ML20149E901
| ML20149E901 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1634, NUDOCS 8801140043 | |
| Download: ML20149E901 (182) | |
Text
AcR372./S34
^
OR G;NAL U:NI1ED STATES O-NUCLEAR REGULATORY COMMISSION IN THE MATTER OP:
DOCKET NO:
333rd GENET.AL MEETING O
LOCATION:
NASHINGTON DC 192 - 328 PAGES:
DATE:
JANUARY 8, 1988
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5 30 No'< liri1cve irorn ACRS Offie Heritage Reporting Corporation t
Officini Reporters 1:20 L Street. N.W.
wunangton. D.C. 2000$
O I:02) 628-4448 8801140043 880108 PDR ACRS T-1634 DCD
1 PUBLIC NOTICE BY THE
()
2 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 6
7 The contents of this stenographic transcript of the 8
proceedings of the United States Nuclear Regulatory 9
Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reportet herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or i
14 inaccuracies of statement or data contained in this trenscript.
15 16 17 l
18 19 20 21 22 23 24 25 O
Heritage Reporting Corporation (202) 628-4888
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UNITED STATES NUCLEAR REGULATORY COMMISSION 2
ADVISORY COMMITTEE ON REACTOR SAFEGUARLS 3
)
In the Matter of:
)
4
)
333rd GENERAL MEETING
)
5
)
6
- Friday, January 8, 1988 7
Room 1046 8
1717 H Street, N.W.
Washington, D.C.
20555 9
The above-entitled matter came on for hearing, 10 pursuant to notice, at 8:30 a.m.
11 BEFORE:
DR. WILLIAM KERR 12 Chairman Professor of Nuclear Engineering 13 Director, Office of Energy Research
()
University of Michigan l
14 Ann Arbor, Michigan 1
i 15 ACRS MEMBERS PRESENT:
1 l
16 MR. CHARLES J. WYLIE l
Retired Chief Engineer 17 Electrical Division Duke Power Company 18 Charlotte, North Carolina 19 MR. JESSE C.
EBERSOLE Retired Head Nuclear Engineer 20 Division of Engineering Design Tennessee Valley Authority 21 Knoxville, Tennessee 22 23 24 i
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MR. CARLYLE MICHELSON Retired Principal Nuclear Engineer 2
Tennessee Valley Authority Knoxville, Tennessee, and 3
Retired Director, Office for Analysis and Evaluation of Operational Data 4
U.S. Nuclear Regulatory Commission Washington, D.C.
5 DR. FORREST J. REMICK 6
Professor of Nuclear Engineering and Director of the Office of Energy Research 7
University of Michigan Ann Arbor, Michigan 8
DR. CHESTER P.
SIESS 9
Professor Emeritus of Civil Engineering University of Illinois 10 Argonne, Illinois.
11 DR. CARSON MARK Retired Division Leader 12 Los Alamos Scientific Laboratory Los Alamos, New Mexico 13
()
DR. HAROLD W.
LEWIS 14 Professor of Physics Department of Physics 15 University of California Santa Barbara, California 16 DR. DADE W.
MOELLER l
l 17 Professor of Engineering in Environmental Health I
l Associate Dean for Continuing Education I
l 18 School of Public Health i
Harvard University l
19 Boston, Massachusetts 20 DR. PAUL G.
SHEWMON Professor, Metallurgical Engineering Department 21 Ohio State University Columbus, Ohio 22 DR. MARTIN J.
STEINDLER 23 Director, Chemical Technology Division Argonne National Laboratory l
l 24 Argonne, Illinois 25 O
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Raymond Fraley, Executive Director 3
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IUDEK 2
Items Discussed Pace 3
Nuclear Industry Initiatives 196 4
Renewal of Nuclear Power Plant Licenses 259 S
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P R O C E E D,I_!J G S, g(,j.
2 CHAIRMAN KERR:
There is around here somewhere an 3
announcement that I should read for the second day, so 4
assuming I have read it, we will go ahead with the first item 5
on the agenda, which is nuclear industry initiatives, and this 6
says Forrest G.
Remick is the responsible subcommittee 7
chairman.
8 DR. REMICK:
Responsible in the sense that I had 9
suggested it several months ago, that in light of the fact 10 that the nuclear related industry has undergone some 11 reorganization of various organizations that they have over 12 the last six months, and since ACRS from time to time 13 interacts with various parts or various of those
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14 organizations, particularly NUMARC, that it. night be a good l
l 15 idea to invite somebody in from the industry organizations to I
16 tell us all about the reorganization, and the time has I
17 arrived, and we are delighted to have with us this morning Joe 18 Colvin.
I believe Joe is Executive Vice President of NUMARC, l
19 and NUMARC, if you don't know, has headquarters just around i
I l
20 the corner, on the corner of 17th and I in the new--what is 21 the name of that building?
22-MR. COLVIN:
Republic Place Building.
23 DR. REMICK:
Must be one of the first occupants.
g 24 MR. COLVIN:
Right.
We were the original tenants.
(O 25 DR. REMICK:
Joe comes to his position in NUMARC HERITAGE REPORTING CORPORATION -- (202)628-4888
197 1
having formerly been with INFO in recent years, and also with (3
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2 Joe is Tom Price, and Tom just before coming in was up on the 3
Hill, various organizations, including OMB and then the NEC, 4
OSTP, and then--
5 MR. PRICE:
ANEC, the lobbying--
6 DR. REMICK:
Okay, fine, so with that preliminary, l
7 Joe, if you would take over?
And we have scheduled until ten 8
o' clock.
9 MR. COLVIN:
I would be happy to go ahead and I
10 address some of these topics.
I am pleased to be here in 11 front of the ACRS today, and especially afte. making the treck 12 in this morning, in the snow, and I am pleased to be here to 13 give you an update on the industry restructuring activities, 14 NUMARC, and hopefully how that, how that interactions have 15 taken place and some of the background and perspective on 16 that, and maybe just, Forrest, if I might expand my background 17 for the benefit of ACRS?
18 DR. REMICK:
Please do.
19 MR. COLVIN:
I am an engineer, having a Bachelor of 20 Science degree in engineering, participated in advanced 21 studies in nuclear engineering, am a registered professional 22 engineer, and I spent over ten years as a nuclear submarine 23 officer in the Navy nuclear power program mostly involved with 24 the operations, design, modification and construction of fg V
25 submarine reactor plants.
In the last three years of my Navy HERITAGE REPORTING CORPORATION -- (202)628-4888
d 198 1
career, I was one of sixteen members of the Nuclear Propulsion
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2 Examining Board responsible for examining all nuclear power 3
shift submarine reactor. tenders and bases to ensure they were 4
operating safely.
5 DR. REMICK:
Under Commissioner Carr by any chance?
6 MR. COLVIN:
Commissioner Carr was a commander of 7
the submarine force Atlantic at the end of my tour on the 8
NPEB, and we did have a lot of interaction.
We actually 9
reported to a different level within the Navy organization, 10 different structural level.
11 I joined INPO early in its formation, spent nearly 12 seven years involved in all of INPO's evaluation assistance 13 activities, was responsible for directing the construction 14 project evaluation initiatives in '82 and
'83, and then 15 lastly, directed INPO's industry and government relation 16 activities which included interaction with NRC, government, 17 Congress, and other industry organizations and activities.
18 And I guess pertinent to todal's discussion, I 19 coordinated the support for and the activities of NUHARC as a 20 committee, the Nuclear Utility Management and Resources l
21 Committee, and also served on the :ndustry's Response and 1
22 Implementation Committee--in fact, put in place the industry i
23 restructuring and reorganization over this tisa period, so I 24 will try to speak to you today from that perspective and give 25 you at least my insights as to, as to how some of this and why HERITAGE REPORTING CORPORATION -- (202)628-4888
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some of this came about.
)
2 Probably the first place to start is to back up 3
chronologically and cover some of the history and some of the 4
industry initiatives that have taken place over time.
5 (Slide) 6 MR. COLVIN:
Let me try to arrange this.
Is that 7
okay, Tom?
8 MR. PRICE:
That's better.
9 MR. COLVIN:
Tom will holler at me if he can't see 10 it, if you can't see it or he can't see it.
11 To go back, and Tom and I think this is important to 12 recognize, and I am sure everyone does, that the industry has
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13 undertaken a number of initiatives to try to structure itself,
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14 posture itself to carry out its mission, and carry that out 15 effectively, and if we go bac). Iz:r the standpoint of the 16 restructuring, the point that I would like to start at is the 17 formation of EPRI in the 1973, 1974 timeframe, and the 18 industry put together the Electric Power Research Institute to 19 coordinate and sponsor its research and development work, both 20 nuclear and non-nuclear, and today EPRI provides a very 21 important role for NUMARC and for the industry organizations 22 in coordinating some of our technical research and technical 23 work in support of regulatory initiatives.
f-24 About $60 million each year at least in the last two
\\v 25 or three years from EPRI's budget and industry sources is HERITAGE REPORTING CORPORATION -- (2021628-4888
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dedicated sol'ely to nuclear technical and R and D support.
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2 you take the next step, really the next, the next point in 3
time was the accident at THI, and in the, immediately in the 4
aftermath of that accident, the industry put together the TMI 5
ad hoc nuclear oversight committee.
It was chaired by Floyd 6
Lewis, then chairman of Middle South, and at that time, they 7
put this high-level committee of a few key people together to 8
try to, to try to provide the resources, to put some of the 9
initiatives in place that were felt to be important.
10 The first one of those really that came out is NSAC 11 Nuclear Safety Center, an adjunct to EPRI in Palo Alto.
We 12 put that together to try to look at the lessons learned from
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14 information to the industry and share the results of those 15 events.
16 Shortly after that--and the slide is wrong.
It says 17 INPO was formed in April
'79.
It really was formed in 18 December of 1979, but the other initiative, major initiative 19 that came out of that committee at that time was the Institute 20 of Nuclear Power Operations where we tried to put together a 21 team of professionals, peers, that would go out and evaluate 22 industry programs, share the lessons learned, the good 23 practices, the areas needing improvement throughout the 24 industry, and try to set standards of excellence and s
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l 25 operations, and I don't need to discuss INPO.
I know you have i
HERITAGE REPORTING CORPORATION -- (202)628-4888
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been briefed on INPO a number of times in the past.
I) 2 In 1980, that the TMI ad hoc oversight, nuclear 3
oversight committee changed its name to UNPOC, another 4
acronym--UNPOC and NUMARC and all those, Utility Nuclear 5
Power Oversight Committee.
It was put together with the, a 6
little bit different composition.
It was put together as the 7
chairman, president, or other senior utility executive on the 8
Board of Directors of the industry associations, and at that 9
time, that was the Atomic Industrial Forum, and Edison 10 Electric Institute and INPO and EPRI and along with a couple 11 of the other organizations supporting different factions of 12 the industry.
The National Rural Electric Cooperative j'")
13 Association, NRECA, had a utility executive supporting the
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14 coor3rative side.
We had the American Public Power 15 Association represented with the utility executive on this 16 oversight committee, representing the public power int.erests.
17 In the--I think the key to that was it is the 18 Utility Nuclear Power Oversight Committee, and these were all 19 utility executives, even though AIF was an organization, for 20 example, that had members that were both utilities and 21 suppliers, and venders, and consultants, et cetera.
22 UhPOC has been instrumental in establishing a number 23 of initiatives.
Mid-1982, INPOC formed the U.S. Committee for 24 Energy Awareness, and then undertook that initiative to 25 provide some public education and advertising campaigns and HERITAGE REPORTING CORPORATION -- (202)628-4888
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coordinate those for the industry.
2 And the next initiative was in.1984, really'iN~'1983 3
and'1984, and'that was the formation of NUMARC as a committee.
4 The reason NUMARC came about I'think principally.was because 5
thefindustry leadership saw a shift in the NRC direction from 6
licensing of new plants and looking at the design and so 7
forth, from, a shift from that into looking at more in the 8
operational area and we saw the general operacing criteria 9
proposals and some other things of that nature.
10 There was concern in the industry that the, that 11 there was not the proper skills, talent and expertise that 12 resides within the NRC to look at those issues.
We are taking 13 the opposite tack.
The industry leadership felt that they
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14 were most qualified-and had the experience.in management and-15 in operations to provide tha problem definition to some of the 16 problems that were affecting the industry.and to work with the 17 NRC in developing the solutions and in effect correcting'those 18 problems itself, and so it took that initiative and that was 19 really the basis of NUMARC.
20 And that was, NUMARC was the Nuclear Utility 21 Management and Resources Committee.
22 DR. REMICK:
Joe, what was the first task that 23 NUMARC took on?
Was it the training rule or.the--
24 MR. COLVIN:
Principally the training area; it is 25 hard to describe at this time, Forrest.
The NUMARC undertook HERITAGE. REPORTING. CORPORATION -- (202)628-4888
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a number of, set up a number of workgroups of key industry
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2 industry executives, typically vice president, nuclear level, j
3 or above, to look at some of these problem areas that we had.
4-One of them was looking at procedures.
One was looking at 5
radiological protection.
Certainly one was to look at 6
training.
7 In turns out that the training initiative was the, 8
is probably the most well recognized of those because of the 9
first general operating criteria proposal was in the area of 10 training, and we also had the rulemaking activities that were 11 directed by Section 306 of the Nuclear Waste Policy Act which 12 directed the Commission to put in place regulations or
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13 regulatory guidance in a number of areas, and so I think from
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14 that standpoint, most people would say training, but in fact 15 there were about ten working groups, nine or ten working 16 groups established to look at a bunch of different issues, of 17 which training was one.
18 Probably the key thing in the NUMARC committee, it 19 was formed to, we asked each licensee basically to name a 20 senior executive to the committee, and we asked two things for 21 that executive--one, that he be the senior nuclear line 22 manager responsible for day-to-day nuclear operations at his 23 utility.
You couldn't describe it by title because the titles 24 vary all over the spectrum out there.
It turned out to be 25 people like Jim Hiller, president of Georgia Power Company was HERITAGE REPORTING CORPORATION -- (202)628-4888
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the senior.n": lear line executive at: Georgia Power, ~ Cordell
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Reed, the senior nuclear line executive as the vice president 3
atLCommonwealth Edison, so_we brought'those people together.
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The other. attribute that we asked was that 5
individual could come to the committee meetings and commit his
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6 utility to action, commit the resources of his company 7
basically without going home and asking permission, so we 8
wanted the, a high enough level industry executive that_could 9
take action and take that action promptly.
10 I think that's a fundamental principle of the old 11 NUMARC as well as the new.
We will get in and describe some 12 of the, how we changed NUMARC and how the* it is a permanent
~13 Washington-based organization in a little bit.
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14 Under that committee structure, as I was indicating, 15 we set about to look at regulatory issues in the management, 16-human resource, and operational area, that were affecting~the 17 industry.
Training was an area.
Security was an area.
11 8 Engineering expertise on shift was an area.
We also looked at 19 maintenance, fitness for duty, and issues such as that where 20 those were really, a lot of those had ties to the people in l
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21 the management sense.
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23 areas, we brought, we developed through this work group gs 24 structure industry positions, position that the industry L
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this Full Committee and without--at that time, that was 55
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2 members. -Right now we have 54 because Dairyland is 3
decommissioning Lacrosse and is not going to operate, but 55 4
members came together, and if we got 80 percent of those 5
members agreeing to a position, then that was binding on the 6
wh' ole, binding on all.
And they went into that with that 7
understanding, that if it was, if 80 percent of the industry 8
felt that that was the right track for the industry, then the j
9 others went into it and supported that even though it might l
l 10 be, not be in the interest of their individual utility either I
l 11 economically or for some other reason, and we all did that 12 certainly consistent within the licanse requirements of the
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This was on a generic basis.
V 14 And NUMARC strength was really that it is the 15 industry.
I mean that committee is the industry.
It is the 16 licensees, all the licensees together.
In 1985, early in 17 August 1985, the Utility Nuclear Power Oversight Committee, 18 UNPOC, asked NUMARC to address some, select the technical 19 issues, to take that process that NUMARC had been involved in l
20 on some of these management, people related issues, and change 21 it over and look at soma key technical issues that were 22 affecting the industry.
23 The first one they chose was Station Blackout.
And 24 I think that's probably one of the better examples that we 25 have in the technical aren, as to how well that the NUMARC HERITAGE REPORTING CORPORATION -- (202)628-4888
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~1eadership and the working group set lip,.have interacted with
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2 the NRC staff.and certainly with the Commission, to resolve an 3
issue, and we think we are bringing that issue to very 4-effective' resolution.
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~5 Probably one of the key things to understand is the 6
NUMARC took a position that they didn't think the rulemaking 7
on Station Blackout was necessary for a number of reasons.
It 8
was not generic.
There are--only 80 percent of_the plants 9
contributed'less than 10 percent of the risk, number of other 10 issues, but out of that process came four NUMARC initiatives 11 and commitments to reduce the overall risk to Station 12 Blackout, irrespective of what.the NRC did with rulemaking, 13 and I think that's, that's t!!e healthy aspect of this process.-
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14 And yes, sir?
15 DR. MARK:
Has there ever been an issue in which 16 NUMARC thcught a rulemaking was a good idea?
17 MR. COLVIN:
Under the old NUMARC, let me think 18 about that.
The NUMARC ob,3ected to rulemaking--let me answer 19 your question this way.
NGHARC objected to rulemaking and 20 training and in fitness for duty.
About, those are about the i
21 only two issues except they indicated that Station Blackout 22 rule they felt was unnecessary, and as a result, proposed some 23 other initiatives and now are working down through them with 24 the staff on Station Blackout.
NUMARC does not believe the 25 Station Blackout rulemaking is necessary today, but will HERITAGE REPORTING CORPORATION -- (202)628-4888 1
207 1
support the staff if the staff goes forth in the Station
..x) 2 Blackout rulemaking, so this is, as I say,'this is a case 3
where NUMARC is supporting the staff'on rulemaking activities.
4 There have been a number.of interactions on this 5
process, and we have developed a, through these interactic_s, 6
a guideline for utilities on how to implement initiatives, 7
corrective initiatives, and Station. Blackout, that the staff 8
has agreement with and intends to reference in a reg guide or 9
other activities as an acceptable way of meeting their l
1 10 proposed rule when that comes out, so to date, I don't think 11 we, we have, we have not gone out and directly supported some 12 rulemaking, but we have only been working on a number of 13 limited issues, and Station Blackout is probably the first 14 where we are not trying to get in a policy statement versus 15 rule.
I think that from our sense, that's not the issue at 1
16 hand.
We want to have the resolution to that problem be an 17 effective resolution that actually corrects the problem we are 18 trying to solve, and not just come out with the rule or policy 19 statement that ends up not correcting that.
20 I hope that answers your question.
I will try to 21 get into some other examples.
Maybe it will be clearer.
6 22 DR. MARK:
Well, I guess I personally agree that the 23 fitness for duty was a real area where rule--not rule.
It 24 doesn't have a question.
There could cases where NUMARC would 25 say yes, a rule is an okay idea, make sure it includes this or HERITAGE REPORTING CORPORATION -- (202)628-4888 1
1 208 1
that.
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3 MR. COLVIN:
Right.
We have supported rulemaking'
'3 as, the new NUMARC, as a council on several issues. -The
~4 standardization policy statement, and the interaction with the 5
staff on where they intend to go on the rulemaking on 6
standardization is one that we are supporting, but that is not 7
out, and so on.
I understand there are a number of issues-8 like that which are in the works.
9 DR. MARK:
Thank you.
10 MR. COLVIN:
Dr. Kerr?
11 CHAIRMAN KERR:
You nentioned Station Blackout as an 12 issue that NUMARC is involved.in, and it seems to me it had 13 positive impact on things.
14 However, as far as I know, NUMARC did not identify 15 Station Blackout as the employee service issue.
It seems to 16 me that one might hope that in the future, assuming that l'7 employee safety issues still exist, that NUMARC would take 18 some initiative not only in settling, but identify some of the 19 issues.
20 Do you expect that will occur?
21 MR. COLVIN:
Yes, sir, and in fact, the mission of l
22 the new NUMARC includes not only coordinating and focusing the 23 industry's activities and operational technical regulatory fs 24 issues, but initiating action on behalf of the industry on
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25 issues that are important either to.the industry or the NRC, HERITAGE REPORTING CORPORATION -- (202)628-4888
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209.
1 in a proactive sense like you are describing, not in a 2-
' reactive mode, so we certainly-have that objective before us
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3-and we-are trying to' work on those.
We are in the process of 4'
working on some of those issues now.
When I get in later I 5
will try to give you a list that in fact it is in your 6
handout, and to describe the process that we are using to 7
identify priorities, as well as solve or resolve some of these 8
issues.
9 Just to continue, in the same timeframe that we'got, 10 INPOC asked NUMARC to undertake some of the technical issues, 11 the leadership of the industry felt that it was very important 12 for the industry to look at itself and decide if there were 13 things that we could undertake, initiatives we could
~
14 undertake, changes we could make, that would put us in a 15 posture to make even more progress, and as a result of that 16 concern that we weren't postured or structured properly, the 17 UNPOC leadership commissioned a study that the Sillin study, 18 the Sillin report was the result.
The result, that was the 19 report of the leadership in achieving operational excellence 20 that challenged for all nuclear utilities.
That was chaired 21 by a task force of Lee Sillin, who had been INPO's Chairman of 22 the Board Paul Norris of Northeast along with Dennis 23 Wilkinson, who was president of INPO, who is president of 24 Harris, and Marcus Rowden who had been past chairman of the 25 NRC.
