR. ANDERSON: If we just said "some other 11 sta ndard" -- 12 MR. SIESSs What you want to say is -- 13 MR. ANDERSON: "Or other requirements." 14 MR. SIESS: What you want to say is, " valves that 15 a re required for certain things in the plant" okay, "are 10 considered by the Staff important to safety whether or not 17 Section 11 appplies to them." This thing is addressing 18 mostly Section 11. Leave Appendix J out. 19 What you are saying is: These are valves that are 20 important to safety and you want them included in an l 21 in-service testing program. We do not care whether they 22 were manuf actured to Section 3, or whatever. These are the 23 valves that we want in there. i () 24 MR. CARBON: You could almost stop at the word 25 " program" and leave it there, I guess. OV ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
i 117 I (} 1 MR. SIESS: You could put a period after 2 " program." If you just want to be sure that people realize 3 that you meant that this was not limited to Section 3 4 valves, you could put a period after "Section 1." 5 MR. ANDERSON: We could say, "whether or not they 6 were constructed to the requirements of Section 3." 7 ER. SIESSa That is right, or you could put a 8 period af ter " program" and put the words back in B that 9 explains tha t this applies to all of them. Okay? 10 MR. ANDERSON: (Nodding in the affirmative.) 11 MR. SIESS: Item 2. 12 MR. ETHERINGTON: What is the procedure for 13 ensuring that both the valves are tight, in this case 14 separating a high pressure from a low pressure system? How 15 a re they tested? 16 MR. PAGEa They are leak tested. 17 MR. ETHERINGTON: How do you test in-service? 18 MR. PAGE: You mean the actual mechanics of how 19 you do the leak tests? i 20 MR. ETHERINGTON: Right. 21 MB. PAGE4 Well, you may drain the line downstream 22 of the valve that we tested and pressurize the upstream 23 stack, and then measure leakage into a beaker, or whatever l () 24 you have handy. 25 MR. ETHERINGTON On the downstream valve, what do ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
118 1 you do there? 2 MR. PAGEs On the downstream valve? I'm afraid 3 you lost me. O 4 MR. SIESS: There are two valves, aren't there? 5 MR. ETHERINGTONs Well, you ha ve te sted the 6 upstream valve now. Your downstream valve is closed. You 7 void the space between the valves, and you collect the 8 leakage. Now how do you test the other valve? 9 MR. PAGEa You would move down the line and do the 10 same thing. 11 MR. ETHERINGTONs Well, then you have to drain the 12 low-pressure system completely. 13 MR. PAGE Well, not everyone does it -- () 14 MR. ETHERINGTONs Is that what they do? 15 MR. BAKER: The other method they use is to 16 pressurize and measure the flow it takes to keep the 17 pressurization equal, or maintain the pressure. 18 MR. ETHERINGTON: That does not work with check 19 valves. 20 MR. BAKER: If you had leakage, you would still 21 g e t that leakage. In other words, if you left the pressure 22 the same, you would get a d rop in pressure. 23 MR. ANDERSON: Are you speaking of checking the () 24 space between two check valves? 25 MR. ETHERINGTON: Yes. O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
119 {} 1 MR. ANDERSON: That calls for another procedure. 2 Sometimes it is a time-consuming, expensive operation. 3 MR. SIESS4 In Item 2, valves tha t perform a 4 pressure isolation f unction should be classified as Category 5 A, or AC if they are leak tested to ascertain any pressure 6 protection, et cetera, is adequate. When would they not be 7 leak-tested? I thought all valves that did a pressure 8 isolation f unction have to be leak tested. Are there some 9 tha t don't? 10 MR. BAKER 4 Well, currently it depends on the 11 owner. Section 11 says that the owner shall classify the 12 valves as f ar as Category A and Category AC. So at this 13 time there may be some that are not categorized. 14 MR. SIESS4 But if I say, " valves that perform a 15 pressure isolation f unction should be classified as Category 16 A or AC," now that to me is a clear statement. All valves 17 that perform a pressure isolation function should be 18 cat egorized A or AC. This says -- I am putting a word in-- 19 "only if they are leak tested." 20 Now are there some valves that do that that do not 21 belong in Category A or AC because they are not leak 22 tested? 23 MR. CHERNY: Frank Cherny again. Let me try that () 24 one. We have had some licensees come in and talk to us 25 about the possibility of verifying leak-tight integrity of O I ALDERSoN REPORTING COMPANY,INC. 400 VIRGlalA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
120 (} 1 these kinds of valves by some kind of continuous monitoring 2 system, instead of doing leak testing. We have yet to see a 3 real concrete proposal of that type. Okay? O 4 But by categorizing valves A or AC, it invokes the 5 Section 11 specific requirements that delineate several 6 things that you have to do to run a leak test on valves to 7 verif y leak-tight integrity. There really is not too much 8 point in asking people to ca tegorize valves " A" or " AC" if 9 they are going to verify leak-tight integrity by some other 10 m ethod. It does not really buy von anything. 11 MR. SIESS: So this is not right, then. "A" or 12 " AC" requires a leak tests righ t? It tells you how to make 13 a leak test? 14 MR. CHERNYs Well, what this says is they should 1sclassify valves as "A" or "AC" if they are leak tested. 16 Th a t is what it says. 17 MR. SIESS: Okay. But they do not have to be leak 18 tes ted. 19 MR. CHERNY: Richt. 20 MR. SIESSs You can verif y a leak tightness by 21 other than leak testing. 22 MR. CHERNYs In concept, yes. We are still 23 daiting to see a good proposal, but that is right. () 24 MR. SIESSs I see. That answers my question. Is 25 there anything else on Item 2? ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
i 121 {} 1 (No response.) 2 MB, SIESS: Item 3 is the containment isolation 3 f un ction. This is perfectly clear until you read the 4 discussion. 5 The next page, Item 4, I have no questions. 6 Anybody else? 7 HR. RAY: I was just curious as to why in Item 4 8 the valves that are used for operating convenience or 9 maintenance are only included in the in-service test if th ey 10 are locked in a given position. Are they always locked in 11 the given position if they are in this role? 12 MR. PAGE: To tell you the truth, I do not know 13 the answer to that. 14 MR. ETHERINGTON: It looks like an invitation to 15 put a lock on the valve. 16 MR. RAY: Yes. 17 MR. SIESS: Well, the way I read that was that 18 these are valves that do not perform a pressure isolation 19 f unction ; otherwise, they would be in position one, right? I 20 MR. BAKERS That is correct. 21 MR. SIESS: They are just valves. But if it is a 22 valve that is locked open or locked shut, there must be a 23 safety reason for it being locked open or locked shut. So () 24 they have to check it to be sure whether it is '.ocked open 25 or shut. That was my naive interpretation of this. O ALDERSoN REPORTING COMPANY,INC. 400 VIRGIN, AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
