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Transcript of 388th ACRS Meeting in Bethesda,Md on 920807. Pp 160-264.Viewgraphs Encl
	ML20141M346
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Issue date:	08/07/1992
From:	; Advisory Committee on Reactor Safeguards
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0K!mNAL 9 O OFFICU1 TRANSCRIPT OF PROCEEDINGS ggq,. Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards

Title:

388th ACRS Meeting Docket No. O LOCATION: Bethesda Maryland DATE: Friday, August 7, 1992 Pacts: 160 - 264 ACTS ?"ce Jo:y-Re%,,h fome jfeof te Comdee n" ANN RILEY& ASSOCIATES, LTD. 1612 K St. N.W, Suite 300

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PUBIC NOTICE BY THE g UNITED STATE NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS / e DATE: Auctict 7, 1992 L) e The contents of this transcript of the proceedings of the United States Nuclear Regulatory Cor.aission's Advisory Committee on Reactor Safeguards, (date) August 7, 1992 as Reported-herein, are a record of the discussions recorded at the meeting held on the above date. This transcript has not been reviewed, corrected or edited, and it ray contain inaccuracies. (# l ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W. Suite 300 Washlagton, D. C. 20006 (202)1.93-3950

l-160 = 1 UNITED STATES-OF-AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 L*** 4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS-5 388TH ACRS-MEETING 6 7 N'uclear Regulatory-Commission 8 Room P-110 9 7920 Norfolk Avenue. 10 Bethesda, Maryland 11 Friday,_ August-_7,- 1992 12 The above-entitled proceedings commenced-at 8:30 13 o' clock a.m., pursuant to notice, David-A. Ward,: Committee-- -N 14 Chairman, presiding. 15 PRESENT-FoR THE ACRS COMMITTEE: .a. 16 Paul G. Shewmon, Vice Chairma'n 17 Carlyle Michelson,_ Member 18 Charles-J. Wylie, Member: 19 Harold W.~ Lewis, Member 20 Ivan-Catton,-Member 21 William Kerr, Member; 1; 22 ) J. : Ernest' Wilkins, L Jr., Member. 23 -Thomas S. Kress,--Member 24 William Linblad,' Member H 25 E. Igne, Cognizant'ACRS-Staff' Member l d". = ANN RlLEYJ &. ASSOCIATES,LLtd. 1 . Court Reporters - 1612 K Street, N.W., Suite 300? Washington, D. C. 20006 (202) 293-3950 l

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~. 161 1 PARTICIPANTS:. 0* 2 G. Bockhold. D. Strawson ~ 3 S. Daubresse ~ K. Whitaker-4 R. F. Fraley G.'Quittschreiber. ~5 D.-Houston J. Wilson 6 D. Crutchfield' B. Borchardt 7 J. Brammer W. Minners 8 M. Dey-B. Rasin-9 10 11 '12 13 L O" 15 j 16 17- ~ 18 19 20 21-22 23- .24-25 l-o p ~ R ANN RILEY.-& ASSOCIATES, Ltd. O- . Court Reporters - 1612 K Street, N.W., Suite 300 . Washington, D. C. 20006 (202) 293-3950l t

162 1 PROCEEDINGS 2 (8:30 a.m.] 3 MR. WARD: The meeting will now come to order. 4 This is the second day of the 388th meeting of the Advisory 5 Committee on Reactor Safeguards. 6 In today's meeting the Committee will discuss or 7 hear reports on the following: one, EPRI requirements for. 8 evolutionary plants; two, regulatory requirements marginal 9 to safety; three, future ACRS activities; four, Subcommittee 10 activities; five, proposed ACRS report on the NRC Severe 11 Accident Research Program plan; six, proposed ACRS position 12 on EPRI requirements for evolutionary-LWRs and regulatory 13 requirements marginal to safety. /"'N 14 Portions of today's meeting will be closed to V 15 discuss information, the release of which would reprecent a 16 clearly unwarranted invasion of persolal privacy. This 17 meeting is being conducted in accordance with the provisions 18 of the Federal Advisory Committee Act. Mr. E. Igne is the-19 Designated Federal Official for the initial portion of the 20 meeting. 21 We have received no written statements nor 22 requests for time to make oral statements from members of 23 the public regarding today's session. A transcript cf 24 portions of the meeting will be kept. It is our request 25 that each speaker use one of the microphones and identify O V ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

163 1 himself or herself. O' 2 Before we go to the first scheduled agenda item, 3 just a couple of quick notes. Last evening before we 4 recessed we handed out a package of letturs, and we 5 indicated that what we would like to do is this morning,. 6 take a poll of the membership on each of these letters or at 7 least the A rated letters of which there are several to get 8 your opinion on whether you think the= letter as presently 9 drafted is ready for paragraph _by' paragraph-consideration. 10 What I plan to do is to do that, but do it at: 11 11:00 o' clock when we get to t'< .c session. _ If you are not 12 quite prepared you have two and one-half more-hours to get 13 ready before the poll. -The other thing is that Sam 14 Duraiswamy has passed out this bi.7 17-package. This is 15 comments and feedback we have-received from the staff on 16 letters over the last couple of months.- -We have time on-17 -Saturday and need-to spend some serious time _with this,_to 18 make sure that'the feedback that we are getting,-that we-19 understand it and it is appropriate. 20 We have scheduled some time for this on Saturday.- 21 I think a couple of you will beLgone by then.._I1will~ 22 appreciate it-if those people will take'a look at the 23 letters and responses: that are their primary responsibility - 24 and-leave comments with me before they._ leave today or; [ q .25 tomorrow. h ANN RILEY & ASSOCIATES, Ltd..- _ : Court Reportars 1612 K Street, N.W.,' Suite 300 Washington, D. C. 20006 _(202) 293-3950i

i i I ' 64 1 MR. WILKINS: Do you want it right now? ':o 2 MR. WARD: No, I would rather have written. Is i 3' there anything else that anyone.would.like_to bring up j 4 before we go to the first scheduled item? i l 5 (No response.] 6 MR. WARD: All right. I believe that Mr. Wylie l 7 will have some opening comments. 8 MR. WYLIE: Thank you, Mr. Chairman. This part of j 9 our meeting concerns the EPRI. advanced light Water _ reactor l l. 10 requirements and' document for' evolutionary plant designs and 1 It is covered ( 11 the staff's final safety evaluation report.-. i 12 in your background information and'is under Tab 7 in your i 13 books. 14 If you recall, at.the July meeting,.we_had a 15 presentation on this subject. At the conclusion of-the: [ 16 meeting it was determined that we should delve more into the ~ 27 details of the staff's safety evaluation.- In that regard, i l-18 we scheduled a subcommittee meeting for July 27-for that 19 purpose. -At that meeting 1was Carlyle Michelson-and Earnest-i. 20 Wilkins and Peter Davis,_our Consultant and_.-myself. 4 21 At that meeting-we had presentations principally. i 22 by the staff, and EPRI representatives were,there_to. answer 1 23 - questions and-make=a presentation.: The ESubcoraaittee 24 determined--that-we should allot"some. time at1this; meeting ^ 25- - for the staff and EPRI to summarize what-they' presented at-O ANN RILEY &. ASSOCIATES, Ltd. . Court Reporters. 7 1612 K Strecti N.W., Suite 300 - Washington, D.' O. 20006 (202) 293-3950 s. -*g e w "'T,r yy-+r wN ry sw T y-er y y,w-9rywyr-y.-W g avg +y g ww my,- y gy9-pyry w g-g g Weywee are v g-me -t p y g-

.-= 165 1 tia. Subcommittee meeting, and requested EPRI to address .,l' 2 certain specific subjects that we discussed at the 3 Subcommittee meeting. 4 4 That's the pun sse of this meeting. I will ask l 5 any comments from Earnest and Carlyle, if they wish to say 6 something. If not, I think we ougut to move r!ght ahead 4 7 because we have a very chort time to do this ir.. I will l 8 call on Jim Wilson from the staff to make a presentation. 9 MR. WILSON: Before I make my presentation for the i j 10 staff, Dennis Crutchfield, the Associate Director-for i 11 Advanced Reactors and Special Projects has a few I 12 introductory remarks. 13 MR. CRUTCHFIELD: Good morning. We hope this will l (i 14 be the last meeting on the EPRI evolutionary FSER with the !V 15 ACRS. We hope to get a letter out of this meeting. This ? 16 has been a long process for the staff. It began'in the 1986 17 to 1989 timeframe, when we received the application from f 18 EPRI for the evolutionary document. 19 There have been'four major revisions to this 20 document. We' issued DSERs last fall, the September / October 21 timeframe. The final safety evaluation report went out in 22 May. We-have been interacting with EPRI since that time. 23 There are about 400 or so vendor / utility specific.open items 24 in there. Those items are the'ones where there is lack of 25 sul'icient detail in the EPRI document. The staff felt it 4 e 3(V ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202)_293 3950 i

-, ~ _ ~..... i 4 166 i would better resolve the. issue:.with the. natural design = rO1 f 2 .before it, so we have put those' issues off.to.the specific I 3 ABWR or Combustion Engineering application for; resolution. F 4 The EPRI document-has been a'very: worthwhile-I l 5 document for us. It has identified major policy questions, 6 the 90-016 document and son and grandson issues, that-fell-7 out of that. The 91-078 which dealt with electrical issues. 8 have raised important issues for Commiss' ion cons'ideration-l 9 and Commission de:ision. In many cases they went beyond lr 10 current design basis, whicu is precisely whera the. 1 11 Commission wanted it to go. f 12 The EPRI document'does not replace our review on ) 13 specific arr.lications. We will-~ continue.to review-those: ~ individually. They will be certified. The EPRI documentiis 14 j' ~15 not a certified document,.and it's not a certified-design.. f 16 Essentially, therefore, it has no regulatory status. ' It-i ~ 17 does provide a useful basis-'for future evolutionary I 18 applicants,-however, to identify what issuesDindustry thinks 19-are important in one of~those_ designs. 20 .We have1 reviewed.what-was;putibefore(us. LWe1 l 21 didn't'have a completa design 1butlwe::reviewedLthe design ~ j 22 detail and amount of information1that EPRI gavejto us; and~ ~ 4 ]- 23-our review-and' evaluation-hastbeen presented to you. j. 24 It costs;a~significant; amount of' staff. resources 25' to do this review. It was'over 30 FTEs spread over that- 'b ANN RILEY &:: ASSOCIATES,. Ltdc Court Reporters: 1612 K Street, N.W.i Suite 300 L Washington,-D'. C. 20006 .(202) 293-5950 u...

167 j 1 time period as I discussed previously, which is a pretty ('T , kl 2 hefty sum of the advanced reactor resources allocated. We 3 think the most efficient way of resolving remaining issues is with the design specific applicants; that is, with 4 5 Combustion Engineering and General Electric Company. 6 We have agreed to work with EPRI and, in many 1 7 cases, the resolution that comes out of those advanced j 8 designs will go back to EPRI, and EPRI will consider those 9 and see whether they want to' include them in the utility 10 requirements document. Therefore, it's likely that we will be publishing a FSER supplement at some point in the future. 11 i 12 Just precisely when that will be is a lot dependent upon i 13 resources and a lot dependent on resolution of issues. f r~s 14 We do hope the ACRS will send a letter-to the. U 15 Commission this month, expressing their approval of the EPRI i 16 requirements document and the staff's SER. With that, I 17 would like to turn it over to Jim Wilson, to provide some 18 more details. 4 19 [ Slides.] 20 MR. WILSON: The EPRI ALWR requirements document 21 is a three volume, 13 Chapter set of requirements 22 established by utilities,.specifically the Electric Pow?r 23 Research Institute for ALWR design, construction and 24 performance. It is from an' operator / owner perspective. 25 Volume 1 of EPRI requirements document contains an . -(r v ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K Street, N.W., Suite 300-Washington, D. C. 20006 (202) 293-3950 1

. _ -. - -.. = _ _. i e i 1681 l 1-executive summary and presents EPRI's policy, and' summarizes 2 their top tierfrequirements._ Volume 2 consists of 13-i- } 3 Chapters and contains EPRI proposed requirements'for an-i 4 evolutionary power plant with_approximately 1,350 megawatts [ 5 electric. Volume 3 consists of 13_ chapters,:and contains 6 the-EPRI proposed requirements for nuclear power plants for-7 which passive' features vill;be used in their designs,.with-8 around 600 megawatts electric. The scope of the requirements _ document:is the 9 10 entire plant. It is NSSS-and safety related and~ BOP and. 11 non-safety related systems structures and-components.._Much l 12 of the scope of the requirements document is not covered by- '4' 13 regulations or regulatory guidance such as: SRPs, and -reg 14 guides. The requirements. document is:not aniapplication for. 1 15 FDA/DC or a design document. It does not contain ?. ~ 16 sufficiently detailed information~for the stafffto. allow a. I 17 determination to-be-made as to whether it meets the 18 regulations. 1 j. - 19 The requirements document' specifies requirements 1 that are for safety and' investment protection, and economics-20 1 j-21 are major.factorsntheyTconsidered in1 preparing these 22 . requirements,'not just regulatory requirements that have to' 23 be met before a plant _can be licensed or designLcertified. 5 ~ 24 EPRI-did;not distinguish or: did notEgivelgreater I 25 . weight to-their regulatory requirementsLcompared to71ts i ANN RILEY & EASSOCIATES, Ltd. Court Reporters-. 1812 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950: ,,,n,.,.- ,,c r

169 1 investment protection or. economic requirements. The 5 2 requirements document reflects the needs and desires of both 3 foreign and domestic utilities. I believe there are a 4 number of -- I think five -- different entities involved 5 with the EPRI steering committee. 6 EPRI is coordinating design teams and consultants 7 in the preparation of the requirements based on direction 8 from the steering committee which meets approximately once a 9 month, and it approvos all changes to the requirements 10 documents and directs and coordinates the activities of the 11 teams and the consultants. 12 The utilities are developing standard plant 13 features specified in the requirements document as the basis /"'g 14 for national standard plant designs. The Nuclear Plant \\J 15 oversight Committee, NPOC, has developed a strategic plan 16 for building new nuclear power plants, and has assigned a 17 significant role to the EPRI requirements document. 18 Severe accident protection requirements are beina 19 added or have been added to the requirements document in 20 accordance with the Commission's direction on severe action 21 policy. Through the steering committee the requirements 22 document is proposing simplification of systems and expanded 23 use of best estimate or realistic analysis methods in place 24 of the staff's conservative _ approach, using either 25 methodology or worse case estimates. f'h U/ ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

n 1n--eae. a ..=s 2 x -.a.-.~ a.~. w .-w I E l . 170-i 1 .Over time, the scope and purpose of the. 2 requirements document has changed. It originally proposed t j' 3 to seek resolution of applicable USIs and GSIs and i l 4 optimization issues. I will go into.that~in a little more 1: l 5 detail in a later slide, when I talk about Appendix.B to i 6 Chapter 1. [ ~ 7 The scope'of the requirements' document has 8 expanded to be design instructions for the whole plsnt. As - 9 I said before.it' covers NSSS and BOP,' safety and non-safety e 10 systems and structures, and components.. In the last'two t i [ 11 years EPRI har become more involved in non-design issues-4 f, l 12 such as technical specifications and emergency planning. 13 The review has been going on for some time. i

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14 Evolutionary requirements document, the first-Chapter, was \\m/ { 15 submitted in 1986. The staff published its first SER in i 16 1987.- The review is nearing' completion at.this point, 17 August of 1992. It has taken a lot longer than people had, h 18 envisioned, back when the set-up tholprogram., l-19 MRR management and~ review staff haveLchanged in { 20 the meantime.. The focused has increased, with the, l 21 increasing interest in advanced reactors and the submittal l 22 of applications--for~FDA/DC from=the vendors. The'-.first- $23 four DSERs were written in the_ late 1980's. They are-quite: 1 24 different in scope, detail an'/ comprehensiveness fromethe d ~ 25 - SERs and the DSERsi.that'were-in 1991 and.1990. O ' ANN - RlLEY &cASSOCIATES, Ltd. 7 Coud Repoders - 1612 K Street, N.W., Suite 300 1 - Washington, D. C. 20006 (202) 293-3950 Ne, + + 1-a ,,.a-- ,m..en--n.,. er+v

4 '171' i 1 The staff has gotten more guidance from the lO2 Commission on what the requirements docurent should be-4 j 3 doing. NUREG-1197 was written back in 1986, prior to Part 4 52 being promulgated. In the last couple of years we have 5 gotten consids.rable direction from the Commlulon' as to how a 6 to view the requirements document. 1 7 The requirements document is going to be-used te-8 revf.ew applications, first by-examining or surfacing.orL 9 discussing sig51ficant policy-questions,. policy issues, and l 10 the commission has further directed that the staff c'ompare' 11 FDA/DC applications to the requirements document. The 12 requirements document by itself,-is not_ complete enough to 13 satisfy the staff. 'As I said before, it 1sinot a design. 14 document. You can't determine if the regulatory-t 15

requirements have been met-just by looking at-the 16 requirements in the requirements in the requirements 17 document.

18 As Dennis indicated earlier, there_is about 400 19 vendor or. utility specific _ issues that will'have-to be-20 deferred, until we review individual applications for design 21 certification-to see if the requirements in those-c 22 applications are adequate. 23 Since-the requirements document was~first' 24' envisioned.and' began to be submitted to the staff--in modular. 25 . form for review one chapter at a' time,--theLvendors have' LO ANN RILEY & ASSOCIATES, Ltd. Court Reporters .1612 K Street, N.W., Suite 300 Washington, D. C. 20006 -(202) 293-3950 a

s 172 1 submitted designs of their own. Where it was first 4 l 2 envisioned that the requirements document would be well in 3 advance of the vendor applications and provide guidance on 4 how to write an application for a design. certification, the 5 vendor designs in some cases got ahead of the requirements 6 document and currently, they are near completion on the 7 remaining plant design applications now. 8 The requirements document, although we employ the 9 SRP as we had envisioned back in 1986 when we wrote NUREG-10 1197, although we use the same criteria as application, it 11 doesn't undergo the same review process as regulatory 12 documents such as Reg Guides, SRPs, USIs/GSIs, the medium-13 and high priority ones which are listed in NUREG-0933. The 14 staff does not control the requirements document, and we 15 can't use it as a basis for licensing future applications 16 for design certification. t 17 [ Slides.] f 18 MR. WILSON: The format of the requirements 19 document is quite different from the format of documents we 20 are used to reviewing for either applications-for operating i 21 licenses or applications for FDA/DC. This was done l' 22 deliberately by EPRI, in its desire to show that these are. 23 utility requirements. These are not regulatory i 24 requirements. It does not follow the SRP, which is more of l 25 a discipline based cut across a plant design. It employs l l /~h i V ANN RILEY & ASSOCIATES, Ltd. Coud Repoders l 1612 K Street, N.W., Suite 300 Washington, D.- C. 200LJ .(202) 293 3950

173 1 more of a systems approach. The chapters talk about 73U 2 specific systems or types of systems rather than 3 disciplines. 4 Also somewhat different than for plant 5 applications, the staff did more than an audit review. The 5 requirements document is not as detailed, is not as large a 7 volume of material, although it is a fairly significant and 8 lengthy document. The staff was able to perform more than 9 just an audit review, which is our normal course of action 10 when we get an application for review. 11 Again, the requirements document is not an 12 application for anything. It doesn't seek approval of a 13 design or certification for a license of any kind. It has /~') 14 no legal or regulatory status. The staff reviewed it at the (_/ 15 level of detail presented and made its conclusions about 16 acceptability; that is, whether it met the regulations or 17 whether it conflicted with regulations, and really ended up 18 treating it more as a large topical report. 19 MR. WARD: Jim, can you explain to me what you 20 mean by more than an audit-review. I guesa an audit review 21 means that you just look at a sample of --- 22 MR. WILSON: As you know, when the staff reviews 23 an application for an operating license they are not able to. 24 look at all of the design documents that are submitted on 25 the docket. We did look at every document, every-part of O ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

174 1 ,c every document that was submitted on the docket-for this e 2 particular project. 3 MR. WARD: It makes it more than an audit. 4 MR. WILSON: It makes it more than an audit, yes. 5 We looked at everything. As I said before, the staff cannot 6 control-changes to the requirements document. At one point 7 it was envisioned that EPRI would make changes, only to 8 reflect the staff's concerns. Once the passive volume 3 was 9 submitted in September of 1990, EPRI expressed a desire to 10 continue to making changes to-the evolutionary plant design 11 requirements in Volume 2, to maintain the two documents 12 parallel where they really cjvered:the same requirements. 13 EPRI has made changes to the things that staff has ) previously found acceptable. Some of the section numbers 14 15 have changed. It's not the same document that was submitted 16 several years ago. As I indicatog, more recent SERs have 17 been much more comprehensive and much more focused than the 18 earlier ones were. But because of the changes we can't lock. 19 the requirements document in place and une it as a basis for 20 forming a conclusion about licensability of a particular-1 21 design. 22 The design certification applications are subject 23 to the results of the design specific review'and hearings, 24 and will be completed after the requirements document effort 25 is completed. Again, that's another feature of the ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 l 0

175' I 1 requirements document. It is not going to be getting..the 2 same public scrutiny that these other documents are. 3 Just as EPRI had three volumes to their-4 requirements document, after some consideration the staff-l 5 concluded that the best solution for documenting _its-review J 6 of the requirements document was to also come out with a 7 three volume SER. Each volume of the staff's SER roughly 8 corresponds to EPRI volume of the same number. 9 Volume 1 of EPRI which described EJRI's policy for 10 the ALWRs and talked about upper tier requirements and d -i ~ 11-provided an executive summary, is roughly' comparable to the: 12 volume one of the staff's SER. In Volume 1, the staff 13 outli1ed the basis, outlined the guidance and guidelines i 14 that it used to review the requirements document. It' 15 presented a chronology of the proje m and summarized.the-16 -staff's review and the regulatory status _of the requirements 17 document. It summarized!the policy issues that have arison 18 as a result of the papers--to the-Commission,_ identifying; 19 issues where-the requirements document.-- proposed 20 requirements that were deviations from. current-regulatory-21 requirements, summarizes the open issues'resulting.from the-22-staff's_ review, and summarizes the-vendor specific utility-23 issues that were identified as a result of the staff's1

p

_24 review of the requirements document. 25 MR. CRUTCHFIELD: Jim, are-you going to skip'that TO ANN RILEY & ASSOCIATES, I.td. Court Reporters _- ~ 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950-- =.= x..