HERITAGE REPORTING CORPORATION -- (202)628-4888
210 U
. 1.
The three of those gentlemen spent nearly a year
.a 2'S Tj-2 talking to a wide variety of people, doing a study, and the 3
result of that.was the, _ was the'Sillin report, and I would 4
like to come back'-to that in just a moment and talk about that 5
a little' bit-more.
Let me just.go through the chronology.
6 One-of the recommendations in the Sillin report was 7
that we establish a new unified industry organization, and 8
that new unified industry organization'became NUMARC as it is
-9 today.
And because this recommendation, these recommendations 10 there was'not organization already in place, that is, a formal
~11 organization with a Board of Directors, governance, structure, 1
12 we formed what we call a response and implementation committee 13 that set about to put that in place.
I will describe that
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14
.more in a moment.
15 NUMARC as a council was formed in April of this year.
16 as a permanent organization, permanently staffed, 17 headquartered in Washington.
It is independently funded and 18 governed.
And on July 1, we had the restructuring activities 19 completed, and I will give you a better sense hopefully as to l
20 what those are.
21 UNPOC as it exists--let me digress for a second, 22 back again--included, UNPOC included these eight L
23 organizations--utility executive, typically the Chairman of i
24 the Board of AIF, American Nuclear Energy Council, lobbying 25 arm, Public Power, U.S.
Committee for Energy Awareness in the HERITAGE REPORTING CORPORATION -- (202)628-4888
211 i
1-public education and advertising, Edison Electric Institute
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representing the investor-owned utilities, EPRI representing 3
the R and D efforts of both fossil and nuclear, INPO supported 4
by all, voluntarily supported by all nuclear utilities, as 5
well as involvement by the supplier community; NRECS l
6 representing the cooperatives.
I 7
MR. MICHELSON:
You use the word "oversight."
You 8
are inferring somehow looking over a particular group for some I
9 particular reason?
What is the reason for the oversight l
l 10 committee?
l l
11 MR. COLVIN:
UNPOC was established basically to look 12 at the industry organizations, and ensure that they are 13 working in a cooperative and effective manner.
14 MR. MICHELSON:
What areas?
15 MR. COLVIN:
In all areas, principally as affecting 16 the electric utility industry.
I think if you look at the 17 membership on there, it was all utility executives.
The 18 chairman of this group and at that time who was representing 19 it was from INPO, was Jim O'Connor.
20 HR. MICHELSON:
They are, all areas include 21 pseudo-political as well as technical.
Were these people
)
22 looking at technical or most pseudo-political?
l 23 MR. COLVIN:
No, sir.
When I say all areas, they
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24 are really looking at broad policy, pseudo-political, other i
25 initiatives, to make sure that--
l l
l I
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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-1 MR. MICHELSON:
Not-safety oversight?
()
2 MR. COLVIN:
Not safety oversight.
-3 MR. MICHELSON:
Just wanted to make sure.
4-MR. COLVIN:
I didn't understand your question.
It 5
is to ensure that we are working effectively, that we were, 6
the things weren't falling through the cracks, that industry 7
organization would be defined as one having the lead and 8
others would support their efforts.
9 MR. MICHELSON:
Is this why you still have a 10 separate UNPOC?
11 MR. COLVIN:
We still have, it now has become 12 NPOC--Nuclear Power Over: sight Committee.
We dropped the 13 utility from its name, and from the acronym.
Because we have 14 expanded membership of NPOC to include some vender supplier 15 representativos so that in fact it is the total nuclear power 16 industry and not just the nuclear utility industry.
17 MR. MICHELSON:
More of an action committee in terms 18 of political impacts as opposed to technical impacts?
19 MR. COLVIN:
Yes, but I couldn't describe it as 20 particularly action.
It will come into bear.
It reviews what 21 the organizations are doing, looks at the issues, kind of 22 discus.-ing broad policies, but it really doesn't take action 23 in the sense of being directive to any of the organizations,
,e g 24 if that helps.
U 25 MR. MICHELSON:
Is it considered a lobbying type?
HER7TAGE REPORTING CORPORATION -- (202)628-4888
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MR. COLVIN:
No, it is not.
,c
(,)
2 MR. MICHELSON:
How does it avoid the lobbying laws?
3 MR. COLVIN:
Well, first of all, it is an ad hoc 4
committee.
That doesn't avoid the law, but in fact it is not 5
lobbying in the sense of the federal law as I understand it.
6 MR. MICHELSON:
I see.
7 MR. COLVIN:
It doesn't interact on behalf of the 8
government or Congress, in an effort to try to sway or change 9
people's minds on pending legislation, as I understand it.
I 10 mean that's not the NPOC.
11 HR. MICHELSON:
It is not going to interact with 12 Congress?
13 MR. COLVIN:
No, sir.
If you have John Conway who
)
14 is the chairman of ANEC's Board and ANEC is the lobbying arm.
15 John is a registered lobbyist.
And John certainly would carry 16 out lobbying activities for ANEC perhaps, but not on behalf of 17 the Nuclear Power Oversight Committee.
18 CHAIRMAN KERR:
You don't avoid the lobbying laws?
19 MR. COLVIN:
I'm sorry.
I couldn't hear you.
20 CHAIRMAN KERR:
Don't avoid the law.
You obey it.
21 MR. COLVIN:
We obey it, yes, sir.
I appreciate 22 that.
23 To go back to the Sillin report for just a minute, 24 the UNPOC task committee report, the Sillin report had three 25 parts.
Part one had the, to do with dealing with improving HERITAGE REPORTING CORPORATION -- (202)628-4888
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operational performance at all facilities, nuclear power
-73 t, j 2
facilities.
The recommendations in that section dealt 3
primarily with INPO.
What could we do with INPO?
How do we 4
change INPO?
How could INPO be given, have INPO's role be 5
made more effective in helping the utilities improve 6
operational performance.
s 7
A number of recommendations in there; those 8
recommendations were addressed by INPO through its Board of 9
Directors, its advisory structure, its advisory council and 10 review groups.
11 The second part of the report dealt with improving 12 the nuclear utility industry interface with the NRC, and the
(^T 13 recommendations in there really had recommendations for the
. tJ 14 new NUMARC as it exists today, and that's one of our primary 15 roles is to try to work as the interface between the industry 15 and the NRC and improve that relationship, and improve the 17 credibility of both the industry, the industry including the 18 NRC, as perceived by Congress and others, not in a lobbying 19 sense, but to resolve some of the issues that are outstanding 20 and focus the industry's resources, as well as recommendations f
21 for what the NRC should do in some areas, and INPO and others.
22 What can we do together to improve the relationship that we 23 have, and continue progress?
24 The last part dealt with establishing a unified g-V) 25 industry organization, and that became NUMARC as we know it HERITAGE REPORTING COROORATION -- (202)628-4888
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215 1
today, the Nuclear Management and Resources Council.
()
2' Now what we, I mentioned a minute ago, that we set-l 3
up a response and implementation' committee to'put NUMARC
'4
- together-to implement those Part 3 recommendation, we set up a 5-committee of nine industry executives, really chosen because f
6 of their involvement and activities in other industry i
7 initiatives.
For example, Joe Farley was chairman'of the-8 INPO's Board, and also had a close tie to EEI.
Art Hauspurg 9
was the chairman of EPRI's Board at that time.
Jim Hiller was 10 the chairman and vice chairman of NUMARC as a committee, e t' 11 cetera.
Bernie Reznicek representing Public Power, large 12 versus small utilities, geographically and so on.
13 We also had other members of the--those were the V('s 14 original nine members.
We added in August of 1986 the other 15 members of that to the committee, and another seven 16 members--Jim O'Connor, who was chairman of UNPOC at that time;.
i 17 Sherwood Smith and Bill Lee, who were, really the three of 18 these gentlemen formed the steering committee to guide what 19 Lee Sillin, Mark Rowden and Dennis Wilkinson did in developing i
20 the Sillin report, and I also sat on that committee and 21 working out setting up the new NUMARC.
22 DR. MOELLER:
E'<cuse me.
I'm not with you.
You are 23 not saying Sillin, Rowden, and Wilkinson became members of 24 NUMARC?
25 HR. COLVIN:
Not NUMARC, but we set up a committee HERITAGE REPORTING CORPORATION -- (202)628-4888
216 1
of the industry whose mission was to develop a structure for
<s
(_)
2 this new unified industry organization that became NUMARC.
3 How should it be governed?
What should its bylaws be?
How 4
should it be funded?
How should it interface?
What should 5
its mission be?
And that's what this committee did.
These 6
sixteen members met throughout nineteen, even from August 1986 7
really until July of this year, putting together the industry 8
restructuring activities.
9 DR. REMICK:
Not only NUMARC, but the industry in 10 general?
11 MR. COLVIN:
Yes.
I was going to comment on that.
12 Really what started out to be strictly NUMARC, implement the
(~T 13 recommendations of Part 3 of the Sillin report, new unified V
14 utility industry organization, as soon as we started on that 15 task, it was obvious that there would be a lot of overlap and 16 duplication with the other industry organizations and groups.
17 And that was a given.
And we went into that process with that 18 understanding and we tried to figure out could we structure 19 NUMARC or this unified organization in such a way that its 20 mission and its responsibilities would be clear and yet not 21 overlap and duplicate what the other, with the other 22 organizations, and we realized from the beginning and finally 23 it was recognized officially in November of 1986 that we could s
24 not head down that path, and what we did was we, the UNPOC d
25 leadership took a resolution to the Boards of ANEC, USCEA, and HERITAGE REPORTING CORPORATION -- (202)628-4888
217 1
AIF, and also to discuss it with NUMARC, that would accomplish
^/%
A_)
2 a restructuring of those four organizations along functional 3
lines, and we didn't know how that would occur.
We knew we 4
would take those four organizations and restructure them in 5
some manner along functional lines, and we expanded that.
6 The response implementation committee--slides are a 7
little out of order just by one page--but to include 8
representatives of AIF.
Notice we got the vender and supplier 9
community people in here from ANEC since they were involved, 10 and also from the U.S.
Committee for Energy Awareness, getting 11 in both the utility side with Bob Ginn and Keith Turley and 12 also the vender supplier side with Harry Reinsch.
13 MR, MICHELSON:
Is thers some reason why combustion 14 is absent from the list?
15 MR. COLVIN:
No, sir.
In fact, that was not 16 intentional.
At that time, it was just felt that the 17 committee was adequate and Combustion felt their interests 18 tere being covered by these gentlemen who were representing 19 AIF, from AIF's Executive Committee in actuality.
We did keep 20 Combustion Engineering and EEI and INPO and the other 21 organizations very closely coupled with this process as it was 22 carried out, so it was not done in isolation.
23 DR. MOELLER:
One thing that would help me also, you 24 mentioned that this committee met and you gave the time span, d
25 It would help to know how many days they actually got together HERITAGE REPORTING CORPORATION -- (202)628-4888
(
218 1
to discuss.
It is like NUMARC?
You say it meets once every 1
2 six months for three hours or--
3 MR. COLVIN:
Okay.
NUMARC--let me answer NUMARC 4
first, and then the response to implementation committee.if 5
you are-interested in both.
I think that was your question?
6 DR. MOELLER:
Yes.
7 MR. COLVIN:
NUMARC frem its beginning on March 7th, 8
1984, had a steering committee of about 15 of the 55 9
executives, and they met almost on a monthly basis throughout 10 1984, and then it probably was on the average of a bimonthly 11 basis throughout the rest of NUMARC's existence, and NUMARC 12 went out of business officially on April 7th of this year.
13 NUMARC as a committee, the first membership of 14 NUMARC, the 55 members that were called the Executive Group, 15 met at least quarterly throughout 1984, five, six, and their 16 last meeting was in the end of January of this year, 1987, as 17 a committee.
18 DR. MOELLER:
For one day?
19 HR. COLVIN:
Full day's meeting; the steering 20 committee meetings typically were a full day and sometimes 21 late into the night.
There were the working group activities 22 as I mentioned earlier about the principal working groups, and 23 they met anywhere from once a week throughout the process to 24 try to solve some problem, to probably every month to six 25 weeks, throughout their existence until they reached some end HERITAGE REPORTING CORPORATION ---(202)628-4888
219 1
point at that time.
(9.,J.
2 The response and implementation committee that I was-3 mentioning who structured NUMARC met about every four to six 4
weeks starting in August.
The first meeting was actually the.
5 about the 2nd of September, of 1986, and met about every four 6
to six weeks for a full day or a day and a half type of 7
meetings, and then we had some subcommittees and other 8
splinter groups to work on specific issues that met usually on 9
two days to try to resolve some issue and then bring it back 10 to the full committee.
11 What we ended up doing, as I mentioned, was 12 restructuring the activities of these organizations along 13 functional lines.
We set up an organization that was 14 responsible for regulation and technical support issues, 15 regulatory and technical support issues, one that was set up 16 to deal with communications, education, and some other 17 miscellaneous technical services, and also one on government 18 affairs, and the way this probably--this I would hope helps 19 you understand what happened.
We took NUMARC as a conmittee 20 responsible for the generic operational and technical issues, 21 and we took from AIF the regulatory and technical and 22 licensing programs that had been headed by Bob Silay and that 23 group, dealing with the regulatory and licensing, and we have 24 combined those functionally into the new NUMARC as a council.
25 We then took the other part of AIF, which was the HERITAGE REPORTIl1G CORPORATION -- (202)628-4888 l
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220 1
Public Affairs and Information Program, PAIP, and some other n(_)
2 issues that PAIP was dealing with--fusion cycle issues, 3
mining, milling, enriching, some other things like fusion, 4
non-proliferation policy, things that would not fit well in 5
the NUMARC mission, of trying to work and solving some of the 6
operational technical issues we have, and pc* those into 7
8 We also took what CEA was doing in its long-range 9
public education and advertising programs and put those, kept 10 those, put those together.
11 MR. MICHELSON:
What is the difference between 12 technical support and technical service?
13 MR. COLVIN:
That's--many people ask that.
Wnen the b'N 14 resolutions were passed, it wasn't really clear as to what 15 portions of what organizations should go where, and they felt 16 that it was not right for all the technical work--there were a 17 lot of technical activities in fuel cycle that wouldn't fit in 18 the NUMARC concept, or be, function within the NUMARC concept 19 of getting the leadership of the industry together to solve 20 their problems and bring that resource to bear on a 21 commitment.
22 There was also a vastly different membership base 23 for these organizations.
In the mining, the milling, the l
24 enrichers, other venders and suppliers really should not be 25 functionally guiding NUMARC, what NUMARC is trying to do, HERITAGE REPORTING CORPORATION -- (202)628-4888
p 221 1
because the licensee has the primary responsibilities.
\\_,/
2 MR. MICHELSON:
Let me ask it differently.
Is 3
technical service non-reactor?
4 HR. COLVIN:
No.
It really still has to do with 5
utility and reactor.
It is not as clean as we would like; if 6
we took the high-level, low-level waste, nuclear waste 7
trcnsportation, and things like that, 8
MR. MICHELSON:
I consider that non-reactor, though.
9 MR. COLVIN:
In that sense, yes, it is.
10 MR. MICHELSON:
Does it deal at all with the nuclear 11 power plant per se?
12 MR. COLVIN:
Not directly.
13 MR. MICHELSON:
That is technical support?
14 MR. COLVIN:
Yes sir.
That's a better detinition.
15 DR. SHEWMON:
Out of existing?
16 MR. COLVIN:
Yes, sir.
AIF as of July, the industry 17 restructuring activities were completed, AIF actually went 18 out, was dissolved.
First of all, AIF was merged.
19 DR. SHEWMON:
That's enough.
Let me finish the 20 question.
NUMARC a minute ago went out of existence but it 21 rose from the ashes to now, to be a cou:icil.
22 MR. COLVIN:
Permanent organization, not ad hoc 23 committee.
24 DR. SHEWHON:
After I shut up, you will tell us how 25 these 55 executives are now handling such mundane things as HERITAGE REPORTING CORPORATION -- (202)628-4888
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222 i
technical support?
gs x,)
2 HR. COLVIN:
Right.
I will get into that.
We took i
3 AIF and merged it legally with the U.S. Committee on Energy 4
Awareness and formed the U.S.
Council for Energy Awareness.
5 We took part of the AIR function, put it with NUMARC, and 6
dissolved AIF.
AIF went out of business as a corporation, a 7
legal corporation, I believe it was September 30th of this 8
year, either as--August 30th.
I can't remember.
September 9
30th, but the restructuring was completed, and in principle 10 those activities had been split off to the other organizations 11 at that time.
12 Let me talk about NUMARC since I think that would 13 get into your questions as to what rose from the ashes of 14 that, and I would like to discuss NUMARC and, in concept, and 15 then get into some specifics to give you some insights.
16 Really NUMARC's purpose is to be the principal 17 industry interface with the NRC on generic operational 18 technical regulatory issues.
And in that process, we are 19 supposed to work with the industry ta focus the industry 20 activities and bring together all tha work that is going on 21 between the utilities, EPRI, INPO, venders, suppliers, and 22 other special issues groups, and bring those resources in a 23 focused manner, and some of, sone of the problems that we have 24 out there, and when an organization speaks for the industry on 3
J 25 an issue, that should br NUMARC and we shouldn't have other HERITAGE REPORTING CORPORATION -- (202)628-4888
223.
1
- organizations speaking for the industry on behalf of the m
k,_)
2 industry before the Nuclear Regulatory Commission as the 3
industry, and that's kind of one of NUMARC's roles.
4 We are also, as I indicated earlier, tasked to 5
identify and take initiatives on issues that are necessary 6
from the utility viewpoint to be proactive, to be ahead.
7 Where we have some problem we ought to be out in front of 8
that, identify the problem, scope it, and undertake some 9
corrective actions before we have that become reactive or we 10 have the NRC tell us wait a second, guys, that is not, you are 11 not doing that in the right way.
12 So we are trying to get into that mode of operations
(~N 13 also.
(_)
14 NUMARC has some other very key principles I will get 15 into as we discuss how NUMARC functions.
I think that would 16 be easier.
17 NUMARC is different than the old new NUMARC in that 18 the old NUMARC was a nuclear utility management and resources 19 council.
Under the new NUMARC, our committee as the new 20 NUMARC as a council, we drop the U, utility, from the acronym, 21 because we have on our governance venders and suppliers.
We 22 brought together, like I described witn the Nuclear Power 23 7versight Committee, some of the venders, supplier community 24 14.to NUMARC so that we h ad that resource to tap and f-g
\\-)
25 coordinate.
HERITAGE REPORTING CORPORATION -- (20P,)628-4888
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We have all licensees represented on our Board of fs
(_)
2 Directors.
Our Board of Directors--
3 MR. WARD:
Are you going to explain when you get to 4
the 80 percent vote--
5 MR. COLVIN:
Yes.
I will get to that.
6 MR. WARD:
Who votes?
7 MR. COLVIN:
I was going to talk about that because 8
everybody doesn't vote.
We do have some limited voting rights 9
for non-utility, non-licensee participants.
10 We have all licensees represented on the Board, and 11 that's either at the Chief Executive Officer, Chief Operating 12 Officer or senior nuclear line executive level.
The change 13 between the old NUMARC as a committee and the new NUdARC as a 14 council is we now have a Board of Directors instead of a 15 committee, and that Board is elevated up with some mix of 16 CEOs, Chief Operating Officer, as well as the same people that 17 were in NUMARC before, and we try to keep about a third, the 18 mix of a third of CEOs, third of Chief Operating Officer, and 19 a third senior nuclear line executives.
And it turns out that 20 it works that way when they.
When they name their directors, l
21 it is amazing that we get pt le like Jack Ferguson from 1
22 Virginia Power has been very active it NUMARC.
He is the i
23 president and chief executive officer.
We get Cordell Reed, 24 the Senior Vice president of Nuclear, and when you get all O
25 these 54 now together, we end up with that mix, just by I l
HERITAGE REPORTING CORPORATION -- (202)628-4888 l
225 1
guess by chance or by luck, but it works out that way without O(,-
2 any, any structure.
3-It is a hundred percent voluntary membership.
4 NUMARC, like INPO, has had a hundred percent voluntary 5
membership from the beginning, from its formation, and NUMARC 6
was incorporated April 7th of this year, and that's when 7
NUMARC as a committee was put out of business.
8 MR. MICHELSON:
A hundred percent voluntary, you 9
mean that everybody volunteers or does it mean ever utility n
10 has volunteered?
11 MR. COLVIN:
Every utility has volunteered.
It is 12 voluntary.
A little different capacity than INPO.
We don't 13 have any evaluation program.
We don't have any tie to, to the 14 insurance and the evaluation process that INPO has, and the 15 utilities have gotten together and supported NUMARC as they 16 did in NUMARC as a committee because they think that's in the 17 best interests of the industry, and we have had tremendous 18 support from the industry in that area.
19 CHAIRMAN KERR:
Do you have mechanics for throwing 20 someone out for not living up to the principles?
21 MR. COLVIN:
Yes, sir, exactly.
If we had a case 22 where we took a commitment, this 80 percent vote, that became 23 a commitment on the industry, through that process, through 24 this vote of this Board, and a utility was not living up to 25 that commitment, then they could be terminated from, their HERITAGE REPORTING CORPORATION -- (202)628-4888
226 1
membership could be terminated, and we~would then identify
~
()
2 that to the other appropriate industry people probably as'well 3
as the NRC if that were germane to the issue.
We do have that 4
built within the bylaws.
5 We also have--I will get into more detail--NSSS 6
venders and supplies as well as the architect / engineering 7
firms as participants.