122 1 M F.. RAY: And tha t is the only test, then, tha t is 2 made to cr.eck it and see if they are locked. 3 MR. SIESS: Because otherwise, they are not -- O 4 MR. BAKER: To check to see if they are in their 5 correct position. 6 MR. SIESS: Yes. But otherwise, they are not 7 important. 8 MR. RAY: That is the intent. 9 MR. BAKERa That is right. to MR. CHERNY: Maybe a good example would be 11 appropriate. I think that there were certain valves on the 12 auxiliary feedwater system at TMI that were in the wrong 13 position at the time of the accident. That is an example of 14 why such valves should be covered in this program. 15 MR. SIESSs They were locked in the wrong 16 position. 17 MR. ETHERINGTON: They were required to be locked l 18 ope n. 19 MR. SIESS Right. Actually, I guess Section 11 20 gives you more details on this. This does reference Section i 21 11. 22 Harold, did you have a question on that one? 23 MR. ETHERINGTON: I had the same question. O 24 c^"Bo"> t ao-25 MR. SIESS: Max? O ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
123 1 MR. CARBON: This number four I guess confuses 2 me. The first sentence sayss Certain valves are excused. 3 The second sentence.ayas If these are valves important to O. 4 saf ety, they should be included in the in-service test it says, "only." I lose something 5 program. And o.. 6 somewhere when I get to the word "only," because if they a re, 7 important to safety why doesn't it stop after the word 8 " program." 9 MR. PAGE: Well, the valve itself is not important 10 to safety; only that it is in the correct positions. It is 11 "a system which is important to safety." 12 MR. SIESSs It says "a system important to 13 saf ety." 14 MR. PAGEs The " system" but not the " valve." 15 ER. CARBONS Oh, okay. All right. l 16 MR. ANDERSON: A little further clarification. 17 The ASME Code Section 11 used to have in it a Category E, 18 which was administrative 1y controlled valves. What it was 19 was checking valves like this to see if they were locked 20 open or closed. They took that out of Section 11. We are l 21 putting it in the Reg Guide. 22 MR. SIESS4 In cid en ta lly, when you check a valve 23 t ha t is locked open or closed, do you just check it to see 24 whether the lock is on it? Or do you check to see whether 25 it is open or closed? This is an old question, now, from . O l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202, 554-2345
i 124 () 1 the ACES. We have seen a couple of examples of valves where 2 everything was in the open position except the valve. 3 (Laughter.) 4 MR. SIESSs You know, the spruce-up ran it from 5 the gate, and then the crew was all the way out and the gate 6 was still sitting in there. So does this check really i 7 involve a flow test c2 some kind to see that the valve is 1 8 truly open? Or just that the wheel is all the way out and 9 the lock is on. 10 MR. PAGE: To answer you, " appearance" is wha t has 11 been used. 12 ER. ANDERSON: The Code has also introduced 13 requirements that you should be able 'f tell the position of O 14 the disk. 15 M'f. SIESS: That would help. 16 MR. ANDERSON: That is a new requirement for 17 valves. 18 MR. SIESS: Because this would catch the i nt ces 19 ve have seen where a valve was locked closed whec ic _a 20 supposed to be loc 4ed open, but it would not help the one 21 where the stem is separated from the disk. 22 MR. CARBON: I ha ve a further question on this. 23 You clarified it for me, I thought, but as I think about it 24 I am not sure. 25 The system is important to safety, and it is in a O ALDFDOON oRTING COMPANY,INC, 400 VIRGINIA AVE., S.., WASHINGTON, D.C. 20024 (202) 554-2345
125 {} 1 normal flow path of an engineered safety feature. Wouldn't 2 the valves likely be then important to safety, also? 3 MR. PAGE: No, that is not necessarily true. I 4 think Frank 's example a minute ago was an example of TMI 5having such valves. 6 MR. SIESS: What about the valves on the 7 accumulator tanks? When you pressurize, you close them and 8 lock them closed; right? 9 MR. PAGE: The isolation valve on the 10 accumula tor? 11 MR. SIESS: Yes. 12 MR. PAGE: Yes. 13 HR. SIESS: Now before you go up, that has to be 14 locked open, I assume, when you get back up at a certain 15 level? 16 MR. PAGE: When you get up above 6-or 700. 17 MR. ?IESS: It is important that it be locked in 18 the rioht position at the right time. It is in a system 19 important to safety, but the valve itself doesn't have to be 20 tested? l l 21 MR. PAGE: No. Testing of the valve itself is not l 22 a part of this section here. We only want to verify that it 23 is in the correct position. () 24 MR. SIESS: Would that valvc como under one of the 25 other ca tegories't l ALDERSON REPORTING COMPANY,INC, 400 VIRGIN lA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
l 126 l 1 MB. PAGE4 I believe the valve you are talking 2 about does not fall under this category. 3 MR. SIESS4 If it is locked open or closed, what O 4 category would it fall in? 5 MR. PAGE: I believe that valve -- you are talking 6 about the accumula tor isola tion valve. That is an active 7 valve. 8 MR. SIESS: That is an active valve, so it would 9 come under one. Okay. But in the a uxiliary f eedwa ter to system, those valves were locked closed. 11 MR. PAGE: As I understand it, they had been 12 locked closed for system pressure test, and then had been 13 allowed to remain in the closed position. 14 MR. SIESS: And they were supposed to be locked 15 open. 16 MR. 2 AGE: Once the test is finished, they are 17 supposed to be reput in the open pocition, and then verified 18 that they are in that position. 19 MR. SIESS: Those valves will not be tested for 20 anything else? 21 MR. PAGE: No. 22 MR. SIESS: Because the auxiliary feedwater system 23 is not a system important to safety? ( 24 MR. PAGE: The auxiliary feedwater system is a 25 system important to safety. Whether the valves meet stroke ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