176 1 to the Volume 27 Skip the intermediate slides, and get to 2 the Volume 2 discussion, where we talk about the 3 evolutionary SERs specifically. 4 The others are there for useful information about 5 schedules, about what our 161 schedules are, what the open 6 issues were and things like that. If we could get to the 7 key parts -- 8 MR. WILSON: Actually, Volume 1 is the most 9 important document that we go over today. I can skip over 10 the chronology, which has been presented in various forms to 11 you before. I would like to describe the staff's review, 12 and 7ee if there is any questions about the conduct of the 13 staff's review. I can't really emphasize enough, the 14 importance of looking at Volume 1, to see what it is that 15 the staff review and what they reviewed it against, what the 16 groundrules were for the review. 17 A little bit later I will go into the definitions 18 of Nhat was an open issue and how did we go about_cicsing 19 it, and'what a vendor specific issue is. 20 [ Slides.] 41 You have all seen these slides before. As I said, 22 the staff reviewed everything that EPRI submitted at the 23 level of detail presented. It did not, however, complete a 24 completeness review. That is, we did not take the Code of 25 Federal Regulations and identify all of the applicable C) Ann nitsv a Associ4Tes, tie. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 m 1

177' 1 regulations and then see if EPRI had-requirements to< address O 2 each and every one of tbose. We-did not conduct a. 3 completeness review. 9 4 The next slide talks about NUREG-1197:and the 5 review approach, and wny the staff could not complete its~ 6 revicW in accordance with the guidance _or.with in accordance 7 with the way we thought we were going to do it back-in-1986. i 8 The next few slides summarize-the' policy issues that were ~ 9 associated.with-Chapter 5 review bac.:-in early 1990.- They 10 were contained in SECY 90-016.. 11 _ Chapter-11 identified'several policy _ issues. 12 associated with the: electrical system.--_That vas in-11991i-13 and were-identified in SECY 91-078._ More-recently, on 14 February-20th, the staff sent a SECY paper up -- a draft __ j n 15= SECY paper up.- You'all-have seen=it. It's the so-called 1 16 son of 90-016. It identified' additional ~ policy. issues.for-17 both evolutionary and passive designs. In fact, there was a 18 series of issues in there associated with the-passive design-- 19 only. i 20 Since the DSER was issuedfin'May of this year,-an 21 -additionaI.eight-or.so= items-have.been-identified associated 22 with passive and evolutionary-review.-- These are-the so-J . 2 3-called-grandson issues. -24 Volume 1 lays-out definitions for the: staff's= 25 binning of_irsues. Duringnthe_DSERs the= staff had-ANNL RILEYJ& ASSOCIATES, Ltd. Coud Reponers ; 1612 K Street, N.Wa Suite 300 Washington; D. Ci 20006 --(202) 293-3950 L u

=--..- - i ? I f 178 I 1 identified areas where EPRI either provided: requirements-4, 2 that did tot meet regulatory requirements or could be 3 misinterpreted, or could not provide sufficient level of~ i 4 detsil for'the-staff to reach a determination-about'whether i 5 the requirements were adequate-to meet regulations.1 These ) 6 were identified as open issues. 4 I 7 Additional.open issues were identified in-the DSER i l 8 that were reflective of the staf f's desire to: continue a { 9 dialogue with EPRI. In many cases we made a recommendation.- 10 You look at the text of the DSER,-the staff recommended 11 something,;nnd then it was listed as an.open issue.. That j. 12 was to keep the door open for further discussion. 13 When the time came to finalize _the SER, the staff ( ) went through and' looked'at.EPRI's responses to_the DSER:open 14 i .15 issues. In some cases EPRI and the staff determined that- ~ 1 16 the level of detail was outside the' scope of the-17 requirements document,.and the issued was closed as.a vendor 18 specific issue.- In some cases'EPRI and the staff-reached-i 19 agreement on-what the: requirements,should'be. Those were 20. also closed. Those were closed. [ 21 In-some cases the staff could nottagree on a: h 22' position. The staff documented its pocition in the SER~, and p 23 indicated that it;was closing it forsthe.EPRI requirements i 24 documentrothat we were not going to be endorsing-or going 25 alongiwith or approving _EPRI's proposed requirements,:but s ANN ' RlLEY & ASSOCIATES,. Ltd.- c Coud Reponers _ ~ L 1612 K Street, N.W., Suite 300 - Washington, D. C 20006 L -(202) 293-3950:

179 1 would defer our review until a specific design application 7-s 2 was received by the staff. 3 Are there any other questions about Volume 1, what 4 it contains, and the groundrules for the review? 5 [No response.) 6 (311 des.] 7 MR. WILSON: Volume-1 summarizes, kind of a bean 8 count by Chapter, of issues. Currently, there are 21 open 9 issues remaining. These have beer identified as policy 10 issues. The staff could not document its position on what 11 we were going to review an application against because these 12 positions deviated slightly or in some cases majorly, from 13 regule. tory requirements-Therefore, the positions were sent 14 in SECY papers to the Commission. These are the'so-called 15 son of and grandson issues. 16 EPRI at-this point has met all of its commitments 17 to make changas to the requirements document. 18 MR. SHEWMON: That first line means that there 19 were 101 specific items which you called out and asked 20 EPRI's response on, and they responded satisfactorily to 21 date for 99 of them;-is that right? 22 CR. WILSON: No. These are separate bins. Vendor 23 and utility specific issues are those. issues for which the 24 staff concluded that the EPRI requirements: document did not 25 satisfactorily address it. Therefore, our review of that l l'b\\ l V ANN RILEY & ASSOCIATES, Ltd. Coud RepOderst 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

180 1 issues will be deferred until we look at an application. \\ s# 2 MR. WILKINS: Paul, the-information that you are 3 asking for is not on this slide. That's the number of 4 issues that existed before they made this process. My 5 recollection is that that answer was 19. 6 MR. WILSON: Something on that order. 7 MR. WILKINS: Something like that. 8 MR. SHEWMON: I just wanted to get clear what was 9 moving on. Thank you. 10 MR. WILSON: -In addition to these issues which 11 will have to be looked at later, we are awaiting direction 12 from the Commission on these issues before we can have a 13 final Agency position. The utility specific issues, we have ('N 14 documented the staff's -- the staff has a position. In some 15 cases it diff from what EPRI had desired. In some-cases s 16 it was EPRI and the staff agreed that it was beyond the 17 ccope of the requirements document, and those issues would 18 also have to be looked at during a specific review. 19 MR. SHEWMON: Some of those issues is what we will 20 get to with Volume 2 that was mentioned earlier? 21 MR. WILSON: Yes. All of these chapters here, 22 one, the tv appendices through 13 are Volume 2. Volume 1 23 provides a summary of the issues that were identified in 24 Volume 2. 25 MR. WYLIE: The 21 open issues are basically the i r(j) ANN RlLEY & ASSOCIATES, Ltd.. Coud Repoders 1612 K Street, N.W., Suite 300 WeshingtOn, D. C. 20006 (202) 293-3950

' 181 i i policy issues. 2 MR. WILSON: Those are the policy issues. 3 MR. WYLIE: We are considering them separately and 4 writing separate letters on them. 5 MR. WILSON: The staff has proposed a position.- 6 Until the Commission endorses it, it is not an Agency 4 7 position, and we feel like we have to leave it open in the 8 SER. 9 MR. WYLIE: I-guess you said -- how many were the 10 total issues that you considered and cl'osed? 11 MR. WILSON: -At the time the DSERs were-all 12 completed. ve had a total of about 416 open-and outstanding-13 issues, op.a and confirmatory issues. EPRI-has closed all. 14 of its cor.firmatory issues. They met the~ commitments that-15 they made that changed the requirements-document in a way 16 that satisfied the staff's concern. 17 About one-half of the issues-from the_DSER were 18 open issues, and'those included-ones that we disagreed with z 19 EPRI on, those that_we didn't have a. position yet,;EPRI may -20 not have had a position yet; or that we made recommendations 21 and left'the door-open'for':further discussion. 22 MR. WYLIE:-- Overall, there was about 415.- 23 MR. WIIsON:- Four hundred'and115 open and ~ 24 confirmatory issues. About=one-halfLof them were open 1 s .25 issues in the.DSERs. h ANN RILEY ' &. ASSOCIATES, Ltd; Court fleporters - 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3960- ___um2__ ._-_-___-A.-:-~--m-

182 .t 1 MR. CRUTCHFIELD: ^eiginally,_there were a 2 sufficient number of open issues in the DSERs, 400 or so 3 odd-open items. Many of those items.got resolved as we 4 completed the review and conti.lued going on. Other issues 5 came available and came open to us.- In other words, we l 6 resolved hydrogen with EPRI last winter after the DSER was 7 issued, so it doesn't appear in this list anymore. 8 MR. WYLIE: How many of those open_ issues that are 9 now closed were closed on the basis that they were deferred 1 I 10 but not really resolved? l 11 MR. CRUTCHFIELD: Probably the good majority of i 12 them. I would say more than one-half. 13 MR. WYLIE: More than one-half of them were 14 deferred but not resolved. 15 MR. CRUTCHFIELD: They were closed by the 16 resolution being, we will work with the specific vendor or 17 utility applicant to close it, because we lack detail here. 18 MR. WYLIE: Okay, fine. .3 [ Slides.] 20 MR. WILSON: Volume'2 of the requirements document 21 contains EPRI's-proposed requirements for evolutionary plant 22-designs up to_about_1,35 megawatts electric. It'is l 23 contained in 13 Chapters that'are arranged on a. systems 24 basis. The exception to this organization is Chapter 1, i 25 which-is kind of an umbrella chapter that addresses 1 LJ - ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

j 183 1 everything at a fairly high-level of detail for the-2 evolutionary plant. 3 It contains EPRIts requirements in the~ areas.'of 4 maintainability and QA,-it cuts across.all chapters.- The 5 specific details of each~ system and how EPRI' intends-to 6 place requirements to address the systems are found-back in -1 7 the later chapters. 8 Chapter 1 DSER was.the first DSER issued, back in i l 9 1987. It covers the key topic areas' listed here for safety 10 performance, structural design, materials. liability, i 11 availability, instructability, operability, maintainability, 12 quality assurance, licensing, design process -- 13 MR. WARD: Y o u d o n ' t h a v e t o r e a d a l l o f t h o s e,- 14 di"* 15 MR. WILSON: Currently,-two open issues which are-16 policy issues before the Commission now, remain' outstanding 17 from Chapter 1. Chapter 1 contains two appendices, one-of 18 which was -- 19 MR.- SHEWlDN: Just a minute. I wondered what van-20 controversial about leak before break, or-if-you wi2' .at 4o 21 that. -That was one of the-two policy issues on the previous 22 slide. 23 -MR. BRAMMER: This~is Jim Bramner, from the NRR 24 staff.- As I understand.the discrepancy-that we have,'it is 25 a lack of detailed'information relative to the requirements b ANN RILEY & ASSOCIATES, Ltd.. Court Reporters ' _ 1612 K Street, N.W., Suite 300 : , Washington l D. C; 20006 y -(202) 293-3950 i i:

184 1 of leak before break which appear basically in NUREG-1061. (]I N-2 I think there's a disagreement between the staff reviewers - 3 - maybe not-disagreement -- EPRI didn't submit enough detail 4 4 to satisfy the staff, relative to those guidelines. 5 MR. SHEWMON: It certainly could apply to several 6 plants, and there's a fair database on materials in the i 7 limits. Is there a change in the limits? h 8 MR. BRAMMER: 7__are are many plants that have been 9 accepted for leak before break, especially the Westinghouse 10 plant. However, the staff position -- my understanding of i 4 11 the staff position is that they need almost plant specific 12 information relative to stresses and those kind of things, ] 13 and the fracture mechanics properties of the materials in 14 ) order to make a complete judgment that leak Lefore break is 15 acceptable, i 16 They are deferring this until the plant specific applications come in. 17 4 18 MR. SHEWMON: If that's the best that we can call 19 up today, thank you. 20 MR. CRUTCHFIELD: It's a policy issue also, in son 21 of 90-016. We can't take a position and say our position is 4 22 X or Y until the Commission approves that. 23 MR. SHEWMON: It's just what is the policy issue, 24 is what interests me. 25 101. CRUTCHFIELD: One of the questions'was -- (3 - t) ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

4 185 1 MR. SHEWMON: This was one of the policy issues 2 that was settled a couple of years ago, I thought. 3 MR. CRUTCHFIELD: We haven't applied it to BWRs 4 before, leak before break. This is one of the questions 5 that we are looking at nov and examining with the 6 Commission, trying to get a Commission decision or,. 7 MR. SHEWMON: You nave applied it to BWRs but you 8 have not applied it to ma+erials which may be susceptible to j 9 stress corrosion cracking. So, the discussion may bc 10 whether or not if they have gone to a 304L, a stress t 11 corrosion resistant material and worked on stress adjustment 12 or something, that you would then allow them and say it's 13 not prone to stress corrosion cracking and therefore that 14 would be a policy issue possibly. You think maybe that 15 might be what it is? l lt MR. CRUTCHFIELD: Yes, sir. 17 MR. SHEWMON: Okay, thank you. 18 MR. MICHELSOH: It's also being applied now to -- 19 you mean it could be applied to a number of. systems outside 20 of containnent. Very little of that has been approved so 21 far, to my knowledge. It has all been inside of 22 containment. 23 MR. SHEWMON: There's another requirement that you 24 have leak detection capability that is much finer than the - 25 .O Ann n:tey & Associares, tia. Coud Repodera 1812 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950

186 1 MR. MICHELSON: The quality of the analysis on the 2 piping, the potential for water hammer, corrosion / erosion, 3 and all the other things outside of containment that were a 4 bit sticky. 5 [Slidea.) 6 MR. WILSON: Chapter 1 which was an umbrella ? chapter that covered really all the systems in the j 8 ovolutionary plant, the details of the requirements for the 9 systems are found in other chapters. Chapter 1 contained 10 two appendices. The first, Appendix A, talked about PRA key 11 assumptions and groundrules. 12 Appendix B, EPRI titled Licensing Regulatory 13 Requirements and Guidance. EPRI listed reg guides and SRPs 14 and arcas where they felt the requirements document had 15 addressed the regulations, and the staff used that part of 16 Appendix B as a cross reference to try and figure out where 17 those things were discussed in the rest of the requirements 18 document. We did not review their list of regulations and 19 guidance to see if it was all encompassing. The staff did 20 not conduct a completeness review. 21 Appendix B also proposed so-called optimization 22 issues which were EPRI proposed requirements which deviated 23 from current regulatory requirements. These issues here are 24 contajned in Section 2 of Appendix B, and they also have 25 been identified as policy issues in the staff's SER. O Ann ni'av a Associares 'ta. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C, 20006 (202) 293-3950

187 1 Appendix B also described or contained EPRI's 2 proposed requirements to address USIs and GSIs. The DSER 3 describes how the staff reviewed the USIs/GSIs and 4 summarizes which ones have not reached resolution and which 5 ones the staff has accepted EPRI's requirements based on 6 proposals to USIs/GSIs which have been resolved by the 7 staff. 8 Appendix B also contains as annexes, the four 9 groups of SECY papers that we described previously, the 90-10 016 issues which address Chapter 5 policy issues, 91-078 11 which talked about the policy issues from the electrical 12 systems review of Chapter 11, and the February 20th son of 13 90-016 issues and the grandson issues from the June 25th 14 SECY paper. ^ 15 KR. CRUTCHFIELD: Jim, why don't you just go to 16 the conclusions. 17 MR. WILSON: Okay. f 18 (Slides.] 19 MR. WILSON: This slide that is up here is a 20 little bit different from the one that is in your handout 21 packet. We have made some modifications to reflect comments 22 from the Subcommittee. I think it was Ernie Wilkins that 23 pointed out, it wasn't enough to resolve the outstanding 24 policy issues and the vendor and utility specific issues and 25 translate them into a design, but you also had to construct O Ann nitsv a Associates, tio. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 s

i 188 f 1 and operate the plant safely in order for it not to be an i O-1 2 undue risk to the public. health and safety. 3 The staff intends to issue its final SER on the i i 4 evolutionary plant requirements document later this inonth as 5 a NUREG. Are there any questions? 6 MR. SHEWMON: I-am interested in what the slide 7 that's called optimization issues. You say these are items 8 where the EPRI proposed deviations from regulatory 9 requirements. Were those usually reg guides and thus things 10 which really weren't rules? It would seem to me that-there 11 is some policy issues here, where -- 12 MR. WILSON: These are areas-identified that they 13 were proposing requirements that were deviations from I 14 regulatory requirements. 15 MR. SHEWMON: A regulatory requirement is not a l 16 rey guide but a regulation; is that right? I 17 MR. WILSON: Reg guides and'SRPs outline 18 methodology for meeting the regulations. You can meet a l 19 regulation-in other ways. 20 MR. SHEWMON: -This is another way to meet them, or 21 this would violate the regulations? 22 MR.-WILSON: These violate the regulations. These l 23 are-deviations from the regulations. 24 MR. SHEWMON: Then,'aren't these policy issues? 25 -MR. WILSON: These.are policy' issues. Each of O ANN RILEY &L ASSOCIATES, Ltd. Court Reporters c 1612 K Street, N.W., Suite 300- - Washington, D. C. 20006 (202) 293-3950: 4', ~.... - - ~, <, - -. ~, -.

m.. I s 189 l 1 these optimization issues is evaluated by the staff, and is l 2 included in the policy papers that are currently before the j 3 Commission. 4 MR. SHEWMON: But that wasn't on your slide 1 5 before, these were issues that were policy issues, j 6 MR. WILSON: These issues are included in the list j 7 of policy issues, open issues, a total cf 21 remaining from 8 the evolutionary plant. 9 MR. SHEWMON: d . Not my list. Thank you. 10 MR. WARD: Would you put up the conclusion slide l 11 again, please? 1 12 [ Slides.') f 13 MR. WARD: That first one'looks like a-pretty 14 broad, powerful acceptance of what EPRI has proposed. I i 15 think that the joy -- out there in California or wherever i l 16 they are -- when you read the clause in there if it's a. i 17 clause, if properly translated into a design -- that's a big 18 it. 19 MR.- WIIsoti: That's a big caveat. 20 MR. WILKINS: They read that in California, too. 21 MR. WARD: - You could make that statement about a 22 sketch somebody provided. I j-23 MR. WILSON: If it meets the regulations it's 24 acceptable. - 25 MR. CRUTCHFIELD:- -As you indicated,-it's a very-i 1.lO ANN - RlLEY: & ASSOCIATES,.Ltd.. - Court Reporters -1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950.- -r-m. u e+Nn. m.

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190 1 broad document. There are a number of ways of putting h O2 together a specific design that could meet the utility ?. $~ I 3 requirements document, some of which would be perfectly b acceptabic to the staff and some of which upon staff review k l may not be perfectly acceptable. Therefore, that's why that t y, 6 clause is in there. 7 MR. WARD: It seems that a real conclusion is s 8 something more along the lines that this exercise has been a 9 successful exchange of thinking among engineers on both 10 sides or something, and has informally resolved certain 11 issues and so forth, and should smooth the path for future 12 work. 13 MR. CARROLL: That's what at says. 14 MR. WARD: Between the lineu. 15 MR. WYLIE. It's a little more than that, though. It has identified those policy issues that the Commission 16 17 must make a determination on. In that regard it's a step 18 forward. Plus the fact, that there's 400 some-odd closed 19 issues that have been addressed. 20 MR. WARD: I am not saying it isn't a step 21 forward. I'm just not sure that this properly reflects the 22 real accomplishment. I think the real accomplishment is 23 more what you said, along the lines of -- 24 KR. WILSON: I think this conclusion which was 25 reviewed by our attorneys, is about as far as we can go as O Ann sitev & Associ4Tes, tio. Coud Reponers 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 ~ l

_. _ - _ _... ~. _ _ J, l i ) 191 1 4 i 1 an endorsement of the requirements document, for what our O2 i approval of the requirements document means. It wasn't j 3 intended to summarize what the process has result 1. in. i i 4 MR. WARD: Okay. j j 5 MR. CARROLL: Tell me about the supplement in the 6 last lines what is going to be in it? ,7 j 7 MR. CRUTCHFIELD3 As indicated previously, there l 8 are a number of items that EPRI continues to want to have f 9 some discussion on, some of which we have listed as open j 10 generic items.that will-resolve on a vendor specific basis, f 11 EPRI feels they could better be resolved generically for all i t i 12 the evolutionary designs. They would like-to continue to i l 13 have some discussions with us on a number of those items. 1 14 Therefore, the supplement will address those items ~ i l 15 at some later point. One of the-things.they have said is, 16 we will await what happens on the ABWR.- If-we like what the 17 resolution is, we will' incorporate it 1nto the requirements 1 j 18 document, give it to the staff, and the staff'can put a j 13 supplement together that addresses that. .j '20 MR.- CARROLL: So, there may be more than one.- h 21 supplement. l i 22 MR. CRUTCHFIELD: - I' hope there-is not more than f 23 one. o 2 24 MR. CARROLL: It's;very fuzzy l as'to wh'st.is going l 25 'to be in it at the present time. L i h ANN RILEYi& ASSOCIATESv Ltd. t ~ Court Reporters J !~ p l1612 K Street,-N.W., Suite 300 Washington, D. C; 20006 L (202) 293-3950; \\. .~

,. _ ~ i a. i l 192 i 1 MR. CRUTCHFIELD: It's supposed to be. ] 1 ] 2 MR. SHEWHON: Charlie, I would like to coae back { 3 to this optimization issue again, because I don't remember 4 which one of these I have bumped into. It seemed to ne that 5 the basis for this was that the EPRI people felt that this i 6 was actually more risk to the plant than a risk to the l j 7 public. Therefore, they should be able to optimize things t l 8 by engineering judgment and not regulation. J 9 Did you get into.a discussion of this at all at {' 4 10 the subcommittee meeting? 11 MR. WYLIE: No. 12 MR. WILSON: First of all, let me=make a remark to l l 23 put these in context. These are the issues that EPRI I 14 identified as departing from regulations. You netice that 15 these issues are, in many cases, the same issues. They are The etaff has 16 the issues in the son of and grandson paper. 17 identified -- 1-18 MR. SHEWMON: I am not sure what those words;mean l 19 and I have ignored it up to here, this is son and grandson 20 of what? g 21 MR. WILSON: Of 90-016. t [ 22 MR. WYLIE: These'are those' policy' issues that we } 23 are addressing separately,-and all of these.are in-that 24 -_ group. [ 25 MR. WILSON: 'The point?is,-the' staff identified an-LA ANN RlLEY & ASSOCIATES,..Ltd. i . Court Reporters - 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 -

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193 1 additional 14 issues where EPRI proposed requirements that O 2 were outside the regulations,-in addition to the ones that 3 they identified in Appendix B as optimization issues. 4 MR. WYLIE: Paul, if you recall, we have the 5 staff's position on each of these issues in the draft SECY 6 of February 7. We also have EPRI's position. 7 MR. SHEWMON: Okay, fine. 8 MR. WILSON: Are there any other questions? 9 (No response.) 10 MR. WYLIE: Thank you. The next item, we have 11 EPRI to make their presentation. 12 (Slides.) 13 MR. BOCKHOLD: I am George Bockhold,. Senior ALWR () 14 Manager for EPRI, also on loan from Southern Nuclear to 15 EPRI. We have a prasentation to talk ebout the 16 requirements. Itreall'[hastwoparts. I have a couple of 17 slides that will give our overall real conclusion and 18 requests of the Committee associated with the requirements 19 document. -Then, Dave Strawson will come up, from NFR, one 20 of our team members on the document. He will talk about the 21 specific questions that the ACRS requested to'be addressed. 22 1 will give the opening remarks,--and really'look 4 23 at first the goals of the document. I think the NRC staff 24 talked about that in more detail.. Really, the requirements 25 -document-identified what the utilities wanted in'the next-ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders: - 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950_..