We said we had 80 percent vote to that 8
like the old NUMARC as a committee, 80 percent vote to adopt 9
these formal industry positions or policies, but these 10 participant members or participant directors on the Board are 11 not eligible to vote on issues that are primarily affecting 12 utilities or on these formal nuclear industry positions or
('N 13 policies.
They have a say in what NUMARC does, but not, not
\\l 14 in the sense of taking a position or voting on issues that are 15 really the utilities' business, and that's so the organization 16 has that input, has the tie and the involvement of those 17 people, but in fact it, the voting rights have some 18 limitations on them, t
19 As I mentioned earlier, HUMARC is an independent 20 organization.
It is separately organized, funded, governed, 21 has a permanent staff here in Washington.
We are in the 22 process of still working on staffing I might add--a little 23 plug--and I will describe the organization.
f 24 Yes, sir?
i
(-)
%)
25 DR. MARK:
In one of your earlier vugraphs, you HERITAGF REPORTING CORPORATION -- (202)628-4888 i
o 227 1
indicated that things like fuel cycle interests go off with
~p)
(_
2 the Energy Awareness Council.
3 MR. COLVIN:
Yes, sir.
4 DR. MARK:
Do the isotope producers appear anywhere 5
in relation to this package you are describing?
6 MR. COLVIN:
They appear under the U.S. Council for 7
Energy Awareness.
The broad forum responsibilities that the 8
AIF had had were transferred in toto to the U.S. Council for 9
Energy Awareness, so we just, the annual meeting tied to the 10 fuel cycle radioisotopes, radiopharmaceuticals.
11 DR. MARK:
That goes with the fuel cycle?
12 MR. COLVIN:
That goes with the fuel cycle work 13 under the Council for Energy Awareness.
14 DR. SHEWHON:
There is a large service industry, 15 some of which is done by venders and a lot of which is not, in 16 the U.S..
Are they involved in this at all?
17 MR. COLVIN:
They are involved with the Council for 18 Energy Awareness, and not with the NUMARC.
19 DR. SHEWMON:
Okay.
20 HR. COLVIN:
Let me walk through this 21 organizationally at least down to this point, and that may 22 help you to understand the relationship between Board, the 23 relationship between participants, directors and so on.
24 We have first of all, two classes of members.
We 25 have members with a capital M, and those are utility HERITAGE REPORTING CORPORATION -- (202)628-4888
228 1
licensees.
If you have an operating license or a construction D)
(
2 permit issued by the NRC, you are a licensee, and you are a
.3
.nember.
And those members are eligible, have the ability to 4
appoint a director, so Alabama Power Company says I am going 5
to name Joe Farley as my director to NUMARC.
That's an 6
appointment by, that's their right under our bylaws, so those 7
54 licensees name their director and that forms part of this 8
Board of Directors.
9 Those 54 licensees then elect twelve of themselves 10 to serve on our Executive Committee.
They also elec* six 11 participant directors at large from venders, suppliers, 12 international, partial owners, consultants, et cetera, to 13 serve on the NUMARC Board and also on the Executive Committee.
14 The Executive Committee is made up of eighteen of 15 these directors, both licensee or member directors, and six 16 participant directors, to provide governance to NUMARC and, 17 this Executive Committee really is more like a normal Board.
18 It looks at things like budget, and staffing, as well as 19 looking at some of the technical and operational issues that 20 we might take to this Board for a vote, that 80 percent vote 21 process.
i 22 DR. MOELLER:
Now if I'm a utility and I have twelve 23 nuclear power plants, and then another utility has one--
24 MR. COLVIN:
You still have one, one director and i
25 one vote in the say of what goes on in the industry.
That's l
HERITAGE REPORTING CORPORATION -- (202)628-4888
1 229 l
l 1
-kind of a unique--I am glad you mentioned had because it is D(_)
2 kind of a unique principle of NUMARC that each company, no 1
3 matter what its total generating capacity or its nuclear 4
commitment, although it may pay different dues or membership 5
base, based on nuclear units and sites, et cetera kind of s
6 like the way INPO does it, but they still only get one vote, 7
so the small utility with one small 150 megawatt single unit 8
station has the same voting rights as Commonwealth Edison, and 9
that, that's what made the process work under the committee, 10 and I think is instrumental to the success of NUMARC as a 11
- council, 12 DR. HOELLER:
Can you show us on this chart who
~g 13 votes?
You know, you were saying 80 percent vote.
(V 14 MR. COLVIN:
Right.
You have got 54 licensees 15 sitting on this Board along with these six individuals to make 16 up a Board that is 60 strong.
17 DR. MOELLER:
They all vote?
18 MR. COLVIN:
Only the 64 licensee people vote on 19 this 80 percent process.
20 DR. MOELLER:
Okay.
Fine.
21 MR. COLVIN:
That's the licensees.
It is a utility, 22 formal nuclear industry position or policy in the sense the 23 utility industry has the responsibility for the operation and 24 the safe operation of their plants, not the vender and the 25 supplier, not the consultants, so that responsibility is HERITAGE REPORTING CORPORATION -- (202)628-4888
230 1
withheld, is held closely by those people,
()
2 Now we want their input.
I mean I think that if-you 3
look at this list--let me walk down here.
Bob Campbell, who 4
chaired the Response Implementation Committee, is our chairman 5
along with Warren Owen, vice chairman.
We have got Joe Farley 6
from Alabama, chairman of Alabama;, Jack Ferguson, CEO of 7
Virginia Power; Bill Lindbled, General Electric; Jerry 8
Houlden, who is CEO at Arkansas; Don Hazur, who is the 9
equivalent CEO at Washington Public Power Supplier System; 10 McCarthy, Detroit; Eugene McGrath, Executive Vice President of 11 Con Ed; Cordell Reed, Senior Vice President at Commonwsalth 12 Edison; Keith Turley, Chairman of the Board of Arizona Public; 13 and C.O.
Woody, Group Vice President of Florida Power and 14 Light.
So that's our Executive Committee, along with Shelby 15 Brewer from Combustion, Bill Kennedy from Stone and Webster, 16 Harry Reinech from Bechtel.
These are the two major 17 architect / engineering firms.
Then we have combustion, 18 Westinghouse, B&W, and General Electric represented at that 19 level.
20 Now these people are on here.
They serve by a vote 21 of those directors.
They are not, they do not serve on there 22 because Westinghouse or GE has the right to have someone on 23 the Board.
The utilities, on the other hand, do.
Each 24 licensee has a right to name a member to our board.
These 25 people elect the participants because they think that would HERITAGE REPORTING CORPORATION -- (202)628-4888
231 1
serve the interests of the industry and NUMARC, and those are ni,_)
2 redone on an annual basis.
3 HR. EBERSOLE:
You say you represent even the small 4
utility with one little unit up to Commonwealth Edison.
All 5
right.
6 At present, the responsibility for safety of the 7
design, construction, operation of these plants is pitched at 8
the utilities, but they are handed many of the design and 9
operational problems by architect / engineering and the, you 10 know, the three commercial--GE, you know, the suppliers.
11 MR. COLVIN:
Yes, sir, the suppliers.
12 HR. EBERSOLE:
In the small utility, who has almost 13 no technical personnel to do other than mouthpiece what he has 14 been told by the AE, and the vender, do you offer him any 15 technical help as a coordinated effort?
16 HR. COLVIN:
We do offer, the NUMARC process does in 17 fact offer that technical help to that, to the individual 18 companies.
We try to draw upon the technical resources that 19 exist, share that, and provide that back to each of the 20 companies, and we have done that on, as NUMARC as a committee, l
21 and we are doing that as a council.
22 Now we haven't provided in the sense of our staff or 23 a working group necessarily going out and spending some 24 dedicated time with a company.
We have provided, you know, in l
25 technical areas such as Station Blackout, we have provided the l
l l
l l
HERITAGE REPORTING CORPORATION -- (202)628-4888 1
232 1
resources to that company and people by drawing upon and
()
2 tapping other groups and organizations, getting EPRI, getting 3
INPO people, getting Westinghouse.to send a cable specialist 4
to TVA, for example.
Some of those types of things are things 5
that we have, we have done.
6 Our staff is relatively small.
It has been, started 7
out with Byron Lee and myself, you know, in April, May and 8
June timeframe, now has grown to about three people total 9
staff here, and we are looking for about 50 to 60 people.
10 MR. EBERSOLE:
I have always thought the AE--
11 MR. MICHELSON:
In addition to?
12 MR. COLVIN:
Total staff.
13 MR. EBERSOLE:
The AEs went off Scott-free most of 14 the time and didn't get wound up in these things.
The vendors 15 more or less do.
Do you think the distribution is 16 appropriate?
We are looking at safety issues?
17 MR. COLVIN:
I don't know how to comment on that, to 18 be honest with you.
The, the one thing that we have and that 19 we are working on that we didn't do under the old NUMARC is we 20 a-e trying to involve more of the venders and suppliers on 21 the, in the resolution of some of the technical issues.
We 22 are undertaking severe accident--we had the editor process and 23 we are trying to close the work on editor and get into severe 24 accident as overall issues, severe accident management 25 programs, the source term issues, and that's part of our work.
HERITAGE REPORTING CORPORATION -- (202)628-4888
233 1
We are involving those venders and suppliers in those n
(_)
2 activities.
We have got the ties at our Executive Committee 3
level, and we also have the ties throughout our working group 4
and advisory committee structure.
5 Over time, I think that's going to help solve this 6
problem, but most of the safeties are performed more or less 7
by the consultants and not as much by the services and not as 8
much by these big players.
I don't know if that distribution 9
is right or not, to be honest with you.
10 MR. EBERSOLE:
Thank you.
11 DR. SHEWMON:
Simple question--there are utilities 12 that have sort of 30 percent of the reactors.
Davis-Besse rg 13 comes to mind., from there to whatever utility is responsible
(/
14 for operating it.
The consortium is the one you call the 15 nuclear utility here?
16 HR. COLVIN:
Whoever has the license is the, has 17 that responsibility, and even though they may be owned, either 18 totally or in part, they have that responsibility.
Wolf Creek 19 Nuclear Operating Company, Wolfknock, that was set up as part 20 of Kansas Gas and Electric, really offshoot.
Wolfknock has a 21 license.
They are our licensee member, not Kansas Gas and 22 Electric, I mean as an example.
23 MR. WYLIE:
Is TVA a member?
24 MR. COLVIN:
SMUD, TVA, all the companies that have 25 a license to operate or conduct a nuclear plant are members i
HERITAGE REPORTING CORPORATION -- (202)628-4888
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and on the Board, represented on the Board, Executive
()
2 Committee.
Just to quickly run through this, Executive 3
Committee provides the broad policy guidance and direction.
4 Byron, Byron is the president, Chief Executive Officer.
I 5
think most of you know Byron, many of you probably quite well; 6
came to us as Executive President of Commonwealth Edison, 7
spent 34 plus years at commonwealth, and he would be here with 8
you today had he not been off at a Nuclear Power Oversight 9
Committee meeting.
I was telling Forrest that he 10 appropriately chose the time and location of that to be in 11 Phoenix during this, during this snow storm.
12 DR. SIESS:
He is no longer with Commonwealth?
13 MR. COLVIN:
Permanently, as of June 1st, he is 14 permanently at NUMARC headquartered in Washington, NUMARC 15 employee, and is the Chief Executive Officer of NUMARC.
t 16 Just to quickly--we are set up organizationally with 17 two cornerstone divisions to address issues.
One we call 18 Operations Management Support Services, and one we, is the 19 technical issue.
The operations and what we call Operations 20 Division, basically would address the people, hu. nan resources.
21 More of the, what I would call the software types of 22 issues--security, training, emergency planning, and so 23 on--would fall within this area.
24 The Technical Issues Division handles the, more of 25 the hardware design, licensing types of issues.
They are l
HERITAGE REPORTING CORPORATION -- (202)628-4888 i
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headed by Tom Tipton, who is the Director of Nuclear
/7
(,)
2 Regulation Affairs at AIF, is the director of our Operations 3
Division, comes to us with a lot of utility experience, at GPU Nuclear and the AEP, and then joined us at this year when we 5
put together NUMARC, came on Board in July.
6 Bill Resin is the director of-our Technical Issues 7
Division, and Bill came to us from Duke Power, been very 8
closely associated with Duke's engineering program, was part 9
of Bill Lee's--Bill Lee put together a special nuclear 10 engineering group to do some work for all of his plants, and 11 Bill headed that prior to coming to us.
12 So these are kind of cornerstone, these are the 13 divisions that work the issues, set the strategies, work with t
14 the organizations and coordinate the activities.
15 Tom Price, who we introduced earlier, is the 16 director of our Industry and Government Relations Division, 17 and Tom has the task, kind of task that I had at INPO to keep 18 INPO coordinated, and now Bill Conway has that.
Tom also is 19 trying to keep us coordinated internally so that what we do P
20 between one of our divisions does not overlap or duplicate or 21 counter some of the work that is done by one of the other 22 industry organizations and whether that be EPRI or INPO or 23 EEI.
24 Just we have also got Bob Szaley, who is senior vice 25 president of AIF on our, as Executive Assistant to Byron, 6
HERITAGE REPORTING CORPORATION -- (202)628-4888
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involved in our--so just a sense of the kind of people that we
()
2
'have, and have involved.
We have been able to hire and 3
attract a very impressive staff with some interesting 4
background.
5 Our General Counsel, just let me mention Bob, has 6
like Tom Price kind of a unique background.
Bob was a Naval 7
Academy graduate, served on nuclear, in the Navy nuclear 8
program for six years, and was a nuclear engineer, went to 9
work for Combustion Engine 6 ring as a licensing engineer, and 10 then got his law degree and went on to the State of 11 Connecticut as an attorney to working on nuclear 12 transportation issues; in fact, chaired the industry's nuclear 13 transportation group for a number of years, spent ten years at 14 Northeast Utility as their special counsel and corporate 15 secretary, and then has come to NUMARC, so he brings to NUMARC 16 a blend of understanding of the technology and the operations 17 of the technology as well as the legal issues and utility 18 cperations, so we are able to, we are able to put together 19 staff capabilities with that kind of background and l
20 experience.
I think that's very advantageous to NUMARC and l
21 certainly to the industry.
l 22 The other committee that I want to talk about 23 because this gets into some specific issues, is this committee 24 called the Issues Management Committee, and the Issues 25 Management Committee, and I don't think this slide is in your HERITAGE REPORTING CORPORATION -- (202)628-4888
237 1
handout, but the Issues Management committee is a committee t'
2 set up, set up to provide advice, counsel, strategies, et 3
cetera, as this shows the objectives here, to NUMARC, to help 4
us sort out what are the issues we really ought to be working 5
on?
What is important to the industry?
6 We have got a myriad of issues out there, and some 7
300 to 400 issues, that if you look at the unresolved safe 0s 8
issues, generic issues, issues that we have identified, you 9
look at any of the thing, you can come up with a big list of 10 issues, and we have got to sort out those to see what, what we 11 ought to dedicate, where we ought to dedicate our resources 12 and NUMARC's resources as well as the industry's.
Where 13 should the senior management of the industry place its time 14 and efforts?
15 The chairman of this Issues Management Committee is 16 Byron Lee, and that was set up to be the president of NUMARC 17 as the chairman, because it is advisory to NUMARC and advisory 4
18 to Byron in that capacity.
We have 12 to 15 members of the 19 utility members, plus two or three representatives from the r
20 participant members, the suppliers, or the AEs.
We have close 21 ties to in this committee since it is going to deal with 22 operational and technical issues, to EPRI and INPO and the 23 four owners groups, so we have EPRI set up to participate in s
24 the meeting, INPO representation participating, and each of I
25 the chairmen of the four owner groups participate in these HERITAGE REPORTING CORPORATION -- (202)628-4888
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meetings, so we bring together that collective expertise.
(\\
(,)
2 The people that are on ere, we include, we include 3
some members of our Executive Committee that have technical 4
and licensing and operational experience as well as try to 5
bring people on this committee that have more detailed 6
experience in some technical issues and ties to other 7
organizations.
8 For example, Al Cutter from Duke Power is on the 9
Issues Management Committee.
He happens to be the chairman of 10 EPRI's Nuclear Power Division advisory committee, has been 11 very involved in licensing and technical issues resolution.
12 We recognize and we set up this committee because we 13 recognize that the Executive Committee, those 18 people we had 14 up there, may be at too high a level to help us deal 15 effectively on some specific technical issues, which was like 16 inventory, that Executive Committee tending to be more policy 17 and overall strategy.
We needed to get down more into the 18 issues, so we have got this Issues Management Committee to 19 look at that.
20 Now we set up a process to look at all these issues, 21 and go through and prioritize them.
Now all the rest of the 22 niides are in your handout.
23 (Slide) 24 MR. COLVIN:
We went through--
25 HR. MICHELSON:
Excuse me.
Is that where you i
HERITAGE REPORTING CORPORATION -- (202)628-4888
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generate your internal issues as well as deal with external
()
2 issues?
3 MR. COLVIN:
Yes, sir.
And I have got some lists of 4
some issues and I will try to describe how we came up with l
5 those, and where we are heading on some of those by example.
6 We put in process a prioritization kind of 7
philosophy or methodology to look at these five items on 8
there, and basically we are trying to work on issues which 9
have generic applicability or potential generic applicability.
10 I think the potentials is a key word in there because NUMARC 11 both as a committee and as a council has undertaken 12 initiatives in containment integrity, dealing first with the 13 BWR MARK I issue in cooperation with the B&W owners group, 14 where that is not by strict definition a generic issue, but it 15 has potential generic applicability to other types of 16 containment, so NUMARC, NUMARC took on that issue sometime 17 back.
That's what we mean by generic applicability.
We try 18 to go through a screening process for each one of these 19 issues.
We look at the issue relative to its importance.
How 20 important is it to the inbistry to be solved, you know, on a 21 scale of very important, moderately important, or not very 22 important, that kind of a--it is a very rough screen on these.
23 We look at it from an immediacy standpoint, how 24 important is it to take some action now as compared to, you 25 know, is this something we need to do today?
Can we work on HERITAGE REPORTING CORPORATION -- (202)628-4888
240 1
this over some longer period of time, or should we not worry m
2 about it in the overall sense of where we are at?
3 Involvement dtals with, the fourth item deals with 4
NUMARC taking on those initiatives or working those issues.
5 Is it proper for NUMARC to take on that issue or is it 6
important for NUMARC to take on that issue in order to bring 7
it to a proper, timely and effective resolution?
And that's 8
what this importance factor or this involvement factor deals 9
with.
10 The fifth one is catch-all because we recognize that 11 you can go through all this and there may be something else in 12 there that elevates that issue up or pushes it down.
It could 13 be high Congressional interest on a specific issue.
It might 14 be that it is of primary interest to the NRC, or that it is of 15 primary interest to NUMARC.
We think that's a very important 16 issue, so that would change this type of screening.
17 We went through that process and we came up with 18 four categories of issues that we kind of jast parceled these, 19 after review of all these issues that we looked at, kind of 20 parceled these things into four general categories.
21 The first category we call priority iSJues, and this 22 category is one in which these issues we consider are under 23 active management of NUMARC, either at its staff or in its 24 working group structure.
We went down this, we look at access i
25 authorization.
We have had a NUMARC working group dealing on HERITAGE REPORTING CORPORATION -- (202)628-4888
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241 1
access authorization, interacting with the staff.
('N)_
2 Check valve reliability, NUMARC was monitoring this 3
and we had an owners group task force to work on check valve 4
reliability in cooperation with INPO and EPRI.
5 Containment integrity I mentioned.
Degree 6
requirements for operators, et cetera; now you need to look at 7
this in the light that this is what NUMARC is managing as an 8
operational or technical regulatory issue, because clearly 9
fitness for duty has had, has been an INPO issue all along.
10 INPO has been evaluating fitness for duty for the industry.
11 Maintenance, certainly INPO has it, has the lead for the 12 industry in maintenance.
Improving--
13 MR. EBERSOLE:
That's a nice one to pick up, for 14 example, because yesterday we heard a presentation on the 15 difficulties with IST as contrasted with the other inspection.
16 What are you doing with in-service testing rather 17 than in-service inspection?
18 MR. COLVIM:
To be quite honest, we have not looked 19 specifically at in-service testing or in-service inspection as 20 it relates to the overall maintenance issue.
1 21 We have a strategy group session on maintenance.
We 22 had it planned for today, but had to cancel it because of the 23 snowfall.
People in Miami didn't want to come to Washington i
24 in the middle of a snowfall, but even the people from New York
(
25 didn't want to come down here.
They were afraid of getting l
i l
HERITAGE REPORTING CORPORATION -- (202)628-4888
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stuck, but we are trying to look at maintenance and integrate
()
2 into that, you know, things like MOV performance, the other 3
issues, what are the issues in there and what can we do or I
4 what should we do as an industry to correct some of those 5
issues?
6 The commitment, I guess we think that the commitment 7
and maintenance to do maintenance like we did training--
8 MR. EBERSOLE:
My impression yesterday was we should 9
write off the code groups or else something is going to march 10 down on top of them?
11 HR. COLVIN:
I really don't have any insights in 12 that.
We will undertake, take a look at that, and be happy to 13 come back at some time and provide you some--
14 MR. MICHELSON:
The one on maintenance, going to 15 deal with MOV performance as well or was it dealing with 16 maintenance as a large generic issue?
17 MR. COLVIN:
First dealing with maintenance as a 18 large generic item, but we have had an initiative under way 19 between NUMARC, INPO, EPRI and ASME on MOV performance which I 20 could describe.