127 j 1 timing or other requirements of Section 11 is not {) 2 important. 3 MR. SIESS: Yes. O 4 MR. PAGE: They merely perform the other tests on 5 the rest of the system. 6 MR. SIESS: Does that help you, ax? 7 MR. CARBON: Yes. 8 MR. SIESS4 Item 5. As I say, that is a nice 9 clear statement. The example is confusing. 10 Item 67 11 (No response.) 12 MR. SIESS Item 7? 13 MR. ETHERINGTON: Editorially, I notice the word (} 14 "f requency" is used quite a lot. The " shortest test 15 f requency" is really " shortest test" period, isn't it? 16 MR. SIESS: Yes. " Frequency" does not qualify 17 "short" cr "long." 18 Anything in 7? 19 (No response.) 20 MR. SIESS: What about the implementation for 21 operating plants, about nine months. Is this something that 22 has been ongoing? 23 MR. BAKER 4 As I said in my introductory remarks, (]) 24 this is not a new requirement. They have been sending this 25 out. It has been going out as guidance rather than a Reg O ALDERSON REPORTING COMPANY,INO, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
128 1 Guide. 2 MR. SIESS: Now on the plants in the last 3 paragraph, "under construction with an OL applica tion 4 submitted," they have got th ee months to revise their 5 list. Now is this one of the outfits that sta rted off with 6 127 Can they do a good list for 700 in three months? 7 MR. BAKER: As I said, NRR has been sending out 8 very much the same guidance, so they e?uld have this 9 guidance already. 10 MR. SIESS: Do you think we have a Guide here that 11 is in the original concept of the guides, of simply 12 formalizing a position that is well established? 13 MR. BAKER: In this case, yes. 14 MR. ANDERSON: It comes closer. 15 MR. SIESS4 Rather than plowing new ground. 16 I am looking at Appendix A. The editor will work 17 on that. The capitalization is random. 18 On page 10 in line 17, there is a note, "the 19 terminology for various sytems such as accumulator systems 20 and others may vary upon the distinctive preference." 21 MR. BAKER: We could just say " preference." 22 MR. SIESS: I think so. 23 I notice in the value impact statement it said O 24 tha t : At the time of initiation of this task, it was 25 decided that if the development of a Regula tory Guide would O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
129 1 be the most viable alternative," that was two years ago I 2 think somebody said. Do you still feel this way? 3 MR. EAKEPs 'a'e ha ve recen tly had a discussion with O 4 some of the people in NRP that are using it, and they still 5 f elt there was a need for it. 6 ER. SIESS: What is the alternative? The 7 alternatives listad here a re regula tions, na tional 8 standards, NUREG Series Reports, or a Regulatory Guide. 9 (Pause.) 10 Is it possible to incorporate this kind of 11 material into Section 11? 12 MR. ANDERSON: The reason this guide is wren is 13 tha t Sec tion 11 for most of the Code does not feel it ,s 14 appropriate for the Code to specify which component should 15 be constructed, or operated, or tested to specific i 16 req uiremen ts. So for instance we have Reg Guide 1.26 which 17 tells what it chould be built to, Section 3, and the various 18 parts of it. 19 When the Code was written, it was concluded that 20 the owner of the plant would have to specify which valves I 21 s ho uld be classified as "A," "B," "C," "D," or "E," and 22 subjected to which tests based on a specific system to be 23 had in that plant and how they were teing called upon to 24 perf orm. 25 So that we had an obligation eight years ago, nine O ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
130 1 years ago to get this Guide out when the Code was written 2 that way, and we are now getting it out. 3 MR. SIESS: And of course you are saying that it O 4 is still up to the owner, but you are going to help him 5 decide. 6 MR. ANDERSON: That is it. 7 MR. SIESS: Anything else? 8 (No response.) 9 MR. SIESS: We have given you some suggestions. I 10 will throw you my copy for some editorial input. It does 11 need some work. 12 (Handing document to Mr. Baker.) 13 Does anybody have any objection to sending this () 14 out and letting other people pick over it? 15 (No response.) 16 MR. SIESS: Okay. So moved. 17 The last item we have is a draft of Revision 2, 18 Regulatory Guide 1.105, Instrument Set Points. This Guide 19 is going to solve all of our problems regarding set point 4 20 drift, and thereby reduce the nunber of licensee event 21 reports at least 50 percent. 22 The Guide endorses, with an absolute minimum of 23 exceptions, an Instrument Society of American Standard () 24 ISA-dS67.04, entitled " Set Points for Nuclear Safety Related 25 Instrumentation Used f or Nuclea r Power Plants." Now you O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
131 /~% 1 have got other people using " safety rela tred. " V 2 It is intended to co out for comnent and is J 3 submitted to us sinply for any comments and (:) 4 recommendations. One of the first questions is the status 5 of S. 6704, which in my copy is marked " draft," and I think 6 we would like to know the status of the draft. 7 MR. WENZINGER: Mr. Chairman, this is Ed Wenzinger 8 from the office of Research. The draft is currently 9 undergoing ba11otting in the ISA Standards and Practices to Report, which is the final approval authority in the ISA. 11 MR. SIESS: Okay, it is pretty well along. It is 12 u p for a pproval? 13 MR. WENZINGER: That is correct. They are the 14 ones who have given us permission to use the draft. 15 MR. SIESS: That is good. That is what we have 16 here ? 17 MR. WENZINGZRs That's correct. 18 MR. SIESS: Suppose we just go through it. It 19 w on ' t take a long time. i 20 Does anyone have any comment on the proposed Reg 21 Guide Pa rt A, Introduction, which references Criterion 13 22 and paragraph 50.36. 23 MR. WENZINGER: That is no change, Mr. Chairman, () 24 inciden tally, from the original Reg Guide. 25 MR. SIESS: Yes. Then the discussion in the first O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554-2345
132 {} 1 paragraph
- w. Tere it says:
"This standa rd is identified as 2 set points." I think it would be worthwhile to oive it its 3 proper number there. 4 MR. WENZINGER: I'm sorry? 5 MR. SIESS4 It says, "This standa rd is identified 6 as" and it just gives the title. 7 MR. WENZINGER: 6704 8 MR. SIESS: 6704 That is more identification. 9 MR. WENZINGER: Fine. We will be glad to do 10 tha t. 11 MR. SIESS: In this next-to-the-bottom line, it 12 says you have already identified a standard there, and you 13 say that it has been incorporated into "a" proposed national 14 sta nda rd. I don't see any real reason to use an indefinite 15 article. It is "the" propo sed sta nda rd, an d it will not be 16 " proposed" prertmsbly at that time. 17 MR. WENZINGER: That will not be correct when it 18 is published final, but it is at the moment. 19 MR. SIESS4 I just identify it. It has not been 20 incorporated into ISA Standard 6704 21 MR. WENZINGER: Fine. 22 MR. SIESS: Does anybody have any comment on the 23 Regulatory Position or the Implementation? () 24 MR. WENZINGER: One point. There is the incorrect 25 date on the draft. The actual date of the draft is May 22, O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