2 i f' 4 1 194 i j 1 generation of advanced light water reactors. I think some O 2 of the most important things is, the utilities definitely. j t want enhanced safety. There were many requirements, 3 t 4 additional capability, r.ot typically found in an operating 5 plant today. That was the focun. t> Finally, I think a lot of the design margin that 7 was added, we wanted to get some benefit as far as 8 operational flexibility associated with that design margin.- 9 NRC agreed to review the design requirements.Lto help assure 10 that a plant that meets the requirements-is licensable. Jim 11 Wilson went over that. ~We think the NRC staff did complete 12 a very comprehensive and thorough review, 13 One'of the elements that we think requires t 14 additional unrk, and-we-have agreement from NRC management i 15 for that work is, there are some generic issues that-we 2 16 believe should be resolved..in the context of design ) 17 requirements. 18 MR. SHEWMON: One of the require:nents I have heard ( 19 of from other countries, and I would suspect.thel utilities-20 here were interested in,Lwas improve ease of maintenance and 21 repair. Yet, I don't see that called out there. 'Is-it l 22 subsumed in something-else? l L 23 MR.1. BOCKHOLD: The requirements document is really 24 a subset of the NPOC plan.- Maintenance and repair in'the 25 NPOC plan is covered as part of standardization beyond-O ANN-RILEY4 ASSOCIATES, Ltd. Court Reponers 1612 K Street, N.W;, Suite 300. Washington, D.- C. 20006 .(202) 293-3950=

4 1 195 l 1' ] 1 design. Building block seven is part of the plan. INPO has l 2 the lead on that and has started work on standardization 3 beyond design. That element has not been finalized yet. l j 4 It's not part of the requirements. 5 MR. CARROLL: The question of Paul is, designing 6 for maintenance. 7 MR. SHEWMON: Sometimes it's sort of not having l 8 the valve-you have to inspect-flat up against the-l 9 containment, sc you can only'get on two sides of it.- 10 MR. BOCKHOLD: We have a lot of those requirements 11 in the requirements document,_ both in specific chapters and 12 in global statements in Chapter 1. 13 MR. SHEWMON: Okay. ( 14 MR. CARROLL: I agree, they do. 15 MR. BOCKHOLD: As I said, this last bullet here ist i 16 that NRC management in the ELWR program have agreed to 17 resolve the standing issues in parallel with evolutionary 18 reviews for final design' approval. I 19 MR. WILKINS:- That will-be-' covered in this L 20 supplement that Mr. Wilson talked about a liccle earlier? 21 MR. BOCKHOLD: Yes, sir,; covered in a' supplement. 22 We think that the NRC staff review of;the. requirements has-23' been effective in identifying and resolving manyLissues,. = 24 especially issues that require policy or generic: resolution. ~ 25 In'the back of our handout =isna' list of.the_ evolutionary I L O ANN RILEY & ASSOCIATES, Ltd. Court Reporters _ ? 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 l- '(202) 293-3950-

196 1 issues and what we believe is the statuef, with some O2 1 comments. 3 Further in the back of the handout'are the generic 4 issues that we have been -- ones that have been basically-5 resolved. Bin two is issues that we expect to be resolved 6 associated with evolutionary design certification reviews. 7 Finally, bin three are issues that we may disagree on with 8 the staff, and we need to work further with them to achieve-9 resolution. 10 We expect to do that over the next several-months. 11 Hopefully, that wil1~be addressed in the supplement that we 12 hcVe talked about already in this meetino. Really, ite 13 request your support for-that supplement to resolve those 14 issues in the context _of requirements.. 15 MR. CRUTCHFIELD: If I might, the_ staff has agreed 16 to work with EPRI on these. issues over the next period of 17 time. We are not going to extend this out to a long,-long 18 timeframe. In many cases we have had-meetings with EPRI on 19 a number of-these issues-and we are going to try oneLaore 20 time to get_ resolution. 21 .After this shot I thinkLthe staff's view is,_we 22 will put the supplement-together and go forward. If:they 23 renain as vendor specific items they; remain thatLway,;but we-24 will try with EPRI to resolve them, one:more time.- 25 -MR. BOCKHOLD: That_ concludes my{ opening remarks,- h. ANN RlLEY &- ASSOCIATES,1 Ltd.-

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197 1 unless there are some questions from the Committee. Dave 2 Strawson will come up and address specific questions the 3 Committee had. 4 MR. WYLIE: Most of those issues have been closed 5 in your FSER. 6 MR. CRUTCHFIELD: Yes, a number of them have. For 7 example, one of them in bin three I believe has to do with 8 emergency lighting on emergency buses, diesel generators. I 9 checked the ABWR/FSER and is going through process now. 10 They have committed to putting emergency lighting on 11 emergency AC power and DC power buses. EPRI does not want 12 to do that. 13 We have essentially resolved it on the ABWR and ) they want to further discuss it, and we will listen to them. 14 15 .(Slides.) 16 MR. STRAWSON: My name is Dave =Strawson, and I am 17 with HPR Asscciates. We were here-July 27th for a-meeting 18 of the Advanced Light Water Reactor-Subcommittee. As a 19 result of that, there were certain questions that we agreed 20 to come back to provide additional information on today. 21 The first questien was with regard to a corrosion 22 program. The specific issue is that at sites there is an 23 extensive amount of copper buried in-the ground. LThere are 24 also cast iron steel tanks, rebar, potential for setting up 25 galvanic currents which could lead to corrosion. .The h ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders. 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 --(202) 293-3950.

i i 1 198 s j 1 question was, what dces the EPRI requirements document iO l 2 require in that regard. + l 3 We do have in Section 9.4 of Chapter 11, j 4 requirements for cathodic protection. It includes a needs 5 analysis, analysis from the point of view of a laboratory 6 analysis of soil and not from a calculation, plus specific 7 protection and monitoring requirements related to cathodic i t j 8 protection. 9 We. agree, that probably more specific emphasis is 1 10 warranted in this area.- It's an important area. We plan to 11 revise Section 9.41 of Chapter 11, to specifically require a 12 site survey to determine cathodic protection needs early in 13 the construction phase, and.to provide further emphasis by i 14-referencing this in the structural requirements in Chapter-15 1. j 16 MR. SHEWMON: Sir, it would..seem-to me that the 17 way you stated the problem, it's more you are concerned i 18 about anodic attack than cathodic protection. Would you try 19 to make sure then, that everything you wanted to protect was l-20 cathodic, with regard to the power. plant; is that'it? 11 MR. STRAWSON: ' What we are trying to do-is, make-22-sure the site specific features that could lead to corrosion l l 23 -of -- i 24 MR. SHEWMON: Cathodic l protection.is usually 'l 25 applied to something which is_not^in-the middle of-a power 4 i!O ANN RILEY & - ASSOCIATES, 'Ltd. Court Reporters 4 i 1612 K Street, N.W.' Suite 300 Washington, D. C. 20006 l_ (202) 293-3950; -, ~ _. -..

199 1 plant with a tremendous set of voltages and currents running 2 around. 3 MR. WYLIE: Paul, I guess this stems from my 4 questio::. 5 MR. SHEWMON: It sounds like it. 6 KR. WYLIE: I find the location of this in a 7 strange place. It's in the electrical section of the 8 Chapter 11, electrical section of the documents. It just 9 basically mentions you have cathodic protection. 10 Well, you put cathodic protection in for corrosion. 11 control. It seems to me that there should be a separate 12 section somewhere devoted to site-corrosion control. The 13 fact that you use cathodic protection is just a means to' 14 accomplish ths end. There should be a site survey early in 15 construction, where you determine what needs to be 16 protected. If you use cathodic protection, you use it. 17 There are other ways of doing it besides putting 18 in rectifiers, basically. You could put in sacrificial 19 anodes and other things where you need them. It's a 20 comprehensive corrosion program that has tozbe carried out 21 early in construction. If you don: do it then, you can 22 design the_ plant and put'rebars in places where they will be 23 destroyed.by. cathodic protaction. 'So, you cannot. apply _ 24 cathodic protection. '5 MR. SHEWMON: That's why_I coined (the wortl " anodic ..O ANN RlLEY.& ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 - Washington, D. C. 20006 -(?02) 293-3950:

i i 200 1 attack" rather than cathodic prorection. 1 2 MR. WYLIE: Right. 3 MR. SHEWMON: I think about this poor little old j 4 rectifier out there trying to compete with a generator, and l 5 I think it's going to lose. ~ 6 MR. BOCKHOLD: We will consider the committee's 7 statements on that, and relook at our requirements l 8 associated with corrosion protection. i 9 The next question was with regard to BWR/MSIVs. 10 Specifically the concern is, the ability of the MSIVs to f 11 close under conditions -- under accident conditions -- with i 12 a break in the steam line. This has been addressed in l l 13 Chapter 3 of the requirements document, by' requiring that i ) the MSIVs be of a type which have demonstrated this 14 15 capability to close under accident conditions without damage l 16 to the valve and with the ability to maintain leak 17 tightness. 4 l 18 A related question was, what testing is there to 19 prove out this capability. We have gone back and find that I 20 the fundamental work here was done roughly 25 years ago, i 21 actually in response to an ACRS concern during review of the 22 Browns-Ferry I and II. application. In_effect, the same t 23 concJrn was raised. GE and Commonwealth Edison agreed.to an 24 extensive test program that was carried out in.their 25 Stateline plant of Commonwealth Edison. O Aww aitev a Associares, tia. Coud Repoders .1612 K Street, N.W., Suite 300 . Washington, D. C. 20006 (202) 293-3950

201 l 1 The results of that are in this General Electric s j 2 report, APED 5750. In brief summary it was a large scale 3 test, 20 inch Y-pattern valves similar to those used today l' j 4 which went through roughly 40 transients, representing steam f 5 water mixture conditions that bounded the fluid conditions j 6 expected during an accident. It's that fundamental work i 7 which is the basis for the requirement. 1 8 Basically, the requirement is a..ng stick to that i j 9 kind of valve. We don't want new kinds of valves in this 1 j 10 application. We want.something that-is proven. i ] 11 MR. MICHELSON: When you say stick to that kind of j 12 valve, do you mean use a valve of sufficiently similar 13 design so that the test results of that vintage'are still 14 applicable; is that what you mean? j 15 MR. STRAWSON: That's correct. { 16 MR. MICHELSON: The words don't say that 4 17 explicitly. If that's what'you intend and the words would l 18 so stato, then it would be a non-problem. l 19 MR. STRAWSON: We don't want a new valve and a new 20 test -- t 21 MR. ' MICHELSON:. My concern is that'some people' 22 don't like those Y-pattern globes. 23 MR'.- STRAWSON: I understand that the French, for 24 example, are -- 25 ME. MICHELSON: They like other~ kinds of valves.- h ANN RILEY & : ASSOCIATES, Ltd. Coud Repoders 1612 K Street,.N.W., Suite 300 . Washington, D; C. 2000G (202) 293-3950-

4 ) } 2 202 l 1 In fact, the English are going to use gate valves to main 4 l J 2 steam isolation on their PWR. I don't know whether we have t i 3 pinned it down sufficiently or not. 4 MR. STRAWSON: I understand that the -- MR. MICHELSON: I don't have any problem with the t 6 gate valve if you do a test, and the English are going to do 7 a test on a 32 inch main steam gr.te valve. i 8 MR. STRAWSON: I understand that the French are 9 considering a Rockwell gate valve for this' application, and 10 would go through extensive testing. If that proved out the 11 valve, it would meet this requirement. 12 MR. MICHELSON: Is it clear that the EPRI 13 requirement is that you have an extensive test program if i 14 you don't use a valve for which you already have the test 15 data */ 16 MR. STRAWSON: We want a valve with demonstrated 17 capability. F 18 MR. MICHELSON: Demonstrated by tests? 19 MR. STRAWSON: .I would conclude tests, yes. 20 MR. MICHELSON: Okay. It's not clear that it's 21 writt:n that way, but I am'aure the' staff vill be clear in 22 the case of ABWR and Leyond. I am sure they will require 23 it. 24-(Slides.) 25 MR. STRAFSON: The issue raised at'the last h ANN RILEY & ASSO'CIATEG, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington,11 C. 20006 (202) 250-3950' f g rm--ee- =, ,,r.,w--- o ev-5 ,e A evm.i i twy-,,2evw%vr + wyye. ec. - rw, a w - t ~ww&*-- e,, .m=~

203 1 meeting was with regard to the impact of fire on equipment 2 and the role that HVAC plays in that. The starting point s t 3 was, if you had a common HVAC system feeding different 4 compartments of safety equipment in the aux box building, 5 how do vou ensure that if there was a fire in the intake -- 6 hot ghs smake migration *- would not occur and take out two 7 trains of equipment. 8 We, at the last meeting, pointed-out some 9 requirements that we have in this regard. For example, I 10 indicated-that we have redundancy in the HVAC system for the 11 switchgear and battery rooms. The question was asked, what 12 do you mean by redundancy. In effect what Chapter 9 e 13 requires is, the switchgear room consist of multiple ) divisions consistent with the safety related electrical 14 15 divisions. That's not very clear. 16 The intent is to have a separate cooling and 17 ventilation system for each division, so that'a fire in one 18 would not impact.two trains. 19 MR. MICHELSON: But.not have redundant ~ cooling in-20 the -- 21 MR. STRAWSON: Not have redundant cooling -- 22 MR. MICHELSON: To the given divisions. 23 MR. STRAWSON: -Right. k4 MR. MICHELSON: This is okay for the battery room. 25 What are you going to doTin the case of instrument rooms, O ANN RlLEY & ASSOCIATES, Ltd.- Coud Repoders 1812 K Street, N.W., Suite 300 Washington, D. C.' 20006 -(202) 293-3950 a

204 1 the same? (~T 4 b-2 MR. STRAWSON: The discussion last time we were 3 referencing provisions only in a passive plant, going back 4 to the evolutionary plant requirements document. We have 5 similar provisions covering engineered safety feature rooms, 6 covering emergency service water, pump compartment rooms -- 7 MR. MICHELSON: By redundancy -- 0 MR. STRAWSON: By redundancy, and we intend to 9 Clarify the book. Admittedly, it's.not very clear at this 10 point. We do intend to clarify the book to make it -- r 11 MR. MICHELSON: Single division. 12 MR. STRAWSON: One division, two division, single 13 system feeding each. /S 14 MR. MICHELSON; Are you going to ask for multiple (_) 15 active components on the given division. 16 MR. STRAWSON: We do, in addition, require -- this 17 is the bottom bullet of this slide -- that you be able to 18 take a single failure in each division. 19 MR. MICHELSON: That won't work for the power 20 supply. If you are really divisionalizing it, it means only 21 one division supplies the power. 22 MR. STRAWSON: We are taking the power from that 23 division which the HVAC services. 24 MR. MICHELSCH: Recognizing that, if the power 25 supply fails on that division then the redundant active C) ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950

.....q 205 1 components within the heating and ventilating won't do you 2 any good, because they are all getting the power from the 3 same division. 4 MR. STRAWSON* Equipment that it is serving is-not 5 running, yes. s 6 MR. MICHELSON: Yes. I just want to make sure we 7 understand. You are not leaving that slide yet. 8 MR. STRAWSON: No. I started to. 9 FR. MICHELSON: I was interested now, in your-10 second bullet. 11 MR.-STRAWSON: The first bullet-is what we have. f 12 The second bullet is what we try to identify what we intend. 3 13 The third bullet is hey, we are going to change it. 14 MR. MICHELSON: The second bullet essentially,.I 15 think, is saying you cannot-have interconnected ventilation 16 systems: is that what it says? 17 MR. STP.AWSON: That's the. intent. It is not what 18 the requirement currently states. 19 MR. MICHELSON: There are two' aspects of-20 ventilation. One is what they. call normal ventilatian,. d 21 which is non-safety, and t.be other is emergency ventilation 22 which is always' division-wise and so forth. Do--you intend 23 this to apply to the non-safety normal ventilation. 24 MR. STRAWSON: Yes. 25 MR. MICHELSON: 'That ends up interconnecting lthe O ANN RlLEY &_ - ASSOCIATES, Ltd. Coud Rep 0ders - 1612 K Street, N.W., Suite 300 Washington,' O. C. 20006 (202) 293-3950i

r ~' l 206 { 1 divisions, of course. 2 MR. STRAWSON: I* ends up litterconnecting. As we 3 discussed last time, we had applied requiressents to 4 isolation dampers for the normal part which would make them 5 a fire barrier. 6 MR. MICHELSCN: Those jsolation dampers have to 7 withstand all adverse influences that might generate within 8 that division, from a pipe break, from a fire, from a flood 9 or whatever. 10 MR. STRAWSON: To the extent that they form part 11 of the subcompartment bhttery, they are subject to the 12 requirements we impose on them. 13 MR. MICHELSON: In some cases that may mean ' (~'g 14 several paunds pressure the duct damper and so forth must V 15 withstand adequately to prevent propagation. Is that 16 spelled out somewhere in the EPRI requirements. 17 MR. STRAWSON: We have separate subcompartment 18 requirements.. I think that they don't -- 19 MR. MICHELSON: Relative to heating and 20 ventilating, is.this spelled out somewhere, so the heating 21 and ventilating man understa-Ja it. 22 MR. STRAWSON: The subcompartment requirements 23 that we have are not contained nor repeated in the HVAC 24 system. 25 MR. MICHELSON: I didn't find them. S. U ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

1 i i 207 1 MR. STRAWSON: Nonetheless, they-would apply. 2 MR. MICHELSON: You are very explicit here, but 3 only on the safety related equipment. This second bullet-4 does not pertain to non-safety equipment, which is-5 ventilating safety related compartments during normal 6 operation. 7 MR. STRAWSON: That's right. These apply to the-8 equipment that is relied on in an emergency. 9 MR. MICHELSON: But not for the normal ventilating 10 equipment. 11 MR. STRAWSON The normal ventilating equipment i 12 has separate requirements, among which is requirements on 13 isolation dampers, I believe_your concern is addressed. 14 MR. MICHELSON: I can't find that requirement on-t 15 isolation dampers that spells out-all of the conditions for 16 which the isolation dampers might have to be effective, and 17 the degree of allowable leakages from them and whatever - - 18 MR. CARROLL: What signals caused them to close.' 3 19-MR. MICHELSON: 1 There's a whole--bunch-of stuff. 20 MR. STRAWSON: In the handout on page two item 21 three, we attempted to address.your. question. We have some-22 references there. I am not sure that it' completely' 23 addresses your question, but that was our attempt.- 24 MR. MICHOLSON: This is-the one-that-I:am supposed. 25 to look at? ANN RlLEY & ASSOCIATES, _ Ltd. ] Court Reporters 1812 K Street, N.W., Suite 300.- Washington, D. C. 20006 -(202) 293 3950

208 1 ND. STRAWSON: No, at the very back of the 2 handout, the next to t' = last page of the handout. We had 3 some specific questions that we were addressing to provide 4 written information on. Item three on that page there was 5 an attempt at answering your question. 6 MR. MICHELSON: That's okay for smoke, but do you 7 address it for steam which is the same ventilation dampor 8 and must also -- 9 MR. STRAWSON: Sir, we have requirements that 10 address subcompartment-capability. 31 MR. CARROLL: What page. 12 MR. STRAWSON: We don't have requirements that 13 specifically address steam as a result of pipe breaks and 14 impact on isolation dampers. 15 MR. MICHELSON: It's not an impact, it's -- 1C MR..STRAWSON: Compartment boundary..But the 17 general requirements on subcompartments, clearly,.you would 18 have to account for all penetrations and --- 19' MR. MICHELSON: I don't disagree. I am only 20 asking for heating and ventilating. Are-those requirements 21 spelled out? 22 MR. STRAWSON: They are not. That's'what-I am 23 saying, they are not. 24 MR. MICHELSON: They don't.need to be,.I guess. '25 =MR. STRAWSON: What's that? - ANN' RILEY & ASSOCIATES, Ltd. Court Reporters - 1612 K Street, N.Wl, Suite 300 - Washington, D. C. 20006 -(202) 293-3950

209 1 MR. MICHELSON: They don't need to be? () 2 MR. STRAWSON: Our feeling is that they are 3 covered by the requirements on the subcompartment. 4 MR. WARD: Does that make sense to you, Carl? 5 MR. MICHELSON: Yes. If the heating and 6 ventilating people, which is a whole different discipline, 7 understand all the subcompartment pressurization and so + 8 forth and the two disciplines get together sure, it can be 9 worked out. That's somewhat of an if. It ought to appear 10 in the PRAs and so forth, to deal with pipe breaks as well.. 11 MR. CARROLL: I think it's a very big if, because-12 HVAC guys just tend to march to their own drummer or -are 13 left out of a lot of the stuff that goes on. 14 MR. MICHELSON: Heat loads and that_ sort of thing. {) 15 MR. CARROLL': Yes, they do.. 16 MR. MICHELSON: It can be'done. 17 MR. WARD: Does this issue surface'in one of the 18 issues? 19 MR. MICHELSON: Yes, it does. [ 20 MR. WARD: Your letter'is going to address' this?: 21 MR. MICHELSON: Yes, as well as our son of 016. 22 MR. WARD: Yes, that's what I am saying. 23 MR. CARROLL:- That's what we'were talking about 24 yesterday. 25 MR. MICHELSON! It comes up again. I am not going. O ' ANN RlLEY &. ASSOCIATES, Ltd. COud Repoderso 1612 K Street, N.W.; Suite 300 ~~ -Washington, D. C. 20006 (202) 293-3950' ~,-.

210 1 to pursue it on EPRI because that's not the place to settle s \\ 2 it anyway. 3 MR. STRAWSON: My inclination would be to move 4 onto the naxt slide. 5 MR. MICHUESoN: I just wanted to see what their 6 position was on it, and I think it's clear. 7 MR. WARD: We have 15 more 41.'"+es. 8 (Slides.) 9 MR. STRAWSON: This issue pertains primarily to 10 auxillary cire water systems, systems collected to large 11 bodies of water where there is the potential that if there 12 was a break you could have major flooding and concern with 13 its impact on safety equipment. The specific question r% 14 raised was with regard to use of flexible pipe and bellows U 15 which is fairly common in those kind of systems, and has the 16 requirement addressed that impact of bellows. Do we 17 specifically cover bellows and how they might affect the 18 issue of flooding. 19 In one of the revisions to the requirements 20 document we did add several sections with regard to this 21 flooding issue. One is in Section 2.3.6.3 of Chapter 6, and 22 also in Section 3.2.9, Chapter 9. These sections address-23 the openings of breaks in piping and the need for prevention-24 and flooding of equipment due to such breaks. 25 They do not, however, specifically address bellows O) C ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20000 (202) 293-3950

211 1 or flexible joints. Again, our opinion is that where such 2 bellows or joints are used they would have to be accounted 3 for in the analysis. 4 MR. MICHELSON: Most of the problem is how big is 5 the break when you have a bellows versus a pipe. Pipes, we 6 understand very well, and can decide how big the break is 7 probably going to be. But on the bellows it's a whole new 8 game. A flexible new joint for these water systems, it's a 9 whole new game. 10 We may way underestimate the flooding potential t 11 simply because we didn't postulate a big enough break. 12 (Slides.) r 13 MR. STRAWSON: This is my final slide. We also 14 had several questions raised with regard to the electric-15 power systems. The first question was with regard to the 16 conbustion turbine generator, our standby. source of-17 emergency power. 18 The question was, what seismic and weather 19 requirements apply. With regard to seismic,'the UBC Zone 2A 20-requirements would apply, in accordance with Section 4.3.2.3 21 of Chapter 1. With regard to-weather effects, Chapter 6, it' 22 calls for the structure to be designed to protect against-231 extreme weather conditionsf flood, tornado, et cetera.- -24 MR.~ CARROLL: -What does that mean? 'Are you going-25 -to meet requirements for safety _relatedcequipment? h ANN RlLEY &. ASSOCIATES, Ltd. i Court Fleporters' l 1612 K Sveet, N.V/., Sune 300

Washington, D. C. 20006 i --

(202) 293-39507 2. .. a

~ l i 212 1 { l MR. STRAWSON: No. It's not safety related. We 2 are going to design so that it will not be flooded out, and l 3 will consider the tornado loads. 4 MR. CARROLL: That doesn't tell me much. 1 l 5 MR. WYLIE: In that tornado missiles? 6 MR. STRAWSON: 'Yes. 7 MR. SHEWMON: You are not against raotherhood, are 1 8 you? t i 9 MR. CARROLL: I guess I can't be. But you are not j 10 designing for the 300 mile and hour tornado or whatever. 1 l 11 MR. STRAWSON: Do you know, Steve? We are not r l 12 making it safety grade. We-are designing so that -- I cm 13 not sure. L 14 MR. BOCKHOLD: Really, I think that our answer is 15 that we are looking for a beefy building'around a commercial L 16 grade good combustion turbine that-can handle a 100 year l 17 flood and handle wind loads'of tornado, but would not go to l 18 the ten to the minus seventh tornado that 300 m le per hour l 19 wind speed would. l; 20 It's going to be an architect / engineer value-21 judgment, and the utility.that purchases it will through i 22 review determine whether it conforms to the requirements or '3 not. That's kind of what we are requiring, commercial j 24 application. It's not safety grade. I 25 MR._WYLIE: _ This stems from ancther question, ANN. RlLEYn & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950-- n

213 1 really. I don't think the requirements document addressed \\ 2 this. Are you going to use the combustion turbine to backup 3 a diesel v'asn you taka it out oi service. The buses are 4 arranged to be able to do this, but the question is, are you 5 going to do that. What is the staff going to accept in 6 order to do that. 7 I guess this is going to fall into really the 8 classification of something that is going to have to be 9 reviewed on a vendor specific plant. 10 MR. CARROLL: I don't know. If I were EPRI, I 11 would be holding the staff's feet to the fire to get a 12 decision on this. 13 MR. WYLIE: I would too, but they haven't. ' /~' 14 MR. CARROLL: Because it's very important, ( 15 particularly the combustion design coming up. It's also 16 going to be an issue on the passive plants because they are 17 not going to consider the diesel safety ro.ated. 18 MR. WYLIE: That's what this question is really 19 directed at. What is going to be required in order to do 20 that. 21 MR. CARROLL: I guess the staff still has the same 22 position; they are still considering whether that will be 23 allowed under the tech cpecs? 24 MR. CRUTCHFIELD:- We are,-as you are aware, just 25 published the standard tech specs. As part of our ABWR C,- ANN RILEY & ASSOCIATES, Ltd. Court Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

214 1 review there is a combustion turbine generator in there'for 2 us to look at. We are examining 1the-standard tech specs, i 3 and there will be some credit given for the fact that therez a 4 is a combustion turbine in therc. The' credit will be in the i 1 5 outage time allowed for the emergency-diesel generators. ] l 6 There will be some relief granted. It won't be .i j 7 unilateral and total relief, but instead of'being ] i 8 unavailable for_a short period of time we will allow longer 9 periods of time for that main diesel generator to.be cut. l 10 MR. WYLIE: That's with allowing the_ combustion: 11 turbine to be connected into the position to supply that' bus j 12 in the event the diesel generator is out of service? i 13 MR. CRUTCHFIELD: Yes, sir. It will be available [ 14 to do that. i j