21 HR. MICHELSON:
I would like to hear you describe 22 that if you may or if we have time today hopefully.
We are 23 having a meeting later on in which you could come and describe 24 it since you are only around the corner I guess.
25 MR. COLVIN:
That's right.
We would be happy to do HERITAGE REPORTING CORPORA"ION -- (202)623-4888
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that.
()
2 HR. MICHELSON:
Maybe better just to delay it until 3
we talk about MOV.
4 MR. COLVIN:
Let me give you a thumbnail on MOVs.
I 5
was going to mention that as an example of the type of 6
interaction we have had between the staff.
Vic Stello sent 7
NUMARC a letter back--AEOD report was issued, the last AEOD 8
report, and asked the NUMARC to undertake some initiatives in 9
MOVs, to improve MOV performance.
As a result of that, NUMARC 10 and INPO and the NUMARC working group on maintenance got 11 together with EPRI, and decided that we did need to take some 12 issues.
That report was accurate, and we needed to undertake 13 some of those and make some improvements, so we put together a 14 task force that have, brought toge'.her INPO, EPRI, NUMARC, and 15 ASME and set out an action plan on that.
16 We met with the staff as recently as September 1, 17 described that, those initiatives that we had underway.
We 18 have EPRI, for example, in the development, and it is just 19 about completed, to finding a technical guide for first the 20 SMB trip-out limit, torque operator.
That would include the 21 proper way to set torques, which is in limit switches, and 22 perform diagnostics and that type of information, and this is 23 the first step in a series of operational guides or technical 24 guides that would be published.
25 MR. MICHELSON:
You may want to think about it from HERITAGE REPORTING CORPORATION -- (202)628-4888
244 1
a mo e distant vantage point that we have, there appears at
[ ()
2 least to be a lack of a real coordinated, concentrated effort 3
on the part of industry to, to handle the MOV problem.
There 4
certainly is a lot of efforts underway.
We are aware of a 1
5 fair number of these and have tracked them in some detail, but 6
it appears that they are non-coordinated within the industry, 7
and we were kind of hopefully I guess for a focal point for 8
coordination, and have been unable to find one.
Perhaps we 9
have been dreaming I guess that maybe NUMARC was the focal 10 point., and I am just hopefully thinking you were going to 11 claim that you are the focal point, but I guess you are not in 12 a position to,laim that.
13 MR. COLVIN:
We have as this issue a priority issue, 14 the issue of MOV performance and coordinating that for the 15 industry, so from that standpoint, I would have to answer we 16 are.
17 MR. MICHELSON:
Normally, we normally anticipated 18 seeing what they call working group on the, set up on the part 19 of industry.
Again, we don't see a working group as such, but 20 we do see a lot of efforts, but not seeming to come to be.
21 You might want to think about when we have developed the--
22 HR. COLVIN:
Be happy to come back and show that.
23 MR. MICHELSON:
Maybe by that time you will have a 24 position which indicates how it is being handled.
25 MR. COLVIN:
Yes, sir.
HERITAGE REPORTING CORPORATION -- (202)628-4888 l
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HR. MICHELSON:
It is always nice to work with one h,/
2 party in the industry when possible.
s 3
HR. EBERSOLE:
May I just sort of I think sharpen it 4
up a little bit?
I want to pass on to you a concern we have 5
which I think is a joint concern, and I think I speak for the 6
committee here.
7 We don't believe that the valves are known with 8
sufficient accuracy to be able to operate under duress and 9
emergency conditions, and the statistics that we commonly use 10 in PRAs and so forth only represent valve statistics, 11 operating in the unloaded modes, easily, doing exercises, et 12 cetera, which are then documented as another successful 13 evolution of the valve, which would reflect in no way what it 14 has to do when it is in trouble like when you break a pipe.
15 HR. COLVIN:
Right.
16 HR. EBERSOLE:
Same thing for pumps and run-out and 17 so forth; now I think this presents a standing vulnerability 18 to the industry, and some day we may bust a pipe and we can't 1
19 close it and that could lead to saturation of critical areas 20 with supporting equipment in a most devastating way, and 21 that's, at least that's one of my own personal ccncerns that 22 we haven't covered.
I think it is shared by many.
l 23 DR. REMICK:
I suggest another, Joe, Tom, 24 willingness of NUMARC to come back and talk to the i
l 25 subcommittee, the overview.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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HR. COLVIN:
We would be happy to come and address
()
2 any specific issues or topics with you in a more detailed 3
fashion.
4 MR. EBERSOLE:
This is only an example.
5 HR. COLVIN:
We will get into it as deep as ne can 6
or you would like to certainly.
7 DR. REMICK:
About 17 minutes left, Joe.
8 HR. COLVIN:
What we did was we tried to break the 9
issues out.
When we started with this process, we started 10 with the, with issues that HUMARC was already working on, or 11 issues that AIF was already working on so that that list is 12 not a pure list from the standpoint of this issue just became 13 an issue.
Wo tried to put this through this process and 14 figure where it should fit.
That causes just a little bit of, 15 of confusion, but in actuality what we tried to do is break 16 the issues out into some discrete area.
17 When we actually address the issues, if you look at 18 degree, or let's check valve reliability, maintenance, MOV 19 performance, those are all part of the same overall issues and 20 we would probably address those through a working group and 21 maybe with some type of smaller groups, but as an overall 22 issue.
Degree requirements for operator, operator 23 requalification, professionalism, senior manager on shift, 24 which is on the, actually on the next pace, would all be O
25 worked together.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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1 DR. REMICK:
On those areas of operators that you j
(
2 talk about, who in NUMARC is your lead person?
3 HR. COLVIN:
On those issues, that's Tom Tipton and 4
his division, to deal with the operator issues.
We have 5
another issues working group chaired by-Don Schnell at Union 6
Electric to work principally on the other requalification 7
issue and the interaction with the NRC staff on that.
I think 8
you have been briefed on the pilot progress that is underway?
9 DR. REMICE:
Yes.
10 MR. COLVIN:
And NUMARC played a key role in 11 interacting with the staff in public meetings on that, getting 12 the industry in there to talk about it, and we are now having 13-interactions with the staff as to, with the pilot program that 14 just was completed at Robinson and working through some of 15 those issues.
16 Yes, sir?
17 DR. MARK:
I understand most of the items there, but 18 I,
I am a little bit puzzled by the NRC reorganization as one 19 of your priority issues.
20 Is this own reorganization you are thinking they 21 need, or are you trying to understand the one they just had?
22 MR. COLVIN:
It is even different than that.
It is 23 the NRC reorganizational issues.
This is impacted by the 24 legislation, pending legislation, proposed legislation in 25 Congress dealing with single administrator, Nuclear Oversight HERITAGE REPORTING CORPORATION -- (202)628-4888
248 l
1 Board, et cetera, Inspector General, because one of NUMARC's
(, )
2 roles is to provide the technical input and background to both l
3 ANEC, the American Nuclear Energy Council, to support its 4
activities, as well as to CEA to support its public education 5
and advertising program.
The technical expertise basically 6
rests within NUMARC so that's why it is one of our issues.
We 7
are trying to look at that and provide input to those 8
organizations at their request, and that's why it is on this 9
list.
10 DR. MOELLER:
'Jhat is your position quickly on 10 11 CFR 20 rulemaking?
12 MR. COLVIN:
To be quite honest, I'm not sure that 13 we have a specific position.
We picked that, that issue up as 14 part of the AIF issue to work with the staff and interact on 15 the Part 20 rulemaking, and we still have that as an ongoing 16 activity.
In fact, this list of priorities, this is the 17 original list as a result of the first Issues Management 18 Committee meeting.
We have moved some issues around These 19 issues are really issues that are under the active management 20 of NUMARC or its working groups; 10 CFR 20 rulemaking was 21 moved to the next category down.
We are still very involved 22 and active in it, but it doesn't fit the definition of 23 importance and involvement and the other things that these do.
24 It is not the, in the same framework.
l 25 DR. SHEWMON:
The single phase erosion-corrosion HERITAGE REPORTING CORPORATION -- (202)628-4888
249 l-there is quite dif2erent from 10 CFR 20 rulemaking or
.O 2
somethino.
3 What, is this an awareness thing?
Are you going to 4
talk to EPRI about it or what?
5 MR. COLVIN:
We set up when, this issue occurred 6
when the Surry had the pipe rupture in December of last year.
7 INPo took a key role in that, in the development.
SOER and 8
other technologies, EPRI played a key role in looking at the 9
phenomena, and developing a program to address that, and in 4
10 March we sot up a NUMARC working group chaired by Bill Stewart 4
11 to put together an inspection program for the industry.
The 12 base for that program is the EPRI check code on 13 erosion-corrosion, the code, that computer code to identify 14 the areas you ought to start looking, so we have been working 15 with the industry on that program, and we have, about 48 of 16 the 54 utilities are actively using that, that check program, 17 to identify areas and have that inspection in prograss.
18 All the utilities have some type of inspection in 19 progress on erosion-corrosion, and what we are trying to do is 20 to solve that issue.
EPRI is, has been the key technical 21 resource to NUMARC on, in that area.
22 Let me shift to this, just kind of walk through 1
23 these just to give you a sense.
The monitored issues are i
24 really issues that don't fit the highest level.
They are 25 issues which may be being worked by some other industry HERITAGE REPORTING CORPORATION -- (202)S28-4888
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organization, group, special issue group or activity.
We are
(
2 monitoring, as it says, monitored, we are looking at that very 3
closely and keeping track of it, and we may have a very, a 4
large component of work, but it is not where NUHARC is 5
actively pushing'that issue, managing it, providing somo L
6 guidance or direction or oversight for it.
A lot of these 7.
issues tie back to the other issues.
There are some that have 8
been moved, senior manager on rhift was moved up to the other 9
list to be coordinated with the other operator type issues and i
[
10 work those in an integrated fashion, to just to give you some i
11 sense of that list.
12 (Slide) 13 HR. COhVIN:
We then had the third category which 14 was kind of the, what we called--we had difficulty I have to 15 tell you with the, defining some names that were meaningful 16 even to us--potential or dormant issues.
Not that they are 17 not important, but the work in this is either ongoing, or it 18 is in pregress, or it is being implemented, or it doesn't, it 19 hasn't been elevated up to the, to the level that we ought to
)
20 involve the senior management of the industry in the 21 resolution of that.
i r
22 That doesn't mean that we are not involved in it, 23 that we are not following it, but we do keep tabs on these 4
t 24 issues, just not, we are not spending a tremendous amount of O
25 sources and time on those.
l HERITAGE REPORTING CORPORATION -- (202)628-4888 I
i
251 1
And the last category we entitled other important F' (x q )~
'2 issues, and these are issues which NUMARC does not take the 3
lead role in but which are important to the licensees, and to 4
the: industry as a whole, and are being worked by other, the 5
other people.
What we want the Issues Management Committee to 6
do is to net lose site that these issues are being worked out 7
there, and are important.
8 DOE programs, fuel cycle issues that both EEI and 9
the U.S.
Council for Energy Awareness are warking; fusion, 10 high-level, low-level waste, et cetera, some of those types of 11 issues, so we may play a role in interacting or supporting 12 those organizations, and it involves the Nuclear Regulatory 13 Commission or FEMA, or EPA, even on something that is outside f~sb 14 of NUMARC's direct role in support of the other industry 15 organizations.
16 Now 1 guess one of the things, just to go back to 17 the, to the, let me go to the monitored issue list, really 18 just to describe this, I think that one of the things we did 19 in doing the, *his list, is to look at the issue and not who 20 was working the issue.
We got a lot of people working these 21 issues.
A lot of people, a lot of people are working the same 22 issue out there, whether it is a special interest group or a 23 consultant or organization.
The life extension and license 24 renewal issue is one that we have elevated up to the priority ba 25 list, and are in the process of forming a working group on.
d
.252 l'
. And NUPLEX has an organizational structure which has been,.the 2
nuclear plant life extension program set up by the industry ist 3
a key, central part-to resolution of life extension and 4
' license renewal, but.the Issues Management. Committee felt it-5 was very important to bring a set of policy, bring some policy
~
guidance and leadership to the overall issue.of' life extension 6
7 and license renewal, so we brought that'together under that.
8 The other thing that I think it is important'to.
9 realize related to who is dooing the work is that NUMARC has 10 been given'the task to represent the industry on the generic 11-
. operational technical regulatory issues.
It can only do that 12 on a limited number..
E 13 On the other hand, NUMARC was formed to, to correct, f
14
'one concern in the industry, and that was that there would be.
15 a group of utilities, or consultants or whomever that would I
16 get together,. form a small group, and interact with the NRC or 17 other government agency on behalf of the entire industry, and 18 would do so in a manner that could impact the entire industry, 19 so we have the role of looking at those special issues gr oups '
I 20 and those activities and not being in a directive or control 21 mode to those activities, but the responsibility to identify 22 l'ack to our Board of Directors whether those activities in our 23 opinion, are in the interests of the entire industry, so we 24 have that kind of a role, too, to carry out throughout this 25 process.
. HERITAGE REPORTING CORPORATION -- (202)628-4888
-253 1-And'the whole purpose of that is.to try to integrate
- ~.
~
2 and focus the activities and get everyone'in support of j
i n
'3 overall: initiatives.
4 Let me just mention a couple of. things that since we 5
.just have a couple of. minutes'1 eft related to our interactions' 1
6 with the staff and perhapn'with ACRS.
7 We have had a number of ongoing interactions th' rough 8
the-examples I have mentioned with NRC staff and the 9
Commission both as NUMARC as a committee, and as.a council, 10 and those interactions have taken place in public, and in a 11 very professional manner.
I think those working relationships 12 have been good.
13 There is a current feeling in Congress, and amongst 14 others, that the industry is cozy with the NRC staff, and 15 that's causing some difficulties I think from the standpoint 16 of our coordination and communication with the staff, and we
.17 are working now with EEO office on trying to define a 18 memorandum agreement, protocol as to how we, NUMARC, can 19 interact or how the industry can interact with the NRC in a 20 manner that's in the best interests of the public health and 21 safety, and do so meeting all the federal laws, requirements, 22 Federal Advisory Committee Act if that applies, and so on and 23 so forth, so I want to share with you we have that in progress 24 and we are working those issues out, and I understand the 25 staff is in the process of developing some policy guidance and HERITAGE REPORTING CORPORATION -- (202)628-4888 L_
254 1
internal directives to their members and'out of this hopefully
(_\\)
2 will come a better way that we can interact and not be subject 3
to some of the allegations and criticisms that we have.
4 DR. MARK:
On just that last point you mentioned, I 5
have forgotten the acronym, ANEC or something.
6 MR. COLVIN:
American Nuclear Energy Council-7 DR. MARK:
Are you in touch with them on trying to 8
bring up the level of awareness of some of the maverick 9
congressmen who use this word "coziness"?
10 MR. COLVIN:
Well, I think--the answer to that is 11 obviously yes.
We don't have a direct role in that other than 12 to support ANEC with the proper technical and operational 13 information so that they could carry that out, and in a 14 straightforward manner with those individual members of 15 Congress, and we do that in support of ANEC.
16 We are trying, we are not, certainly not a lobbying 17 organization and don't involve ours except at the request of 18 Congress.
19 DR. MARK:
I realize that, and that is why I 20 wondered how you fed into that discussion.
There is a real 21 need for communication between the NRC and people like 22 yourself.
23 MR. COLVIN:
Yes, sir.
24 DR. MARK:
And it should be understood by the people 25 who obviously don't understand it.
HERITAGE REPORTING CORPORATION -- (202)628-4888
255 1
MR. COLVIN:
ANEC has some initiatives under way in
(_)
2 that area, and we are supporting those.
We have, as NUMARC 3
have appeared before Congress in the, in our short life since 4
really April on four occasions on behalf of the industry, and 5
testifying before Congressional committees, and hopefully 6
through that process, you know, we will be able to get some of 7
that information out, and help that.
8 DR. REMICK:
From time to time various of our 9
subcommittees or the Full Committee, we have an issue that we 10 are considering and sometimes we would like to have some input 11 from people, you know, from the utilities, licensees.
12 Sometimes we don't know who are the appropriate people that r~s 13 might have a program that we want to hear about.
\\-
14 Is NUMARC willing to assist us when we have a need 15 to try to identify people who might come in and address such 16 issues?
17 MR. COLVIN:
Yes, sir, absolutely.
What we have 18 asked, we would appreciate the opportunity to do that on 19 behalf of the industry and support ACRS.
20 We have, really have that role as part of our 21 mission statement for the industry with the Nuclear Regulatory 22 Commission itself.
We have been set up such that if possible, l
l 23 if the NRC staff does not know who in the industry should i
24 undertake that initiative, we have tried to get them to call f-I k_
l 25 us.
It may not be NUMARC, but what we will do is be the l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
266 1
facilitator to find out who that should be, and then put them
<~
(,s).
in contact with one another, so we would be pleased to try to 2
3 fulfill that need to the ACRS.
4 We vould also be pleased, Forrest, to appear before 5
ACRS on any isrues, and provide more in depth information 6
related to our programs and activities, and what we are doing 7
on behalf of'the industry.
8 DR. REMICK:
Dave had--
9 DR. MOELLER:
The Union of Concerned Scientists I 10 gather at the end of 1987 issued a report which in essence is 11 sort of the state of nuclear power in the U.S..
and this 12 committee from time to time has considered the development of rm 13 such a report on a periodic, periodic basis, but without too L.)
14 much success.
15 Do you or any of your subgroups plan or have you 16 ever issued a report on the state of nuclear power, meaning i
17 particularly the state of nuclear power safety?
l 18 MR. COLVIN:
In answer to that, I really don't know l
19 specifically.
I mean I know of some reports and some studies l
20 that have been been issued like that either from AIF--I know l
l 21 that the USCEA has that responsibility and has a report 22 conceptually in progress to deal with that.
I 23 Where that is heading and exactly the scope of that, 24 we got an outline the other day to look at, to provide some 7-)
\\)
l 25 input and comments on, but that's not well defined at this l
HERITAGE REPORTING CORPORATION -- (202)628-4888 L
257 1
point.
That is not something that NUMARC would most likely do
(,)
2 as far as a state of the industry report.
That would fall 3
under the broad forum of communications responsibilities of 4
the Council for Energy Awareness.
5 MR. MICHELSON:
It is not apparent to me that there 6
is any direct connection between INPO and NUMARC.
They are 7
two entirely separate organizations?
8 MR. COLVIN:
Yes, sir.
9 MR. MICHELSON:
If we came to you with a request for 10 something that INPO ought to be supplying, I guess you would 11 tell us to call INPO?
Is that right?
Or coordinate IMPO 12 needs, our needs for INPO through you?
fN 13 The reason I am bringing this up, to be perfectly
()
14 frank, is there have been occasions in the past in which we 15 have asked for INPO assistance in presentations, and I think 16 almost without exception, they have not come to us.
I am 17 thinking particularly in the valve area.
18 If we come to you and told you of our problems but 19 then go to INPO and try to impose upon them to try and provide 20 the guidance, input, so forth, that we might like to have?
21 MR. COLVIN:
Yes, sir.
I think we would give it the 22 old college try, but we don't have any direct--
23 MR. MICHELSON:
The same sponsor in both cases?
The 24 Board of Directors of INPO is the Board of Directors of NUMARC 7gV 25 in many respects.
Some of the same faces I'm sure even appear HERITAGE REPORTING CORPORATION -- (202)628-4888
258
-1 in both1 cases.
(h I
2-
-MR.
COLVIN:
It is interesting that you mentioned 3-
.that.
I was trying.to search back in my memory, having spent 4
the last seven years, nearly seven years at INPO, and.I ' don't' 5
really recall that, that being a problem, but on the other 6
hand, maybe we have got, what we have a problem with is 7-communications and as to what the need is and what the scope 8
of that activity, and INPO may uell'not have been the right 9
organization, and that's, we would be able to try to sort some 10 of that out.
11 DR. REMICK:
INPO has addressed some of the 12 subcommittees and the Full Committee.
13 MR. MICHELSON:
Specifically the details on their
.O, 14 valve program and so forth, they just have not come forth.
15 DR. MOELLER:
What I wanted to say is INPO has come 16 on rad protection and a number of other issues, and been most 17 cooperative with a number of our subcommittees.
18-MR. MICHELSON:
But one--
10 MR. COLVIN:
I an glad to hear that.
That was my 20 feeling also, and on the other hand, there may be occasions 21 where a call to INPO, INPO might not be the right organization 22 to provide th.c information, and we would try to be the 23 facilitator.
24 MR. MICHELSON:
They are the right ones in this 25 case.
HERITAGE REPORTING CORPORATION -- (202)628-4888 k
259 1
MR. WYLIE:
In seeking that type of assistance, r'(_)s 2
would be through your office?
3 MR. COLVIN:
Yes, sir.
I think that certainly we 4
would try.to be responsive, as responsive as possible to that, 5
but I think we, I think it is clear as Dr. Michelson pointed 6
out, we are not directive.
We are independent, and INPO, we 7
have no ability to put pressure on INPO nor any other group or 8
organization, 9
MR. MICHELSON:
Hight be the best way to go is 10 NUMARC because they can tell you at least who to call if they 11 really didn't want to get involved themselves.
Maybe we just 12 didn't get the right people.
~3 13 DR. REMI/,K :
Our time is up.
I want to--on behalf k_/
14 of the Committee, Joe, and Tom, we appreciate your coming in 1
15 on this snowy morning, and being with us.
16 MR. COLVIN:
We enjoyed it.
17 DR. REMICK:
We greatly appreciate it.
You gave us 18 some valuable information.