133 1 '79, not June 26th. ~ 2 MR. SIESS: Where is that? 3 MR. WENZINGER: The first line in the Regulatory O 4 Position, Ma y 22. 5 MR. ETHERINGTON: Editorially, the third line, the 6 antecedent is " criteria" so that should be "e s tab lis hes, " 7 shouldn' t it? 8 MR. WENZINGER: Singular? Yes. Thank you. 9 MR. SIESS: At least this one has got -- Why did 10 you think it necessary to define " systems" -- oh, you define 11 "saf ety related" as " systems important to safety"? 12 MR. WENZINGER: Yes, consistent with the 13 discussion you had earlier today. 14 MR. SIESS: Does anybody want to look at or 15 comment on the ISA standard, or figure on how that is going 16 to reduce set poin t drif t? You know, sometime I think we 17 ought to ask the Staff to get us one of these instruments 18 a nd b rin g it in and show us what these " set point locks" 19 are. Give us a diagram as to why all these set points drift 2(, all the time. i I l 21 MR. WENZINGER: Set point drift can be caused by a 22 number of things, mechanical things as well as electrical 23 things. It can be caused by a change in calibration of a (D 24 sensor. It can be caused by a change in the value of a %) 25 power supply output voltage. It can be changed by l O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D C. 20024 (202) 554 2345
134 1 environmental conditions that might affect the current t ha t 2 the transistor produces. It can be changed by the aging of 3a resistor, any number of things. g V 4 When you looked at it, it really would not tell 5 you very much. You would see a nice little box with a lot 6 of electrical components in it. I could point to a 7 screwdriver adjustment that had a little nut on it that you 8 tighten down so that due to vibration the estimate would not 9 change. 10 MR. SIESS: That is not always enough. 11 MR. WENZINGER: That is correct, but that is just 12 one of the possible causes. 13 MR. ETHERINGTON: Is the drift usually 14 progressive, so that you are able to monitor it continuously 15 to keep it from drifting? 16 MR. 'JENZINGER: As a general rule, that is 17 correct. In fact, the standard requires that you keep track 18 of how the drift varies with time, and allows that that 19 would be a way of determining how often one would check to 20 see what the actual set point might be. 21 MR. SIESS: Harold says, "is it usually 22 progressive?" I will ask you: Is it always progressive? 23 MR. WENZINGER: The answer to the first question 24 is "yes." It usually is. The answer to the second question 25 is "no." O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
l 135 1 MR. SIESSa The component could actually fail? {) 2 !B. WENZINGEE: Yes. Some components could fail 3 catastrophically and yet only have a small effect on the set ) 4 point, although a measurable one. 5 MR. ETHERINGTON: Could some reverse themselves? 6 MR. WENZINGER: Oh, yes, those that are pressure 7 and temperature sensitive. 8 MR. SIESS: The impact of this on safety is 9 negligible because there are usually multiple readings, 10 multiple inputs, and things of that sort? A sudden failure, 11 a sudden shif t in a set point is not likely to cause a 12 serious problem in a plant other than shutting it down, 13 maybe? 14 MR. WENZINGER: That is correct. 15 MR. SIESS: Eecause usually you are reading off of 16 more than one instrument. 17 MR. WENZINGER: And it may not cause shutdown due jto the coincidence. 19 MR. SIESS: Logic, again. 20 MR. WENZINGER: That is correct. 21 MR. SIESS You were on the committee? Is that 22 rig ht ? 23 MR. WENZINGER4 Yes, sir. () 24 MR. SIESS: Now this apparently incorporates 25 everything you thought was important from the previous Reg A%Y ALDERSoN REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
136 1 Guide? 2 MR. WENZINGER: That is correct. I was the author 3 of the original Reg Guide, and I was the NFC member on the 4 committee. 5 MR. SIESS: I did not notice an awfu1 lot of 6 decrease in LERs af ter that original Reg Guide came out. Do 7 you have any feelings on that? 8 MR. WENZINGERs We tried to incorporate all the 9 items that we thought would increase that into the 10 standard. 11 MR. SIESSa Did the Reg Guide do much good? 12 MR. WENZINGER: One of the things the Reg Guide 13 did not adequate 1y address is the question of providing an 14 adequate margin between a nomina 1 set point and the 15 a11owab1e value of the set point, which is shown on page 12 16 now of the standard. That was not addressed in the old Reg 17 G uide. In other words, in a number of cases, and in 18 particular GE pressure switches, there was an inadequate 19 al1owance between the nominal trip set point and the 20 allowab1e value. So that even a very smal1 amount of drift 21 resu1ted in exceeding the tech spec limit. 22 This standard now specifically addresses that and 23 requires that sufficient margin be provided. So that in the O 24 1nterve1 setween the schede 1ed ed3eetments of set points, 25 the expected value drift would be less than that causing it O ALDERSON PCieORTING COMPANY,INC, 400 VIRGINIA AVF, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
137 ] 1 to exceed the allowable value. 2 MR. SIESS Is it likely to increase the number of 3 trips? 4 MR. WENZINGER: I think no t. It also addresses 5 tha t question of changes in drift that go below the nominal 6 set poin ts f or increase in value and reverse for decrease in 7 value. It does not require resetting when the nominal t rip 8 point goes below the set point limit, but it recommends it 9 on the basis of avoiding these spurious trips. 10 These various points, incidentally, were not 11 covered in the original Guide. 12 MR. SIESS: I get the feeling that this is the 13 closest thing to a compete endorsement of a standard we have 14 ever seen. 15 MR. WENZINGER4 I agree. It is the closest thing 16 tha t I have seen. 17 MR. SIESS You came awf ul close to not adding 18 any thing. 19 MR. WENZINGER Yes. They did desire to reference 20 an IEEE standard which we have cedorsed separately in that l 21 reg a rd. 22 MR. SIESS: Any objection to this going out for 23 comment, gentlemen? 24 (No response.) 25 MR. SIESS: You are a very effective member of the O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