5 MR. MICHELSON

It won't be-automatic,7will it? l 16 MR. CRUTCHFIELD: No, sir. EIt will be'put in' 17 there and be manually lined upLto that_ bus-. 18 MR. MICHELSON:- So, it 1sn't any good -for: the ~ 19 short term. big.LOCA, it's allaright for:the longer term: load 20 following LOCA. I l 21 MR. CARROLL:. The logic that has been bothering us e 4 22. 1s, why are you going to11ose offsite power'. _Probably in-23 most instances it's going to be extreme weather.. It's' going 24 -to be a tornado or hurricane or'something_ coming through. If I have a diesel out:of: service and I'm relying ~on the 25 .O ANN RlLEY- & ASSOCIATES,. Ltd. Court. Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 t (202) 293 3950

d l 1215' i i i combustion gas turbine for that safety bus, the same tornado-4 J -- 2 or hurricane or seismic event is very.likely to-take it'out, i - 3 because it hasn't-been designed for it. 4 MR. BOCKHOLD: ' The_ normal operating condition 5 would be to have your diesels available. It'you had a i l 6 problem and one was out and you were at power, you would 4 { 7 like to-have-a little more time to get it back with this 4-extra capability of this-combustion turbine. You should be l 8 i j 9 allowed to have more time to get-it back. } 10 It's not the desire of-the utilities to operate-- 1 i 13 without one of the diesels.- 1 j 12 MR. CARROIL: I understand. This goes back to the l 13 more basic question-of N_plus 2, but we' won't' bring that up, =c 14 again, right Charlieir 15 MR. STRAWSoN:.Section.11.2-1 and 11.2-21show a-p 16 four winding tran=former. This was a change in the l 17 requirements document. The requirements document requires 18 now that we have-a reserve-power supply:to the-first-tier 19 electrical bus._ By_.way of_ illustrating this-We put in a-i 20 four winding transformer in the. figure. [ 21 This transformer is'not required by the document.- 22 The figures-don't impose requirements. 23 MR. WYbIE: Suppose _you'didn't'have a four-g. 24 winding,-what would you do? 25 MR. STRAWSoN: I am not an electrical person,_but i O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300.- Washington, D. C. 20006 (202) 293-3950-

.~ d-i- 216 1 I understand you would have two, three winding transformers -2 instead of a single four winding transformer, s { 3 MR. LINBLAD: What is a four winding transformer? 4 MR. WYLIE: It's a primary with three secondaries l 5 of different voltages, different impedences between + L l 6 windings. 7 MR. MICHELSON: Strictly. custom -- 8 MR. STRAWSON: You have a high voltage -- this-is l 9 one winding, and then we take them three separate off of i. 10 that. We have agreed to go back and look. - There was a 11 concern raised that a four winding transformer is not a. 12 reliable design. We have agreed to go back and look, and 13 try to get to the bottom of it. 14 We are aware thatLthe P4 plants-in France use the ~ 15 four winding transformer and -- l 16 MR. WYLIE: You know,.there are.some other j 17 conditions placed on that circuit by:the EPRI-requirements, i 18 and that is that the-BA-circuit of.the lowest voltage that 19 you can supply from and this kind ofLthing - xI-doubt the i-j. 20 French do that.- Regardless of that, that~is still a { 21 complicated transformer. l 22-That thing has, by my count, you have twelve 23 single phase windings in that thing. You have-something; i 24 like 13 or-14 bushings on it.- _You'have 24 some-odd j 25 connections, plus all thoseitaps inside that thing. Where 4 --O ANN RILEY & ASSOCIATES, Ltd. Court Reporters e 1612 K Street, N.W.i Suite 300 ,~ Washington, D. C. 20006 -(202) 293-3950_- f v v v y = w i.- wE,w ,w w c,,-v. r,, t ,w.-' ~ b,*,-4-+

217 '~ 1 is your spare? You.are not going-to get one very quick. iI 2 MR. DAUBRESSE: I was involved in the development 3 cf Chapter 11,-and the background on this issue-is that j 4 originally we had a three winding transformer feeding-i 5 directly to the permanent non-safety bus. As a result of-6 the regulatory policy issue on additional' power supplied to i 7 the top tier-load, we needed some additional capability for 8 that reserve transformer, mostly because in the case of --- 9 it's likely that the top tier would be at-a..different } 10 voltage. ~ j-11 We could notl feed the-top tier' loads-from-the= 12 existing winding. It seemed like it was without resolution 13 but the situacion would be to provide'a-four winding-i_ 14 transformer, of which two secondary windings'would-be the 15 voltage of tho non-safety vessel. The secondary winding 16 would be at the top tier. We looked at the experience wj'* tb 1e types of 17 18 transformers'and found-that four. winding; transformers are-19 - used in nuclear plants today.- We-think that1there may-be a j 20 -simplification benefit to other options such as two,.three 21 winding transformers, which would probably_ double:the 1 22-reliability problemt of one transformer. i 23 So, we are not sure we are-losing here, although-24 we understand-that:we need more bushings ~and windings.- It's 12 5 'probably less bushings:andcless: windings-thanLwe would have-h- ANN RlLEY & _ ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.~ C. 20006 -(202) 293-3950

l -o i 218-i i-1- with two, three winding-transformers.

j

![O 2 MR.. WYLIE:- Yes, but'you have two transformers.- 3 MR. BOCKHOLD: ' We will continue to look at it. j l-4 MR.-STRAWSON:- That's.the conclusion'of what I-had: I 5 there. l i 6 MR. WARD: Any-wrap up, Charlie?. l 7 MR.'WYLIE: No. i. 8 MR. WARD:' Are we writing a letter on-this? -9 MR.'WYLIE:. We don't have a draft now, but will by-l 10 the end of the day. 11 MR. WARD:.Okay. Thank you very.much, Mr. WylieL l 12' and gentlemen. Staff,'thank-you very'much. Let's take a; d 13 break until 10:15. i l 14 ~[Brief recess.] l ( 15-MR.-WARD: Let's. reconvene. The next topic?is~'-- 16 'there's an oxymoron in--here somewhere -- regulatory-. i p 17 requirements marginal to safety.. I will:-leave thatLto Dr. q l 18 Lewis. 19 MR. LEWIS: -Jaecause I'msthe:dosignated! expert on. 20 oxymorons? -I think_everyone:has; noticed over.thelyears:that 21 ~there's a-steady stream of proposals to increase: regulation,- 22 -and there=are very few proposals _to-decre'asefregulation. I? O ~ 23 think we even mentioned'it in our.' letter on1thessafety ~ ~ 24 goals. j ft '25 As a matter of-tradition that I'have noticed in1: 1 p u ANN-RILEY & ASSOCIATES,- Ltd; q6 Court Reporters' 1612 K Street, N W., Suite 300 ' Washington, D. C. 20006 j (202) 293-39501 -!l a

q l[ 219-1 studying government, every newLadministration starts out its-l' 2 job by looking at.the mass of' Federal regul'ations'and 1 l-3 discovering.that they are.largeLand growing. 'In fact, I }. 4 think I once saw an analysis in which they: vere' compared to-. i-5 the canonical' growth curve'of weeds, and they fit-reasonably. i 6 well. i l 7 So, the NRC is no exception, in having had a S program in place for some years-trying to' find placesrin-o I. 9 which regulations can be relaxed without negative impact _on- ~ ~ 10 the health'and safety of the public. What we are to hear. h ~ 11 about'today.is the. current fruits'of.that activity.and'the l-12 proposals that come from it. -Am'ILright?- i 13 MR. MINNERS: I hope so. l' 14 MR. LEWIS: It's up-to you l 15 (Slides.] u 16

MR.-MINNERSi_-'As you said,,the' Committee 1did have-

[ 17 a comment on their comments'on the safety goal. In: reply to I i 18 that, Chairman Selin said_we want-to!go further,L. Land-the-( I' 19 Commission will soon-receive:staffarecommendations:on2 a plan j. 20 to selectively. evaluate the entire body-of: regulations. 21 This briefing is to show you what that statement means, NIL e i 22-hope. l 23 That's just_a. general outline-off.the briefing.-lWe ~ -J 24 provided you withia, paper and there wereislight. 25 modifications..I-think-the only' thing that;I' remember-that: q 1 JOL -msv ussmuss, ut . Court Reporters .1612 K Street, N.W., Suite 300 L Washington,' Dc C. 20006 (202)_293-39502 )

i 220 1 was of any significance at all was a statement on resources () \\/ 2 that was changed in the copy of the paper you got back in 2 June. and what was transmitted to the commission recently. l 4 What I want to emphasize here is the process part l 5 of this program rather than some of the particular issues i 6 that have gone into it. -I hope that we are over the program j 7 aspects, that we have studied this enough, and that we can 8 start to go into actually changing some regulations. We 9 would appreciate your comments and suggestions on specific 10 issues. That is always a question of which one of these 11 things are marginal to safety and which ones are not. l 12 In trying to get some issues we had an industry 13 survey, and we also had a workshop and had a-Federal f 's 14 Register notice. From that, we'have gotten public comments 4 15 back and have gone through those public comments. Based on 16 people's judgment, we have selected some things that we 17 think we are going to start to look at, which if changed, 18 would reduce burden and have a small effect on safety. 19 One of the first comments we got is that-this i 20 process ought to be a continuing one. At the moment there 21 is heightened industry due to the President's question. 22 This should be a continual function of the Agency. I firmly 23 believe in that. There are lots of regulationsLthat we put 24 in -- people said we want a license and we-didn't have all 25 the facts, and nobody wanted to take all the time to make a /~ Q) ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

221 1 very careful analysis. We said if you do this conservative \\- 2 thing we will_give you a license. We can certainly 3 reexamine many of those. 4 We intend'to initiate rulemaking in three areas, 5 which people have generally come to the consensus - -I think 6 high burden areas. Anyway, the industry seems to thirk they 7 are troublesome to them, so we are going to look at those. 8 There are also two specific areas with specific requirements 9 that we are going to work on, to try to' relax or eliminate 10 those. 11 Then, we are going to examine some other-proposals 12 that people say would be worthwhile to look-at, but we l 13 haven't come to a conclusion of whether they;are worthwhilo, 14 both from the sense that we would reduce-burden and also 15 that they don't have a.large effect on'public safety. 16 MR. KRESS: Warren, on that public: comments 17 bulletin, as I recall you sometimes get comments like the 18 NRC should not even consider-doing such a-thing as this, 19 from the public. 20 MR. MINNERS: Yes. 21 MR. KRESS: What do you do with comments like 22 that? I'mean, how do you accommodate:them in your, thinking? 23 MR. MINNERS: .I think.my1 answer toLthat-is -- and 24 .I don't think we put a direct answer to anybcdy--- we did 25 note that those comments were made. The answer-is'that' O ANN RlLEY & ASSOCIATES, Ltd. .Coud Repoders - 1612 K Street, N.Wi, Suite 300 Washington, D. C. 20006 (202) 293-3950

l 222! 1 there is a limited amount of resources. If you are spending 2 resources on things that are-marginal to safety you can get l 3 more bang for your buck by taking those resources and 4 putting them on real safety luues.- 5 This is not a program to save utilities money, 6 although I don't think that's a-bad objective'in itself. I 7 think it can be justified as a_ safety program,-is that-we l 8 are trying to most efficiently allocate the limited-9 resources that we know that we have and that we know that 4 10 the utilities have. people are doing a lot'of maintenance - 11 - I think it's control systems that aren't doing much'for_- 12 risk. Let's take that-maintenance and that effort and 1 l 13 occupational exposure, and put it on something more 14 worthwhile. 15 MR. KRESS: Does that mean by eliminating _some ofc 16 these regulations you may actually be. improving' safety?: l 17 MR. MINNERS: Well, I guess.'that's a theoretical j 18 possibility, of the specif c examples.that are-up here,jI-19 am sure that you could say that there was'an improvement-to f 20 safety. Although the steam-line leakage one, if you balance 21 occupational hazard versus public hazard,-you might;say 22 there's an' improvement in net safety. 23 MR.- LEWIS:' Let-me make a pitch. This is an l 24 interesting.line of: question,lmake a1 pitch on what Tom--may 25-have.been pointing at. _I would argue'that;it.does improve i-ANN RlLEY- '& ASSOCIATES, Ltd.- .Couri Reporters : 1612 K Street, N.W., Suite 300 - 1 Washington, D. C. 20006 (202) 293-3950 ~ " n

a 223 1 safety to eliminate marginal regulations because the thing f~ I 4 'N / 2 that matters, as Shannon proved in 1949 in his work on 3 communication theory, what matters is the signal to noise 4 ratio and not the signal or the noise. Adding noise even if l 5 it doesn't add in specific information, still degrades the 6 signal to noise ratio and degrades the effectiveness of the 7 communication channel. 8 Another way of putting it is, we have made a big 9 to do and have been through this many times, on the issue of i 10 coherence of regulation. The more regulations you have that 11 are irrelevant, the more possibility there is for 12 incoherence in th9 regulatory body which degrades its 13 effectiveness. (')T 14 So, I think that eliminating regulations that are 15 marginal to safety has positive benefit for the safety.of 16 the enterprise, which brings me to my real concern which is 17 that any enterprise succeeds only if the people involved in 18 it have an incentive and a motive for doing it. I keep 19 trying to find why I should really think that the staff is 20 sort of gung ho and motivated to eliminate requirements 21 which are marginal to safety, 22 You have said that you feel that'way, and I have 23 no reason not to believe you. But, why? 24 MR. MINNERS: Why should we be motivated to do 25 that? AV ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington,~ D. C. 20006 (202) 293-3950

234. 1 MR. LEWIS: Why should you be gung ho to eliminate \\/ 2 requirements marginal-to safety? 3 MR. MINNERS: That's-a good -- 4 MR.-LEWIS: -In ten-vords-orLless. 5 MR. MINNERS: I think there's a culture inLthe 6 Agency-the opposite-way. I think traditionally, careers 7 have advanced on the finding problems?and fixing them. -I. 8 think there's a cultural Agency bias to impose-regulations 9. and not relax them. 10 I think the reason now why we are doing it is, 11 because the President snid-he-would like it done. I think-12 the Chairman is behin'd it.-.I think if-mere people had 13 raised the issue in the past maybe this program would have_. o 14 gone ahead faster. --The squeaky wheel;gets-the grease,-and-15 this was not a-squeaky wheel. 16 MR.- WARD: That's a good response, but the last ~ 17 part of it -- I guess see how ineffective this Committee is. ] 18 We were-_asking for this in_our very earliest safety goal-19 implementation _ letters, in 1987, 20 .MR. LEWIS:' I will agree, that we are ineffective. 21 MR. WARD: But there:are other_. indications of-22 that, too. 23 MR. LEWIS: There are,_indeed. .I_would even go to 24 the next step, would this be a betterEworld if we were nore-j 25 effective. But that's another subject. c O ANN RlLE' &JASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W.,' Suite 300 Washington; D. C. 20006 .(202) 293-39501 1

225 1 MR. WARD: No, I don't want to touch _that. 2 MR. MINNERS: I-think that's one of the reasons we 3 want to do something in this area, is to institutionalize 4 it. I have been with the generic issue program a l'ong-time,- 5 and I think it's a good program. That may be self-serving 6 or not, but I think that's the type of institutional 7 relation that we want to get on this program. It's visible, 8 it's tracked, the people know what's going on, the people 9 have to meet milestones. 'When things don't get done, people 10 start complaining. 11 (Slides.] ~ 12 MR. MINNERS: Generally,.the public comments were 13 that the regulatory process is dynamic, which it.is, and it~ 14 keeps changing. We have'had a tendency to go upcall the-15 time and never down, and we need more emphasis:on. reviewing. 16 what we have done, j 17 As I say, I am not-so sure about the may diminish 18 with time part there.. I can't think-.of:an example there. -I-19 certainly think.that some of-our initial requirements were. -20 not accurately predicted. We admitted they weren't. They 21 were conservative, and we weren't trying to make accurate 22 predictions. 23 Now that we have better tools for doing more 24 accurate predictions, we ought to use those to modify.the ~ 25 requirements appropriately.- This is the point:that I-was h ANN RILEY. '& ASSOCIATES, Ltd. Court Reporters 1612 K Streeti N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 L l __E _ __ _ _ _ _ _ _ _ _.. _ _. -.

226 1 making was, we should use the most efficient use of 7_s I ) \\/ 2 resources. If we are doing marginal things we ought to take 3 those resources and put it on more useful things. 4 MR. WILKINS: That bullet says licensee resources. 5 I thought you were talking about NRC resources. 6 MR. MINNERS: Both. More importantly, the 7 licensee resources. That's more important. 8 MR. WILKINS: There's more money tied up in those 9 than there is in the NRC? 10 MR. MINNERS: No, there is more safety tied'up in 11 that. 12 MR. WILKINS: More safet'J, all right. 13 MR. MINNERS: If they are doing inadequate (~N 14 maintenance on some piece of equipment because they diverted V 15 maintenance to some lesser safety item, I mean, that's-a 16 safety question. I think this program can be justified on a 17 safety basis and not on saving a licensee's money. I am not 18 against reducing the amount'of money that I pay for 19 electricity. 20 This is the instituting of the thing, and we agree 21 with that. The industry has strongly encouraged us to 22 continue with this program. They were even' suggesting that 23 we put it into a rule. 24 (Slides.] 25 MR.-MINNERS: Now,' we are down-to the nitty nC ANN RlLEY - & ' ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

227 1 gritty, of what we hope to do. We'are going to see hot we O 2 can institutionalize it. That hasn't been thought-through. 3 I guess the industry's suggestion is probably one extreme,- 4 Of putting it into-a' rule. We can have'a' letter.- I think 5 it.will probably end up something like the generic isrue 6 program. That hasn't been decided. 7 We would expect that we would have some: kind of 8 periodic inspection or-assessment of regulations, to see if: 9 some of the' previous ones could be reduced either because 10 conditions are changed and you have new information or the s 11 burden was underestimated, or whatever.- - 12 MR. LEWIS: Warren, just out of' curiosity, you 13 will not be surprised that one of the things _that jumps:to { } 14 my mind is diesel'generatora. I recently had occasion;to 15 look at the first-ACRS letter on' diesel generators. What it 16 said is that no nale is necessary because we think things 17 are in pretty good shape.- That's'what our first letter-18 said. 19 But one-is pushing'on anyway, c:?theidieselirule. 20 The-consideration-of whether:it might:be' marginal.did not 21 prevail in that case, despite1our well known ineffectiveness-22 and fairly clear letter on_the-point. It's just an example 23 that~I.was thinking of. 24 MR. MINNERS:- I agree.- -I think the. argument:on 25 diesel generators-is a lot more sophisticated than b ANN RILEY & ASSOCIATES, ' Ltd.. Coud Reponers ~.1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 m , _. _ - -. _ - _ - -. _ ~ - - _ - -.

6 228 1 discussions we used to have on regulations before. 4 I 2 MR. LEWIS:- I don't'want to restart that argument 3 here. It just occurs.to me as a-~ case where we said the rule j 4 wasn't necessary.- 5 MR. MINNERS: I agree. I hope you would agree l 6 that the issue is being looked at_very hard and the t 7 arguments are being made, which was not always the-case in 1 8 the past. 4 j - 9 MR. CARROLL: In fact,-your proposed rule that I 10 went out for public comment asked the question, is a: rule 11 necessary. 12 MR. LEWIS: We have already expressed an opinion 13 on it. Our first letter said it'isn't necessary. The { ) program has still pushed. ahead, and--the question _is still-14 15 being asked. In the end, it will beLan.important-question.. t 16 MR. CARROLL: Yes, indeed. { 17 MR. LEWIS: As it has been, from;the beginning. .I 3 18 MR.. CARROLL: Yes, indeed. 19 MR. MINNERS: We have suggestedLwhat program -- we-3 20 hope to get atlthe approved in about a year or something.- I x l 21. am not so sure that.that quick' approval is:necessary. I J e l-22 think it's more necessary to get the rules rolling,cto.get-l- the changes made. We are going to be working'onithat,.but-I 23 24 don't'think that's my highestLpriority.. 25-I think thatltrying_to:get-some1results-out of the l I -. - - ANN RILEY & ASSOCIATES, -Ltd. [' Court Reporters - l-1612 K Street, N.W.', Suite 300 Washington, D. C. 20006 _(202) 293-3950: L L-

229 1 program is a higher priority for me. 7_}s ( 2 MR. WARD: Warren, as I understand the program, 3 you are going to solicit suggestions from outside the agency 4 for eliminating requirements. 5 MR. MINNERS: Correct. 6 MR. WARD: Then, reanalyze and react to those. 4 7 You don't have a program for some sort of internal 8 generation of suggestions. 9 MR. MINNERS: Well, that hasn't been decided yet. 10 Whether we should sit down every three years and go through 11 all the new requirements or not to see if they are 12 worthwhile, I -- 13 MR. WARD: Sit down this year and go through the ("N) 14 old requirements. (_ 15 MR. MINNERS: We have done that, basically. 16 That's what this exercise was with the Fede"al Register 17 notice, was try to go through the requirements and get 18 people to identify issues. 19 MR. LEWIS: In our agenda we will, I hope,_we will 20 hear from NUMARC later in the meeting about how well they 21 have been consulted and about what their comments are en 22' this program. The ACRS has always -- not always -- fairly 23 consistently approached or suggested a very broad sort of 24 top down look at-the body of regulation, and that's not what 2n we are talking about here; is that correct? (~T C/ ANN RILEY & ASSOCIATES, Ltd. Coud RepCders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

a j 230 1 hR. MINNERS; No, I don't think so. LThis is more-1 L; - x z 2 of trying to find the baJ actors and fix-them. 3 MR.. KRESS: Do you envision-that asLa one time j' 4 thing, or something that might continue on,and on? 5 MR. MINNERS:- That's what we were-suggesting!is, 6 we are' thinking about how we can institutionalize that 7 process, whatever the process is going to be. The-3 suggestion is that maybe every three years we have some. kind 9 of a look at the rules and the guidance that;has been 10 1ssued. 4 11 MR. KRESS: I can'see.that_while these things'are: i l 12 down at the noise level,'that it would_be relatively easy to= 13 identify things that might be marginal to' safety. But as 14 you continue'down the road _you are. going.;to start digging. ] 15 into the meat'of the. things that are no longer. buried in the-16 noise level. Do you-have some systematic way of deciding 5 17 when you reach that point or some criteria.to judge-whether- ~ 18 this is really marginal orinot marginal,;basedLonfsomething. 19 .other than a survey and judgment?~ 1 20 MR.-MINNERS: I1think wefare. going;to:use7the 21 safety goal. guidance and precedent that we have used:in PRA.- 22 PRA is going to be.our basic tool for-judging the safety-4 23 - significance; of these requirements.: 'Now, you'runsinto_ things when you:. start doing-24 25 security requirements.- PRA doesn't~ work;too well there.; h ANN RILEY.& _ ASSOCIATES, Ltd. Court Reporters. 4 i 1612 K Street, N.W., Suite 300_ Washington, D. C. 20006 4 (202) 293-3950- ~-6 n g ,sgy + .e. w p r -m .-mmu.,--- w 4, e-

231 1 You can do part of the problem wit.h PRA but the initiating 2 events are not too amenable to anything but bayesian 3 statistics. 4 MR. KRESS: That is very interesting. You do have 5 then, plans for using PPA as a quantitative toolsfor judging-6 marginal to safety? 7 MR. MINNERS: I would expect that we would.have a B regulatory analysis that would accompany each one of these-- 9 rule changes that told the change in risk and the change.in 10 cost. 11 MR. KRESS: Looking at each of them one at a time,-- 12 as opposed to -- 13 MR. MINNERS: Yes. If-we-wanted to have some: 14 change in the containing testing procedures,Lwe would-have-15 analysis. Some of those tre judguental. I mean, chow much 16 does testing pr' "edures change risk. There'.s a lot of 17 judgment in there. You cL.,do some -- you can:do frequency, 18 I guess, and get some ideas about-it. But you.are-not going 19 to pin it down exactly. 20 It's like all risk analyses. _I-think it's_a g'ood 21 thing to do_because it makes you study the problem and makes 22 you try to quantify the problem, but-you can't completely 23 believe in the numbers at the end. You have a-lot of 24-uncertainties,Lyou have some bias youlhave incompletements, 25 you have-all these-things which you have to~ factor into_your b ANN RlLEY & -ASSOCIATES, Ltd. 1 Court Reporters : 1612 K Street, N.W., Suite 300