19 Mr. Chairman, I turn it back over to you.
20 CHAIRMAN KERR:
Fifteen-minute break.
21 (A brief recess was taken.)
22 CHAIRMAN KERR:
The renewal of nuclear power plant 23 licensees, Mr. Wylie is the cognizant subcommittee chairman, 24 MR. WYLIE:
Thank you, Mr. Chairman.
The fs 25 information on this portion of our meeting is at Tab 9, and as I
HERITAGE REPORTING CORPORATION -- (202)628-4888
~.
$N i
'260-1-
the Chairman mentioned, this concerns the NRC-staff-program
()
2 for the development of policy for nuclear power-plant 11 cense 3
-3 renewal.
4 ACRS was briefed by the staff on June the'Sth of 5
last year on this subject, and today we will be briefed by the 6
staff.again on the current status of this work, so I.will turn
- 7 that over to Mr. Cleary,-who will present, make the 8
presentation.
9 HR. CLEARY:
Thank you.
The presentation this 10 morning will be split in two parts.
I will,make the first 11 part of the presentation.
I-am Don Cleary, the task manager.
~
12 for license renewal policy development.
The second_part of-13 the presentation will be made by Shivaji Seth, from the Mitre 14
-Corporation, who is our prime contractor for providing t
15 assistance in our efforts.
16 (Slide) 17
.MR.
CLEARY:
This morning, I would like to cover
~
18 several items.
One is review schedule considerations.
We i
19 will be looking for ACRS review at several points.
Our work l
l 20 schedule for the next six or so months is very tight.
I will l
L 21 go over the schedule in just a moment.
I want to provide an t-22 overview of a report which has been prepared by the Mitre 23 Corporation working very closely with the NRC staff, and I l
24 will provide an overview of a number of procedural issues, l'
l 25-procedural / legal issues that we are working on.
HERITAGE REPORTING CORPORATION ---(202)628-4888
261 1
Then Mr. Seth will provide a discussion of the
(_)
2 technical issues which are presented in the Mitre report.
3 (Slide) 4 MR. CLEARY:
The objectives that I would like to
-5 accomplish this morning are to provide a briefing to you on 6
regulatory options for license renewal.
The report I have 7
referred to is titled regulatory considerations of technical 8
issues pertaining to nuclear plant license renewal.
9 Another objective is to solicit your comments on 10 that report.
The report, we are working on a Commission paper 11 at the moment that is under review within Research, and I 12 anticipate that within the next two or three weeks, the 13 Commission paper, and the report is an enclosure to that, will
(-V) 14 be available to you, and we will send it to you concurrently 15 with transmittal to the Commission.
16 CHAIRMAN KERR:
Let me see.
The report is titled 17 regulatory consideration of technical issues.
Is Mitre 18 working on the regulatory consideration primarily or on the 19 technical.4.ssues primarily?
20 MR. CLEARY:
Mitre is providing broad-based 21 as3istance to us.
We have, there are a number of staff people 22 from various offices that have provided input, discussion, and 23 review of Mitre documents.
We have had a number of workshops 24 with NRC staff.
Mitre is putting that report together.
The s
I 25 heart of the report really is the technical considerations 1
i HERITAGE REPORTING CORPORATION -- (202)628-4888
262 1
that would ultimately-lead to an approach toward reviewing
<-(_)x 2
information requirements and review procedures for license 3
renewal.
4 CHAIRMAN KERR:
I was trying to find out whether you 5
are asking Mitre to define the policy or whether you have 6
defined the policy and are now going to work out the details 7
or what?
What is it that you are asking Mitre to do?
8 MR. CLEARY:
Mitre is providing technical assistance 9
to us.
The way the program is organized is that the policy 10 decisions and analysis of Mitre work will be done within the 11 staff, various review groups, interoffice review groups, sc 12 Mitre will be doing the technical analysis and collecting e.ll rs 13 of the information, and working with the staff to assist the L) 14 staff in making policy decisions.
15 CHAIRMAN KERR:
If one wanted to find out what the 16 policy is, what report would one look at to determine that in I
17 contrast to the report referred to here?
l 18 MR. CLEARY:
The policy has not yet been developed, l
19 and that, I'll clearly explain where the policy statement 20 comes in when I get to the schedule.
21 CHAIRMAN KERR:
Mitre is developing this before the l
l 22 policy has been defined?
i 23 MR. CLEARY:
That is correct.
Mitre, we have gone I
l l
24 through a process of issue identification, looking at some of i
x 25 the options that, difference approaches that might be taken in l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
l 263 1
terms.of information usage, analytical methods, and that's the
)
2 point that this report is at, and we are trying to get 3
feedback on the report before we proceed with the actual 4
development of the policy.
5 If I may move on, I think that will become clear.
6 CHAIRMAN KERR:
I hope so.
7 DR. LEWIS:
In the interest of helping the Chairman 8
understand, if you look at vugraph No.
2, Mitre's 9
presentation, it explains the approach for policy development 10 which Mitre has to do, and it says identify issues, identify 11 options, evaluate options, integrate into policy, which I hope 12 tells you a great deal.
13 CHAIRMAN KERR:
Thank you.
Please, Mr. Cleary.
14 MR. CLEARY:
Thank you.
And the third objective is 15 to alert you to the fact that we are working on a tight 16 schedule and that we do need to set up some coordination 17 mechanisms sa that we can get appropriate ACRS review at appropriatestagesinthedfvelopment of policy.
18
/
19 MR. MINNERS:
Mr. Chairman, Mitre is a non-profit 20 organization, so in relation to your question about policy, 21 they are a little different than your run-of-the-mill 23 contractor, so I just want to put that in perspective.
23 DR. SHEWMON:
Like Brookhaven Lab is the run-of-the 24 mill contractor?
25 MR. MINNERS:
They all have their own separate HERITAGE REPORTING CORPORATION -- (202)628-4888
264 1
characteristics.
I didn't know Mitre is a non-profit
{ )
2 corporation.
3 CHAIRMAN KERR:
I was just curious.
4 MR. MINNERS:
I didn't know Brookhaven was 5
non-profit.
6 CHAIRMAN KERR:
Curious as to how the policy is 7
being set.
I gather it hasn't been developed yet.
8 MR. MINNERS:
There is going to be interim policy 9
action here because technical issues are going to affect 10 policy as well as the policy affect the technical issues.
11 DR. LEWIS:
The Mitre representative here is not 12 unfamiliar with this.
13 MR. CLEARY:
I would like briefly to go over the V, T 14 major milestones of the program.
15 On November 6th of 1986, we published a Federal 16 Register notice requesting comments on various issues that had 17 been identified.
We received the comments, and they have been 18 taken into consideration, and we are still working with th7m.
19 On July 21st of last year, we sent a paper to the 20 Commission which contained very much the same information that 21 we provided to you in the June briefing, and that covered the 22 status of our activities on license renewal policy, and 23 reported on the public comments.
At the moment, we are g-24 developing a Commission paper or have developed a Commission
(..)g f
25 paper which is under review, and will be sent to you, as I HERITAGE REPORTING CORPORATION -- (202)628-4888
265 1
said before, within the next two or three weeks.
This paper
/~N
's_)
2 requests the approval from the Commission to notice the Mitre 3
report which will be published as a NUREG CR as available for 4
public comment.
We intend to have a public meeting two weeks 5
after the close of the comment period where we would' summarize 6
the responses, provide initial evaluation, and provide an 7
opportunity for some dialogue.
8 Major objective is to get to the Commission by the 9
end of September, this coming September, a proposed policy.
10 The next slide shows the interim schedules, and I will give 11 you some indication of how we are going to go about this.
12 We anticipate issuing the final license renewal 13 policy about September of
'89, and about the same time, issue 14 proposed regulations for public comments, and then hopefully l
15 about 1991 or
'92, these will be in the possession to be 16 issued as final regulations.
17 Concurrent with all of this activity, there is 18 activity that has started and will accelerate on developing 19 regulatory guides and standard review plans to provide an 20 adequate basis for development of license renewal applications 21 and the staff review of those applications.
22 Near-term schedale for the next six or seven months, 23 I mentioned the Commission paper which will be sent to you.
24 (Slide) 25 MR. CLEARY:
We will notice the Mitre report in the HERITAGE REPORTING CORPORATION -- (202)628-4888 J
~
266 1
Federal Register, and the public meeting which will happen two
,3
(..)
2 weeks after the close of the comment period.
We anticipate, 1
3 we anticipate having a draft proposed license renewal policy 4
developed by the first of July for in-house review.
We have.a 5
very ambitious work program-over the, through July, through 6
the summer.
We have the involvement of major offices in NRC.
7 For example, OGC has one lawyer working a high percentage of 8
his time on this, and several other lawyers providing 9
assistance to him, who are coordinating very closely with NRR 10 and with AEOD and within the various divisions in Research, 11 for example, the aging research program.
12 We hope to have the proposed policy to the 13 Commission by the end of September, and have it noticed in the 14 Federal Register by the end of the calendar year.
15 (Slide) 16 MR. CLEARY:
I have already made these points.
We 17 need --
18 (There was a brief pause in the proceedings.)
19 MR. CLEARY:
I have already made the points on this 20 slide I believe.
We need in addition to all of the technical 21 staff work, staff reviews, we need review by CRGR and ACRS'.
22 We are working under a tight schedule.
We will need to, in 23 the very near future, set up a schedule for interaction with 24 ACRS.
j 3
i 25 MR. WYLIE:
Our first comments that you are seeking 1
l i
i i
HERITAGE REPORTING CORPORATION -- (202)628-4888 I
267 1
is during the public comment period after issuance of the
()
2 paper, is that correct?
3 MR. CLEARY:
Basically, yes.
We, of course, would 4
be happy to receive your comments at the earliest convenience 5
of yours.
6 (Slide) 7 HR. CLEARY:
Shiv will go over, summarize the 8
process that Mitre followed in coming to this particular 9
report.
It represents a series of working documents which 10 were developed through intensive discussions with various 11 members of the staff.
We had two working sessions.
Each of 12 the drafts were thoroughly reviewed by NRR and by various 13 divisions within Research, AEOD, and OGC.
(-
14 The report has three major sections in it--technical 15 issues and options, which Shiv Seth will talk about, framework 16 for technical information requirements, which he will Elso 17 cover, and procedural issues pertaining to license renewal, 18 and I will briefly cover the procedural issues.
19 (Slide) 20 MR. CLEARY:
The, we have been careful to have the 21 report take no positions or make any recommendations.
What we 22 are attempting to do is to provide a statement of the scope of 23 our thinking, the scope of the options as we see them, and to 24 get feedback, public, industry reaction on that.
25 Also we are not taking positions or making HERITAGE REPORTING CORPORATION -- (202)628-4888
268 l'
1 recommendations because there is still a tremendous amount of
,n.
(_);
2 analysis going underway.
We need to further specify and 3
evaluate.the technical approach that would be required to 4
license renewal evaluation, and also there is a whole host of 5
legal questions that are under review.
6 (Slide) 7 HR. CLEARY:
Our intent in making this report 8
available for public comment, comment from the public, other 9
government agencies, industry, is to get their comments on the 10 scope of the issues and the options that have been identified 11 at this point, any information they have on the relative 12 merits of each of the options, and anything else on related eg 13 matters that they want to furnish, b
14 The Federal Register notice says very explicitly 15 that we have comments available from the previous requests for 16 public comments, and that they have been factored into our 17 analysis and will be, we will continue to evaluate them so 18 they don't need to duplicate comments that were already 19 furnished.
20 (Slide) 21 MR. CLEARY:
There are a number of procedural issues 22 that have been identified and grouped in various ways.
This 23 is a list of twelve procedural issues that I would like to 24 cover with you.
25 One of the issues is the form of the license HERITAGE REPORTING CORPORATION -- (202)628-4888
269 1
renewal.
There is a question as to whether in terms of the r()
2 exact legal definition and in terms of the procedural 3
implications of the legal definition, whether we have a new 4
license, is it a renewed license?
Is it essentially an 5
amendment to an existing license?
And OGC is looking very 6
carefully at these questions, so that we can in discussions 7
with them, can set the procedural or the guidance for 8
development of the procedural approach to license renewal 9
reviews.
10 The length of the renewal term, there seems to be a 11 general feeling that renewal term could go up to an additional 12 40 years, but ehis is also under study.
Industry has asked
(~g 13 for flexibility in the renewal term.
Ultimately, the renewal V
14 term or provisions for renewal term will have to be justified 15 on the basis of the, of technical safety considerations, and 16 we hope to make considerable progress during the next six or 17 so months so that this will be fully air 9d in the policy 18 statement or material supporting the policy statement provided 19 to the Commission in September.
20 CHAIRMAN KERR:
How far along have you got in 21 defining the technical safety considerations?
22 MR. CLEARY:
That is basically the essence of the 23 presentation that Shiv Ceth will be giving.
That will be 24 revealed and discuss it at that point.
25 The latest date for renewal application, 10 CFR now HERITAGE REPORTING CORPORATION -- (202)628-4888
270 1
specifies that 30 days, an application should be submitted 30
.( )
2 days prior to expiration.
There is the obvious consideration 3
that it is going to take time to renew an application, and 4
this 2.102 will obviously have to be modified.
The 5
determination, though, will come after we have pretty much 6
scoped out what the review process will be, and working with 7
NRR looking at schedule implications.
8 MR. WYLIE:
That seems like an awfully short time 9
for all the work that has got to be done.
10 MR. CLEARY:
The next six months?
11 MR. WYLIE:
I am talking about the 30 days prior to 12 expiration.
rs 13 MR. CLEARY:
It is not tenable.
d 14 MR. WYLIE:
Totally unrealistic.
15 MR. CLEARY:
It is not tenable, that's right.
16 DR. MOELLER:
Would you say that one again?
In 17 other words, this is for renewal, so they have a license and 18 they must submit the renewal 30 days before the expiration of 19 the existing?
20 MR. CLEARY:
That's a general requirement for any 21 NRC license.
Obviously there wasn't consideration given 22 specifically to nuclear power reactors and the review time 23 required when that blanket licensing requirement was put in 10 24 CFR.
25 DR. MOELLER:
So when you were talking about and l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
271 1
Charlie was talking about the short time, you meant for the
('\\
\\,)
2 NRC to review it?
The licensee knows years ahead that--
3 MR. WYLIE:
Oh, sure.
But I mean that obviously 4
they are not going to do that.
5 MR. CLEARY:
No.
It is obvious it is going to be 6
somewhere in the neighborhood of a year or two years.
7 MR. WYLIE:
At least.
8 DR. REMICK:
That has been a general requirement for 9
all NRC operator licenses, by-product, material, you got them 10 within 30 days, they didn't lapse, or got them in at least 30 11 days of termination and so on.
I know it has been like this.
12 MR. CLEARY:
And under existing regulations, as long 13 as they get it in within 30 days and we are reviewing the 14 license, they can continue to operate, so, for example, if it 15 did take us two years to review a license, they would be 16 operating essentially two years beyond.
17 MR. WYLIE:
They just automatically get a two-year 18 extension.
19 MR. CLEARY:
That is correct, and of course, that's 20 not a good situation from a policy perspective.
2:
The earliest date for renewal applications, there is 22 obviously a planning requirement that industry has.
We are 23 told that, by industry, that they should know ten to twelve t
24 years ahead of the expiration of a license as to whether they
(
25 are going to be allowed to continue to operate, so that they l
HERITAGE REPORTING CORPORATION -- (202)628-4888
272 i
1 can develop alternative capacity if they are not allowed.
i
(_)
2 This, of course, has considerable implications in terms of the 3
informational basis that's available on the plant is 12, 13, 4
14 years prior to expiration of the license.
5 There are considerations for provisions, whether you 6
give a provisional okay and require that certain things be 7
done before final license is granted.
There is some backfit S
rule implications.
If a utility comes in early as opposed to 9
later, does that have, does the extended life then become a 10 consideration in backfit calculations?
If so, how can 11 utilities, individual plants, be treated equitably?
12 Then, of course, there is case load implications.
(~)
13 The more flexibility that we give industry, the higher the v
14 probability that we are going to get a bunching of 15 applications with accompanying consequence of delays, 16 potential delays.
That's something that has to be looked at 17 carefully.
18 The effective date of renewal, industry has proposed i
19 two basic alternatives--a tack-on which is that approval would i
(
20 be given for a license commencing on the expiration of the 21 current license.
The supersession is that when approval for a 22 license is given, it supersedes at that time the existing I
l 23 license, and there, of course, are legal and procedural 24 implications for both of these alternatives that we are l
25 looking at.
l l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
273 I
1 Use of the backfit rule, I mentioned that there is a
(,) -
2 consideration of the applicability of the backfit rule to 3
requirements which may be imposed in license renewal, and 4
there is consideration of renewed term in backfit requirements 5
which are undertaken under the current license.
6 Environmental reviews, it has some technical 7
considerations.
We put it under procedural just as a 8
convenience.
9 (Slide) 10 MR. CLEARY:
We have given some consideration to 11 this.
We are having discussions with the people that are 12 still left in the agency that have had considerable experience 13 over the years under, working under NEPA, and there seems to r3 V
14 be a, a general consensus that there is going to have to be
/
15 some sort of an environmental analysis, either an EIS or an EA 16 done for each of the license actions, license renewal actions.-
17 Exactly what will have to be done will be determined by a 18 scoping study which will likely be termed the generic 19 Environmental Impact Str.tement to determine the extent of 20 potential environmental impacts from re-licensing individual 21 plants and an obvious and basic question is, is there anything 22 new?
23 If we find that there are some new things, then it 24 may be difficult to justify an EA.
If we find that there is l
25 not expected to be anything new, then maybe it would be easier l
HERITAGE REPORTING CORPORATION -- (202)628-4888 i
l 274.
'1' to justify.an EA, but we-are gearing up to do'a scoping study,.
I
)
2 and eventually a generic Environmental Impact Statement.
'3 The public hearings--this is basically.a legal 4
issue, but it looks as if_that there is, we have to give an 5
. opportunity for a hearing in a license renewal action.
The 6
questions then become the timing of the hearing.
Is it a 7
hearing before license renewal decision is made or is it going 8
to be a hearing after a license renewal decision is made?
9 CHAIRMAN KERR:
When you say it is a legal' issue, 10 you are referring to NRC regulations?
11 MR. CLEARY:
NRC regulations, and the, the Atomic 12 Energy Act, and Administrative Procedures Act, and the scope 13 of the litigationRis to a considerable extent, a set of 14 technical questions will have to be resolved technically, and 15 we hope that by September, we will have some positions on, on 16 the nature of the hearings and the scope, general scope of the 17 hearings.
18 MR. WYLIE:
What does section 18 specifically say 19 that leads you to believe that you have to have public 20 hearings?
l 21 MR. CLEARY:
I believe that that's for construction, L
22 I am not exactly sure, for construction permit and operating I
23 license, you have to give the opportunity for a hearing.
24_
Under our regulations, hearing is, you have a hearing for a 25 construction permit, and the opportunity for a hearing under HERITAGE REPORTING CORPORATION -- (202)628-4888 L
275 1
the operating license.
()
2 MR. WYLIE:
You basically are saying this is a new 3
plant, you have got to go through the same process, is that 4
it?
5 MR. CLEARY:
Yes.
And it goes back to the nature of 6
the license itself.
If it is considered within a legal 7
perspective, a new license, then under our regulations, 8
hearing may be required.
9 MR. WYLIE:
Depends on how you rule as to whether it 10 is an extension of an existing license or new license?
11 MR. CLEARY:
Yes.
12 CHAIRMAN KERR:
What was determined, do you have a fS 13 choice as to which you decide, or is that left up to the
'\\_.)
14 lawyers?
15 MR. CLEARY:
Well, we need to get a clear analysis 16 first from the lawyers, and then as in so many things, 17 sometimes that analysis is not, conclusions are not crystal 18 clear, so then it becomes a policy issue.
19 CHAIRMAN KERR:
You certainly have precedent already 20 for extending or for renewing reactor licenses.
May not have 21 very much precedent for renewing power reactor licenses, but--
22 DR. REMICK:
You did decide in those cases that a 23 hearing would be noticed, those extensions in the past?
24 MR. WYLIE:
That what?
25 DR. REMICK:
That the Agency has decided that a HERITAGE REPORTING CORPORATION -- (202)628-4888
276 1
hearing, an opportunity for a hearing is required for renewal I,
2 of non-power reactor licenses, they have that precedent.
.I 3
think that's what you referred to?
4 HR. CLEARY:
Yes.
It will be extremely difficult to 5
get away from at least having the opportunity for a hearing.
6 Under emergency planning, the basic question is 7
whether existing requirements are adequate to continue into 8
the extended license period, or the renewed license period.
9 There probably won't--at this point in time, we haven't seen 10 any major problems or pitfalls in this area.
It looks like it 11 will, the ultimate position will be pretty straightforward and 12 perhaps a determination that at least most of the existing 13 requirements are adequate.
14 DR. MOELLER:
Down through the years, through your 15 drills and so forth, you have pretty much upgraded everybody's 16 emergency capability to a common level?
17 MR. CLEARY:
That's right.
Periodic requirements 18 for on-site, periodic requirements for off-site, for state and 19 local participation, the evaluation, continual upgrading of f
20 the plants, keeping of current information.
21 (Slide) 22 MR. CLEARY:
Decommissioning is another issue; 10 23 CFR does have a requirement in it for financial information to 24 be furnished in renewal applications.