138 1 committee. 2 MR. WENZINGEF: Thank you. 3 MR. SIESS: You made all your points, I a ssume. O 4 XR. WENZINGER: All the important ones. 5 MR. SIESS: Gentlemen, we have a number of items 6 coming up for next montha Reg Guido 1.23 on meteorological 7 programs, post-comment guide f or endorsement vnich I don't 8 think will be much of a problem. Apparently no' of us here 9 know much about meteorology, but we will get Frank Gifford 10 to look at it, I think. 11 We have got Reg Guide 1.13 on spent fuel storage 12 f acility desion basis. It was originally scheduled for tis 13 month, but the staff had some internal problems with it. 14 That is a precomment guide which we may spend some time 15 hea ring wh a t the Staff's internal disagreement is. Is that 16 possible? 17 MR. MORRISON: Yes. In fact, it is possible that 18 it may not even get resolved. 19 MR. SIESS: Is it a real argument? 20 .1 R. MORRISON: That is in another division. I am 21 not that familiar with the details. 22 MR. SIESS: Then we have a proposed guide, a 23 precomment guide on response time testing of instruments (]) 24 used in protected systems, which is endorsing I ouess an ISA 25 standTrd? l () 1 ALDERSON REPORTING COMPANY.,ING, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
139 1 MR. DURAISWAMY: Six or seven. 2 MR. SIESS4 And we have another precomment guide 3 item which is proposed revision to 10 CFR Part 50, Section O 4 50.55( A), Codes and Standards, which is quite substantive. 5 This is Class II and III categories, right? 6 MR. MORRISON: Right. 7 MR. SIESSs How soon can we get that? We would 8 like for Bush to have a chance to look at that. 9 MR. EURRISON: Well, we have to have it three 10 weeks before the meeting, so we are talking about like in a 11 week. 12 MR. SIESSa Because we would really like a change 13 to look at that thing, and Harold is not officially on this ( 14 committee, are you? 15 MR. ETHERINGTON: I was not planning to come in 16 nex t mon th. 17 MR. SIESS: This is a precomment, anyway. When it 18 90es out f or comment, it will get to you, and we will get 19 your comments later. 20 Then the last comment on this list is an internal 21 matter. Mike Bender had written a letter two or three 22 months ago suggesting that it would be nice if the Staff 23 could write a short safety analysis report, or a safety (]) 24 evaluation. The applicants could prepare a short safety 25 analysis report for ACRS use. And since that had something O ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
140 (]) 1 to do with regulatory activities, they asked us to look at i 2 it. If we can get Mike here for the meeting, we will 3 discuss it. If not, we vill wait until we can. I think it 4 comes under the item of " pie-in-the-sky." 5 MR. CARBON: We are going to ask someone to make 6 more reports? 7 MR. SIESS: Just shorter ones. 8 MR. CARBON: it would be an additional one? 9 MR. SIESS They could not get an SAR down to 10 whers it v s 15 years ago, anyway, and those were not 11 short. Those were three volumes. 12 Gentlemen, where is the schedule? Next month, the 13 f ull Committee meetings are the 15th, 16th, and 17th, I 14 guess, the usual Thursdai, Friday, and Saturday. We would 1 15 of course like to meet on the 14th. 16 As of now, we are scheduled tenta tively it says 17 h ere, " meeting on the floatip~ nuclear plant," manufacturing 18 license on the 14th, which micht sli p. Human factors has a 19 meeting. Nobody here is on t$at, but some people who are on 20 the committee are on it, Kerr and Bender and Mr. Ward. 21 Procedures and Administration is scheduled to meet 22 a t 1:00 p.m., and that would get Bender and maybe that could i 23 be moved antil 6:00, 4:00, 5:00 or 6:00. If necessary, I l ) 24 think one is optimistic. And Shipping Port is scheduled to l 25 meet on that date in the afternoon. ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
141 O the= te='=tive1r e re e'caea=1ea to eet 2 MR. CARBON: It looks to me like we could meet in i 3 the morning without any great 4 MB. SIESS: The thing is, I think we would have 5 more if they call came in, and then we could get through by 6 12:00. We might get through a pretty good batch by 1400 7 o ' clock. 8 Then the other alterna tive of course is to meet 9 the day before, on Tuesday. Monday is a holiday for some 10 people. It is Thanksgiving Day in Canada, and Columbus Day 11 her e. I do not know if anybody else minds traveling on it; 12 I d on ' t. 13 I think I will just let Sam do a little 14 negotiating during the Full Committee meeting with members 15 o f this committee. 16 MR. DURAISWAMY: We do have a meeting room 17 problem. 18 HR. SIESS: Yes. We do not need this big room. 19 It is just a small group from the staff coming in, and we 20 are not going t0 get industry people on Reg Guide 1.23, and 21 they usually do not show up for precomment guides. 22 I would like for you to try, Sam, to get it on 23 Wednesday and plan on it not te. kin g all day. Procedures can 24 shif t to later in the afternoon. But if not, we will see 25 wha t we have to do. Negotiate with the committee members O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 . ~. _... -. _ _... _, _ _. - - - _ - - - _ _ _.. -. _ _ _. _ - _ _ - _ _ _ _
142 (} t and see how many of them plan to go to something else. 2 MR. DURAISWAMY: Okay. 3 MR. SIESS: Shipping Port. I do not think that is 4a license activity, and I think that is a bunch of nonsense, '~ 5 frankly. Bill, we will meet either Tuesday or Wednesday, 6 and we will get as much of this as we can in case we are 7 ticht for time. You might think about which one of these 8 you would put at the bottom of the list. 9 I would propose not to take them in the order on 10 Sam 's list here, but to get Part 50.55(A) in there fairly 11 early, and try to take care of 1.23. Right? 12 MR. MORRISON: Yes. That is right. Those are the 13 two most important ones. ( 14 MR. SIESS: The other two, if they get held up a 15 little bit, we might just go ahead and send snem out after 16 we have seen them. I would like to consider that as a 17 possibility, that if we get a copy of the precomment guides, 18 one on endorsing the s tanda rd, send it out and let's get 19 some commen t. 20 MR. CARBON: I would support that, but I will have 21 dif ficulty getting there on Tuesday. I will try to do it. 22 MR. SIESS4 Suppose it were Tuesday af ternoon? l 23 Would that be easier? () 24 MR. CARBON: It would be easier, but it would 25 still be hard. l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