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V 232 1 judgment. You can't just give it to your computer and come 2 out with an answer. j 3 (Slides.] l 4 MR. MINNERS: Thece three'were what seemed to be 5 based on the public comments and within the staff, things i 6 which people thought didn't have a lot of -- were marginal 7 to safety and had some burden on licensees. These 8 illustrate the difficulty af doing this. Here, I guess we-9 have techniques and PRA to do the fire protection. Maybe we l 10 can make some assessments of that. i 11 The same thing here, we_can_probably make some 12 assessments and also soue assessment of the burden. We are-13 going to try to attack these three-issues first, and start 14 on those. 15 In addition to that,'there are'two other things-16 that are not rules. The main steam line-isolation-valve 17 leakage control system in BWRs_ic1now being pursued as.of-4 18 relaxation. _Then, there has always been talk about relaxing-i 19 the containment leak rateLin containment testing. You can ~ 20 certainly do a PRA on that to show what the risk change is ~ 21 and also_what the burden change'is.. 22 Then, we have four other. things which people have 23 said would be good.to look at.- There hasn't been a general l 24 consensus,Lso.these'are study projects. I would envision 25 something like prioritization. .We are_ going'to do that-kind ~ b ANN RILEY '& -- ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

233 1 of study to see what kind of risk is involved here and what 7~ >V 2 kind of burden. 3 This one was initially dismisced, on the basis 4 4 that there wasn't any burden on licensees because they had 5 already installed the systems. I think industry properly 6 pointed out that there was a lot of maintenance inspection 7 testing costs that still went along with this stuff that 8 should be included. So, we are going to redo this.one for 9 the burden analysis. 10 MR. WARD: What sort of possibilities do you see 11 for Appendix B QA. I mean, what kind of simplification or 12 elimination or whatever. 13 MR. MINNERS: Not all of this -- at least I 4 ("'T 14 haven't thought it out well. '%) 15 MR. WARD: Maybe you aren't there yet. 16 MR. MINNERS: No, we are not there. one of'the 17 things that I am going to talk about later is, we are going 18 to have a workshop on some of this stuff. We are relying 19 heavily that we will get some specific suggestions from 20 industry. We have some generalities in these areas but what 21 we need is some specifics; which criterion should be changed 22 or thrown out or modified, or whatever. 23 I think as Mr. Rasin will say later, I think that 24 they are going to support our program. We need their 25 support to be able to do this, and I think we are going to ANN RILEY & ASSOCIATES, Ltd. Coud Repodars 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

. ~ i f 2341 -r l 1 get it. 2 I think the reason this is-picked is, people have-l 3 a suspicion that-it doesn't have much saffect on safety. The l 4-conventional'visdom is that it's a huge burden, soI think j-5 that's why it was picked. That has to be analyzed a little 6 bit better, and somebody has to come up with a concept of 7 how we are going to change it to reduce the_ burden but not 8 change the safety, ,a 9 -MR. WILKINS: The Barclay memo suggested the 10 changes ought to be in'the direction of '.ess proscriptive 11 and performanceLbased. i 12 MR. MINNERS: Yes, and.that's wh.c I personally 13 need a lot of help on.. I think different people-have d; /~N 14 different definitions'of what performance basedimeans. .U i } 15 MR. WILKINS: Of:what that means,'yes. 16 MR. WARD: Yes, I'll say. 17 MR. MINNERS: -I don't_have a concept-of what~a f 18 performance based QA program would be. { 19 MR. CARROLL: Read _your reg guide, your new reg 20 guide-. 21 MR. MINNERS: -Maybe.that's a suggestion. As I i '22 said, I don't have a concept.- ~ 23 MR. JWIS: You guys are_way ahead o'f,me,'because 24 I am still stuck a little bit'on the termLwithout adverse 25 impact on. safety. If the criterion for: removing something-n ANN RILEY. & -ASSOCIATES,- Ltd. u Court _ Reporters 1612 K Street, N.W., Suite 300 l Washington, D. C. 20006 (202) 293-3950;

235 1 is that it can-be-done without adverse impact-on safety _that _O. 2 suggests that it had absolutely _no safety-significance,- 3 which I don't think many people are going to admit many_ 4 things. 5 So, the original idea -- in fact the title of the-6 program -- is marginal to safety. Marginal is an open term, 7 in terms of the criteria.. You have named some of-the 8 criteria, the burdensomeness-and so forth, of the thing.- In 9 the er, there will have to be some-kind ofTquantitative 10 basis for removing regulations'which,-though they do contributo positively to safety and'therefore cannot:be 11 12 removed without adverse-Impact, don't contribute-enough. 13 That's the hard part. l 14 MR. KRESS: That was my point earlier, that + { 15 somewhere along-the line~you aro going to have to' start-1 16 looking at those and deciding'what your criteria is for when= 17 you will quit doing that. 18 MR..MINNERS: That's right.:- l l-19 MR. LEWIS:--I just think that one.better-face up-l l 20 to the~ fact that it's;not going tofbe asleasy-as::the-21 viewgraph makes.it_look. 22 MR. KRESSi~ lYou wil1 want' to get ridLof some 23-regulations that have - an adverseieffect: on-safety, I think. - 24' MR.' LEWIS:; That.have a.: positive effect. 1The ones-25 that have'an adverse.~effect, yes, -you will want to. get: rid l h ANN RlLEYJ&1ASSOCIATESb Ltd. - Court Reporters - 1612 K Street, N.W.,LSuite 300 l - Washington, D.~ C. 20006 l

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. ~. I 236' 1 of. EO 2 MR. KRESS: .I am sorry, positive-effect.- You are i l 3 right. i 4 MR. LEWIS: That's right._ As Warren correctly-5 said, the safety goals are going to play an-important role. 3 6 So, one is going.to get into this entire business that'we j 7 sort of-finessed, on'how you-sort.of use the safety _ goals-to B make this-kind of decision. 9 MR. MINNERS: Again, the diesel generator i 10 illustrates that. I'mean, isJth M doing anything for 11 safety.'or-_isn't-it 'doing anything for; safety. That's_the I 12 judgments that are going to be_.made, and people have 4I 13 different opinions.- Ifagree;witheyou.- I.~think the 14 relaxations are more difficult-toJdo tha'n getting'new-15 requirements on,.~because there are peopleLwho haveLvested' a { 16 interest in thes'e.and have strong opinions.and know quitela 17 bit about them. So, these are: going 2to be difficult.to-; 1 18 change. j ) 19 MR. LEWIS: ; I can_ foresee our grandchildre'.1.- 1 20 _ arguing about confidence levels. 4 21 .MR." CARROLL: Or saidjanother way,cPR7.,-w h6w.did' i. I [ that.go nowl'-lPRA neans;never-having-;to:say ycu are 22 q 3 23 certain.- i 24' .[ Laughter ; ) ' 25; [Slidea.') 4lh ANN RILEYL & ASSOCIATES,' Ltd. _. _ Court Reporters - L i L 1612 ~K Street, N.W., Suite 300 Washington, D. C. 20006 f(202) 293-3950 L 4 o,

237 8 1 MR. MINNERS: This is our schedule. This is the 73 2 schedule for the periodic teview. It's a three year 3 period. As I said, we want to get this institutionalized 4 and exactly how this is. going to be done, whether or not you 5 are going to go down each regulation and do an explicit 6 analysis of each one or whether you are going to try to pick 7 out the bad ones based on your knowledge, or exactly how we 8 are going to do that hasn't been decided yet. 9 Down here is exactly the things that we are going i 10 to start out. Here is'this workshop that I was talking 11 about, in early 1993. Maybe'we can speed that up. This-is 12 where I would hope that I would get a lot of help from 13 industry on specifice of here is the revised form of the [' regulation you are going to have it in, and maybe some 14 15 information on what burden this is imposing on licensees, 16 and maybe even some risk estimates and stuff like that. 17 MR. WILKINS: Do you contemplate holding several 18 essentially identical workshops in different parts of the 19 country, or a series of workshops in one spot? 20 MR. MINNERS: I guess I hadn't thought about that. j 21 In talking with Moni, I'think it was kind of just one 22 workshop. We could think about more. 23 MR. WILKINS: You used the plural, and that's the 'l reason I am asking the question. 25 MR. MINNERS: It's a: good question. I just C.m ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

-238 1 thought one workshop. e-A- 2 MR. WILKINS: One workshop.- l 3 MR. MINNERS: Maybe it :would be worthwhile to have 4 more than one. 4 5 MR. WILKINS: Wnatever. 6 MR. WARD: On'th'e QA question, in-May of_1909.the-7 ACRS sponsored a workshop on Cpt, in which we tried to j 8 address the questions of the effectiveness-of-QA and whether 9 there should be some changes made. I don't think we' 10 successfully extracted ~much help from that.- There might be-11 some helpful information in that workshop.that someone:else. 12 could extract. 13 MR. MINNERS:- I think my problem'is' going [to be 14 getting resources to apply them.- That's going!to.be the 15 hardest part. 16 MR. LEWIS: I hate to be a broken-record,Ibut as 17 you try to-develop the criteria you will,get' lots of ~ l 18 suggestions through theseLworkshops:perhaps, if it's a. 19 perfect world you:will. - All4 these' issues we have been-20 talking about, 6>out marginal 1guestions-and whether howsone 21 uses the' safety goals:are going:to requiretstatistical-22 expertise on the part of the staff in order to do-that. t 23 I don't think-I need to say anymore. 24 MR. MINNERS: We will do the.best we can,-how 25 abont that. s\\ U ANN: RlLEY_ & ASSOCIATES, Ltd.-- . Coud Repoders _1612 K Street, N.W., Suite 300 - ' Washington, D. C. 20006 --(202) 293-3950

'1 239 1 MR. CARROLL: That's not always' clear, 2 MR. MINNERS: We willitry to do the best-we-can.- j.- 3 Tha intend to work with the ACRS on _this. As we get specific-4 proposals we want to discuss them with you and^get your: 5 opinions and advice. 1 guess the question I have-now is,_ 6 does the ACRS want to pursue more discussions on the ~ 7 specifics in the three regulation's before.we_go to~the 8 workshop or would you like to wait until after we have l 9 gotten-some input from the workshop and refined those p 10 programs'more. l 11 MR. CARROLL: The:three regulations being?! 12 MR.-MINNERS: :The three regulations being -- 13 MR.-CARROLL: Containment leak rate:-- 14 MR. WARD: Appendix -- ] 15 MR. CARROLL: Combustion gas and-hydrogen. 4 16 MR. WARD: Workshop first. 17 MR. MINNERS: The idea isLto try to make=these 1C less proscriptive andlmore performance? oriented,f_whatever 19 that means. It seems to me like 50.44'isya pretty 4 what I-4 20. would call--- a performance based _ regulation...You have to 21 be able to take care:of a.certain percentage:off- ~I-would 22 be interested in'seeing what people.mean-by performance 23-based in-that sense. 24 MR. MICHELSON: LCould youltell~me:approximately. 25 what yta_had in-mind in putting down: fire protection: ANN RILEY & - ASSOCIATES,' Ltd.. 2 ' Coud Repoders 1612 K Street, N.W.,' Suite 300 Washington, D. C. 20006 '(202) 293-3950-

240 l L 1 features; what are these, the superfluous nature of them? -2 Why do vm chink it's a good, candidate? l 3 MR. MINNEitS: I am relying-mostly on industry 4 comments on that because'I haven't thought about that much. 5 MR. MICHELSON: I expect the' utility industry has 6 commented that they would like not to be burdened >by_ fire-1 protection features as presently proscribed. 7 1 8 MR. MINNERS: I think it's basically the scope of ( i" i 9 this. They seem to be suggesting that we could apply PRA' l 10 techniques to define fire areas and fire barriers, and how l 11 much fire protection do you-need. 12 MR. MICHELSON: You certainly could apply PRA l 13 techniques if you had enough information with which to do-- 14 the'PRA, which is not the Dresent state of the art 15 necessarily. That's what they had in mind..They would- } 16 rather use a PRA approach than - -- 17 MR. MINNERS: PRALor risk based, I_ don't'know 18 which one you want to.say. 19 MR. CARROLL: .I think it's acknowledged that. 20 there's a lot of overkill. 21 MR. MICHELSON: 'PerhapsLthere-is. 22 MR. MINNERS:- I'have had-.your feelings tool As I-23 keep saying, I' hope we get some more specifics from the 24-industry, exactly whattthey-mean when they want these to be-25 performance _ based. We'have. generalities. lIt's going to be-b ANN RILEY & ASSOCIATES, Ltd.- .l ~ . Court Reporters.. 1 1612 K Street, N.W., Suite 300 1 Washington, D. C. 20006 '(202) 293-3950L

241 1 difficult for us to do, because we don't have that much 2 resources. If we get some good specifics from people and ~ 3 basically all we have to do is the administrative aspects of 4 it, we can probably handle three rules. 5 MR. LEWIS We will talk among ourselves. 6 MR. MINNERS: That's the end of my presentation. 7 Does anybody have any more questions? 8 MR. LEWIS: I have one question. I see this 9 obviously, as a useful exercise. First, let no ask another 10 question. We have in our package, a set of comments which 11 were made by project engineer in Region I. You have 12 received these and you have taken them into account in your 13 -- or not. 14 MR. MINNERS: I don't know the answer to that 15 question, sorry. My answer would be yes, we will. We will 16 get them and I will check with my -- 17 MR. LEWIS: We have a thick and apparently well 18 thought out set of comments from one of your project 19 engineers in Region I. Back to the other comment. You 20 know, if one were to just look at this list and say this is 21 a review of the NRC regulatory strinctu'. and these are the 22 list of things which can be handir$ with aininum effect, 23 this is a fairly thin list. I undelc;tand that it' T 24 beginning program. .l 25 I would see the vork that is done on these as ) O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K St eet, N.W., Suite 300 WasNnoton, D. C. 20006 -(202) 293-3950

242 I 1 important, not for themselves, but in the sense that they 2 form a kind or -- I hate to use the word paradigm because 3 it's been so over used -- as a paradigm for the way you will-4 treat the really hard problems when the hard problems come 5 along. 6 I, personally, have no deep problem with the 7 selection of these. But you will clearly get anny more 8 suggestions, and your problem is not raing to be not so auch 9 the lack of suggestions as the problem of how to make the 10 decisions. That is what-is going to bo determined on these-11 first few.- 12 MR.'HINNERS: 1 think-we have done enough study.. 13 I would have a difficult time saying that these arn the 14 absolute-best selections that could be made. I think it's 15 better, hey, let's get; going on this.tH ng and:try to do: 16 some of this stuff. Try-to change some of the regtriations 17 rather than trying to do more. planning and c.nalysis.. I am-- 18 not sure how much more you get out of it.. 19 MR. LEWIS: other questions? 20 MR. WARD: Is the staff looking for an ACRS' letter-21 at this time?. 22 MR. MINNERS:

Yes, I-'would like an endorsement 23 letter.

24~ MR. LEWIS: We will.. talk about this sidong 25 ourselves. g O ANN RlLEY &: ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 - Washington,- D. C. 20006 (202) 293 3950; J

243 1 MR. MINNERS: If you have any specific suggestions 2 or comments about how we should proceed, they would bs 3 welcomed. 4 MR. WILKINS: Do you want an answer to the 5 question that was the third bullet on the slica? 6 MR. MINNERS: Yes, I would like that. 7 Mr.. LEWIS: We will talk about that too, cmong 8 ourselves. I warn you though, that if we write a letter at 9 this meeting it will mean thau I write it between now and 10 our letter writing session, so the committee will not have 11 adequate time to consider it according to our -- 12 MR. CARROLL: I have one for Warren. You keep 13 talking about misapplying -- you use the example of p 14 misapplying maintenance to something really not important. 15 I would only ask that you read the letter that we are 16 putting out this month about the license extension rule 17 versus the maintenance rule, versus perhaps the reliability 18 assurance program; three things that deal with mainter.ance 19 that are similar but different. 20 Here might be an opportunity for you guys not to 21 have to change requirements in the future but to get them 22 right in the first place, so that all three of those 23 programs are really truly consistent. At the moment they 24 are not, the best we can tell. 25 MR. MINNERS: I know as part of the maintenance Oi) ANN RILEY & ASSOCIATES, Ltd. s_ /. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 s

l 244 I j 1 reg guide packago we are providing a regulatory analysis 2 which is going to have a comparison of these different ) 3 requirements, Appendix B, the maintenance rule, license 4 renewal rule and all these. I forget the whole litany. 5 And, a discussion of the whole interaction of how they i 6 connect and how they are different. 7 MR. CARROLL: There is no reason that they should i j 8 be different, in many respects. It's going to be a burden l 9 to people'to keep track of all three. of these things that 4-10 really, when you get down to it, are maintenance. a 11 .MR. MINNERS: The license renewal rule is j l l 12 different than the maintenance rule because it's supposed to. 13 do a different thing. 9 l 14 MR. CARROLL: No, it isn8t. i v 15 MR. MINNERS The license renewal rule was very 16 narrowly constructed to say all we want-you to look at is 17 things that are unique to license renewal.- That was a 1 l 18 policy -- 19 MR. CARROLL: Read our. letter. i 20 MR. MINNERS: Okay. l 21 MR. LEWIS: Our letter hasn't been -- i j-22 MR. CARROLL: I know. 23 MR. LEWI3: When we write it, read it. l 24 MR. MINNERS: You said misapplication of 25 maintenance, and I didn't mean that. That'sia little ~ i-ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 t 4 (202) 293-3950_-

245 1 stronger than I would say. What I was trying.to say is that 2 we have -- like a main steam line isolation system -- 3 MR. CARROLL: I understood what you were saying. 4 MR. MINNERS: -- which has low significance. If 5 we take away the system we don't have to do any maintenance 6 on it at all. People can then take that resource and put it 7 1.7 better use. 8 MR. CARROLL: I understand. 9 MR. LEWIS: Jay was raising questions which we 10 normally put into the list called coherence. Now, we have 11 another set of questions which are called signal to noise 12 ratio. Somehow, they do go together in generating the 13 communication..Thank you very much, Warren. I think -- who 14 was speaking for NUMARC, please. 15 MR. RASIN: I will be. 16 MR. LEWIS: I was. going to say that now we are 17 going to get the other side of~'the story, but now I realize 18 it may not be the other side of the story. 19 MR. RASIN: i believe-you are correct in assuming 20-that I am not here to oppose this program.. It's been a 21 while since I have been with :you, as Charlie Wylie pointed 22-out to me this morning. -I-am sorry-for-that. I really 23 would have liked to-have been with you last month for the 24 license renewal discussion, which-is still an area we are-2 5.. quite concerned about. h ANN RlLEY &- ASSOCIATES,. Ltd. Court Reporters - 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950_- r _sr

246 1 I was, hosever, on a forced vacation. My wife and 2 my secretary, jointly, decided that while my attitude was 3 pretty good my disposition was becoming somewhat suspect. 4 MR. LEWIS: So, they decided to dispose of you.- 5 MR. RASIN: I went to take care of that. 6 MR. CARRULL: How is your attitude today? 7 MR. RASIN: It's great. 8 [ Slides.) 9 MR. RASIN: This is a-very timely subject, because 10 what I would like to do at first is make you aware of some 11 discussions in the industry that were leading us into what 12 we think is going to be an extremely broad initiative,-and 13 not directly as a response or tied to this recent staff 14 effort. It was prompted-by some events like the Yankee 15 shutdown and like the San onofre-I situation, followed.by 16 some real soul searching in an economic business sense by a 17 lot of the utilities in the country, and a realization _that 18 we are already to a large degree.as-an' industry pretty non-19 competitive and the situacion is getting worse. Therefore, 20 there is a lot of things that we need to do about that. 21 In conjunction.with those industry discussions, 22 some discussions were held by some of our CE0's with 23 Chairman Selin. In fact,_they were followed up by an 24 address of Chairman Selin to the last NUMARC Board of 25 Directors meeting.- ANN RlLEY &. ASSOCIATES, Ltd. Court Reporters _. 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 L (202) 293-3950 :

f 247 1 At that meeting, after listening to our concerns 2 and suggestions to him, he turned around to us to provide a 3 challenge, acknowledging that perhaps it was true that some 4 NRC activities may have inadvertently and needlessly 5 contributed to nuclear plant expenses; and that could well 6 be part of the problem. Then, he challenged us to provide 7 him with recommendations on ways to Amprove this situation. 8 MA. LEWIS: I find it interesting though, that his 9 second bullet -- I don't know if it's an exact quote -- 10 finesses the question we were talking about with Warron, 11 because it says maintaining an overall level of safety and 12 not things within themselves can be eliminated without 13 adverse impact. That's a better choice of words. 14 MR. RASIN: That's correct. How you implement 15 that is really going to be a quandary. It is exactly the 16 quandary that you are dealing with, with the implementation 17 cf safety goal policy. That's probably going to have to be 18 some of our up front considerations, as to how do we do that 19 and what level of standard is set, and how do we come to 20 agreement on it and how is that perceived by the outside 21 public, the Congress and our ratepayers. 22 As a result of this challenge, we agreed to 23 provide industry resources for this on a large scale. We 24 further agreed that we needed to provide specifics and not 25 simply anecdotal information'or complaints. We currently O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

r 248 1 have a task force at NUMARC that is kind of set aside 7-2 working over the rest of this year, to come up with some 3 very detailed game plans as to how we would approach this. 4 I would like to emphasize that we are taking a 5 very broad look at this. It's easy to point the finger at 6 the staff and say it's all your fault. But we have come to 7 the realization in the industry, that we really need to take 8 a look at ourselves. There's a difference between having 9 the regulatory process imposed on you and then the way that 10 one responds to that regulatory process. We often complain e 11 about being intimidated by the inspection activities. We 12 are driven by a desire to get a SALP I rating. 13 We have to conclude that a lot of the fault.is r' 14 b) ours ar.d we have to take a hard look at ourselves too, as we 15 determine how to go forward. 16 (Slides.) 17 MR. RASIN: We do, however, consider this to be a 18 vital effort for the industry. We really see it as 19 something we have to go forward with. I will leave you a 20 copy -- I don't have enough to pass out. I have a few 21 copies of a letter that we sent to the NUMARC Board of 22 Directors shortly after this meeting. We will also note 23 that it was an acceptance of this great challenge by Mr. 24 Byron I.ce, who then proceeded to go on to retirement and 25 wish us good luck. oC ANN RILEY & ASSOCIATES, Ltd. Coud Reporters 1612 K Street, N.W., Suite 300-Washington, D. C. 20006 (202) 293-3950 l

249 1 (IAughter. ) 2 MR. RASINt He wasn't quite sure how we were going 3 to do this. We aren't either. But one thing we have been 4 told by the industry is that we will do it, some way or 5 another. 6 Finally, the Board is very serious about the fact 7 that we are at a p int where we havn to undertake this 8 activity if we are to remain a competitive and viable 9 industry. The time for just being in love:31th the 10 technology is over and the business man is really taking 11 over in the industry. We have to now begin to reconcile 12 those two entities. 13 MR. KRESS That second bullet ~~ before you take 14 it off -- that's a pretty strong statement. 15 MR. RASIN: It is, and it's probably a surprising 16 one for the industry to make in a public. setting.

However, 17 I can tell you from the economic analysis going on and from 1 83 the discussions that we had at our last Bo'ard of Directors 19 meeting,.I organized a panel discussion looking not only at 20 license renewal but at the whole question of economio 21 operation over the life of a plant, whatever that life was, 22 really in response'to the San onofre situation and to some 23 other analyses that we were aware =of in the industry.