The, probably the major 25 issue here is the requirement that a decommissioning plan be HERITAGE REPORTING CORPORATION -- (202)628-4888
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submitted a year prior to the expiration of the license.
f'T
(_/
2 Obviously it would, or it may well not be worthwhile to have a 3
utility go through the expense of developing and submitting a 4'
decommissioning plan at the same time that we are entertaining 5
an extension, renewal of the license.
6 Antitrust is basically a legal determination. but at 7
the moment it looks like a full review is not required for a 8
license renewal, but the people in NRR who have been, who are 9
responsible for antitrust reviews feel that, recommend that it 10 would be prudent to at least notice in the Federal Register 11 that a license renewal application is being entertained and 12 that if anybody has information that or concerns about the 13 antitrust situation at that particular plant, that they should f-]
(/
14 notify NRC staff.
15 Price-Anderson Act coverage, that's still being 16 looked at, but at this point in time, it looks as if coverages 17 would continue during the renewed license term.
18 That completes my portion of the presentation.
If 19 you have any questions, or maybe we will move on and come 20 back.
21 CHAIRMAN KERR:
Is there some probability that NRC 22 will decide not to renew licenses?
23 MR. CLEARY:
As a general policy, I don't, I don't 24 see that.
I think the--
25 HR. MINNERS:
Not renew any license, or some?
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CHAIRMAN KERR:
Power reactor licenses, q
- (,/
2 MR. CLEARY:
Just make the blanket policy that we 3
will not entertain?
4 CHAIRMAN KERR:
I say is that, in your thinking, is
~
5' that a possibility?
6 MR. MINNERS:
I think on technical terms, that's a 7
possibility.
8 MR. CLEARY:
Wa made, in the paper that we submitted 9
to the Commission on July 21st, we stated clearly that we were 10 assuming that there would be license renewal provisions 11 developed.
As Warren says, those provisions may be so 12 stringent that there is de facto policy of no license renewal, g3 13 but we are, we are proceeding to attempt to develop a policy V
l 14 and guidelines.
15 CHAIRMAN KERR:
Thank you.
16 MR. EBERSOLE:
Wasn't that the case in Humboldt Bay, 17 for instance?
18 MR. CLEARY:
Rilative to?
19 MR. EBERSOLE:
Shutdown.
l 20 MR. MINNERS:
I think that is correct.
I think 21 those people decided that they were under hazard, that they 22 would have to make backfitting changes which weren't worth it 23 which would be analogous to maybe not knowing what we put out.
24 MR. EBERSOLE:
Even without those being actually l
l
%)
25 specified in detail?
l l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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,N i
l 1
MR. MINNERS:
Yes.
/'
i i,T s/
2 MR. WYLIE:
That wasn't a license renewal, was it?
3 MR. EBERSOLE:
I don't know.
Well, how old--I don't 4
know whether it was.
5 MR. WYLIE:
I mean it was just a backfit that they 6
faced that they said wasn't work worth it?
7 MR. EDERSOLE:
In ess9nce, that's it.
8 CHAIRMAN KERR:
Further questions?
Thark you, Mr.
^
9 Cleary.
10 MR. CLEARY:
Thank you.
Mr. Seth?
11 MR. SETH:
Good morning, everyone It was a little 12 difficult to get here.
I am surely very nappy to be here, and r
il to see so maisy of you with whom I worked before, arid it is
-(
14 certainly worth it.
15 (Slide) 16 MR. SETH:
My name is Shiv Seth, and I am with the 17 Mitre Corporation.
18 MR. WARD:
Which is a ncn-profit corporation we 19 understand.
20 MR. SETH:
Well, let me--
21 DR. STEINDLER:
It is like Brookhaven!
22 MR. MINNERS:
A highly qualified non-profit 23 organization!
24 MR. SETH:
In response to some of the questions that 3
%_)
25 were csked, I think I would like to mention that Mitre is j
i HERITAGE REPORTING CORPORAT1;N -- (202)628-4888
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providing technical support and assistance to the NRC.
Any O
(_j 2
policy decisions are made by the NRC.
They collect 3
information, analyze information, provida iaeas, and 4
alternatives.
The NRC will ds;ide what ideas to pursue 5
- further, 6
Here is what I would like to present, a brief recap, 7
just what Don introduced by way of policy approach.
8 Very briefly, the public perspectives that we got 9
from the public comment was in fact our starting point, so I 10 want to touch on that.
11 I understand that public comments were discussed in 12 an earlier briefing to the ACRS.
13 Then how we have categorized these issues; then a 14 discussion of the technical issues and options, and finally, 15 essentially a framework, a very nreliminary attempt to 16 organize the kind of technical information that we think might 17 be included in a license renewal application.
It is meant i
18 only as a, only to provide assistance in furt-her evaluation 19 and discussion that is likely to take place in the policy 20 development process.
21 (Slide) 22 HR. SETH:
The process began with NRC's issuance of 23 the Federal Register notice inviting comments, and that 24 process itself was very helpful in trying to understand the 25 issues, identify the issues, characterize those issues, and l
HERITAGE REPORTING CORPORATION -- (202)628-4888
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categorize those issues.
We have taken the issues end 4
()
2 identified certain options.
As Don mentioned, they will be 3
put out for public comment, further evaluated using those 4
public comments, and then integrated into a draft policy, and 5
here again I.might say this is HRC's schedule, and I guess a 6
point was made earlier that this explains what Mitre is doing, t
7 That's right, but it is, it is the NRC's process, and Mitre is 8
providing assistance in this process.
9 The NRC, if you might recall, submitted something 10 like 21 questions for public comment.
They range from 11 appropriateness of the policy development at this time, the 12 timing issues, procedural issues, questions, also technical, f-13 and I have just paraphrased some of the questions that i
14 related--I'm sorry.
I paraphrased all the questions that 15 relate to plant safety.
These are the sort of technical 16 questions.
I present them because they are representative of 17 the technical concerns related to license renewal policy 18 development.
19 The first question is snether the plant should be 20 required to demonstrate conformance to current regulations as 21 far as the license base is concerned, i
22 Second one relating to bow operating history and the 23 PRA might be utili?ed. and then the remaining questions are 24 even more specific, and they express the concerns related to 25 the aging of the plants, so they range from being very broad HERITAGE REPORTING CORPORATION (202)628-4888 s
~
282 1
down to some specific concerns which invite almost~
f) 2 plant-specific answers, and we have categorized and grouped 3
these. issues, and I will get to that, but just before that, I 4
would like to' summarize the kind of perspectives we got.
5 (Slide) 6 MR. SETH:
Very briefly--
7 DR. SHEWMON:
One that is not on there is are we 8
talking about a ten-year or 40-year or will that come later?
9 MR. SETH:
The renewal term, the timing issues, I am 10 not, I think these are plant safety issues and I think the 11 answers to these would probably drive these other timing 12 issues as well as procedural issues.
We look upon the 13 procedural issues as providing the vehicle, but these 14 technical issues as really addressing the technical and safety 15 concerns.
16 DR. SHEWMON:
Fine.
17 MR. SETH:
Okay.
The industry response constituted 18 75 percent, but essentially all the utilities essentially 19 endorsed the NUPLEX viewpoint, and you heard in an earlier 20 presentation that NUPLEX has played a key role in developing 21 positions on license renewal and life extension.
The industry 22 view was that there is an improved licensing basis and in fact i
23 on the date of license expiring, and that licensing basis, 24 that approval licensing basis which is NRC's standard for
(
25 judging safety should be used for the renewal term, that only HERITAGE REPORTING CORPORATION -- (202)628-4888
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safety significant items which are subjected to age-related
.O
(,/;
2 degradation and not part of normal replacements and c
3 maintenance activities be reviewed by the NRC.
4 CHAIRMAN KERR:
In your view, did the industry give 5
a rational basis for its recommendation thst one use the 6
licensing basis already in effect?
7 HR. SETH:
I think there are parts to which, that 8
normal maintenance and replacement activities, there is more 9
justification on that, saying that these components are 10 already replaced.
The NRC already has various programs to 11 review utility programs, and that they should not be reviewed 12 again.
13 As far as safety significance, in my opinion, there 14 wasn't a very clear-cut methodology laid out, although it was 15 decided pilot studies which have been carried out and studied 16 at Monticello--
17 CHAIRMAN KERR:
I'm referring to the first bullet.
l 18 Maybe I don't understand what is meant.
19 MR. SETH:
I was on the second one.
(
20 CHAIRMAN KERR:
I thought so.
Maybe I'm not sure 21 what is meant by use the licensing basis already in effect.
I i
22 thought that probably meant the license requirements at the j
23 time the plant was originally licensed.
Is that what is meant i
by that bullet?
25 MR. SETH:
That's right, but it could be amended.
l t
t HERITAGE REPORTING CORPORATION -- (202)628-4888
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CHAIRMAN KERR:
My question is did the industry p\\)
2 comments give-a rational basis for that recommendation, or was 3
it just a recommendation that said we think you ought to do 4
this?
5 MR. SETH:
The rationale was that the NRC 6
continually has programs which review the safety.and the 7
design basis of the plants, and in fact, that the licensing 8
design basis, for example, which exists at the time of license 9
expiring, is in a way approved by the NRC.
The very fact that 10 the plant has been operating for 40 years, and there is an 11 approved licensing basis for that plant to operate at the last 12 day of the 40-year term, that should, that basically should be 13 all right for renewal.
14 CHAIRMAN KERR:
Was an argument of this sort given?
15 MR. SETH:
Excuse me?
16 CHAIRMAN KERR:
I say there was an argument of this 17 kind given in the comments?
18 MR. SETH:
Yes.
19 CHAIRMAN KERR:
Thank you.
20 MR. SETH:
But I would like to come back to this 21 issue once we get part of this, and this is one of our, one of 22 the issues that we regard as one of the technical issues, so I 23 will come back to it.
24 DR. MOELLER:
What about the fourth bullet under 25 industry?
What was their argument there?
HERITAGE REPORTING CORPORATION -- (202)628-4888
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MR. SETH:
The argument there was that codes and A)
(_
2 standards were being updated.
Just because the plants were 3
getting older, that their aging had to be addressed, and these 4
efforts are' going on anyway, and so--
5 DR. MOELLER:
Then if they are being done, then you 6
could tie them to renewal without any problem.
I don't 4
7 understand their argument.
8 MR. MINNERS:
He means uniquely; only because of 9
renewal.
That was the question--only because of renewal.
10 MR. SETH:
These activities are needed as plant is 11 getting older.
Starting from day one, and as it gets older, 12 they need to keep a watch on the codes and standards and r~g 13 revise them as necessary.
I guess that's the argument that NJ 14 was made.
15 The non-industry view was rather limited, and one, 16 essentially there was one, two public interest groups that 17 provided answers, and one of them really comprehensively.
18 They emphasize that the entire plant be reviewed, 19 not just safety-related equipment.
20 MR. EBERSOLE:
Would you explain that fourth bullet 21 to me?
I didn't get it through my thick head.
I sort of see 22 it in reverse, that is, renewals should not be tied to 23 revisions in codes and standards, or am I wrong?
24 MR. SETH:
Yes.
You probably are expressing better, 25 it better that way.
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MR. EBERSOLE:
You are not going to let them dig (Q_)
2 into extending codes and standards that might justify renewal?
3 MR. SETH:
You would not--
4 MR. EBERSOLE:
Or expect that as a basis?
5 MR. SETH:
You would not have complete revisions to 6
codes and standards, for example, 7
DR. SHEWMON:
The codes and standards are revised-8 every year or two, and when you grant a license, it says 9
inspection will be done as per the license that year.
Forty 10 years later the codes and standards, especially in things like 11 Section 11, have changed a lot.
At least one example of this 12 could be okay, what part of Section 11?
Or you are going back 13 to your interim testing, is it going to do circa 1960 or does l
14 it have to be 1990?
15 MR. EBERSOLE:
Yes.
16 MR. MINNERS:
But we, the NRC looked to all of those 17 things supposedly, and said hey, should this be backfit on 18 plants?
And I guess the argument can be illustrated by saying l
19 hey, it was good enough for the plant to operate in the 39th 20 year, why or why aren't those codes and standards that we l
l 21 backfit or didn't backfit good enough for the plant in the l
22 dist year?
l f
23 DR. SHEWHON:
One of the things--
i 24 MR. WARD:
The 4ist year isn't necessarily the 25 question.
The 61st, yes, and 71st year may be the question.
1 HERITAGE REPORTING CORPORATION -- (202)628-4888
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MR. MINNERS:
Then in the 60th year we will have to je-).
(_
2 decide whether we should backfit the new codes and standards, 3
so to continue operation in the 61st year.
4 MR. WARD:
The license renewal is only going to be 5
for a short time?
6 DR. SHEWHON:
Don't know yet.
7 MR. MINNERS:
I agree with you.
We would have to 8
look--maybe in our backfitting we are not looking far enough 9
ahead.
That's not Noximotto.
Right now we just look at 10 plants operating up to the 40th year.
And that was one of the 11 questions.
Maybe the backfitting implications are we ought to 12 be looking at hey, what would happen in the 60th year?
Would 13 it be appropriate to backfit this plant because it might 14 operate for 60 years instead of 40?
15 MR. KNIEL:
General rationale for this is we are 16 backfitting things, we are making changes when they are 17 required for safety.
There is nothing unique, as was pointed 18 out, about the license renewal that requires you to do 19 sonething different at tha': stage.
We just continue doing the l
j 20 same thing.
21 HR. WARD:
But your perspective changes if you l
22 anticipate the plant is only going to run for ten more years, i
l 23 50 more years.
24 DR. MARK:
When you do the cost / benefit, you take 1
25 account of the fact that the plant only has got ten years to 1
l l
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go?
()
2 MR. MINNERS:
That's what we have done.
3 DR. MARK:
Suddenly have to say it has got 50 years 4
to go.
5 MR. MINNERS:
Also the technical analysis might be 6
different if you thought the plant was only going to run ten 7
years versus run another 20 or 30.
8 DR. SHEWMON:
One of the things that doesn't come 9
through here at all is something like the SEP approach where 10 you say okay, what is the risk to this plant?
What are the 11 items?
12 HR. MINNERS:
It will come through.
13 MR. SETH:
I think two pages down they did say the 14 plants be updated to current requirements, that the 15 performance history be evaluated very comprehensively, and 16 that perhaps further aging research was needed, and in fact 17 there were concerns expressed that the current research may 18 not be enough or may not be funded enough, but they needed, 19 they talked more research was needed before decisions could be
(
20 made.
21 DR. HOELLER:
Were these non-industry comments t
22 categorized, or I'm sure you know where they came from?
23 MR. SETH:
- Yes, 24 DR. MOELLER:
Were they from average members of the f-(_g) 25 public or from organized--
4 HERITAGE REPORTING CORPORATION -- (202)628-4888
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MR. SETH:
Okay.
In general, the non, the
(,s) 2 non-industry comments were from individual citizens, some of 3
whom were consultants.
There were two public interest groups.
4 DR. HOELLER:
Okay.
5 MR. SETH:
One of those public interest groups 6
provided very comprehensive answers, and I think most of these 7
comments were really coming fram that particular group.
8 DR. MOELLER:
Thank you.
9 DR. SHEWMON:
What was that group?
10 MR. SETH:
This is the Ohio Citizens for Responsible 11 Energy.
12 MR. KNIEL:
The non-industry response is pretty 13 limited.
We did get a comprehensive set of answers from the 14 Ohio Citizens for Public--
15 MR. SETH:
Yes.
Did I not mention that?
Yes.
They 16 provided very comprehensive--
17 DR. MOELLER:
Did the Union of Concerned Scientists?
18 MR. SETH:
No.
19 MR. WYLIE:
They did not?
i 20 DR. SHEWMON:
I would be interested in getting their 21 address later.
I have never heard of them.
22 MR. SETH:
I will be happy to provide that.
23 MR. SETH:
Here is how we have categorized these 24 issues.
Don went through one through twelve of these
(~')
i V
[
25 procedural issues.
Technical issues in our mind arise from l
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aspects of the plant that have changed with time or need to
- 3 2
change with time.
They involve questions related to technical 3
information, analysis, status of that information, and how 4
that information could be used in regulatory decisions.
5 The first issue then--there are basically two issues 6
here.
One relates to the design basis question that we were 7
just getting into earlier, and the second is the large group 8
here all relates to aging, impact on hardware, and 9
implications for operations and management, and I will 10 describe that in a little bit.
Le:'s go to the next one, 11 licensing design basis.
12 (Slide) 13 MR. SETH:
It appears there are two types of 14 concerns.
As the NRC safety review methodology has become 15 more and more comprehensive and safety review criteria have 16 been more detailed, the plants that have, I should say the 17 manner in which the various plants conform to the regulations 18 and regule.cory guidance is not uniform, and that is in a sense 19 the question that was asked, and I think that the concern 70 there is that these older plants may not meet the current 21 guidance, and whether or not they should be reviewed from that 22 standpoint, and that's where the SEP comes in.
It responds to 23 that question.
24 Let me just, the next bullet really responds to fm l
25 that, so let me take that out.
The NRC has, carries out I
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various programs, the SEP for one, where the principal
(
2 objective was to in fact compare the technical positions that 3
existed then when the plants were originally licensed, and the 4
positions now, look at t'~ safety significance of those 5
differences, take a totc plant view of those differences, and 6
use in some certain cases risk analysis to, to provide that 7
perspective, and then to document that safety review.
8 In the SEP program, although ten plants were 9
reviewed, and generally for two thirds of the issues that were 10 identified, the NRC found that these plants may not have met 11 those, the current criteria, they did have features that, that 12 certainly met the intent of those criteria for two thirds.
13 For one-third of those issues, there were l
s-l 14 modifications made to the plant, and some 300 different l
15 actions were carried out for these plants.
16 Programs --
17 DR. MARK:
Do you know whether in connection with 18 fossil or hydroelectric plants, there is a license pattern 19 similar to this where it is licensed for X years and that has l
20 to be reviewed?
l 21 MR. SETH:
For the fossil plants--
l l
22 HR. WYLIE:
Hydroelectric plants are licensed for a l
l 23 period of time, and that license expires, has to be renewed, 24 MR. WARD:
Can't hear you, Charlie, j
i 25 MR. WYLIE:
Hydroelectric plants, t
1 HERITAGE REPORTING CORPORATION -- (202)628-4888 i
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MR. SETH:
They have a 50-year license.
()
2~
Hydroelectric plants have 50 year, and several of them are 3
coming up for renewal.
4 DR. SHEWHON:
There should be something on the 5
pressure system in a fossil plant.
6 DR. MARK:
Pipe thing.
7 DR. SHEWMON:
I don't know--
8 HR. WYLIE:
They have to repeatedly meet the code 9
requirements.
10 DR. SHEWMON:
Must be some inspection.
11 MR. WYLIE:
Inspections, yes.
As long as they do 12 that, they continue to operate.
13 MR. MINNERS:
But I think the hydro plants were an 14 economic license, not a safety license, so there is a little 15 bit of difference.
16 DR. MARK:
There can be cracks around the dam that 17 is--
18 HR. MINNERS:
I don't think the license concerned 19 itself with cracks.
The license was only an economic license.
20 DR. MARK:
So there is no precedents there that 21 could be compared?
22 MR. MINNERS:
Precedural there might be precedent, 23 but as far as safety goes, I am not sure there is too much 24 precedent.
25 MR. WYLIE:
The only thing peculiar about i
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hydroelectric is the end of the period, I think there is the-(m_)'
2 stipulation it becomes government property.
3 DR. SHEWMON:
That economic license, I can't quite 4
see the government deciding whether a utility is going to make 5
money, should try to make money off of it.
6 MR. MINNERS:
No.
There was a tradeoff in that when 7
you built a dam on a river, some people's interests in using 8
the river are changed, and so, you know, it is a public 9
resource, like an FCC license.
It is a limited resource.
10 DR. SHEWHON:
I get it.
Thank you.
11 DR. LEWIS:
There is analogy in aircraft that is 12 close in connection with safety in aircraft.
An aircraft is 13 licensed once, but it is issued an air worthiness certificate 14 on a regular basis--annually, as a matter of fact.
15 DR. SHEWMON:
As long as somebody looks at it and 16 the parts seem to be functioning the way they were designed 17 to, after 20 years somebody says you have got to see if ne 18 want to still fly that design?
19 DR. LEWIS:
No, no.
The license is forever, but it 1
20 is a positive action.
It has to receive an air worthiness 21 certificate every year in order to be--
22 DR. SHEWMON:
The requirements for that air 23
'forthf. ness certificate change with time?
I l
24 DR. LEWIS:
Yes, they do.
They do.
I 25 MR. WARD:
Okay.
i I
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DR. MOELLER:
They are upgraded?
()
2 DR. LEWIS:
Yes.
3 DR. MOELLER:
Okay.
4 HR. SETH:
The point I was making is that the 5
program such as the SEP/ISAP, TIM action plan and perhaps the 6
IPE that the NRC is considering, programs such as these, the 7
NRC assures on a continuing basis that the design basis of the i
8 plants is adequately safe, and so an argument could be made 9
that you do not need to revalidate the licensing basis.
10 However, the second concern is the interpretation of 11 regulations for the older plants, plants that have now shown 12 increasingly symptoms of aging, embrittlement fatigue, cracks, 13 and it may be or may not be.dequate as the safety review O's i
14 criteria for older plants.
15 The NRC aging research program is working toward 16 developing regulatory guidance and safety review procedures to 17 address these aging concerns.