143 () 1 MR. SIESS4 I think we will try to get it on 2 Wednesday, but figure that we could probably do it in a half 3 a day, if a half-day means 1:00 o' clock. 4 MR. DURAISWAMY: Do you need the staff for 5 toaorrow? Tomorrow we are scheduled to talk about the 6 procedures. 7 MR. SIESS Bill, we have gotten ourselves 8 involved in rules, which is not really new because we have 9 been looking a t 50.55 and those rules; but with the Kemeny 10 Cr.mmission and others saying we ought to have a more active 11 part, we have picked up on it and for now all rules that 12 have to do with things we are interested in are sent to us. 13 This subcommittee is the steering committee for it. 14 We pass them out to va.ous people, and I am going 15 to take some time during the Full Committee meeting to go 16 over this with the Full Committee. Sam is collecting a list 17 of rules. There are an awful lot of them. They come in at 18 various stages and various degrees of importance. Do you 19 think there ought to be somebody from the rule-writing 20 groups to participate in that? I can't figure who it would 21 b e. 22 MR. MORRISON: It is hard for me to say. 23 MR. SIESS: It is not just the Office of () 24 Research. We get some from ELD, f rom Licensing. 25 MR. MORRISON: NR3 is putting out a lot of rules O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
i i 144 () 1 on their nea r-term OL opera ting re ac to rs, near-term cps. 2 MR. SIESSs We have looked at them so often, most 3 of them are going to be coming from Standards. I don ' t 4 really think we need tog much participation. I think it is 5 mostly our problem. I just thought I would mention it. 6 M'. MORRISON: When will this be? 7 MR. SIESS: Friday morning, last thing. I will 8 think about it. I do not think anybody needs to be there. 9 Bob Bernero needs to be here. 10 MR. MORRISON: Jerry Thomas is the designated 11 person in R AS. 12 MR. SIESSs Yes, he probably should show up. 13 MR. MORRISON: For the ACRS liaison. 14 MR. SIESSs I think we have more time than we 15 need. Your liaison man probably ought to show up, but again 16 it is not too important, maybe for us to try to decide how 17 ve want to handle some things. If we decide on that, we 18 will write a note to the staf f and do it. I don't think 19 anybody realized how many rules there were. We don't need 20 anybody else here when we present this to the Full Committee. 21 The meeting is adjourned. 22 (Whereupon, at 12:38 p.m., the subcommittee 23 meeting was adjourned.) 24 25 O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 t
t t MUCLEAR REGULATORY CO.W4ISSION O This is to certify that the attached proceedings before the 8 in the matter of: ACRS/ Subcommittee on Regulatory Activity Date of Proceeding: september 9, 1981 Docket Number: Place of Proceeding: Vashington, D. C. were held as herein appears, and that this is the original transcript thereof for une file of the Commission. Jane W. Beach Official Reporter (Typed) n t u. f, bassil / l C icial Reporter (Signature) O O
O O O. ~ h f%JOR ATAS OF REVISION TO ABS 3.2 (19E N
- 1. WPORTItG ARRANGFKfffS FOR 0q racANI7ATIONS
- 2. REVIEW AND AUDIT PROGR#1 ItKLWIfE ACTIVITIES, CONTENT, AND FRFRENCY
- 3. ESPONSIBILITIES T SHIFT Si!PERVISOR AND OWPATING PERS0H1 14. SHIFT R LIEF A.T T11Rf0/ER
- 5. CONTROL R001 ACCESS
- 6. WORKING IUR CRITERIA
- 7. EQl!IFENT CONTROL
- 8. EERGENCY PROCEDUE FOR%T AND CONTENT
- 9. APPEf0lX A, lYPICAL PRXEDUES s a-+
~ O O O WNEES FROM "FOR C0ffD'T" VERSION T RG 1.33 EGULATORY POSITION CHANGE 1 POSITION REVISED TO CLARIFY TIE EIATIONSHIP EMEN RG 1.28, "QA PROGRAM EQlIRENNTS (DESIGN At0 CONSTRICTIOFD," AND RG 1.33 2 FBI POSITION TO CLARIFY THE MFINITION T "OlRLITY C6TROI." ~ 3 POSITI0f! REVISED TO CLARIFY lHE ACCEPTABILITY T REPORTING ARPANGEM9fiS MID TO CLARIFY TE QA ORGANIZATIm INVOLVEENT IN TE APPROVAL T KRSONtEL WHO KRFORM VERIFICATION FlKTI0tS 3 (DELETED) TE AREAS T K5DiF0GE HAVE BEEN IPCLLDED IN ANS 3.2. THE itf-tjelT TO ANS 3.1 HAS BEEN CLARIFIED IN ANS 3.2. 14 POSITION PFVISED TO PFFEPFNCE RG 1.101 e 46 5 5 (DELETED) DISClSSION OF ISEG PRENAllE 6 (DELETED) ANS 3.2 HAS BEEN KVISED TO DISWSS CONVENItE A DJORlN. 5 NEW POSITIft! TO Al.lDI URGD!T TEW, S C. OWrf w-
O O O ~ CHAtEES FROM 'FOR CGTENT" VERSION E E 1.33 (cont'o) PAGE2 REGIAATORY POSITION CHANGE 6 FBI POSITION TO CLARIFY TE REFEEtEE IN ANS 3.2 T0 tm-1 FOR AIDITItG GllIlRTE 7(ELETED) ANS 3.2 PAS BEEN REVISED Ti; itEUJnE EE PROVISION WAT BE QA ORGANIZATION ENSIE TE PROPER RRFORM40E E AlDITS. ELR9TS TO E CONSIDERED IURING AN AUDIT AE CONSIEED TO E SIFFICIENTLY ADIRESSED IlY ANS 3.2. 7 POSITION REVISED TO ALLOW FLEXIBILIT/ IN TE ftlf0RMANCE OF A PLANT T0lR AND SHIFT EPORTING. 8 POSITION REVISED TO ElfiE ENDORSEE NT OF ANS 3.2 KM KING HOUR CRITERIA 9 PDI POSITION TO CLARIFY BE APPROVAL 0F TDFORARY PROEIUES CONSISTFNT WIE TECH SECS, 30 (ELETED) POSITION 9 HAS MADE llilS POSITION UfECESSARY E
O O O DIANGES FRffi "FOR C0tKNT" VEPSION OF RG 1.33 (axa'o) PAGE3 EGULATORY POSITION DIANGE 10 POSITION REVISED T0 (1) CLARIFY WEN VERIFICATION MAY E ACCOPLISHED BY WANS OTER THAN A SECONO OIRLIFIED PERSON, (2) E CONSISTENT WITH t11EG 0737, (3) ELETE THOSE PROVISIONS INCL!ED IN ANS 3.2, AND (4) ALLOW FLEXIBILITY IN THE QUALIFICATION OF VERIFICATI0t! KRS0hEL. 32 (ELETED) QA ORGANI7ATIW APPW/AL OF KPSONNEL ADDRESSED IN POSITION 3. EVIEW 0F PROCEDlES ADDRESSED IN POSITION 14. PERFORMANE (F All0lTS HAS EEN INCLIED IN ANS 3.2, 11 NEW POSITION TO ENSUE FOLLOW-UP ACTION IS TAKEN TO VERIFY IMPLEENTATION rF CORRECTIVE ACTION (PPWIES CONSISTENCY WITH EG 1.28) 32 NEW POSITION TO DISO.'SS MAINTENANCE OF RECORDS (PROVIIES CONSISTENCY WITH m 1.28) 13 POSITION EVISED CLARIFY THE I!SE OF ANSI N45.2 IN LIBl 0F N04-1
E o o o CHANGES FRCM "FOR OMENT" VERSION OF RG 1.33 (CONT'D) PAGE4 EGUlATORY POSITION CHANGE 14 POSITION EVISED TO CLARIFY (1) THE INWLVEKNT E THE QA ORGANI7ATION IN THE DEVELOPTNT OF PROCEDURES, (2) TE APPROVAL OF PROCENIES EQUIRED BY TE01 SKCS, (3) TE KRF0PMANE OF A STEP-BY-STEP REVIEW 0F NEW PROCEDIES, AND (4) TE PERF0fu%NE OF PROEDUE EVISIONS. 15 (DElflED) COWNis ON THIS POSITION HAVE BEEN FORWARDED TO THE COGNIZANT PRCSTAFFFORACTION 15 PART OF POSITI@! DELEIED SIN & (1) QA ORGANIZATION APPROVAL OF ERS0tEL ATRESSED IN POSITION 3, (2) REVIEW 0F PROCEDURES AtDRESSED IN POSITION 14, AND (3) ERFORMANCE OF AllDITS HAS BEEN INCLilDED IN ANS 3.2. PROVISION AmED TO CLARIFY THE INDEPENDENE OF KRS@EL PERFORMING INSWCTIONS. 16 NOCRWE 18 (ElEIED) POSITION ADEQtMTELY ADIRESSED IN ANS 3.2 19 (ELETED) POSITION ADEQlMTELY ADIESSED IN ANS 3.2. 20 (DElflFB) POSITION AE.00ATELY ATESSFD IN ANS 3.2.