24 We-had a very interesting discussion on.that,'and 25 found out from'a lot.of the utilities the' exact status--of O ANN RlLEY & ASSOCIATES, 'Ltd. Court Reporters: 1612 K Street, N.W., Suite' 300. Washington, D.' C; 20006 -(202) 293-3950-

250 1 their business at this time. As a result of that the entire 0 1 2 Board felt very strongly, this is the situation we are'in 3 and it's up to us to look at what we'are going to do about 4 it. 5 MR. KRESS: Have there actually been some 6 quantitative economic analyses made that shows there is 7 significant enough improvement in your economics due to this l 8 particular program, that they would actually make you more - 4 i 9 - I know it would make you more corcpetitive -- but make you 10 competitive.- 11 MR. RASIN: No, sir, we have not done that kind of 12 analysis. We havo detailed ecolaomic analysis on a number of 13 plants, that show in fact that for'some utilities some very 14 well run nuclear power plants that you would recognize are 15 not, in fact, compeiitive within their ownl company. That 16 competitiveness is compared to_ existing coal fired plants 17 that haven't upgraded to meet their requirements of-the 18 Clean Air Act. 19 That's something that 1. guess we had always felt 20 wouldn't come true. The clean Air Act.was' going to be so 21 onerous on us that nuclear would remain -ompetitive. That 22 is some of the stimulus of the industry to move'into this,- 23 is havinr1 very company specific analysis to show'that 'is not 24 the case. 25 . Thecefore, we don't have an analysis to convince ANN RILEY & - ASSOCIATES, Ltd. Court Reporters 1612 K Street,-N.W., Suite 300. ~ Washington, D. C. 20006 (202) 293-3950: 4 ,y.y.,..,,.,,,,n -.,_g,%,.,,,, - - r,.-.w,, 9.c..v,4: ,..m .,-~-y--, ,.-%.ey w.., , ~ 9 +r,, e .,_-u v.-r .y,

251 1 ourselves from a cost benefit point of view, we should 0 2 pursue this line. We have analysis that shows us from a 3 business point of view that we have to. 4 MR. MICHELSON: Are you trying to pursue this for 5 present day plants or for future plants? 6 MR. RASIN: Present day plants. 7 MR. MICHELSON: I am a little confused then. EQ B for instance, is presumably already taken care of. What are 9 you going to gain now competitively by reducing the 10 requirements on EQ? How does that work? 11 MR. RASIN: We can talk about that a little mure.- 12 MR. MICHELSON: I'gave that as an example.. Fire-13 protection is another example and so forth. There are'some 14 things you have to do, I realize, but I don't think what you 15 have left to do on a routine basis je the difference between 16 being competitive and not being competitive. 17 I can understand where adding all those features 18 to begin with to a new plant might very well put it in'a 19 non-competitive state. 20 MR. LINBLAD: Carl, I am interested in hearing his 21 response, but my recent experience is that EQ and-fire 22 protection was a continuing burden; that-it-wasn't a one 23 timo thing. 24 MR. MICHELSON:. Yes,'but it such a large 25 continuing burden'as making the difference between O ANN RlLEY & ASSOCIATES, Ltd.- Court Reporters 1612 K Street, N.W., Suite 300 : -Washington, D. C. 20006 ' (202) 293-3950:

t 252 1 competitive and non-competitive? 2 MR. LINBLAD: At one plant we had 15 people 3 assigned to the project. 4 MR. MICHELSON: Well, I understand if you have 5 thermal lag throughout your plant and it's not a problem. 6 You are going to have to go back and do something anyway. 7 MR. SHCWMON: That was before thermal lag. 8 MR. CARROLL: The cumulative effect -- I mean, 9 security is on the list. 10 MR. RASIN: Absolutely. 11 MR. MICHELSON: Yes, some I can understand, and 7 12 can see some of them are more difficult problems. 13 MR. WILKINS: Like in any business, your financial () 14 success usually depends on a lot of things, no one of which V 15 by itself is a go/no go situation. If you don't pay 16 attention to every single one of those things you are going ( 17 to end up bankrupt. 18 MR. LEWIS: There's a parable about a camel's 19 back, isn't there? 20 MR. RASIN: There are no panaceas in here, for 4 21 sure. If you look at the economic analysis, what you find 22 out is this point of-view, and it's very interesting. The 23 nuclear business was viewed as a capital intensive business 24 and that's history, and that's almost a given. However, if 25 you look at recent analysis one concludes in fact, it is a (V ANN RILEY & ASGOCIATES, Ltd. COud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950

253 1 labor intensive business if you really add up the ongoing O \\l 2 O&M costs. 3 The effect of many of the regulations and the way 4 that they are implemented as led to a great expansion of the 5 number of people that it takes to run a plant. That is the 6 area where we have not been able to gain control. So, all 7 of these things are additive in that regard. They require 8 additional expenses for the equipment because of the paper 9 kind of requirements. That carries kith it, a need to 10 expand staKf to handle the same thing. 11 So, we are increasing staff for instance in the 12 r;intenance and QA type areas, not to work on the plant but 13 to do paperwork to demonstrate clearly that you have fully 14 met the regulations. That's not a very productive situation. 15 That's ;he.jpes of things that we have to deal with. 16 MR. LEWIS: I think your profitability is really 17 not our primary concern here. 18 MR. RASIN: Absolutely not, nor.is it the staff's. 19 That's why it is really incumbent upon us to take this 20 larger view and realize it's our business and we have to 21 take care of it. 22 MR. LEWIS: I am just trying to get us off the 23 economic debate. 24 MR. CARROLL: Car. I ask one more economic 25 question. When Selin first came aboard he asked the staff, ! O(~N ANN RlLEY & ASSOCIATES, Ltd. I Coud Reponers 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950

.~. 254 ) I was it true that these rumors that O&M costs were 4 [ ' 2 skyrocketing and I saw the staff's response,-which seemed to I j 3 be that if you look.2t the data for the last two or three j 4 years it has leveled off. Is that your view? l 5 MR. RASIN: Actually, the last two or three years 4 ] 6 is a bit of an extreme. If you look over last-year's data, j 7 the last reported data, there does appear to be a leveling I ] 8 off to the point that OEM costs are increasing generally i l-9 around the rate of inflation.-However, that is on an 1 1 10 average. { 11 If you look more specifically -- a { 12 MR. CARROLL: It's also a big ITumber. - i 13 MR. RASIN: It's a big number and there's an 14 extremely widespread in it. With the newer plants: reaching f 4 j 15 more of a stable situation while the older plants which have 1 16 been some of the better performers, are on a pretty steep l 17 curve now with catching up and particularly with staff f 18 additions. I 19 MR. CARROLL: Okay, thank you. l 20 (Slides.] i-21 MR. RASIN: Let meEsay a-few words about our j 22 response to this current staff initiative, because we did i 1 23 put in the best effort we could in theiralatively short u 24 Federal. Register comment time to respond to it.: I would-25-likeitol emphasize a few points.- I' won't=go into-the. + ~ dlO Anw - uss=ms, ut p Court Reporters - 1612 K Street, N.W., Suite 300 - Washington, D. C. 20006 (202) 293-3950 w-78rf tr -=-4++-y w~ t- .q gr---t-v4-ev v.- ew vs o-re e, v u -w -gw.c' ? vin-+ y +.:m -3 y e-9 y g,

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255 1 attachments because Warren covered those pretty well in O 2 terms of the areas and categories. Let me make a fe. 3 statements which we tried to make up front in our cover 4 letter, to give our views on this, and then I would be happy 5 to respond to any of-the further detail you would like. 6 We believe that we have to acknowledge that the 7 regulations have served us well in terms of maintaining 8 public health and safety. I think it would be a mistake-to 9 stand here and view the entire body of regulations as a 10 complete disaster. In fact, it's not. 11 The general design criteria lead to a very well 12 designed nuclear power plant which provides a lot of margin 13 for the protection to the public. We should not overlook 14 that point. 15 However, there is a maturing nature to the 16 industry that we should acknowledge. Many of the 17 regulations were created as we gained experience'with these 18 plants. We now have a lot of experience. We know more what 19 is important and what is not important, and if we don't one 20 could reasonably.ask what have we been doing this last 20 or 21 30 years. 22 So,-this maturing. nature.certainly.providec'a 23 reasonable reason to take a reconsideration of-the 24 regulation and for industry-to look at_the-broader viewpoint 25 as to the way we do business.- b . ANN-RILEY & ASSOCIATES, Ltd. Court Reporters? 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 '(202) 293-3950: I

256 1 The greater experience level of the industry and O 2 the NRC, we think, supports performance based regulation 3 approach. I have to agree with Warren, however, that what 4 this performance based regulation approach means is 5 something that is going to require an awful lot of debate. 6 I sat and listened to an introduction to an exit interview l 7 on a procurement inspection focusing on the QA program, and 8 heard the statement this was a performance based inspectic, 9 at which time, we proceeded to talk about all-the-paper that 10 was or wasn't there and filled in, in the'right order. 11 Obviously, that view of performance was a little 12 different from what we had in mind. At the1same time, we 13 have not been able-to explicitly state what.s a performance i r ) base regulation in terms of something like Appendix R or i 14 15 Appendix B. 4 16 MR. WARD: You recognize the difficulty in doing 1 i 17 that. 4 la MR. RASIN: Absolutely. s l 19 MR. WARD: Everybody talks about performance base i ' 20 regulation including.the commissioners. -Hut it's.one of 21 things that when you say-it fast it sounds good, but when 22 you get down to figuring out exactly what it.isi it is -23 proven to be very difficult from what I can see, i 24 MR. RASIN: _ Yesi - sir.- It's~become'a new industry-J ' 25 buzz word, acturally. We_all use'it,=and I. don't think any i 5 O ANN RILEY & ASSOCIATES, Ltd.

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257 1 of us know exactly what we mean. 2 There is another activity that we have underway. 3 As you are probably aware, we participated with the staff in 4 a briefing on risk base regulation not too long ago, 5 actually this spring. We provided sont views on an idea for 6 approaching regulation and particularly the operational 7 regulation from a risk base point of view. We do have an 8 effort underway on that with even the proposal of perhaps a 9 pilot plant approach to that before us. 10 In light of this broad initiative we are taking-11 another look at that, as to exactly how does that fit in and 12 how may it be the underpinning of this broader initiative.- 13 one final thing that I would like to point out. 14 There was some discussion with Warren on the regulations. I 15 have to tell you, in our review of,the regulations it's 16 often cimes very difficult to point to the words in the book 17 and say there's a problem. In fact, the regulations are 18 generally fairly high level and_very hard to argue with. 19 In fact, where we get into trouble.is.when we go 20 to the regulatory guidance and the implementation, and 21 probably'even more so with the interpretation und ongoing -22 interpretation of those regulations;.what it means,.and 23 exactly what has to be shown.to show compliance:with that 24 regulation. 25 'That-is the area that has really accelerated O ANN RlLEY & ASSOCIATES,. Ltd.- Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950-

1. 258 I j 1 tremendously over the years and, in fact,. continues to 2 accelerate. That again, is psrt of where the industry has'a 1 l 3 problem in the way we are responding to that continued I 4 interpretation. We need to take a look at ourselves. In 1 { 5 looking at this, it won't be simply just reading 10 CPR 50. 6 We have to take a look at the guidance and the history of ~ l 7 implementation over the long term. i j 8 MR. WARD: That seems to be really a big one. 9 lt's not the regulations _so much as the body of regulatory l 10 practice. I didn't hear Warren say anything about this. 4 j j 11 There doesn't seem to be any acknowledgement in the NRC j 12 program, that this may be where-75 percent of whatever i j 13 problem there is exists. It's going to be harder to got a j t 14 handle on it. { 15 I think that's why the list of regulations that 1 16 Warren showed looks kind of a little bit like tokenism, 17 because it isn't getting at the heart of the' problem. l 18 MR. KERR: I certainly agree that that is a 19 serious problem. It has been my observation from this i 20 viewpoint-that I have had over the years, however, that part-21 of that problem lies with.the_ utilities, some of'which have i 22 been unwilling to acquire the technical' expertise to stand j up to the NRC when the utility was right and the NRC was 23 24 wrong. I-have seen certain utilities who,-when they-Ib ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 - Washington,- D. C. 20006

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259 1 disagreed with the NRC, were able to support what they 7_ 2 wanted to do because they had a combination of guts and 3 technical expertice to do it. I hava seen other utilities 4 which would cave in when they could have, with some i 5 additional effort, made a case. 6 I think, although it would be ideal to have 7 perfect regulators, if utilities are going to achieve some 8 of what you hope they would want to achieve, they have to be 9 willing to staff themselves to the point where they do have 4 10 the capability to argue their case better. 11 MR. RASIN: I think that's absolutely correct. 12 That's exactly what I meant when I stated that in fact we 13 have to look to ourselves on this problem and not just point ) 14 the finger at the NRC. We have examples of that all the (G 15 time. If you look coross the industry you do see that 16 spectrum of technical ability and perhaps we should say 17 operational regulatory courage. I don't know if that's a 18 good tern. He do see wide variations. l 19 As an industry, our typical response to a l 20 regulation on the regulation stage is we need some 21 flexibility to implement this in the best, most effective 22 manner. As soon as you move to implementation the comment 23 shifts to, tell us exactly what we havt to do to satisfy you 24 because we don't want to get any violations. That is 25 something ana have to overcome ourselves, l i 7-, V ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 tJ =P -r-'-'*t--t

1 f 260 4 1 That's basically what I have to present to you.

O 4

2 Again, I will leave a copy of Byron's Board letter with you j 3 for your information. I am sure we will be discussing this j 4 in more detail with you over the coming years. I would be l 5 happy to answer any further questions that you might hnve. 6 MR. SHEWMOP Part of your message is, you think 1 2 7 you have a challenge but you aren't sure what you are going 8 to do yet. Is that it, or did I misc something?- 4 9 MR. RASIN: I think it's correct to say that I ] 10 can't stand here and give you a presentation on here are all i 11 the components of our action plan. We do have a dedicated ~ 4 12 task force that we have actually pulled five of our 13 permanent staff people ~at NUMARC aside a5d closeted them off ('] 14 on a special assignment, to develop a plan which is in its \\e 15 first draft form for discussion with the industry at our 16 Board level and probably at a combined Chief Executive 17 officer level within the industry.. l 18 MR. SHEWMON: Fine, thenk you. 19 MR. WARD: In addition to-what Bill Kerr was 20 saying about the industry role, it seems to me that the NRC 21 program is going to depend-entirely on what.youLehallenge 22 them with. They are not going toEsurface ideas.for changing 23 regulations themselves. They are only going to. react to-24 outside the agency suggestions. 25 MR. RASIN: I hope that that's not completely' 3 b v ANN RlLEY &~- ASSOCIATES, Ltd. Coud Reponers 1812 K Streeti N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

- ~. 1 1 261 1 true. Certainly, being realistic, we understand that the 'i ) 2 people who wrote these regulations are very sincere people 1 3 who-believe very strongly in what they have done, and they i 4 are not likely to be the ones to come forward and say I ) i 5 don't need this after all these years. l } 6 on the other hand, I think as an Agency, we do see 1 7 a determination at least at the top to move forward in the 8 spirit of the President's initiative. We hope that we can j 9 proceed to work together. 10 If this turns into a' complete confrontational 11 thing between the industry and the staff -- l j 12 MR. WARD: No, I didn't'mean it's confrontational. 13 They are going to be looking to the industry for 14 initiatives. It seems to me that's the way their program is j 15 designed. 16 MR. RASIN: I think that's a -- i i 17 MR. WARD: They are expressing a willingness:to j 18 oaal with those, but they are not going to initiate many i. 19 things. It's up to you. } 20 MR. RASIN: I think that's a reality _we will have { 21 to accept. Along with that goes,.as I stated before, the 22 burden to provide hard facts and data and'not just; anecdotal complaints. That's something that we acknowledge. 23 1 -24 .Thank you very much. 25-MR. LEWIS: Thank you very much, Mr. Rasin. We .i p. V ANN RILEY &-' ASSOCIATES, Ltd.- Court Reporters. 1612 K Street / N.W., Suite 300 - Washington, D. C. 20006 .(202) 293 3950 ~

262 1 have, I guess, six minutes or something like, that still 2 allocated to this subject. If we want to write a letter and 3 I am required to draft it, thers are two approaches we can 4 make. We can go around the table and get people's inputs 5 which is not sensible in six minutes, ask you to give me 6 inputs by the end of lunch, or I will tell you what I would 7 write without inputs, which is another option. 8 MR. CARROLL: Let's try that one. 9 MR. SHEWMON: Why don't you start with the last 10 one. 11 MR. LEWIS: Okay. What I would write is that - I 12 . will say we but I mean I -- are happy that this 3s going.on. 13 It's something that is overdue. The list in my view:is a 14 little thin but that doesn't matter at this point, because 15 the hard questions are going to be to implement' decision 16 making within the list and the. list can serve as well as any 17 other list as a set of paradigms for these' difficult 18 questions of whether the rule should be with at adverse 19 impact or without too much adverse impact to the extent to 20 which the costs and the burden are different things,.or the 21 question of whether in fact it's the rules or the regulatory 22 practice which is the issue. 23 Those things can be fought out.on more or list, 24 any list. We look forward, as this program matures, to 25 interacting closely with it and will keep an eye on it. 3 $ <b g i ANN RILEY &- ASSOCIATES, Ltd. Court Reporters ? 1612 K Street, N.W.; Suite 300 h Washington, D. C. 20006 (202) 293-3950-1

263 1_ That's what I would say, 2 MR. CARROLL: I am going to write additional 3 comments if you say paradigm. 4 MR. LEWIS: I might write additional comments, 5 depending on what the Committee does with the letter. 6 MR. KRESS: Are you going to say anything about 7 use of PRA in safety goals? 8 MR. LEWIS: Yes, because you just reminded me. 9 PRA and safety. goal. That's in the--package _of very 10 difficult things that they.have to resolve. You have to 11 resolve these things on an issue slways, and in_the abstract l 12. doesn't help. I do think that again, the~ point that: Jay 13 brought up about coherence, is a_ relevant point. 14 All-that-can be-tolded'in.- I think on this one, I ~ 15 would not' slap the staff around and say-they are doing a 16 terrible thing or anything like that. .t 7 MR. WARD: 'I think they have a wonderful attitude 18 on this. You talked about Rasin's attitude. I think 19 Minners has a. wonderful attitude. 20 [ Laughter) 21 MR. LEWIS: -You have to understand that-it's 22 temper. 23 MR. WARD: I think you ought to say something- ,24 about the issue'of regulatory practice:as opposed to -- 25-MR. CARROLL: -He said-that. O ANN RILEY :& ASSOCIATES, Ltd. Court Reporters - 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3960

-l 264 1 MR. LEWIS: I just did. i 2 MR. KERR The letter shouldn't be longer than ten pages. 4 MR. LEWIS: The letter, if I write it, will be 5 quite short. 6 MR. CARROLL: You don't want to work statistics 7 into it some way or another? 8 MR. LEWIS: You bet. 9 MR. WARD: Thank you very much, Mr. Minners and 10 Mr. Rasip. Let's turn to the'next agenda-item. W . e can go 11 off the record now. 12 [Whereupon, at 11:30 a.m., the-transcribed portion 13 of the meeting concluded.] O" 15 16 17 18 '_4 19 20 21 22 i . ) 23 -24 q- -25 - ANN' RILEY 1& ASSOCIATES, Ltd. L Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 --(202) 293-3950

l t O REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: 388th ACRS Meeting NAME OF PROCEEDING: DOCKET NUMCER: PLACE OF PROCEEDING: Bethesda, Maryland were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting cor:pany, and that the transcript is a true and O accurate record of the foregoing proceedings, h wp 0, vd- ) of ficial Reporter Ann Riley & Associaten, Ltd. ( 1 1j i

.: 9 9 o A L W 32 i. Evolutionary Plant Final Safety Evaluation Report Presentation to h . Advisory Committee on Reactor Safeguards Bethesda, Maryland August 7,1992

~ ~ O O o Utility /EPRl/NRC ( Agenda Utility Requirements Document Goals, Conclusions and Requests

Response to Specific ACRS Technical Questions Corrosion p

~ Main Steamline isolation Valves ~ Heating Ventila"ng.and Air Conditioning Systems i Flexible Pipe Combustion Turbine Generator Reserve Transformer-n. i Advanced LWR Program ACRS 8/92 2 - i

O O O Utility /EPRl/NRC Utility Requirements Document Goals Utilities defined what they wanted in design requirements Enhanced safety, additional capability not found in typical operating plants Extra margin available to improve operational flexibility NRC agreed to review design requirements to help assure tnat a plant that meets requirements is licensable NRC staff completed a comprehensive and thorough review Requirements should resolve generic issues in the context of design requirements to achieve regulatory stability NRC management and the ALWR Program have agreed to resolve outstanding. issues in parallei with evolutionary reviews for ABWR Final Design App;aval ACRS 8/92 3

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= 1 ,r Utility /EPRl/NRC q a Conclusions & Requests j g 4 3 ,I The NRC staff review of the Utility Requirements Document has. [ [ been effective in identifying and resolving issues that-require: { . policy or:genericfresolution L r ! Attachments toiour presentation contain a status of policy issues - c [ L ~

and a c~opy;of the Ju.ly 30,1992 5tter on catagorization.of-SER.

issues. a w LThe ALWR staff requests;that the ACRS support the agreement-j i L. L i ~ that a supplement to the Evolutionary Plant FSERLshould resolve q . outstanding ~ generic design. issues in parallel S...n evolutionarv l [ ' reviews'for ABWR Final Design' Approval! . ~ l ( 1 e Advanced: LWR Program; U

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l s ) l c.w. f L.,

s.,~ O O O ~ Utility /EPRl/NRC 3 N, Corrosion Program Question Explain the ALWR Reauirements for Providing Cathodic Protection -Section 9.4.of Chapter 11 provides requirements for cathodic protection includes needs analyses, protection and monitoring requirements Section 9.4.1 of Chapter 11 will be reworded to specifically require a

site survey.to determine cathodic. protection needs early in the construction. phase and to implement these needs

.l A reference 1to Section 9.4 of Chapter 11 will be added to the structural requirements in Chapter 1 ( ) Advanced LWR Program: ACRS 8/92 5 '

O O O Utility /EPRl/NRC i BWR MSIV Pipe Break Question i Discuss the Capability of the MISVs to isolate Pipe Breaks Under-Loading Conditions Associated with the Broken Pipe Sectiqn 5.4.1.9 of Chapter 3 requires that MSIVs be of a type which have demonstrated the capability to close under the high flow conditions of -steam line break without damage to the valve' and with the ability to maintain leak tightness -MSIVs in current use have been demonstrated to meet this requirement based on. testing conducted in the late 1960's.at CECO's Stateline Station. The results of this demonstration are contained in General Electric Topical

Report APED 5750-1 ACRS 8/92 6 u

-+ s e

O O 0 1 t ~ Utility /EPRl/NRC j h .Switchgear and Battery Rooms HVAC Question 1 I 3 i P Explain Redundancy for the Switchaear and Batterv Rooms H'iAC f[

Section 8.2.2.3.1 of. Chapter'9 requires that the switchgear room cooling

. system consist of multiple divisions consistent with the safety-related 1 L electrical divisions j It-is intended that j LaLseparate cooling and ventilating system serve each electrical division 1 the ventilation. systems be powered from.De same electricai' division i-they are' serving; j i the ventilation systems not be cross connected between rooms of other divisions I Volume Il of the Utility Requirements Document-will be revised to clarify: 1 l the above explanation SectionL8.2.1.2.1 of ChapterL9 requires that'each HVAC system for, L L safety-related systems be; capable of performing its intended function [ L . assuming a single active component failure l Advanced LWR Program [- CRS 8/92 7 f

O O

O LUtility/EPRl/NRC Compartment Flooding Question Discuss URD Reauirements for Flexible Pipe or Bellows ^ +- The URD has been revised in response.to ACRS concerns relating to flooding due to breaks in auxiliary water-systems piping - - -Section 2.3.6.3 of' Chapter 6 and Section-3.2.9 of Chapter 8 have-ibeen added to address l openings'or breaks in the piping.and the need for prevention andl mitigation of such breaks The new requirements are generic'and do n'ot address bellows or.

flexible joints specifically. cTheLURD.is silent on the use of bellows,.

j I but the designer would haveTto meet flooding requirements for systems with bellows . Advanced LWR Program ^

~ O O O Utility /EPRl/NRC Electric Power Systems Questions What are the ALWR Seismic and Weather Reauirements for -the CTG?_ Structures and equipment.shal! be designed for seismic in accordance with UBC for Zone 2A (Chapter 1, Seotion. 4.3.2.3) The building-and related structures shall be designed to protect the CTG against extreme. weather: conditions such as floodetornado, etc. (Chapter-6, Section 4.6.4.3.4) .. Discuss the four windina reserve transformer illustrated in Chapter 11. Fiaures 11.2-1 and 11.2-2 The figures are illustrations and not meant to be requirements 1 i To? address' the. concern regarding the reserve transformer, revisions to figures are being considered-Advanced LWR Program ACHS 8/92 8

"p Evolutionary Plant Refuirements Policy Issues ,.V ISSUE EP Status

Comment I.

