ML20150C637
| ML20150C637 | |
| Person / Time | |
|---|---|
| Issue date: | 05/24/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2573, NUDOCS 8807120571 | |
| Download: ML20150C637 (25) | |
Text
hhf"0b?8
['O A 7NSE O
I j"y"1 P' l 4
DATE ISSUED: 5/24/88 J L L ' i.C J _
5/[/f[
SUMMARY
/ MINUTES OF THE ACRS SUBCOMMITTEE MEETING ON THE GENERIC ITEMS APRIL 27, 1988 WASHINGTON, D.C.
INTRODUCTION The ACRS Subcommittee on the Generic Items held a meeting on Wednesday, April 27, 1988 at 1717 H Street, N.W., Washington, D.C., to discuss the Integrated Safety Assessment Program II (ISAP II) and integration of related Generic Issues. The entire meeting was open to public atten-dance. Mr. Sam Duraiswamy was the Cognizant ACRS Staff Engineer for this meeting. A List of documents submitted to the Subcommittee is included in Attachment A. A copy of the presentation schedule for the meeting is contained in Attachment B.
ATTENDEES ACRS: C. P. Siess (Subcommittee Chairman), C. Michelson, F. J. Remick, D. A. Ward, and C. J. Wylie Sam Duraiswamy (Cognizant ACRS Staff Engineer)
Principal II).C Speakers: M. Miller, C. Thomas, and W. Minners EXECUTIVE SESSION Dr. Siess, the Subcommittee Chairman, convened the meeting at 1:30 p.m.
and stated that the purpose of the meeting was to discuss:
- Elements of the proposed ISAP II.
- Results of the survey conducted to determine the industry interest in participating in ISAP II.
8807120571 880524 DESICNATED ORIGINAL 3 PDR Ccctified Ey h ,
)
l Generic Items Mtg Mintues April 27, 1988
- Staff's recommendations to the Comission associated with ISAP II.
- Status of the Staff's efforts involving integration of related Generic Issues.
He said that the Subcommittee had received neither written comments nor requests for time to make oral statements from members of the public.
DESCRIPTION 0F ISAP II - MRS. MILLER, NRR ISAP II Process Mrs. Miller stated that the proposed ISfo II is a follow-on program to the pilot ISAP. The pilot ISAP, which is an outgrowth of the Systematic Evaluation Program (SEP), was initiated in May 198S. It was designed to provide a comprehensive review program for operating reactors that would address all safety issues and provide an integrated, cost-effective implementation plan using deterministic and probabilistic techniques.
Millstone Unit 1 and Haddam Neck plants participated in the pilot ISAP.
Mrs. Miller stated that the proposed ISAP II is a voluntary, systematic program to evaluate regulatory issues and to establish an integrated schedule for the implementation of those issues. All utilities partic- )
ipating in ISAP II will be required to perform at least a Level 1 PRA. i They will be expected to update their PRAs periodically so that plant I configuration and procedural changes are reflected in a timely manner.
Utilities may need to perform deterministic evaluations of those plant issues that cannot be evaluated within the context of a PRA. Another component of ISAP II is the operating experience review that would evaluate total plant operating experience to determine any particular systematic weaknesses and trends. The exoerience review would be used l as a tool against which to compare the PRA findings and validate their reasonableness. She stated that operating experience review will be emphasized only for those plants that use generic industry data associ-ated with component failure rates as input to the PRA. Those plants l
l
i
- 1 l
)
Generic Items Mtg Mintues April 27, 1988 l
that input plant-specific component failure data into the PRA will not be required to perform a supplemental review since a review has already been done in accumulating such data.
Mrs. Miller stated that all issues within the scope of ISAP II will be assessed and ranked on the basis of safety significance, risk reduction, personnel exposure, etc. Then an integrated schedule will be estab-lished for implementation.
Mr. Ward commented that not requiring an operating experience review for those plants that use plant-specific data does not seem appropriate.
Also, he does not agree that plant-specific data will be so complete that plants using such data do not have to sort out generic data. Mr.
Kelly responded that plants with several years of operating experience may have a reasonable data base on . things that occurred more frequently. j They may not have adequate data base on things that occur once or twice during the life of a plant; for such things, they have to use the information in the generic data base.
I Mr. Ward commented that he is optimistic whether the above mentioned I approach could be carried out effectively in actual practice. He suggested that the Staff take a close look at this approach.