O O O l OMNGES FROM "FOR C0ffElfT" VERSION OF R31.33 (cmT'n) PAGE5 EGIIIATORY POSITION TEE 17 N0 Gl# E 18 POSITION KVISED TO CLARIFY THE KMORIZATION OF IttEDIATE ACTIONS BY OPERATORS. POSITION REVISED TO IRETE G!lIDANCE FOR TE APPROVAL OF ESF RESET AND DEPARTi1E FROM EERGENCY PROCEll!ES THAT HAS BEEN INCLl0ED IN ANS 3.2. 19 POSITION REVISED TO TElfiE SYWTOPE INCLIOED IN ANS 3.2. 24 (IELETED) POSITION 4 MAKES THIS POSITION INECESSARY 20 POSITION REVISED TO CLARIFY THAT INSTRICTIONS AE ECESSARY ONLY WHEN SYSTEM IS ALTEED 21 POSITION REVISED T0 (1) ElEE PROCEDURES INCLII)ED IN ANS 3.2, (2) CLARIFY EARLIER GilIDANCE, MD (3) INCUJE PROCEDlPES FOR CRANEOPERATORS. 27 (DELEIED) ANS 3.2 HAS INCLUDED DISOGSION OF PROCEDIES FOR #NINCIATORS 22 NEW POSITION TO INCUE A PRnCEDIE FOR HANDLING EAVY LOADS i
i O O O j i OMNGES FR01 "FOR CatBIT" VERSION OF RG 1.33 (cota'n) PAGE6 1 1 3 EGilATORY POSITION 0%NGE' 1 23 POSITION REVISED TO TIEE THOSE ASKCTS ADE0lRTELY I 1 ADTRESSED IN ANS 3.2. i i ^ i I i i i i I i l l 1 i i 1
fN Instrmuent Society of America 1] l k l Reply to: IBM Corporation 2K1/004 P.O. Box 1328 1980-a1 tiecuti.e soard Boca Raton, FL 33432 f accuthe Committee
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(] s.n.fo",*/e"'"' September 3, 1981 v r.e,.s..ein,3<,3 s ie m sn. e co, Mr. Karl R. Goller, Director o s'.'."J,'o' Tao! Division of Facility Operations """"',"';'"',,, Office of Nuclear Regulatory Research ^Mg',*" Nuclear Regulatory Commission Washington, D.C. 20555 Department Mce Prc,idents '#tG% s.ip ..,o u.... 4
Dear Mr. Goller:
w~rgusvg '",',',,'"",""'"", Th i s l e t t e r au t h o r i ze s t h e NRC t o e n dors e I S A-dS 6 7. 04, r.,io,,,,,,,8if',*l" d r a f t F, dated 5/22/79, and ISA-dS67.06, draft 0, dated
- ~mnde*~ge,; 10/21/80, as specified in the " Instrument Society of uc~n'oc> America (ISA) Huclear Regulatory Commission (NRC) Agree-
"""U."i2 ment On Use of Draf t Standards", copy enclosed. To,ey Pines Technology Publ.t&hons s,one & w,ss,1,'""."".ce"> Although we are authorizing NRC use of these two draf t standards, you should be aware that several concerns Standard * & Prarr isd!" U regarding their technical content have been raised by M [f,0.'/Jmembers of the ISA Standards & Practices Board. These '"""*"*"'* technical concerns may ultimately result in changes to / ""' '""d,'j' IS A-dS67.04 and ISA-dS67. 06 prior to final approval and rs,MiJ"c"' publication by ISA. Ost,ws 2 R W. I, vine cim a s i.n & co.inc. We will, of course, work closely with your staff during o L&.TC">'dthe final review and approval of these two standards. If """""7',i"'; ISA can provide any additional assist ance dur?., your - uo, Ef/o'e-;l review procedures, please let me know. c uo EO ..... e d% o."4' '.Te,' Each & Astoria es c,3,"lC8 Thomas J. Harrison 6eo-oo coppe c*a Vice-President C +r,<t 9
- "i "fn', ;. Standards E. Practices Dept.