18 To be sure, these could lead to potential 19 modifications in the licensing basis.
Once they come up for l
l 20 license renewal, for example, certain age-related failures or I
21 uncertainty with respect to ac,ing might point that you need 22 additional safety features or changes in design, or changes in 23 operational load, and so on, and that could affect the 24 licensing basis.
l l
Also the NRC is going to require an extensive l
25 l
l l
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documentation to make sure that it can assess the effects or
()
2 review at least the effects of aging.
3 So this is where we are.
In fact, this launches us 4
straight into the next issue, which is the aging.
5 (Slide) 6 HR. SETH:
As we have seen earlier through many of 7
the questions which the NRC asked, there are several concerns 8
related to aging.
How do you identify critical components and 9
structures which are particularly susceptible to aging?
How 10 do you use operating history and PRA?
There could failure 11 modes which are unanticipated, and rates uncertain.
Which 12 items should be monitored?
Where should additional 13 maintenance go, and so on, i
14 The adjustments that operations and management has 15 is really two adjustments.
One is that there are many ways in 16 which aging affects operations and management aspect of the 17 plant.
For example, as the plant gets older, and there are 18 increased repair and replacement activities, and thereby f
19 perhaps potential for maintenance-type errors; also the 20 maintenance backlog needs to be managed.
Spare parts 21 inventory needs to be controlled; additional training to 22 provide the technicians training and detection of age-related 23 failures and controlling aging effects.
I 24 The other side is that operational management also 25 affect the rate of aging.
For example, improper maintenance 1
I I
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and testing could accelerate the effects of aging.
There are
()
2 various concerna.
3 To identify broad options for addressing these kind 4
of concerns, we have subdivided the issue into two categories.
5 One is the assessment of aging effects.
That is estimating to 6
the best of our knowledge right now the, the effects of aging, 7
but then we recognize that there are uncertainties in our 8
assessments and you need to protect the plant against these 9
uncertainties, and what we are calling it is the management of 10 risk in continued aging and is protecting against 11 uncertainties.
And let me get into these two now.
12 MR. EBERSOLE:
What are you going to do about 13 age-related decreases in reliability that don't manifest 14 themselves by failures until you have some sudden thing like 15 an earthquake?
I am thinking of all these old plastic parts 16 of which there will be zillions in the control systems.
17 I don't like plastics and never have, most of them 18 anyway, and I have a horror of thinking of all of the things 19 in the guts of plant control systems.
20 MR. SETH:
Yes.
I hope that that's where the second 21 sub-issue, that's where it will go.
You are trying to assess i
22 the effects on those plastics as best as you can, but there 23 are going to be uncertainties and our knowledge is limited and 24 so there is this uncertainty and you need to provide some 25 protection, and there are two broad approaches I think.
They HERITAGE REPORTING CORPORATION -- (202)628-4888
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are not new, but I will try to mention them and see if this
()
2 strikes some consonance with you.
3 (Slide) 4 HR. SETH:
Now when we talk about options, I think 5
options mean different things to different people.
We are 6
going along with the use of the word options, but really on 7
many of these technical issues, you cannot have, you cannot 8
exclude the desirable elements of any option.
That is what we 9
have found, so what we have here, by options really what we 10 mean is that different aspects of an approach that you might 11 want to deliberately separate out to further evaluate and 12 write public comments and so forth and then integrate it into 13 a policy, so I think they are not to be considered as mutually 14 exclusive, but just for further evaluation and looking at the 15 pros and cons, strengths or weaknesses of these different 16 approaches.
I think that the current aging research program 17 of the NRC, and perhaps what is needed, will almost surely 18 integrate various elements of these options that we are 19 talking about here.
20 They are very broad options here.
I mean for 21 assessing the aging effects you may choose to emphasize 22 deterministic method or you would choose to emphasize 23 probabalistic methods.
And as I mentioned, you probably want 24 to combine the two, but look at the pros and cons of each of i O 25 these approaches.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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In the deterministic method, you would, the
().
2 licensee--typically for all the options' these bullets are 3
essentially what the licensee would do and NRC would review.
4 The licensee would identify safety significant items based on 5
generic studies.
Now by generic study, I mean here both NRC 6
and industry studies.
The industry work; for example, on the 7
two pilot plants, Montjcello and Surry, have been, have 8
actually not only provided categories of critical components, 9
but they also provided a methodology for identifying l
10 components in a plant-specific manner, using expert judgment 11 and operating experience.
So generic requires qualification 12 here.
That's what I just explained.
13 Then you would, for those components the licensee O
14 would determine the effects of aging using various mechanistic 15 models, and NRC is providing guidance in calculating the life 16 of the components looking at duty cycles, remaining duty 17 cycles and thereby the life components.
Yo?2 take into account i
18 the operating history of the plant, the environmental 19 conditions that existed, past failures and accidents such as, i
20 for example, fires or water hammer events that could have 21 occurred earlier, and might have led to certain aging effects l
22 which will have to be evaluated.
So there would be a l
23 methodology to estimate these aging effects, and then to i
24 determine the safety significance of these effects using 25 essentially traditional methods, safety review methodology HERITAGE REPORTING CORPORATION -- (202)628-4888
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using, identifying single failure points, commca mode
()
2 failures, and that sort et thing.
3 In the probabalistic approach, as we know, 4
plant-specific PRA would be utilized.
That PRA would have to 5
account for aging, and NRC is sponsoring research into how a 6
PRA could in fact reflect the effects of aging much more 7
explicitly, increasing anticipated failures could decrease the 8
reliability of the systems, and so on.
9 DR. SHEWHON:
Where is that work being done?
10 HR. SETH:
This is being done by--
11 MR. CLEARY:
Idaho National Lab; Bill Wesley is the 12 person on that.
13 DR. SHEWHON:
When did it start and when are they 14 likely to have anything out?
15 MR. CLEARY:
It started more than, almost a year 16 ago.
And I think within a, within the year--this is being 17 done in the Division of Engineering, sponsored through the i
18 Division of Engineering, and right now I think they are l
19 assessing exactly wha.t they will be doing, i
20 DR. SHEWMON:
Fine.
Okay.
21 MR. CLEARY:
Within a year.
22 HR. SETH:
This is what I meant here by stressing l
23 the effects of aging in terms of changes in availability, i
l 24 changes in risk, this kind of thing, and I think in response
)
l 25 to one of your questions here, that is best done for active 1
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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components.
It is, because of lack of data, it is difficult
()
2 to model passive systems, and look at the failure 3
probabilities.
However, again, there is, NRC is sponsoring 4
these into approaches--what one could do.
There is carry out 5
sensitivity study to quantify the uncertainties that would be 6
there on such failures, and you would then factor in the 7
increased failure probability Using the, in the PRA sense, and 8
then demonstrate that the risk due to aging is minimum, 9
increased risk is minimal.
10 MR. WYLIE:
Isn't this, this area here--you might be 11 going to touch on it.
I don't know, but the NRC has had a lot 12 of research aimed at aging research for several years, but it 13 is, in the budget restraints, that had been cut considerably.
14 They have been getting along, not very well.
Is that going to 15 be given an added emphasis by the Commission?
16 MR. SETH:
Let me make a point and then--Don?
17 MR. CLEARY:
We were supposed to have a contingent 18 here from the Division of Engineering to answer questions like 19 that.
20 MR. KNIEL:
We know their budget has just been cut.
21 Cut it by about $3 million for Fiscal Year
'88.
22 MR. WYLIE:
The answer to these questions you are 23 talking about, you have got to have that research.
24 MR. KNIEL:
We still have some of the research, 25 MR. SETH:
From a regulatory perspective, I can say i
HERITAGE REPORTING CORPORATION -- (202)628-4888 t
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that that launches us into the second sub-issue because that's O
(_/
2 where if you don't have research, your uncertainties are going 3
to be larger, you will have to make more conservative 4
regulatory decisions.
5 MR. WYLIE:
Oh, sure.
6 HR. SETH:
That's where it will go if there is not 7
additional research.
That's my view.
8 MR. WYLIE:
Just the scope has to be, has had to be 9
limited, very limited, and to the extent that the things that 10 Jesse was talking about a while ago are not even looked at.
11 CHAIRMAN KERR:
It does not seem unreasonable to me 12 that the people who are applying for the license should be 13 asked to demonstrate that aging is not a problem.
I don't 14 necessarily see that NRC hasn't demonstrated it.
15 MR. WYLIE:
Somebody has got to do the research, and 16 industry is not doing it.
17 CHAIRMAN KERR:
The industry might do it if it were 18 told--
19 MR. WYLIE:
I understand what you are saying and I 20 agree with you.
I think they should be doing it.
21 MR. WARD:
They have to be told more than 30 days in 22 advance.
23 MR. SETH:
I think these questions lead us into how 24 do you manage the risk?
And I think you could look at one l
25 cption B as perhaps being more conservative.
l i
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MR. WYLIE:
Let.me make one more point, though.
As
()
2 I understand, much of the research that NRC has~been doing is 3
so that when industry does come back and say hey, this is 4
okay, they know something about how to address that, and that 5
in absence of the research NRC has been doing, they would be 6
very helpful.
7 DR. SHEWMON:
The research that you are talking to 8
that NRC was doing and.isn't now is this accelerating aging 9
stuff at Sandia?
10 HR. WYLIE:
No.
No.
Basically a lot of this is 11 taking existing equipment and that it has naturally aged in 12 plants and analyze it to see how well it performs.
That was 13 one of the bases for doing it, but it has been very meager 14 because of the budget.
15 HR. CLEARY:
I don't want to speak for the Division 16 of Engineering, but relative to the recent budget cuts, they 17 have assured me or told me that they have put the highest 18 priority on those activities that will support regulatory 19 requirements, licensing, and as Shiv said, the problem that 20 you come up with is that perhaps your requirements have to be 21 much more conservative, and also there may be some timing 22 problems because you do put more of a requirement back on the 1
23 industry to come up with the answer, 24 CHAIRMAN KERR:
One of the things that has to be t
25 decided upon is what it is that industry would have to i
1 HERITAGE REPORTING CJRPORATION -- (202)628-4888
S-303 1
demonstrate.
What we are seeing at this point is a lot of
()
2 possibilities but no decision as to which of these, if any, 3
are going to be used,'and I think, I was promised earlier that
)
i 4
when I heard Shiv's presentation I would know the criteria j
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5 that NRC was going to use, and what I am seeing I think is not 6
unreasonable, are a number of possibilities.
7 How are you going to decide among these 8
possibilities as to which of those is to be finally included 9
in the package?
Is that going to be based on public comments 10 or on recommendations from Mitre, none of the above?
11 MR. CLEARY:
All of th' above, including staff 12 analysis; as I said before, we are working very closely with 13 various offices and programs, including the aging research 14 program, and they are very sensitive to the need to support 15 license renewal policy.
16 CHAIRMAN KERR:
You don't need aging research'unless 17 you are going to use aging research to decide whether to 18 re-license the plants.
If you are going to use it, it seems 19 to me you need to decide what it is, what sort of information 20 you need for aging research.
21 MR. MINNERS:
I, I don't know if I heard you right, 22 but I think we need aging research for itself, okay.
Whether 23 we had license renewal or not, we would still need aging 24 research.
O 25 MR. MICHELSON:
Not all components last 40 years.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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MR. MINNERS:
Correct.
(7
/ )
2 DR. STEINDLER:
I have a little trouble with that 3
comment.
Is that a scientific statement?
Aging research is 4
interesting, difficult to do, expensive, but how can you 5
justify the NRC doing that unless it is related to licensing?
6 Or did I misunderstand what you were saying?
7 MR. MINNERS:
License, I said yes, it is related to 8
licensing, but it is not related solely to license renewal.
9 If we didn't have license renewals, and the operative word is 10 renewals, we would still want to have some aging research.
11 MR. MICHELSON:
For safety?
12 MR. MINNERS:
Correct.
13 MR. WARD:
You are saying you have granted licenses 14 for 40 years in the past partially blindly?
l 15 MR. KNIEL:
Right.
16 MR. MINNERS:
Confirmatory research.
17 MR. WYLIE:
Now on top of that, you are looking at 18 extending those licenses into an unknown area, relatively 19 unknown, although you know that a lot of these components will i
20 last 60, 70 years.
l l
21 MR. MICHELSON:
We know a lot of components aren't 22 going to last four years.
Now when do you have to start 23 replacing them for safety's sake?
l 24 MR. WYLIE:
That's right.
l 3
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l 25 CHAIRMAN KERR:
It strikes me that an alternative to l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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1
' aging-research in principle, maybe not in practice, is to
(
I 2
develop methods of testing which tell you whether a component 3
is operating or not,-and perhaps whether it will operate or 4
not for the next year.
If you have that, you don't need aging 5
research.
6 MR. WYLIE:
That in effect is what a lot of the NRC 7
research program was aimed at.
8 MR. EBERSOLE:
But Bill, I think you are going to 9
find lots of pieces you can't test.
10 CHAIRMAN KERR:
I said it may not be practical to do S
l 11 it.
I don't know.
12 MR. EBERSOLE:
I recall an interesting case where P
13 the pilot operated safety valves were artifically aged too 14 fast, and the phospherous bron: springs stiffened up and quite 15 within the interval of testing, they found those safety valves 16 were way above the trip set point.
In short, they were losing 17 their safety valves real fast, and the common mode fact was 18 there because they were identical like the old one-horse i
19 sleigh of everything was coming apart at once, and they didn't 20 have safety valves.
They caught it because they did test, but 21 it turned out the contractor thought he was going to do a 22 beautiful job and he piled the insulation up around the valves
[
23 to keep heat loss down, ruined the springs--interesting.
l i
l.
24 MR. SETH:
The other concern, maybe it is not just 25 year-to-year testing, testing for assuring the operability for 7
l t
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306 i
1 just shorter time, but you want to be sure that the plant will
()
2 be safe for a number--
3 HR. WYLIE:
That is not the only example of that.
4 HR. EBERSOLE:
Oh, there is lots more.
That was 5
especially interesting to me because it was a safety valve.
6 HR. SETH:
Getting back to the options for managing 7
the risk of aging, thero again, they are well-known 8
traditional safety philosophies, and I think you cannot do 9
without both of them.
10 One is to emphasize, though, prevention of failures, 11 The other is to emphasize the safety systems, mitigation, 12 containment systehs.
The first one has elements, and what NRC 13 has been developing in projects for liability assurance also O
14 work that has probably, that has reflected into maintenance 15 policy, but basically it is the identification of significant 16 components and structures throughout the plant that might 17 adhere, not just safety-related equipment.
18 CHAIRMAN KERR:
So risk significant is not 19 synonomous with safety-related anymore?
Is that what you are 20 telling me?
21 HR. 3ETH:
That's the way we are viewing it.,
yes.
22 HR. EBERSOLE:
There is a standing case right now, I 23 think it is the ANO one they have been running for some years, i
24 way up, elevated temperatures in the containment, accelerated 25 aging.
l l
l l
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MR. SETH:
Right.
(_)
2 MR. EBERSOLE:
I don't know but what that doesn't 3
imf!y they are going to have to strip the wires out of there 4,
and p,t in new ones.
That's what they are doing.
And I think 5
that just, that's still on the floor, what is going to have to 6
happen.
7 CHAIRMAN KERP Please continue.
We are going to 8
run short of time.
9 MR. SETH:
The second would be the then 10 identification of assumptions related to performance measures 11 that you might assign such as availability life, also I
12 performance targets for these risk significant components, 13 comparing the, these assumptions or these, these assumptions 7t/
14 with what you would estimate or predict when you take into 15 account aging, and then carrying out the necessary hardware or 16 operational modification to the plant.
17 These are basically one-time changes that you carry I
18 out, and also that analysis there would identify not only 19 these one-time changes that you need to carry on, but ongoing 20 program we are calling here the aging management program which 21 would, which would involve monitoring the hardware; also 22 adjustments to the operational and management aspects, some of 23 those which I referred to earlier, like maintenance backlogs 24 and so on, and emphasize condition, condition monitoring of 73 V
25 equipmenc.
So this would be, this has several elements, as I HERITAGE REPORTING CORPORATION -- (202)628-4888
308 1
said, of reliability assurance program which NRC is sponsoring l,/ >
2 also at Brookhaven National Lab.
g 3
The second approach is the emphasizing the safety 4
system.
There you. essentially, the licensee would essentially 5
carry out what is under option A, but restrict it to the 6
safety-related systems and components only.
You might want to 7
include more safety, but I didn't want to get into that, but 8
some smaller set, not the significant set probably.
But I 9
would like to point out that in the, in option A, that thero 10 are approaches that are bein; developed and talked about for 11 identifying the significant component such as risk achievement 12 works and risk reduction works which I think they are also e^s 13 geared to Bill Wesley, I don't know, but some of the groups.
LJ 14 Okay.
Here you wculd assess your safety systems, 15 assure adequate safety margins, and if needed, add safety 16 features, and these could be like the decay heat removal 17 system or primarily depressurization.
18 CHAIRMAN KERR:
What is meant by safety margin in 19 this context?
20 MR. SETH:
Well, you would find that all the 21 operating history, you might have used up the original safety 22 margin that would be there.
23 CHAIRMAN KERR:
What is meant by the original safety 24 margin?
25 MR. SETH:
When the plant was new, you might have l
i i
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for a component let's say 250 heat-up or cooldown cycles, and N
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now you have used up a lot of it or It could be uncertainties 3
in concrete structures, structures supporting the press _re 4
vessel.
5' CHAIRMAN KERR:
You are really t'alking abelt 6
component life, not margins?
It is just if you design for a 7
certain number of fatigue cycles, you have used them up and so 8
you don't have them any longer?
Is that--
9 MR. SETH:
That's right.
But there is probably a 10 margin of safety there.
There is uncertainties about ht nany 11 cycles or what, what stress certain components might be tble 12 to carry and there are uncertainties in that, ar.d you would 13 try to ensure that you haven't gone very close to that, and if f-)
(/
14 you have, then you would try to carry out design modifications 15 or replace a lot of equipment and that sort of, those 16 measures.
17 We have, as I indicated earlier, tried to develop a 18 framework for that, could be used in further discussions and 19 evaluations.
This essentially integrates the various types of 20 technical information that might be needed or that might be 21 included in a license renewal application.
For example, types 22 of data could be plant-specific, operating history, and 1
23 analytical methods such as probabalistic risk assessmenus, 24 deterministic evaluations of residue vessel life.
This ceuld 25 provide a basis for integrating this kind of information.
HERITAGE REPORTING CORPORATION -- (202)628-4888 t
310-1 Here in the first step, this is rather
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straightforward where you are proceeding essentially from 3
collecting data to identifying what changes are needed and 4
what sort of an ongoing program would be needed in the renewal 5
term.
6 Here in the first step you would obviously collect a 7
lot of information such as design basis information, results 8
from previous tests and inspections, past failures, past 9
events-maintenance, maintenance practices of the past, and so 10 on, use that information for carrying out failure modes and 11 effects analysis which are particularly suitable for passive 11 structures and components, and a PRA.
s, 13 Then given the PRA, you could, you would identify J
s these significant items and in parallel develop targets for 14 15 residue life.
16 CHAIRMAN KERR:
I don't understand the statement the 17 framework is based on a combination of all options.
Does that 18 mean you are not going to use among options but you are going 19 to use them all?
20 MR. SETH:
Basically.
21 CHAIRMAN KERR:
So they are not really options.
22 MR. SETH:
That's what I was trying to explain 23 carlier when I was saying they are not mutually exclusive.
24 Here is a way in which you could combine the--
.7 3
?S CHAIRMAU KERR:
Not all are mutually exclusive, but HERITAGE REPORTING CORPORATION -- (202)G28-4888
b 311 1
you are going to use them all?
,~s f(,)
2 MR. SETH:
Right.
3 MR. CLEARY:
Parts and then varying degrees, varying 4
emphasis.
5 MR. SETH:
Yes.
There is different emphasis.
You 6
could alter the emphasis, but the way it is shown here, it has 7
elements.
8 CHAIRMAN KERR:
This is soing to be sort of 9
confusing to a licensee, information that you can dig up 10 anywhere, and we--and give it to me, is sort of what I have 11 seen on these charts up to now.
12 MR. MINNERS:
I don't think the intent is to ask gg 13 licensees to bring us everything.
Obviously we would have to LJ 14 have some definition of what information you want ' rom a 15 licensee, and that is going to be a process that is going to 16 take some time to develop to get details.
17 CHAIRMAN KERR:
You tell me you are on a very tight 18 time schedule for doing this, or I think.
Is that what I 19 heard?
20 MR. CLEARY:
Yes.
21 CHAIRMAN KERR:
So how is it going to be done?
At 22 what point is somebody going to discriminate among these 23 various possibilities and say here is what we are going to do?
24 MR. CLEARY:
Much of it is going to be done over the 7-D 25 next six months and what, and the policy statement that you i
HERITAGE REPORTING CORPORATION -- (202)628-4888
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see this summer will cover a lot of these customers and reach i,)
2 conclusions.
3 CHAIRMAN KERR:
Decisions will have been made.
4 MR. KNIEL:
That will be a proposed policy 5
statement.
A year later the final policy is coming.
6 MR. SETH:
In response to one thing, for example, 7
you might stress differently, in trying co decide how much 8
emphasis to place in each of these, you would look at the 9
ststus of information, the kind of information that is 10 available, and how it could be used for making ary or 11 developing any approach.
12 For example, if risk assessments are not adequate rx 13 for looking at the residue or for iudging the increased U
14 failure probability cf structures, for example, or passive 15 components, you would stress that less, and use the risk 36 analysis only for active components to look at just the 17 effects on availability.
18 CHAIRMAN KERR:
You almost know that risk assessment 19 is not adequate at this point because nobody has used any l
20 consideration of aging in risk assessment so as far as I know.