Main Elements of ISAP II Mrs. Miller stated that main elements of the ISAP II process include the following:
)
4
- Utilities participating in ISAP 11 should submit at least a level 1 PRA for review and approval by the NRC Staff.
- Each utility should submit a list of issues to be included in ISAP 11 for review by the NRC Staff.
Gcneric Items Mtg Mintues April 27, 1988
~
- Each utility should submit evaluation, proposed resolution, and ranking os ISAP II issues for review by the NRC Staff.
- Following an agreement between the NRC Staff.and the utility on the proposed ranking and resolution of issues, the Staff will issue a integrated safety assessment report.
- Each issue should be ranked High, Medium, or Low. As a general rule, issues ranked High should be resolved in one or two refueling outages; issues ranked Medium should be resolved in two to four outages; issues ranked Low may be deferred to four outages and may be considered for dropping from the utility's schedule. Should there be any difficulties in meeting the above schedules, NRC and utility will negotiate and come up with revised schedules as appropriate.
- Schedules will be reassessed following each refueling outage to include new issues.
Anticipated Benefits of ISAP II Mrs. Miller discussed briefly some of the benefits expected of the l proposed ISAP II: )
- Safety would be enhanced because issue of highest safety signifi-cance would generally be addressed first as a result of an inte-grated assessment to rank issues.
- The integrated schedule would provide a predictable safety basis for the Staff and utilities to manage current work loads and to estimate the resources necessary to meet future requirements. The resources required by both the Staff and the utilities are expected to be reduced in the long run because some issues would be combined and some issues with low safety significance would be eliminated.
.l
. i l
Generic Items Mtg Mintues April 27, 1988 l
- Participation in ISAP II would require a utility to perform and maintain a detailed PRA which would lead to an enhanced understand-ing of plant capabilities. Also, the PRA would improve the inter-face between the licensee's engineering and plant operations personnel in areas of mutual responsibility. .l l
- Licensing and Generic Issues are treated on a plant-specific basis and are weighed against all other pending actions. Through the 1
ISAP 11 process, the licensee would have an opportunity to demon- j
- strate, by using the FRA, that certain Generic Issues are not I
justified at his facility on the basis of the safety significance of the issue.
- ISAP II process will help improve outage planning by providing a longer term outlook of modifications for the upcoming outages.
This could reduce outage delays. !
Pilot ISAP Vs ISAP 11 Mrs. Miller stated that although the pilot ISAP and ISAP 11 are similar I in many respects, ISAP II is a separate program and certain programmatic )
differences exist. Some of the differences between the Pilot ISAP and I ISAP II are as follows: l l
l
- The scope of issues to be included in ISAP II is more limited than that of the pilot ISAP. )
i
- Unlike the pilot ISAP, ISAP 11 participants would not be required to incorporate the resolution of lessons learned from the SEP.
- ISAP II participants would not be expected to address unresolved Generic Issues before the Staff reaches a generic resolution.
4
i
, s l
Generic Items Mtg Mintues April 27, 1988
- ISAP II would include only current and future items on a plant's regulatory agenda. ISAP 11 participants would not be penalized for their participation by being required to address issues that they would not otherwise be required to address. !
' ISAP II will not require a license condition.
' ISAP II will provide foundation for completion of the Individual Plant Examination (IPE). )
i ISAP 11 Vs. IPE Mrs. Miller discussed briefly the main differences between IPE and ISAP II:
- Under the IPE program severe accident sequences will be evaluated.
ISAP II does not deal with severe accidents.
l l
- The ISAP 11 process requires at minimum a level 'l PRA. An import-tant advantage of ISAP II is that its PRA can be conibined with a containment vulnerability assessment to constitute an acceptable method for a utility to perform its IPE.
- Criteria will be established within the IPE framework for determin-ing which of the identified risk reduction modifications must be implemented. The modifications identified through the IPE program will then be evaluated and ranked for overall safety significance in the ISAP 11 process. If additional potentially significant risk reduction modifications, that were not identified by the IPE Program, are identified through the ISAP 11 process, they will be considered for implementation with respect to the same criteria used for the IPE determinations.
1 I
Generic Items Mtg Mintues April 27, 1988
- l
- ISAP 11 participants would not be required to implement resolutions !
to additional PRA findings other than those identified for modi-fication in the IPE analysis, l Mrs. Miller stated that in SECY-87-219, which provided an assessmen't of the pilot ISAP, the Staff recommended that ISAP 11 be continued as an important element of the implementation program for the severe accident policy by providing the vehicle to prioritize and schedule the actions arising from the IPE. Upon further consideration, the Staff does not believe that the option of incorporating ISAP II within IPE is an appropriate one. They now believe that if ISAP II were implemented it should be done as a separate but compatible program to the IPE. In this way, ISAP 11 could incor; orate regulatory actions other than the resul-tant IPE actions. The IPE analysis would not be encumbered by the concurrent need to implement ISAP II.