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s%..n....io...,,,,,n fwY, O T J H / b h 0"'".',0 s~s.eiro. ca Enclosures l P C. Mo,a tesineers & Co
- l. O' o.u,,c. n c c :
Erin Collins, ANSI HQ. n!/dI*,*i'R Lois Ferson, ISA HQ. ,,,,, ["j* Harold Hopkins, Chairman SP67 ,f,f,ugr; Richard Jones, ISA S&P Bd. Joseph Tana, Secretary SP67 1.~o...c o.,~,~ Ed Wenzinger, NRC George L. Wessman, Chairman ANSI NSMB INTERNA TIONA L HEA DQUA RTERS 67 A s EXANDER DRIVE. P.O. box 12277, RESEARCH TRIANGLE PARK, NC 27709
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1 l INSTRUMENT SOCIETY OF AMERICA (ISA) - NUCLEAR REGULATORY COMMISSION (NRC) AGREEMENT ON USE OF DRAFT STANDARDS This is an agreement between the ISA Standards & Practices (S&P) o (. Department and the NRC Division of Facility Operations. l The purpose of this agreement is to ensure a consistent and reason-able use of draft ISA standards by the NRC. This agreement continues in effect until either the NRC Division of I Facility Operations or ISA notifies the other in writing why and when I the agreement should be terminated. This agreement permits the endorsement of draft ISA standards by the NRC under the following specified conditions: 1. In consideration of its copyrights, ISA shall be the sole agency for public distribution of draft ISA standards or approved ISA standards endorsed by NRC in Regulatory Guides. 2. In order to minimize, to the extent practical, any potential for compromising the consensus process that could result from endorsu-ment of a draft standard, the NRC will obtain and consider public input on the referenced draft standards and Regulatory Guides through Q its formal regulatory process. Any such comments will be forwarded to the ISA SP67 Committee for their consideration. 3. When considering the endorsement of a draft ISA standard in any NRC Regulatory Guide, the NRC shall send the Vice-Pre ~ident of the ISA S&P Department a letter requesting permission to endorse that draft standard. Before actually endorsing the draft standard, the NRC shall receive written permission from the ISA S&P Department for that endorsement. Such permission shall not connote ISA approval of the draft standard. Draft NRC documents including Regulatory Guides issued for comment, 4. formal NRC reports, NRC Standard Review Plans, and Safety Analysis Report Outlines may endorse or reference draft ISA standards that have S&P Board approval for use. 5. Effective Regulations and Regulatory Guides that endorse standards generated by ISA should endorse published ISA standards only, taking into account the responsibility of the NRC and the need to provide standards on a ti'nely basis for the effective regulation of nuclear facilities. Assurance that this goal is pursued shall p be the responsibility of the Director, Office of Nuclear Regulatory Research, NRC. .I v If the draft ISA standard is released using step (4) above, the 6. Vice-President of the ISA S&P Department shall send a letter to the NRC staff with the proper draft (as edited by ISA staff) providing permission for endorsement of the draft ISA standard.
f. ~ 8 _2 In the event permission is not granted, the Vice-President of the 7. ISA S&P Department shall so inform the NRC in writing together with an explanation of the primary technical basis for withholding permission. g Copies of all correspondence between ISA and the NRC staff concerning the ISA V 8. the endorsement of draf t standards shall be sent to: Vice-President, S&P Department; the Managing Director of SP67; In addition, and the Director, Office of Standards Development, NRC. pertinent correspondence, such as the request for permissio be transmitted to the ANSI Nuclear Standards Management Board Chairman. t Endorsing a portion of a draf t ISA standard shall be permitted except that in no case shall only an appendix be endorsed, since this is 9. not a mandatory part of any standard.
- 10. The ISA Standards & Practices Department shall ensure that discussion is included in the standard that clearly indicatas the basis for the scope of the standard and delineates its constraints and Similarly, the NRC shall explain to the ISA Standards
' limitations. & Practices Department the basis for any significant exceptions and additions it may wish to make in endorsing the standard.
- 11. When a draft ISA standard has been endorsed, the NRC staff and
() ISA shall work closely together so that all technical issues are The endorsement procedure used by understood by both parties. the NRC staff shall recognize the likelihood of changes as the consensus process is completed and shall be flexible enough to Likewise, ISA shall recognize appropriately adjust for these changes. the impact of substantive technical changes made to referenced material on the endorsement procedure. RL
- l. E,14tl Date Thomas J. Hat *ison Vice-President - StP Department Instrument Socie ty of America b
b [ cf /fM/ / Date' Karl R. Goller, Director Division of Facility Operations Office of Nuclear Regulatory Research kq s I b h Y2ws F/n-lE i Glefi F. Harvey f / Date/ r-f Ex6cutive Director Instrument Society of America I l
DBa11elle wo Pacific Northwest Laboratories P.O. Bou 999 August 31, 1981 4 y' g Cl Rachland, % ashing.cn U.S A. 99352 --+...a Telephone tsmi 375-2223 Telen 15-2874 G ,.3. hwt.Ela.r.ic.cc"M, ~ ;15 thy CCWiiM ON Mr. Sam Duraiswamy, StaYf' Enhiheer~5 Advisory Committee on Reactor Safeguards U.S.. Nuclear Regulatory Comission Washingtcn, D. C. 20555 Dear Sam I have been reviewing the Regulations, Reg. Guide package piecemeal with the idea that portions may be forwarded. At this time, I do not plan on attending due to meetings in Washington the week before and the week after. I have completed my review of Appendices G and H as the top priority item. My examination consisted of changes since my May 31, 1978 letter, the ear'ier draft and the final draft incorporating or rejecting the coments received earlier this year. Basically, Appendix G and the ASME Codes track much better than in the old version which is a definite benefit. I feel the modification of g IV A-2, which was the most controversial item, retain sufficient safety margins without severely penalizing the plant operators excessively. The flange flaw problem was an outgrowth of ASME XI sample problems and the .*.ction taken by NRC to alleviate the problem would be what I expected. Most of the other changes in Appendix G were for editorial clarification rTther than being substantive. With regard to Appendix H, the major effort was to get it to track ASTM E 185. Almost all of the changes since last year are editorial clarification. The changes in II are relaxations without having negative safety connotations. B.uically I find the changes in both G and H in the correct direction and dm quite satisfied. Very truly yours, kVY T / ~5pq /er H. Bush 3 W Sen r Staff Consuitant l 519/ par /ttachments W -r
OBaHelle B Regulatory Guides Identification of Valves for Inclusion in Inservice Testing Program () Basically this guide is one of clarification of NRC policy; much is applicable to older plants. In essence, it endorses ASME XI re valves and clarifies when to do or not to do such testing. I see no conflicts with.ASME XI; the requirements are reasonable rather than unrealistic and I continue to feel that valves are the achilles heel of plants so these requirements are desirable. l.13 - Spent Fuel Storage Facility Design Basis i examined this guide somewhat cursorily. Basically they accept ANSI N 210 with evreptions. I had no problems. Possible some of the caveats with regard t3 ANSI are overly conservative; however, I'll leave that decision to someone else. RG 1.105 - Instruna nt Setpoints - Accept ISA S 67.04 with Clarifications One question. Obviously NRC considers the standard acceptable. The attached is still a draft. Is S 67.04 final? RG1.33-{ML () It is obvious that QA guides generate a great deal of discussion. I confess I have difficulties in understanding some of the more subtle nuances raised by industry. I have one more major concern. The NRC responded to the many industry comments by making a large number of substantive changes as deletions or revisions. Looking at them separately they seem to clean up the Reg Guide. I can't tell if there have been negative effects or not. I suspect that it may be necessary to develop another revision to handle the overall changes. My overall reaction is one of lukewarm acceptance; I'd like to see a clean copy. i f l f-I e. ,,.,.n ,}}