SECY-90-016 Issues A use of physically-based source term done agree but schedule for referencable NRC position on implementation of new source term problematic for Evolutionary Plants B anticipated transients without scram closed agree C mid-loop operation done agree but NRC Staff expanding issue to include all " Shutdown Risk" and Staff position still developing D station blackout closed agree E fire protection closed agree but question "line-of-sight" in containment and the impact of " safety related" in Policy F intersystem loss-of-coolant-accident closed agree G hydrogen control closed agree but considering possible improvements by using catalytic recombiners H core concrete interaction - ability to cool done agree, however need NRC clarification of extent core debris of analysis of effect of uncooled core debris I high pressure core melt ejection closed I agree J containment performance done agree, ALWR approach is consideird an acceptable deterministically established alternative to NRC Staff's CCFP of 0.1 K dedicated containment vent penetration closed allow vent but prefer other solutions to expected scenarios L equipment survivability closed agree M elimination of operating basis earthquake closed agree N in-service testing of pumos and valves closed agree

O Evolutionary Plant Rekuirements Policy Issues (Continued) II Other Evolutionary Design Issues A industry codes and standards closed agree B electrical distribution done agree C seismic hazard curves and design done agree on use of "scismic margins" as alternative to l seismic PRA { parameters D leak-before-break closed agree E classification of main steamlines of closed agree boiling water reactors (BWRs) F tornado design basis closed agree G containment bypass done agree H containment leak rate testing closed agree I post-accident sampimg system done disagree with need for dissolved gas sample J level of detail NA NA k prototyping NA NA L ITAAC NA NA M reliability assurance program donc agree but questions of implementation remain N site specific probabilistic risk assessments done agree O SAMDAs NA NA P generic rulemaking related to design NA NA certification Q common mode failures in digital I&C overall agreement, exept for need for analog control systems indication R beyond design basis analysis of external implementation questions (seismic margins) events S multiple steam generator tube ruptures agree, analyze as " Safety Margin Basis" T PRA beyond design certification agree but need clarification on implementation U control room annunciator reliability agree

" Status" Codes (See Monthly Reporf):

NA = not applicable to Evolutionary Design Requirements done = all EPRI/ALWR work done and available for discussion with the NRC closed = no additional interaction expected between EPRI!ALWR and the NRC for SER J

'\\ Electne Powar Researen \\nstitute Leaaershto in Science anci Technology O-July 30,1992 Dr. T. E. Murley Director, Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, D.C. 20555

Dear Dr. Murley:

Subject:

Categorization of Evolutionary Requirements SER Issues As agreed in our June 25 meeting, we have examined and categorized our specific concerns and issues with the May version of the Safety Evaluation Report on Volume II of the Utility Requirements Document (URD). We believe the attached list of " bins" reflects a useful categorization such that NRC and - industry resources can most effectively continue the issue resolution process. Three bins were established:

Bin #1 contains a number of relatively minor concerns. These'concenu were -

O siven to rour eroject uaa ser aaa coasiderea ta the oasotas cie aug ot the Volume II SER. We expect that changes will be made in the SER to address ~ j these issues prior to finalizationin August.

Bin #2 contains issues where we disagree with the issue resolution described -

in our own SER but where the Evolutionary Plant Certification applicants L currently maintain positions that don't conflict with the URD..We will monitor the resolutions reached between the applicants and the NRC over ' the next several months. Where those resolutio_ns are acceptable to our own ' Utility Steering Committee (USC), we will make the necessary URD_ changes - l to clarify the resolution position. We would also expect' changes in the l Supplemental SER for Volume II. (Note that since the final SERs do not l now exist for the ABWR and the System 80+, we cannot agree today tha_t the i USC will endorse the resolutions finally reached between the NRC and L Certification applicants.); ~

Bin #3 contains issues where the current course ofissue resolution between.

l the NRC and the Certification applicants appears not to address the Utility /ALWR I'rogram concern. On these issues, we expect to continue the ' dialog with the NRC at an appropriate level - for example in the August 13 meeting with you ~and your senior managers. This category may also l expand in the future as the resolution of " Bin #2" items continues. Headquarters: 3412 HdMew Avenue, Post office Box 10412, Palo Alto, CA 94303, USA e (415) 855 2000 Tehex: 82977 EPRI UF e Fax: (415) 855-2954 - - M4rshingtort Ofnce: 1019 Nineteentn street. NN, suite 1000 Wasnington, DC 20036, USA * (202) 872 9222 e Fax: (202) 296-5436

N f Electne Power - . Researcn \\nstitute Leaaersnio to Science ana Technology-Dr. Murley, these are relatively smalllists considering the thousands of requirements found in the Utility Requirements Document and reviewed as part of the staff SER. We hope that this general spirit of cooperation will be maintained as we continue our efforts to define the stable regulatory basis that everyone believes is necessary for a future resurgence of nuclear power in this - country. ' If there are any questions in this matter, do not hesitate to contact me (415-812-2826), Ted Marston (812-2803) or John Trotter (812-2810).; Sincerely. f nNNN i George Bockhold Jr. Senior Manager [-- Advanced LWR Program CC:. : J. Wilson 1 E. Kintner ) O t -) l [ h -1 i 1 j-k p =

i

?- 4 i i Li,i -i LQ " Heaoquarters: 3412 Hillview Avenue rbst Offica Box 10412. Palo Alto, CA 94303. USA (415)'85s-2000. Telex: 82977 EPRI UF e Fax: (415) 855-2954 Washatgfon Othee 1019 Nineteentn street. NW. Suite 1000. Wasnington, DC 20036. USA e (202) 872 9222

Fax: (202) 296-5436 -

Ej [.

O O O Evolutionary Plant Utility Requirements Document, Safety Evaluation Report Issue "Binning" Bin #1, Minor Issues Resolved via Comments to May 1992 SER +. Comments provided to the NRC Project Managers. Changes expected to be reflected in the August,1992 (Final) Safety Evaluation Report. ID 'Iltle FSER pg or # 1-1-1 Hardness for stainless steel E.1.V-66 1-1 Alloy 600 E1.V-67 1-1 IST F.1.V-95 E1.V-96 E1.V-99 1-1-4 Valve qualification E1.V-100 E1.V-101 1-1-5 Non-addressal of hydrogen mitigation E1.V-1 1-1-6 Not specific enough on transient & accidents E1.V-5 1-1 Basis for accident management E.1.V-7 1-1 A Uncertainty treatment Ch1A 1-3-1 Snubbers - p3.2-4 1-3-2 GSI-29 reterence p3.2-4 1-3-3 Single failure p 33-2 1-3 PORV reference p 33-3 1-3-5 Missing " exception" p3.5-6 1-3-6 CVCS safety classification E3.V-3 1-4-1 Wrong figure # p 4.4-1 1-4 Fuel design forload follow E4.V-6 Prinied: July 30,1992 at11:11 AM f

g. 1-4 GSI-9 reference - p 4.6-2 i 1-4-4; - Fuel holdown force : p 4.6-3 1-6-1: Cask pit design and cask drop - 6.4 ' 1-6-21 Reduced bond of epoxy-coated rebar. 6.4-19 r y 1-7-1 13 Ch. 7 typos - various-o 5 Ch 8 typos :- various 8-1 1-8-2.- Pump minimum flow design 1 1-9 L Centainment annulus ventilation - - 9.8.- e ,.[

1-11-1 Electric power reliability:

3 41 4 ..t L.w 'j ..d'.- e ~ . 7 3 l PrintNiJuly 30,1992 at11:11 AM L A t a W .L I, 4 2.~d.'O+ " 4 ,. 4d-r.Nd c -s .' ?' - - w r + i, U 4v e w 6 + n-y y l~='. 4 w e-r + .+.e.m..-. v =

s.

e ,m.- + . ~

~. ~. O in #2, Issues Resolved via Ongoik Work with Certification Applicanth B Issues discussed by EPRI/ALWR with current applicants - General Electric and - ABB/Combustien Engineering. Those discussions have not indicated that the applicant /NRC agreements have caused a conflict with Utility Requirements. Changes to the Utility Requirements Document will be considered later to reflect,in Volume II, agreements between the NRC and the Certification applicants. Unless otherwise indicated, NRC position is expected to be the same for all ALWR Design Certification Applicants. . Changes to the NRC Safety Evaluation are expected to be part of first Supplement to the Safety Evaluation Report. ID title FSER # or page Specific Certification Applicant? 2-1-1 Use of Zone 2A. p 1.4-6 2-1-2 Recurrence interval for winds p 1.4-15 2-1-3 Nitrates / nitrites E.1N-63 & P.1.0-10 1 2-1-4 Tornado wind speed and aircraf t impact p 1 4-22 2-1 A-2 Internal fires 2-1B-1 GSI-HF-4.4 (procedures) 2-1B GSI-HF5.1 (MMIS-local) 2-1B-3 GSi-HF5.2 (MMIS-Control Room) 2-1B-4 GSI-94 (additional LTOP) System 80+ 2-5 Safety-grade Wetwell/ Drywell sprays ABWR 2-5 Unquenched core debris bed assessment 2-5-3 Hydrogen - 2-6-1 BWR Turbine building classification - ABWR-2-6-2 Inspection of potential structural degradation of SR structures Printed: July 30,1992 at11:11 AM 4 sn

2-6-3 V & V of computer programs 2-6-4 Diagonal bars in containment walls ABWR 2-7-1 GSI-82, Peyond Design Basis Accidems in SFP 2-9-1 Fire Protection inside containment 2-9-2 " Safety-Grade" Fire Protection Provisions ~ 2-11-1 Load capability of CTGs 2-11-2 PRZ neaters in EDG load calculation E.11.V-11 System 80+ 2-13-1 60-year life of TG p 13.2-1 2-13-2 Need for prototype testing (of turbines) p 13.3-9,13.4-2 2-13-3 Turbine Missie issues E.13.V-3/ P.13.M-1 E.13.V-1 E.13.V-5 E.13.V-6/ P.13.V-2 E.13.V-8/ P.13.M-2 E 13.V-9/P.13.O-2 E 13.V-10 Prinied: July 30,1992 at11:11 AM s. _.

O O O Bin #3, ' Issues Identified in May 1992 SER for Which Monitoring of Certification Application Is Not Sufficient _ Issues discussed by EPR1/ALWR with current applicants - General Electric and ABB/ Combustion Engineering. ' Those discussions have indicated that the applicant /NRC agreements have caused a conflict with Utility Requirements or have not addressed the issue found in the SER on Volume II.' - Discussion with the NRC will continue under the industry leadership of the

+

EPRI/ALWR Program Changes to the Utility Requirments Document may be needed after further discussions. a Changes to the NRC Safety Evaluation may be needed in light of these further .. discussion and they would then be part of first Supplement to the Safety Evaluation Report. ID title. FSER # or page Specific Certification Applicant? ~ 3-1 QA for NNS and forITS p 1.7-2 & p 1.9-2 3-1B-1 : Finality of GSI Resolution for ALWRs various, App. B to~- Chapter 1 3-4-1~ EPA for RPS power supply E.4.V-4 .A li W R 3-5-1 Safety grade charcoal adsorber filters : see GSI 3-11-1 Emergency lighting in continuous rating of E.11.V-12 EDGs-3-11-4" Design oflighting system E.11.V-20 Printed: July 30,1992 at11:11 AM .m_. _..m C- _ N '- -g

EPRI Eiec*ac Power Rssea cn Institute Leaoershio in Scence and Technology ( July 30,1992 Dr. T. E. Murley Director, Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, D.C. 20555

Dear Dr. Murley:

Subject Categorization of Evolutionary Requirements SERIssues As agreed in our June 25 meeting, we have examined and categorized our specific concerns and issues with the May version of the Safety Evaluation Report on Volume II of the Utility Reouirements Document (URD). We believe the attached list of " bins" reflects a useful categorization such that NRC and industry resources can most effectively continue the issue resolution process. Three bins were established:

Bin #1 contains a number of relatively minor concerns. These concerns were

,_s , ) given to your Project Manager and considered in the ongoing cleanup of the Volume II SER. We expect that changes will be made in the SER to address these issues prior to finalization in August.

Bin #2 contains issues where we disagree with the issue resolution described in our own SER but where the Evolutionary Plant Certification applicants currently maintain positions that don't conflict with the URD. We will monitor the resolutions reached between the applicants and the NRC over the next several months. Where those resolutions are accepiable to our own-Utility Steering Committee (USC), we will make the necessary URD changes to clarify the resolution position. We would also expect changas in the Supplemental SER for Volume II. (Note that since the final SERs do not now exist for the ABWR and the System 80+, we cannot agree today that the USC will endorse the resolutions finally reached between the NRC and -

Certification applicants.) Bin #3 contains issues where the current course of issue resolution between the NRC and the Certification applicants apper.rs not to address the Utility /ALWR Program concern. On these issues, we' expect to continue the dialog with the NRC at an appropriate level-for example in the August 13 meeting with you and your senior managers. This category may also expand in the future as the resolution of " Bin #2" items continues. /- V Headouarters: 3412 Hdiview Avenue, Post office Box 10412 Pelo Alto, CA 94303. USA e (415) 855-2000. Telex: 82977 EPRI UF e Fax: (415) 855-2954 Wastyngton office: 1019 Nineteentn street. NW, suito 1000, Washrngton, oC 20036, USA. (202) 872 9222 + Fax: (202) 296-5436

EPRI E!ectrr Power Researcn Institute Leaaersnto in Science ana Teuhnmogy G' Dr. Murley, these are relatively small lists considering the thousands of requirements found in the Utility Requirements Dociunent and reviewed as part of the staff SER. We hope that this general spirit of cooperation will be maintained as we continue our efforts to define the stable regulatory basis that everyone believes is necessary for a future resurgence of nuclear power in this country. If there are any questions in this matter, do not hesitate to contact me (415-812-2826), Ted Marston (812-2803) or John Trotter (812-2810). Sincerely nd&N George Bockhold Jr. Senior Manager Advanced LWR Program r% fO cc: J. Wilson E. Kintner w^, Nj Heacquarters: 3412 Ediview Avenue, Post offi:e Box 10412, Palo Atto, CA 94303. USA * (415) 855 2000. Telex: 82977 EPRI UF e Fax: (415) 855-2954 Washingt en office: 1019 Nineteentn Street NW, Suite 1000, Washington DC 20036, USA + (202) 872 9222 + Fax: (202) 296 5438

Evolutionary Plant Utility Requirements Document, Safety Evaluation Report Issue "Binning" Bin #1, MinorIssues Resolved via Comments to May1992 SER Comments provided to the NRC Project Managers. Changes expected to be reflected in the August,1992 (Final) Safety. Evaluation Report. ID Title FSER pg or #._ 1-1-1 Hardness for stainless steel E.1.V-66 1-1-2 Alloy 600 E.1.V-67 1-1-3 IST E.1.V-95 E.1.V-95 E.1.V-99 1-1-4 Valve qualification E.1.V-100 E.LV-101 1-1-5 Non-addressal of hydrogen mitigation E.1.V-1 1-1-6 Not specific enough on transient & accidents E.1.V-5 1-1-7 Basis for accident management E.1.V-7 1-1 A-1 Uncertainty treatment Ch1A 1-3-1 Snubbers p 3.2-4 1-3-2 GSI-29 reference p3.2-4 1-3-3 Single failure p 3.3-2 1-3-4 PORV reference p 3.3-3 1-3-5 Missing " exception" p3.5-6 1-3-6 CVCS safety classification E.3.V-3 I 1-4-1 Wrorig figure # p 4.4-1 1-4-2 Fuel design for load follow E.4.V-6 Printed: July 3 992 at11:11 AM

1-4-3 GSI-9 reference p 4.6-2 1-4-4 Fuel holdown force p 4.6-3 1-6-1 Cask pit design and cask drop 6.4-39 1-6-2 Reduced bond of epoxv-m3ted rebar 6.4-19 1-7-1 13 Ch. 7 typos various 1-8-1 5 Ch 8 typos various 1-8-2 Pump minimum flow design 1-9-1 Containment annulus ventilation 9.8-25 1-11-1 Electric power reliability Printed: July 30,1992 at11:11 AM 6 O O

Bin #2, Issues Resolved via Ongoing Work with Certification Applicants Issues discussed by EPRI/ALWR with current applicants - General Electric and ABB/ Combustion Engineering. Those discussions have not indicated that the applicant /NRC agreements have caused a conflict with Utility Requirements. Changes to the Utility Requirements Document will be considered later to reflect, in Volume II, agreements between the NRC and the Certification applicants.- Unless otherwise indicated. NRC position is expected to be the same for all ALWR Design Certification Applicants. Changes to the NRC Safety Evaluation are expected to be part of first Supplement to the Safety Evaluation Report. 4 ID title FSER # or page Specific Certification t Applicant? - 2-1-1 Use of Zone 2A p 1.4-? 2-1-2 Recurrence interval for winds p 1.4-15 2-1-3 Nitrates / nitrites E.1.V-63 & P.1.0-10 2-1-4 Tornado wind speed and aircraft impact p 1. 4-22 2-1 A-2 Internal fires 2-1 B-1 GSI-HF-4.4 (procedures) 2-1B-2 GSI-HF5.1 (MMIS-local) 2-1 B-3 GSI-HF5.2 (MMIS-Control Room) 2-1 B-4 GSI-94 (additional LTOP) System 80+ 2-5-1 Safety-grade Wetwell/Drywell sprays ABWR 2-5-2 Unquenched core debris bed assessment 2-5-3 Hydrogen 2-6-1 BWR Turbine building classification ABWR-2-6-2 Inspection of potential structural degradation of SR structures Printed: July 30,1992 at11:11 AM O O O.

l 2-6-3 V & V of computer programs 2-6-4 Diagonal bars in containment walls ABWR 2-7-1 GSI-82, Beyond Design Basis Accidents in SFP 2-9-1 Fire Protection inside containment 2-9-2 "SafeW-Grade" Fire Protection Provisions 2-11-1 Load capt.bility of CTGs ~ 2-11-2 PRZ heaters in EDG load calculation E.11.V-11 System 80+ 2-13-1 60-year life of TG p 13.2-1 2-13-2 Need for prototype testing (of turbines) p 13.3 s,13.4-2 2-13-3 Turbine Missie issoes E.13.V-3/P.13.M-1 E.13. V-4 E 13.V-5 E.13.V-6/P.13.V-2 E.13.V-8/P.13.M-2 E.13.V-9/ P.13.0-2 E.13.V-10 Printed July 3 992 at11:11 AM

Bin #3, Issues Identified in May 1992 SER for Which Monitoring of Certification Application Is Not Sufficient Issues discussed by EPRI/A".WR with current applicants - General Electric and ABB/ Combustion Engineering. Those discussions have indicated that the applicant /NRC agreements have caused a conflict with Utility Requirements or have not addressed the issue found in the SER on - VolumeIL Discussion with the NRC will continue under the industry leadership of the EPRI/ALWR Program Changes to the Utility Requirments Document may be needed after further discussions. Changes to the NRC Safety Evaluation may be needed in light of these further discussion and they would then be part of first Supplement to the Safety Evaltiation Report. ID title FSER # or page Specific Certification Applicant? 3-1-5 QA for NNS and for FIS p 1.7-2 & p 1,9-2 3-1B-1 Finality of GSI Resolution for ALWRs various, App. B to Chapter 1 3-4-1 EPA for RPS power supply-E.4.V-1 ABWR 3-5-1 Safety g-sde charcoal adsorber filters see GSI-83 3-11-1 Emergency lighting in continuous rating of E.11.V-12 EDGs 3-11-4 Design oflighting system E.11.V-20 Printed: July 30,1992 at11:11 AM e 9 0 m - ~

7 V ALWR Program Responses to Questions from the July 27,1992 Meeting with the ACRS Subcommittee on Improved Light Water Reactors Heating, Ventilating and Air Cconditioning: 1. Do ALWR requirements permit nonsafety heating coils and safety-related freon coils in the same air handling unit? There are no explicit ALWR requirements which prohibit nonsafety heating coils and safety-related freon coils in the same air handling unit.- However,if the air handling unit is required to perform a rafety-related cooling function, there are other ALWR requirements which must be - satisfied to assure the function is not impaired by the presence of a - nonsafety element, reference URD Paragraph 8.2.1.1.19. Thisincludes control of the nonsafety heating element in such a way that the safety-related cooling function could not be compromisea by a concurrent - (] actuation or falh re of the heating element. From a practical standpoint,it is unlikely that plant designers would provide a nonsafety heating element in a safety-related air handling unit. 2. Are there ALWR requirements for assuring HVAC cooling to redundant safety-related instruments? Instruments associated with redundant divisions of safety-related. l components would be located in separate compartments (except inside l the control room or containment). The compartments containing. redundant safety systems would he serviced by separate divisions of HVAC systems which are supplied ac power from the same electrical division supplying power to components in the Engineered Safety Features compartment. For example, HVAC requirements for compartments housing Engineered Safety Features in Paragraph 8.2.4.3 state that each compartment shall be cooled by a fan coil unit supplied by essentialchilled water. (O v ACRS 8/7/92

3. Are the HVAC systems required to handle steam as well as smoke? There is no ALWR requirement for HVAC systems to mitigate the effect of steam from a pipe break outside containtnent. Furthermore, there is no ALWR requirement for ductwork to be designed to withstand differential pressure due to a pipe break outside containment. There is a commitment in Chapter 1B to meet requirements of SRP 9.4.1,9.4.2, and 9.4.3 for HVAC systems which reference SRP 3.61 to evaluate the effects of high and moderate energy pipe breaks. As part of that evaluation, the effects of steam migration to other compartments would be identified and any safety-related components located there would need to be qualified for. the resulting environmental effects. Digital Computer Control and Instrumentatiom 4. What is the requirement for mode on restoration of power after loss of motive power? This question concerns the ability of control functions (on/off or (~3 otherwise) to recognize and appropriately respond to a loss of motive U power to equipment.' If there is no designed-in-capability for the control function to sense and respond to a loss of motive power, equipment will continue to operate as before after motive power is restored. The response of plant equipment to the loss and restoration of motive and control power must be carefully considered during the design process so - as to provide a safe and stable outcome for these events. Requirement 3.5.1.1 in Chapter 10 addresses this issue for loss of motive power. The failure state of plant equipment upon loss of motive power is selected on a case-by-case basis. Restoration of power should occur without changing the state of the equipment and the equipment should be re-initialized in the manual mode. Requirement 3.5.1.1 will be modified to account for loss and restoration of both motive and control power. i i t 4 v - ACPS 8/7/92 I i

6 O NRR STAFF PRESENTATION TO THE ACRS

SUBJECT:

EPRI ALWR Requirements Document for Evolutionary Plant Designs DATE: AUGUST 7,1992 PRESENTER: James H. Wilson Project Manager O standardization Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation PRESENTER'S NRC TEL. NO.: (301) 504-1108 O

p d. O PURPOSE 1 1 l To discuss the results of the staff's review of the EPRI ALWR Requirements Document for evolutionary light L l Water reactors and to request that the ACRS prepare a letter to the Commission. O l O I

.l' EPRI ALWR REQUIREMENTS DOCUMENT O A 3-Volume,13-chapter set of requirements for ALWR design, construction, and performance established from an p_wner/ operator j perspective. Volume I contains an executive summary, presents EPRI's ALWR policy, and summarizes its top-tier requirements. Volume 11 consists of 13 chapters and contains EPRl-proposed requirements for an evolutionary nuclear power plant (approximately 1350 Mwe). l Volume ill consists of 13 chapters and contains EPRI-proposed requirements for nuclear power plants for which passive features will be used in their designs (approximately 600 Mwe). e Scope: Entire plant Not an application or a design document - insufficiently detailed a O '""*9-Safety, investment protection, and economics are major e factors in preparing requirements. e Requirements Document reflects the desires /needs of both foreign and domestic utilities comprising the ALWR Steering Committee, t e EPRI coordinates design teams and consultants in the preparation of requirements based on direction from the Steering Committee. Utilities are developing standard plant features specified in the H Requirements Document as a basis for national standard plant designs. . Severe accident protection being added. O steerino committee seekin9 simp rication of systems, and ii expandes use of "best-estimate" or " realistic analytic methods.