21 You can almost toss that one out initially, can't you?
22 MR. SETH:
I have seen, myself, some results, again, 23 from Bill Wesley where he has, there are papers which he has 24 and made presentations where there have been studies 25 incorporating aging into--
j HERITAGE REPORTING CORPORATION -- (202)628-4888
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DR. SHEWMON:
Contractors always put out reports.
/~'T
,j 2
Whether they mean e.nything or nct is a separate question.
It 3
seems to me on many of these components you can actually go 4
off and test instead of somebody sitting in a room and trying 5
to assemble numbers and pushing them through a calculator.
6 Where does the question of in-sorvice inspection and 7
certification to functionality of the equipment come out?
8 MR. SETH:
I think it is coming here.
If you 9
already know that the item is going to be safety significant, 10 you would actually get all of that information here.
11 DR. SHEWMON:
With regard to your question of 12 whether or not you used up your fatigue life, the generally 13 accepted procedure is to see if there is any cracks that have f3 G
14 started in high stress areas.
You look for these things in a 15 standard inspection.
If you find them, you already have done 16 something about them.
If you don't find them, there is not a 17 problem.
18 MR. MINNERS:
Do we want to test the toilet seat 19 covers even though they are made of plastic?
20 DR. SHEWHON:
Don't want to make use of the ISI 21 results.
That will answer the questions he is talking about.
22 That's another question.
23 MR. MINNERS:
Yes.
24 MR. SETH:
You may want to project ten years into bo 25 the future.
Gee, right now the component may be all right, HERITAGE REPORTING CORPORATION -- (202)628-4888
314 1
but given the data, given data on other similar components,
,(_j 2
what.would you be able to say about that?
3 DR. SHEWHON:
That's what--Section 11 handles it, 4
handles it fairly well.
You ought to check it.
It is not a 5
bad document.
6 MR. MICHELSON:
I think one of the concerns with PRA 7
are the active components, and the active component data that 8
I have seen in the past has not differentiated whether the 9
valve has been in service one year, two year, three years, but 10 clearly the, the probability, reliability of the valve is 11 goi?ig to perhaps vary with time.
12 DR. SHEWMON:
There was an earlier question of after 13 somebody has done maintenance, is it as good as new or not?
Uck Valve Reliability Security Containment Integrity Severe Accident Policy Implementation f
Degree Requirements for Operators Severe Accident Management Program l
Emergency Planning Shutdown Decay Heat Removal FEMA Protective Action Guidelines Single Phase Erosion - Corrosion l
Enforcement Policy and Investigations Standardization and Licensing Refom f
Fitness for Duty Station Blackout l
Maintenance Technical Specification Improvement l
MOV Perfomance Training and Qualification Litigation l
NRC Reorganization 10 CFR 20 Rulemaking i
Operator Requalification 10 CFR 50.59 (Safety Evaluation)
Operator Professionalism l
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NUMARC MONITORED ISSUES Adequate Levei of Protection Definition Hot Particle Advanced Light. Water Reacter Program, including Important-to-Safety Advanced Reactor Severe Accident Program (ARSAP)
Integrated Safety Assessment Programs Backfitting Integrated Schedules Bolting Integrity Life Extension and License Renewal Chernobyl Follow-up Activities Nuclear Plant Aging Containment Leak Rate Testing Piping Integrity i
Decommissioning Probability of Causation / Radiation Tort Litigation Deminimis Concept in Radiological Protection Quality Assurance Emergency Response Data System Safety Goals / Cost Benefit Environmental Qualification of Equipment Safety Implications of Control Systems EPA Radiological Protection Standard Seismic Qualification of Equipment External Events Senior Manager on Shift i
FEMA Guidance Memoranda Source Tern l
Filtered Vent for Containment Systems Interactions Fire Protection TVA Cable Testing e
^
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6 POTENTIAL OR DORMANT ISSUES Auxiliary Feedwater Reliability Interfacing System LOCA Buckling Behavior of Steel Containments Interlocks and LCOs for Class IE Tie Breakers Classification of Instrumentation, Control and Lightning Protection of Nuclear Power Plant Structures Electrical Equipment Loads, Load Combinations, Stress Limits Component Cooling Water System and Service Water local Control Stations Safety System Reliability low Temperature Overpressure Protection l
Containment Venting (Operational Issue)
NRC Balance of Plant Inspections Control Room Design Standards NRC Policy on Plant Staff Work Hours, Shifts, etc.
Control Room Habitability Plant Air System Anomalies Criteria for Safety Related Operator Actions PORY and Block Vaive Reliability DC Power Reliability Pressurized Thermal Shock Diesel Reliability Reactor Coolant Pump Seal Failures Disturbance Analysis System Reevaluate Position to Auto Isolate FW from SG During Failure of HPCI Steam Line w/o Isolation
- Steam i.ine Break Flooding of Safety Systems Via Floor Drains Reliability Engineering HP Injection Systems Research on Training Simulators Hydrogen Combustion in Containment Structures Review Criteria for Human Factors Aspects of Controls, Hydrogen Control for large Dry Containments
& Instruments Hydrogen Control Measures and Burn Effects Safety Systems Status Monitoring (RG.I.47)
I&C System Reliability Spent Fuel Pool Accidents Initiating Feed and Bleed Procedures Steam Generator Integrity In-Site Testing of Valves Two-Phase Natural Circulation Inspection Procedures for Upgraded Emergency.
Water Hammer Operating Procedures e
~
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i OTHER IMPORTANT ISSUES DOE Nuclear Production Reactors DOE Programs on HTGRs DOE Programs on LMRs Financial Considerations / Cost-effectiveness Fuel Cycle (Enrichment, Mining and Milling, Reprocessing (alternate fuel cycle))
Fusion High Level Waste Disposal / Spent Fuel Storage / Rod Consolidation j
International Safeguards / Proliferation Low Level Waste Disposal
/
TMI-2 Recovery / Decontamination Issues Transportation of Nuclear Material / Waste l
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(}')
RES STAFF PRESENTATION TO THE ACRS
SUBJECT:
REGULATORY OPTIONS FOR NUCLEAR PLANT LICENSE RENEWAL DATE:
JANUARY 8, 1988
('])
PRESENTER:
DONALD P. CLEARY SHIVAJ1 S. SETH (MITRE)
PRESENTER'S TITLE / BRANCH /DIV:
SENIOR TASK MANAGER i
REACTOR AND PLANT SAFETY ISSUES BRANCH DIVISION OF REACTOR AND PLANT SYSTEMS PRESENTER'S NRC TEL. NO :
492-3556 l
SUBCOMMITTEE:
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OUTLINE REVIEW SCliEDULE CONSIDERATIONS OVERVIEW OF REPORT OVERVIEW OF PROCEDURAL ISSUES l Q TECHNICAL ISSUES PRESENTATION-MITRE i
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OBJECTIVES TO BRIEF ACRS ON THE REGULATORY OPTIONS FOR LICENSE RENEWAL DISCUSSED IN THE MITRE REPORT "REGULATORY CONSIDERATION OF TECHNICAL ISSUES PERTAINING TO NUCLEAR PLANT LICENSE RENEWAL."
TO SOLICIT ACRS COMMENTS ON THAT REPORT.
THE REPORT WILL BE
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SUBMITTED TO ACRS CONCURRENTLY WITH SUBMITTAL TO THE COMMISSION, COMMENTS FROM ACRS WOULD BE APPRECIATED DURING THE PUBLIC COMMENT PERIOD, TO ALERT ACRS TO THE NEAR TERM SCHEDULE FOR DEVELOPING A PROP 00:D LICENSE RENEWAL POLICY AND THE NEED FOR TIMELY ACRS REVIEW, 2
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I PREVIOUS DRIEFINGS OF ACRS l
MARCH 5, 1987 JUNE 5, 1987 O
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MAJOR MILESTONES
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PUBLISH ER NOTICE REQUESTING COMMENT ON VARIOUS LICENSE RENEWAL ISSUES NOV, 6, 1986 SECY-87-179, "STATUS OF STAFF ACTIVITIES TO DEVELOP A LICENSE RENEWAL POLICY, REGULATIONS AND LICENSING GUIDANCE AND TO REPORT ON PUBLIC COMMENTS JUL, 21, 1987 COMMISSION PAPER DISCUSSING REGULATORY ISSUES AND OPTIONS AND REQUESTING APPROVAL T0
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SOLICIT PUBLIC COMMENTS JAN, 1988 PROPOSE A LICENSE RENEWAL POLICY TO COMMISSION TO BE ISSUED FOR COMMENT SEP, 1988 PUBLISH FINAL LICENSE RENEWAL POLICY SEP 1989 ISSUE PROPOSED REGULATIONS FOR PUBLIC COMMENT SEP, 1989 PUBLISH FINAL REGULATIONS 1991-1992 ISSUE REGULATORY GUIDES AND STANDARD REVIEW PLANS EARLY 1990s O
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NEAR TERM SCHEDULE COMMISSION PAPER DISCUSSING REGULATORY ISSUES AND OPTIONS AND REQUESTING APPROVAL TO SOLICIT PUBLIC COMMENTS JAN, 1988 FEDERAL REGISTER NOTICE REQUESTING PUBLIC COMMENTS ON ISSUES AND OPTIONS FEB, 1988 PUBLIC MEETING TO DISCUSS COMMENTS RECEIVED MAY 1988
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DRAFT OF PROPOSED LICENSE RENEWAL POLICY COMPLETED FOR INTERNAL REVIEW JUL, 1988 PROPOSED LICENSE RENEWAL POLICY TO COMMISSION SEP, 1988 EEDERAL REGISTER NOTICE REQUESTING PUBLIC COMMENTS DEC. 1988
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O REVIEW OF PROPOSED LICENSE RENEWAL POLICY CRGR ACRS NEAR TERM SCHEDULE TIGHT Q
NEED TO ESTABLISH SCHEDULE FOR RELATING TO ACRS 6
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O THE REPORT REFLECTS IN-DEPTH DISCUSSIONS REVIEWS OF TWO PREVIOUS DRAFTS BY VARIOUS STAFF MEMBERS FROM THE OFFICE OF O
NUCLEAR REGULATORY RESEARCH NUCLEAR REACTOR REGULATION ANALYSIS AND EVALUATION OF OPERATIONAL DATA THE GENERAL COUNSEL 7
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O THE REPORT HAS THREE MAJOR SECTIONS TECHNICAL ISSUES AND OPTIONS FRAMEWORK FOR TECHNICAL INFORMATION REQUIREMENTS PROCEDURAL ISSUES PERTAINING TO LICENSE O
RENEWAL r
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NO POSITIONS ARE TAKEN NOR ARE RECOMMENDATIONS MADE BECAUSE:
FURTHER SPECIFICATION AND EVALUATION OF THE TECHNICAL APPROACH TO LICENSE RENEWAL IS NEEDED RELATED LEGAL ANALYSIS IS NOT YET COMPLETED O
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PUBLICATION OF THE REPORT FOR PUBLIC COMMENT WILL PROVIDE INDUSTRY, THE PUBLIC AND OTHER GOVERNMENT AGENCIES THE OPPORTUNITY TO COMMENT ON:
SCOPE OF ISSUES AND OPTIONS CONSIDERED RELATIVE MERITS OF EACH OPTION Q
ANY RELATED MATTERS 10 0
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PROCEDURAL ISSUES PERTAINING TO LICENSE RENEWAL FORM OF LICENSE RENEWAL NEW LICENSE / RENEWAL / AMENDMENT PROCEDURAL IMPLICATIONS UNDER REVIEW BY OGC LENGTH OF RENEWAL TERM TECHNICAL BASIS
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POLICY CONSIDERATIONS FLEXIBILITY LATEST DATE FOR RENEWAL APPLICATION 10 CFR 2,102 SPECIFIES 30 DAYS PRIOR TO EXPIRATION SHOULD ALLOW TIME FOR REVIEW 0F APPLICATION 11 O
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PROCEDURAL ISSUES - CONTINUATION 1 EARLIEST DATE FOR RENEWAL APPLICATION INDUSTRY PLANNING REQUIREMENTS TECHNICAL BASIS FOR RENEWAL DETERMINATION LICENSE CONDITIONS BACKFIT RULE IMPLICATIONS CASELOAD IMPLICATIONS
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EFFECTIVE DATE OF RENEWAL TACK-0N SUPERSESSION USE OF THE BACKFIT RULE APPLICABILITY TO REQUIREMENTS DUE TO LICENSE RENEWAL CONSIDERATION OF RENEWED TERM IN BACKFIT CALCULATIONS 12 s_/
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PROCEDURAL ISSUES - CONTINUATION 2 ENVIRONMENTAL REVIEW EIS vs EA GEIS - SCOPING STUDY PUBLIC HEARINGS OPPORTUNITY FOR HEARING APPEARS TO BE REQUIRED UNDER
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SECTION 189 0F THE AEA TIMING OF HEARING NATURE OF HEARING SCOPE OF LITIGATION EMERGENCY PLANNING i
l ADEQUACY OF EXISTING REQUIREMENTS FOR RENEWAL PERIOD 13 O
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PROCEDURAL ISSUES - CONTINUATION 3 DECOMMISSIONING FINANCIAL INFORMATION RECulRED IN RENEWAL APPLICATION (10 CFR 50.33F(2))
NEED TO COORDINATE LICENSE RENEWAL AND SUBMITTAL OF DECOMMISSIONING PLAll (10 CFR 50,82)
(l, ANTITRUST REVIEW MAY NOT BE REQUIRED MAY BE PRUDENT TO NOTICE IN EE TO ALLOW INTERESTED PARTIES TO IDENTIFY ANTITRUST ISSUES PRICE-ANDERSON ACT COVERAGE l
COVERAGE APPEARS TO CONTINUE DURING RENEWED LICENSE TERM O
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TECHNICAL ISSUES PERTAINING TO NUCLEAR PLANT LICENSE RENEWAL PRESENTATION TO THE ACRS JANUARY 8, 1988 SHIV SETH THE MITRE CORPORATION e
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OUTLINE 8
APPROACH FOR LICENSE RENEWAL POLICY 0
PERSPECTIVES FROM PUBLIC COMMENTS 9
CATEGORIZATION OF LICENSE RENEWAL ISSUES S
OPTIONS FOR TECHNICAL ISSUES S
FRAMEWORK FOR TECHNICAL INFORMATION REQUIREMENTS E
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bbile Comments on l
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Development 1r ir
,------------__l l Integrate Options!
Evaluate Identify Identify J
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'linto Draft Policy Issues Options e
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APPROACH FOR POLICY DEVELOPMENT l
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NRC INVITED PUBLIC C0tNENT ON SEVERAL QUESTIONS RELATED TO PLANT SAFETY 8
SHOULD THE PLANTS BE REQUIRED TO DEMONSTRATE CONFORMANCE TO ALL REGULATIONS IN EFFECT ON THE DATE OF RENEWAL APPL 7. CATION 7 9
HOW SHOULD NRC USE PRIOR OPERATING HISTORY, PERFORMANCE BASED INFORMATION AND PRA7 9 L'dICH COMPONENTS WILL REQUIRE RESIDUAL LIFETIME EVALUATIONS 7 WHAT SHOULD BE THE TECHNICAL PARAMETERS AND CRITERIA 7 9 HHAT ADDITIONAL MONITORING AND MAINTENANCE PROGRAMS WILL BE NEEDED7 WHICH ARE THE MAJOR "LEADTIME" MONITORING ITEMS 7 9
HOW SHOULD CODES AND STANDARDS BE REVISED 7 M
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Su m ARY OF PERSPECTIVES FROM PUBLIC COM ENT INDUSTRY:
0 USE THE LICENSING BASIS ALREADY IN EFFECT S
REVIEW ONLY SAFETY SIGNIFICANT ITEMS SUBJECT TO AGE-RELATED DEGRADATION WHICH ARE NOT PART OF NORMAL MAINTENANCE AND REPLACEMENT ACTIVITIES 0
ONGOING EFFORTS ALREADY MONITOR AGING AND REPLACE EQUIPMENT AS NECESSARY 8
ANY REVISIONS TO CODES AND STANDARDS SHOULD NOT BE TIED TO RENEWAL NON-INDUSTRY:
0 REVIEW ENTIRE PLANT (EQUIVALENT TO NEW OL) 0 UPDATE PLANTS TO CURRENT REQUIREMENTS 0
EVALUATE PERFORMANCE HISTORY COMPREHENSIVELY FURTHER RESEARCH NEEDED TO GUIDE DECISIONS M
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CATEGORIZATION OF LICENSE RENEWAL ISSUES I ISSUES RELATED TO' t LICENSE RENEWAL ;
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TECHNICAL PROCEDUR2 t
ISSUES t
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- 1. Form of Renewal
- 1. Licensing Design Basis l
- 2. Length of Renewal Term
- 3. Latest Date of Application
- 2. Age-related Degradation
- 4. Earilest Date of Application A. impact on Hardware
- 5. Effective Date of Renewal
- 6. Use of Backfit Rule B.impIIcation for Operations
- 7. Environmental Review and Management
- 8. Public Hearings k
- 9. Emergency Planning
- 10. Decommissioning
- 11. Antitrust Review
- 12. Price-Anderson Act Coverage 6
- These timing issues may involve technical considerations.
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LICENSING BASIS ISSUE 0
CONCERNS:
CONFORMANCE TO CURRENT SAFETY REVIEW CRITERIA INTERPRETATION OF REGULATIONS FOR OLDER PLANTS 0
THE NRC ENSURES THAT SAFETY SIGNIFICANT DESIGN AND OPERATIONAL DEFICIENCIES ARE IDENTIFIED AND RESOLVED ON A CONTINUING BASIS.
EXAMPLES:
SEP/ISAP, TMI-ACTION PLAN, IPE, GSI THEREFORE REVALIDATING THE LICENSING DESIGN BASIS WOULD NOT BE NECESSARY 0
THE NRC IS DEVELOPING REGULATORY GUIDANCE AND SAFETY REVIEW PROCEDURES TO ADDRESS AGING CONCERNS POTENTIAL MODIFICATIONS TO LICENSING BASIS DOCUMENTATION OF OPERATING HISTORY AND INFORMATION NEEDED TO ASSESS AGE-RELATED DEGRADATION 7
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PLANT AGING ISSUE 0
CONCERNS:
IDENTIFICATION OF CRITICAL COMPONENTS / STRUCTURES USE OF OPERATING HISTORY AND PRA UNCERTAINTIES IN FAILURE MODES, HATES AND EFFECTS NEED FOR ADDITIONAL MONITORING AND MAINTENANCE ADJUSTMENTS TO OPERATIONS AND MANAGEMENT 0
IN ORDER TO IDENTIFY REGULATORY OPTIONS, THE ISSUE MAY BE SUBDIVIDED INTO:
ASSESSMENT OF AGING EFFECTS:
ESTIMATING AGE-RELATED DEGRADATION OF CRITICAL COMP 0NENTS MANAGEMENT OF RISK DUE TO CONTINUED AGING:
P.0TECTING AGAINST UNCERTAINTIES 8
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OPTIONS FOR ASSESSMENT OF AGING EFFECTS A.
EMPHASIZE DETERMINISTIC METHODS S
IDENTIFICATION OF SAFETY-SIGNIFICANT ITEMS BASED Oid GENERIC STUDIES S
DETERMINATION OF EFFECTS OF AGING ON PERFORMANCE USING MECHANISTIC MODELS 0
EVALUATION OF THE SAFETY SIGNIFICANCE OF AGING EFFECTS USING TRADITIONAL SAFETY-REVIEW METHODOLOGY B.
EMPHASIZE PROBABILISTIC METHODS 0
IDENTIFICATION OF RISK-SIGNIFICANT ITEMS BASED ON PLANT-SPECIFIC PRA 8
ESTIMATION OF EFFECTS OF AGING IN TERMS OF CHANGES IN SYSTEM AVALABILITY AND RISK 0
DEMONSTRATION OF MINIMAL It.iREASE IN RISK DUE TO AGING 9
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OPTIONS FOR MANAGEMENT OF RISK DUE TO CONTINUED AGING A.
EMPHASIZE PREVENTION OF FAILURES 6
SELECTION OF RISK-SIGNIFICANT COMPONENTS AND STRUCTURES THROUGHOUT THE PLANT FOR THE AGING MANAGEMENT PROGRAM S
IDENTIFICATION OF ASSUMPTIONS RELATED TO PERFORMANCE MEASURES SUCH AS AVAILABILITY AND RESIDUAL LIFE 9
COMPARISON WITH RESULTS OF AGING ASSESSMENTS S
IMPLEMENTATION OF NECESSARY MODIFICATIONS TO PLANT HARDWARE OR OPERATIONS 8
MONITORING THE CONDITION OF RISK-SIGNIFICANT ITEMS TO VERIFY ASSUMPTIONS B.
EMPHASIZE MITIGATION OF EFFECTS 0
MANAGEMENT OF AGING RESTRICTED TO SAFETY-RELATED COMP 0NENTS AND STRUCTURES 8
ASSURANCE OF SAFETY MARGINS 10 e
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A SAMPLE FRAMEWORK FOR INTEGRATING TECilNICAL INFORMATION REQUIREMENTS I
THE FRAMEWORK IS BASED ON A COMBINATION OF ALL OPTIONS l
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Identify implement Rask-Changes 7
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Signaticant Required To items Meet Collect and j
I.nalyze Rask-Targets r
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Analyze Perform Saanificant J
Plant FMEAs ltems and Specific and PRA Compara With Data L
J Targets
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Develop 9
W Performance Targets p
Conditions t
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