4 OVERVIEW O l Over time, scope & purpose of Requirements Document changed J - Originally proposed to seek resolution of applicable [ USis/GSis & Optimization issues f - Scope expanded to be design instructions for the entire plant - EPRI becoming involved in' non-design issues _- Technical-Specifications, emergency planning Review has taken longer than first envisioned - Evolutionary review from 7/86 through 8/92, not including supplement NRR management and review staff changed; focus increased - staff reevaluated what approvalIAW NUREG-1197 could mean, including from a legal p'erspective l Document, by its very nature, is not complete enough to [ satisfy the'strdf L l L Vendors submitted designs, resulting in reduced need for-l- Requirements Document - Requirements Document doesn't tc.dergo same review process Q of regulatory documents - Reg. Guides, SRP, USI/GSI reviews I

I OVERVIEWXCONT.1 .O 3 Difficulty in Review & Use of.Requiremente Document l Format different from usual - systems formr.t instead of by discipline (SRP) Staff performed more than audit review Requirements Do::ument has no legal or iregulatory status thoff cunnot control changes to document O . Staff expected 1he document io se changed oniv to reflect staff's concerns; EPRI has made.other changes. - EPRIintends to continue modifications Design Certification. applications subject to re'sults of design specleic review & hearings.that will-t:e completed well after review of Requirem6nts Document is completed: e O

l VOLUME 1

O

" PROGRAM

SUMMARY

OF THE STAFF'S l . REVIEW" i Volume 1 of the staff's final SER lays out the groundrules for the staff's review of both evolutionary and passive plant designs: 4 i presents a chronology of the project i summarizes purpose and regulatory status of requirements document, including Commission guidance summarizes NRC review criteria summarizes policy issues e summarizes open issues resulting from the staff's review-summarizes vendor-or utility-specific issues e s l + v g e e- .~-,.,w we -- a w-w -d m. e

-t

O CHRONOLOGY l

i j 1982 EPRI began effort ' 1983 EPRI categorized USis/GSis and developed Plant j Optimization issues 1984 initial ACRS briefing l 1985 initial Commission briefing EPRI began development of Requirements Document 1986 EPRI submitted Chapter 1 Staff issued NUREG 1197 1987 1st DSER issued O 1989 EPRI completed submittal of Rev. O of Requirements Document 1990 EPRI submitted Revision 1 to entire docurnent 1991 Last DSER issued 1992 Preliminary version of SER issued-O

1 t REGULATORY STATUS O Does not have legal or regulatory status. Serves as a vehicle to obtain consistent resolution of common operating plant problems, issues generically applicable to designs, severe accident issues, and certain USis/GSis. Serves as a vehicle to identify major concerns wi% i.WR design concepts using passive safety systems early in the design process. Identifies what utilities desire in future designs. Not intended to be used as basis for supporting design certification rule for dealgn-specific application. Commission has assigned review of evolutionary Requirements Document equal priority with that of ABWR and System 80 + (December 15,1989 SRM). Commission has instructed staff to compara future designs + against the Requirements Document (December 15,1989). O

t !~ 4 CONDUCT OF STAFF'R REVIEW rO l As requested, the staff endeavored to review the EPRI ALWR r t Requirements Document at the various levels of detail r' presented, i 4 Standard Review Plan was used as guidance, but the level of i detail did not permit a completeness review. 1 i Staff assumed that all current regulatory requirements would be ( i j met by a design that complied with the EPRI ALWR f Roquirements Document, except:: i i Q where deviations are identified in the document, 1 i where the staff identified a. potential incompatibility j-4 [ between EPRI-proposed design requirements and current t i regulatory requirements, or where the staff identified a possible mininterpretation of: l' regulatory requirements.- 1 Staff-used Appendix B to Chapter 1 as cross-index to other-- l parts of the Requirements Document, but did not attempt to-ensure that EPRI had addressed all applicable regulations. 4 i !, Oi ,~s.,6 ,,. +.. - -.

CONDUCT OF STAFF'S REVIEW (CONT.) O NUREG 1197, " Advanced Light Water Reactor Program" Issued December 1986 defined proposed programmatic approach to reviewing Requirements Document described results of early efforts concerning USI/GSI review e Volume 1 of SER describes how review was performed revie u acy. nd aw as NUREG-1197 O promCjart 4 d iC CFR Part 52 required reconsideration of some of 1:arly USI/GSI review Staff could not reach conclusions sought in NUREG-1197 Requirements Document haa. no legal or regulatory status staff did not perform a completeness review NRC does not control document-rnisinterpretation pg _ Requirements Document possible due to level of detail presented Staff will consider results of review of Requirements Document-e O-during review of FDA/DC applications.

4 SECY-90-016 O issued January 12,1990 e e o Policy issues Pertaining to Evolutionary Plants Only A. EPRI's public safety goals B. source term C. ATWS D. mid-loop operation E. station blackout F. fire protection G. Intersystem LOCA O H. hydrogen generation and control I. core-concrete interaction - ability to cool core debris J. high pressure core melt ejection K. containment performance L. ABWR containment vent design M. equipment survivability N. operating basis earthquake / safe shutdown earthquake O. inservice testing of pumps and valves - 1 e ACRS Letter - 4/90 SRM - 6/90 0

O SECY-91-078 Issued March 25,1991 j i Policy issues Pertaining to Evolutionary Plants Only e A. alternate source of power for non-safety loads B. connection of safety bus offsite power sources through nonsafety buses ACRS Letter - 5/91 !lO SRM - 8/91 i U 4 v ,_c,,_.- .._.r_.,

FEBRUARY 20,1992 O DRAFT COMMISSION PAPER Policy issues Pertaining to Evolutionary and Passive Designs I. SECY-90 016 issues

11. Other Evolutionary and Passive Design issues A. Industry codes and standards B. electrical distribution C. seismic hazard curves D. leak before-break O

e. ciassification of main steam iine of boiiina water reactors (BWRs)

F tornado design basis G. containment leak rate testing H. level of detail I. prototyping J. inspections, tests, analyses, and acceptance criteria (ITAAC) K. reliability asturance program (RAP) L. severe accident mitigation design alternatives (SAMDAs) M, generic rulemaking related to design certification l h i

4 FEBRUARY 20,1992 O DRAFT COMMISSION PAPER 1 (CONTINUED) lit. Passive Design issues Only A. regulatory treatment of non-safety systems l B. definition of passive failure l C. thermal hydraulic stability of the Simplified Boiling l Water Reactor (SBWR) D. safe shutdown requirements E. control roorn habitability iO F. radionuclide attenuation l G. simplification of off-site emergency planning l l e ACRS Letters - 5/92 f i lO 1 i

JUNE 25,1992 O COMMISSION PAPER Policy issues Pertaining to Evolutionary and Passive Designs A. common-mode failures in digital I & C systems B. external events beyond design basis C. elimination of operating basis earthquake from seismic design D. multiple steam generator tube ruptures E. PRA beyond design certification F. role of passive plant control room operator O

o. controi rom annunciator reiiabiiity H. regulatory treatment of non-safety systems in passive plant designs O

4 l l L DEFINITIONS

O j

Openissues a. l Open policy issues for which the staff has taken a position, but f for which the Commission has not had the opportunity to provide guidance. l j Vendor-or Utility Specific ___ Items ~ l i f These items must be satisfactorily addressed 'during the staff's review of a vendor-or utility-specific application, includes: LO items that were determined by EPRI to be outside the scope of'the Requirements Document - items that were inadequately addressed by EPRI items that could not be addressed generically i 1 F g .._.d....,,,',.h._,._,_m.-. ,,,,,,,,,y.w, q [- 7, v

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l lO

SUMMARY

OF ISSUES Vendor / Utility Chaoter Onen Confirmatory Specific 101 1 2 39 1A 57 1B 18 2 5 3 3 4 7 5 O ~ 6 26 7 7 8 2 9 13 10 76 11 22 12 9. 13 10-Total 21 0 410 l l O

R O VOLUME 2 NRC REVIEW OF EPRI'S ALWR REO.UIREMENTS DOCUMENT FOR EVOLUTIONARY PLANT DESIGNS O CHAPTERS 1 - 13 O a

CHAPTER 1 O "OVERALL REQUIREMENTS" Submitted 7/86 DSER issued 9/87, revised 2/88 ACRS Meetings 10/87,4/89,7/90 and 4/91 Chapter 1 to Volume ll of the EPRI Requirements Document contains common requirements, both top-tier and detailed, for evolutionary plants in the key topic areas listed below. Key Toolc Areas e safety operability, maintainability performance o quality assurance e structural design licensing materials e design process reliability, availability a mechanical equipment e constructibility 2 open issues remain (policy issues)' E.1.0-1 tornado wind speeds (4.5.2)- E.1.0-2 leak before break (4.5.5) 101 vendor-or utility-specific items O

APPENDIX B TO CHAPTER 1 " LICENSING AND REGULATORY REQUIREMENTS AND GUIDANCE" 4 Appendix B was not submitted as part of the original Evolutionary Requirements Document, but was included in Revision 1, submitted on September 7,1990. However, many of the topics now contained in Appendix B were discust.ed throughout the 13 chapters of the original Evolutionary Requirements Document and were addressed in the DSERs for the corresponding chapters. The staff did not issue a DSER for this appendix. O Kev Tooic Ateas regulatory requirements and guidance e e optimization issues e generic safety issues e policy issues 18 open issues reinain1 policy issues) n 57 vendor-or utilig-specific items V

OPTIMlZATION ISSUES O in Appendix B to Chapter 1, contains the following " optimization issues," which are EPRI proposed deviations from regulatory requirements: Operating Basis Earthquake and Dynamaic Analysis Methods Tornado Design BWR Main Steam Line Valves and Leakage Control Simplification of Post-Accident Accident Sampling' System Containment Leakage Rate for ALWR O Evolutionary ALWR Licensing Design Basis Source Term e Dedicated Containment Vent Penetration EPRI has proposed to resolve each of these issues by providing technically supportable alternatives to current regulatory requirements. Each of these'" optimization issues" is evaluated in Section 2 and is included in the policy papers contained in Annexes A, B, and C of Appendix B_to Chapter 1 of the staff's SER. 4.-

USI/GSI REVIEW O 10 CFR Part 52.47 requires applicants for FDA/DC to submit proposed resolutions to the USis and medium and high priority GSis in NUREG-0933 six months prior to (complete) application. EPRIlimits scope of USI/GSI review to those unresolved issues as of January 1990. Design certification reviews are expected to continue for several years after the Requirements Document effort stopped. SER provides traceability of review and gives either - evaluation of each of these issues & status of staff's review - explanation of why issue is not _specifically evaluated.. Staff is working within fomework of GSI resolution path, including waiting until final resolution is obtained and is monitoring safety status.of unprioritized & new issues. ' Results of long-term research efforts may affect' resolution of GSis. Since generic agency resolution not yet identified for some issues, staff may have to reevaluate. Design Certification application once J Q . generis resolution is determined. .~

SECY-91-161 SCHEDULE August 18,1992 Issuo Final SER for EPRI ALWR Evolutionary Requirements Document as NUREG-1242 o September 2,1992 EPRI responses to Passive DSER open and confirmatory issues due n April 16,1933 Technical staff inputs for Passive SER due to Projects O aune2,,,993 issue einai SER for eeRi eassive plant to Commission and ACRS September 24,1993 issue Final SER for EPRI Passive plant and supplement to.SER for EPRI Evolutionary piant as Supple-ment 1 to NUREG-1242 O

CONCLUSIONS O e Staff concludes that the EPRI ALWR Requirements Document for evolutionary plant designs specifies requirements that, subject to resolution of the identified outstanding policy issues and utility e nd vendor-specific issues, if properly translated into a design in accordance witn NRC regulations in force at the - time the design is submitted, should result in a nuclear power plant that will have all the attributes required to ensure that there is no undue risk to the health and safety of the public or = to the environment. l O Staff intends to issue final SER in' August 1992 in accordance e with the schedule presented in SECY 91 161, and will issue a Supplement at a later time. O

7 .. / NRC INITIATIVES TO O ELIMINATE REQUIREMENTS MARGINAL To SAFETY INFORMATIONAL BRIEFING FOR THE ADVISORY COMMITTEE-ON REACTOR SAFEGUARDS, AUGUST 1992 FULL COMMITTEE MEETING WARREN MINNERS, DIRECTOR O D1 VISION OF SAFETY ISSUE NESOLUTION OFFICE OF NUCLEAR REGULATORY RESEARCH MONI DEY SENIOR IASK MANAGER DIVISION OF SAFETY ISSUE RESOLUTION OFFICE OF NUCLEAR REGULATORY RESEARCH r O

i \\ 4 i i OUTLINE O 1 2 j BACKGROUND AND PURPOSE OF BRIEFING i l BACKGROUND 0F PROJECT i 1 PUBLIC COMMENTS AND PLANNED STAFF ACTIONS i

lO FUTURE INTERACTION WITH ACRS i

i l r I 1 r. l' O 2 ~., _, _..... - ..~.- - - ~.. - -, -.... - -.. - ~.....

i i BACKGROUND AND PURPOSE OF' BRIEFING-i i STAFF PROVIDED ACRS WITH DRAFT SECY l PAPER ON JUNE 11,

1992, AND FINAL r

SECY PAPER RECENTLY. i i i a SECY SUBMITTED-TO COMMISSION PRIOR TO ACRS BRIEFING DUE TO TIME CONSTRAINTS FOR PREPARATION OF NRC REPORT FOR THE PRESIDENT. .i B BRIEFING AIMED MAINLY TO GENERALLY INFORM ACRS OF PROGRAM AND PLANNED ACTIONS. ~ O l BRIEFING WILL EMPHASIZE PROCESS, AS-OPPOSED TG INDIVIDUAL TECHNICAL ISSUES. 1 STAFF PLANS TO FREQUENTLY-CONSULT THE-ACRS FOR COMMENTS AND-l SUGGESTIONS ON-SPECIFIC ISSUES IN PROGRAM. O 3 L

BACKGROUND l C) J l INDUSTRY SURVEY CONDUCTED IN l INITIAL PHASE OF PROGRAM TO OBTAIN SUGGESTIONS FOR CANDIDATE ITEMS. l SUBSEQUENTLY, SURVEY CONDUCTED TO l OBTAIN RECOMMENDED CANDIDATE ITEMS l FROM INDIVIDUAL STAFF MEMBERS. l l CANDIDATE ITEMS RESULTING'FROM SURVEYS WERE ANALYZED FOR POTENTIAL BENEFIT-AND MARGINAL IMPACT ON l SAFETY. l BASED ON REVIEW OF ABOVE ANALYSES, l STAFF PROPOSED CONCLUSIONS,-AND l () PLANNED ACTIONS TO THE COMMISSION-l IN SECY-91-224, JULY 29, 1991. l SECY PAPER WAS PROVIDED TO THE ACRS U i AT THAT TIME. l l L COMMISSION APPROVED STAFF'S l CONCLUSIONS AND-PLANNED ACTIONS, INCLUDING THE SOLICITATION OF I PUBLIC' COMMENTS, IN SRM-DATED l AUGUST 26, 1991. l l FEDERAL REGISTER NOTICE'TO SOLICIT-PUBLIC-COMMENTS PUBLISHED ON FEBRUARY 4, 1992 AND PROVIDED TO l ACRS. O 1 4 =

i PLANNED STAFF ACTIONS ) TWENTY-FOUR PUBLIC COMMENTS RECEIVED IN i RESPONSE TO FEBRUARY 4, 1992 FRN. ADDITIONAL COMMENTS WERE RECEIVED DURING CRGR SPECIAL-REVIEW-OF l REGULATIONS. 1 BASED ON ANALYSIS OF PUBLIC. COMMENTS, STAFF-PLANS TO: INSTITUTE.A CONTINUING EFFORT TO ELIMINATE BURDENSOME AND MARGINAL-TO-SAFETY REQUIREMENTS. INITIATE RULEMAKING IN THREE' AREAS C) NRC PROPOSED TO REDUCE 1 BURDEN. WITHOUT ADVERSE IMPACT ON SAFETY, BY MAKING THE REGULATIONS LESS PRESCRIPTIVE AND MORE-PERFORMANCE i ORIENTED.- l 1 MODIFY-LICENSES IN TWO AREAS NRC PROPOSED TO RELAX OR ELIMINATE. EXAMINE FOUR AREAS CONSISTENTLY-SUGGESTED IN'PUBLIC COMMENTS 1FOR -POTENTIAL BURDEN-REDUCTION WITHOUT-l ADVERSE' IMPACT ON SAFETY. I J 0; s 1

ONGOING EFFORT TO ELIMINATE () REQUIREMENTS MARGINAL TO SAFETY AND REDUCE REGULATORY Bt:-4 DEN PUBLIC COMMENTS REGULATORY PROCESS DYNAMIC. = SAFETY CONTRIBUTION OF SOME REQUIREMENTS MAY NOT HAVE BEEN ACCURATELY PREDICTED OR MAY DIMINIcH i WITH TIME. REQUIREMENTS SHOULD APPROPRIATELY FOCUS LICENSEE RESOURCES FOR EFFECTIVE REGULATION. DEDICATE RESOURCES AND' ESTABLISH SYSTEM FOR PERIODIC REASSESSMENT OF REQUIREMENTS TO REDUCE OR~ ELIMINATE BURDENSOME REQUIREMENTS WHICH HAVE MARGINAL SAFETY SIGNIFICANCE. STRONGLY ENCOURAGE NRC-TO CONTINUE STAFF-INITIATED-PROGRAM. INSTITUTIONALIZE:0NGOING REVIEW, E.G., BY MODIFYING BACKFIT RULE. () 6 d

_. _ 7.. _ _ _ _. _. _. _ STAFF ACTION i O l BASED ON PUBLIC COMMENTS, STAFF PLANS i j TO INITIATE ONGOING EXAMINATION OF i l REGULATIONS, AND SUBSEQUENTLY l INSTITUTIONALIZE PROCESS. CONTINUING EFFORT WILL-CONSIST OF THREE-YEAR PERIODS DURING-WHICH STAFF i WILL: i 1. INITIATE' ACTION'TO ELIMINATE R.EQUIREMENTS SUGGESTED IN PUBLIC

COMMENTS, EXAMINED AND PROPOSED BY O

STAFF TO HAVE POTENTIAL FOR BURDEN REDUCTION AND MARGINAL IMPACT ON

SAFETY, AND FINALLY ENDORSED'UY PUBLIC.

l 2. INITIATE STAFF ANALYSES OF MERITORIOUS PUBLIC-PROPOSALS THAT ~ APPEAR TO'HAVE POTENTIAL'FOR^ BURDEN REDUCTION WITHOUT ADVERSE IMPACT ON I SAFETY. i i l. f O 7 r i

3. BASED ON STAFF ANALYSES, PROPOSE O NRC ACTIONS FOR PUBLIC COMMENT AND SOLICIT OTHER SUGGESTIONS. ABOVE SET OF ACTIONS WILL BE REPEATED EVERY PERIOD. PuBLIC INPUT IN A PERIOD WILL BE USED TO DETERMINE NRC ACTIONS IN FUTURE PERIODS. STAFF PLANS TO RECOMMEND MEANS FOR INSTITUTIONALIZING PROCESS WITHIN ONE YEAR. O 9 O 8

CURRENT PLANNED STAFF ACTIONS-THE STAFF PLANS THE-FOLLOWING-ACTIONS FOR THE-FIRST. PERIOD: A. INITIATE'RULEMAKING IN THREE AREAS NRC PROPOSED TO REDUCE REGULATORY }

BURDEN, WITHOUT-AN ADVERSE IMPACT-ON SAFETY, BY MAKING REGULATIONS LESS PRESCRIPTIVELAND MORE PERFORMANCE ORIENTED:

(A) CONTAINM'ENT' STRUCTURE LEAKAGE s TESTING PROCEDURES-(10zCFR 50, APPENDIX: J). (B) FIRE. PROTECTION FEATURES O (10 CFR 50, APPENDIX R). (C) FEATURES FOR POST-ACCIDENTL COMBUSTIBLE GAS CONTROL (10 CFR

50. 44)-.

B. MODIFY LICENSES IN TWO ARrMKTHAT-THE: NRC PROPOSED TO -RELA'X UA ELIMINATE: (A) MAIN STEAMLISOLATION VALVE 1 LEAK 4 ..C O N T R O L S Y_S T E M.. (B) ALLOWABLE CONTAINMENT LEAKAGE-RATE: UTILIZED IN: CONTAINMENT' TESTING. LO-9

o i i. i; i C. ANALYZE THE POTENTIAL FOR BURDEN 4 l: O REDUCTION, WITHOUT ADVERSE' IMPACT e ON SAFETY, IN THE.FOLLOWING AREAS CONSISTENTLY SUGGESTED IN THE-l PUBLIC COMMENTS: l (A) QUALITY' ASSURANCE CRITERIA l (10 CFR PART 50, APPENDIXfB). [ (B). ENVIRONMENTAL QUALIFICATIONEOF-ELECTRIC EQUIPMENT 1W ORTANT TO l SAFETY (10 CFR 0 56 m ). l (C) PLANT SECURITY REQUIREMENTS j (10 CFR 73.55). I [ (D) POST-ACCIDENTjSAMPLING. SYSTEMS (NUREG-0737-AND REGULATORY-. O GurDE 1.97). i STAFF HAS-EFFORTS UNDER'WAY TO ADDRESS. l THE FOLLOWING-:TWO ACTIONS-PROPOSED'-IN l THE PUBLIC COMMENTS:- f (A) MODIFY '10 CFR 20 DOSE -L.IMITS WITH REGARDLTO HOT'. PARTICLES. - 0 .(B) PERMITLLICENSEEiADMINISTERED ~ ~ REQUALIFICATION:: EXAMINATIONS UNDER.NRC OVERSIGHT. 3 j i h. 'l [ [O ao r l-l e = -.. -. - _... - _ -. -. - -. _. -... -.... +.. ~.......,

-. ~. /m. L). /~ tv FIGURE 1 SCHEDULE FOR PERIODIC REVIEW OF REGULATIONS AND CURRENT PLANNED STAFF ACTIONS A. Periodic Review of Regulations - End of Period / start Start of Feriod - 3 years - of New Period 8/95 2/92 8/92 2/95 A Based en Complete actions A A Initiate staff Published initiated in 1st propostd NRC action on staff analyses actions for publicly endorsed publish 2nd set period Initiate staff comment NRC proposals of proposed NRC actions on pub 71cly Initiate staff acticas Solicited other Solicit other endorsed NRC proposals from analyses of proposals frem pmposals public meritorious public .. Initiate staff proposals public analyses of certtorious public proposals B. Schedule for Current Planned Staff Actions ~ 8/92 .2/93 8/93 I/94 8/95 A A A A Initiate 3 Conduct Staff recoener.dation Publish Publish A rulemakings workshops for institution-- pmposed final rules

- Initiate action on 3 alizing periodic rules to modify 2 license conditions..

rule-review of Initiate staff analyses makings regulations for Institutionalizing continuing review of regulations, and 4 potential areas for burden reduction. 11

i u L FUTURE INTERACTION WITH ACRS ? I () ? i STAFF PLANS TO CONSULTLCOMMITTEE-FREQUENTLY FOR COMMENTSLAND SUGGESTIONS.FOR PROGRAM, l SPECIFICALLY FOR THREE RULEMAKINGS. l WORKSHOP PLANNED IN EARLY 1993 TO = i DISCUSS' APPROACHES AND FRAMEWORK: FOR DEVELOPING PERFORMANCE-BASED l REGULATIONS. l WOULD THE ACRS LIKE TO DISCUSS l T = l PROPOSED FRAMEWORK AND PRELIMINARY- ! () APPLICATIONSETO THE THREE l REGULATIONS-WITH THE STAFF PRIOR TO [ OR AFTER THE WORKSHOP? l l STAFF PLANS TO REQUEST ACRS REVIEW OF PROPOSED RULES AND PROPOSED -METHOD TO INSTITUTIONALIZE ' CONTINUING' REVIEW.. i !o i i (O u i I a-.

L ,.s O

D 4

INDUSTRY PERSPECTIVE. ON REVIEW OF REGULATIONS ADVISORY COMMITTEEf0N ' REACTOR O SAFEGUARDS WILLIAM H. RASIN VICE PRESIDENT & DIRECTOR TECHNICAL-DIVISION NUCLEAR MANAGEMENT AND RESOURCES COUNSit O

L. l IO CHAIRMAN SELIN'S CHALLENGE TO THE NUCLEAR POWER INDUSTRY p i - i Some NRC activities may have i l j inadvertently, and needlessly, l contributed to nuclear plant expenses l \\ i O l e industry should provide him with l recommendations.on ways.to I eliminate unnecessary and costly. l activities while still maintaining overall l safety L l l L s i 1 [ j 1 a 1 NUMARC a

O INDUSTRY RESPONSE e Agreed to apply the resources of the nuclear power industry to provide -recommendations on areas where the application of rules or regulations have provided little added value but have had major cost impact O e Agreed to provide necessary supporting data i 2 NUMARC 1.

i.r Lc u i O INDUSTRY PERSPECTIVE l } l i j Industry considers this a valuable L opportunity to achieve greater efficiency and productivity in the use l of-the industry's resources l l lO e This initiative is vital in order for nuclear power to remain a viable and-l competitive option.in the future l-t i i. 4 l i ltO 3 NUMARC t I' _,,-..._.,.._-,.-...,_...-.......;..,._.._..-,~..._,

l. IO INDUSTRY VIEW OF ELIMINATION OF REQUIREMENTS MARGINAL TO SAFETY i i Regulations have served us well in l protecting public health and safety l l Maturing nature of the technology should dictate a reconsideration of regulations !!O Greater experience level. of industry i and NRC supports movement to Performance Based Regulation Regulatory guidance, implementation and interpretation are more l troublesome than regulations themselves 4 NUMARC .-_.._,...we.. .____,,._,_,,,,,...,,,,,,.,,,,,,,,,,,,,,,,,__..,,,._,,_.,,,_.,_.,._..,,___,,,.......,,,,,,,_,,,,.,,y}}

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