With reference to a statement made by Mrs. Miller that potentially risk 1 reduction modifications identified by the ISAP 11 process will also be considered for implementation, Dr. Siess commented that ISAP 11 is !
intended only to prioritize and resolve issues already identified; identification of issues is a function of the IPE Program and not a function of ISAP II. Mr. Thomas responded that one of the functions of l the PRA performed for the pilot ISAP was to identify risk issues. Mrs. l Miller stated that since IPE deals primarily with severe accidents, there is a possibility that it may not identify all significant risk issues. Although the possibility is small, en ISAP II PRA that encom-passes all sequences, may identify certain new issues that were not identified by the IPE Program.
Dr. Siess asked whether this requirement was included in Generic Letter 88-02 that was sent to all utilities. Mrs. Miller responded that the details of this provision were not explained in that letter.
. F --
Generic Items Mtg Mintues April 27, 1988 Mr. Ward commented that IPE is not just devoted to dealing with severe accidents. The distinction that IPE deals with severe accidents and ISAP II does not deal with such accidents is not a good one. He be-lieves that the main difference between IPE and ISAP II is that IPE '
identifies new risk issues and ISAP II evaluates and prioritizes al1 existing issues as well as the new issues identified by the IPE Program.
Mr. Kelly stated that the PRA performed for ISAP II is reviewed exten-sively by the NRC Staff since it is used to evaluate, rank, and resolve significant regulatory issues. They want to make sure that there are no major deficiencies associated with that PRA. On the other hand, the PRA performed for IPE does not receive an in-depth review by the Staff.
He believes that the licensees will get more benefit out of the PPA l performed for ISAP II.
l Dr. Siess stated that he does not believe that the licensees are con- j vinced that they will get more benefits out of the ISAP 11 PRA. Since J licensees are required to maintain the PRA performed for ISAP II, it will cost them more resources. On the other hand, IPE PRAs are not l required to be maintained.
Dr. Remick asked why the ISAP II PRA receives an in-depth review by the Staff and the IPE PRA does not. Mr. Kelly responded that since a licensee participating in ISAP II will be allowed to drop some issues based on the information obtained from the PRA, they want to ensure that the PRA is done right and does not have any deficiencies. l l
Mr. Michelson asked whether licensees are required to consider external events under the ISAP 11 PRA. Mrs. Miller said no.
In response to another question from Michelson, Mr. Thomas stated that IPE will require eventually that consideration should be given to external events, e
1 4
Generic Items Mtg Mintues April 27, 1988 Dr. Siess asked how the existing seismic issues will be dealt with by the licensees since external events are not required to be considered in the ISAP 11 process. Mr. Kelly responded that although it is not required, there is nothing that prevents the licensees from adding , j issues associated with external events into the ISAP II process. 1 Mr. Michelson commented that he is concerned that the Staff has not yet I decided as to how to handle external events. Since external events can be significant risk contributors, the Staff should make a decision soon on this matter.
Mr. Ward commented that although there are some differences between ISAP 11 and IPE, he believes that they are closely related and serious consideration should be given to combine these two into one program.
Dr. Siess stated that there are some major differences between ISAP II and IPE. ISAP 11 process is intended to rank and resolve issues. On the other hand, IPE is to disenver new issues. ISAP 11 requires that a )
Level I PRA should be performed and maintained. IPE requires a level 2 or 3 PRA, but it does not have to be maintained. Also, those who adopt the IDCOR approach do not have to perform a PRA for IPE. Since the differences between these two programs are major, he is not sure whether they could be combined. ,
l Mr. Ward stated that the following approach could be used to combine ISAP II and IPE into a single program. All licensees should be required to perform and traintain a full scope, state-of-the-art PRA, givirg consideration to internal as well as external events. New issues identified by the PRA should be combined with the existing list of outstanding issues. Then, using the ISAP 11 approach these issues should be evaluated, ranked, resolved, and scheduled for implementation.
Generic Items Mtg fiintues April 27, 1988
~
Mr. Thomas stated that in SECY-87-219 the Staff recommended to the Commission that ISAP II be continued as an element of the IPE program.
Subsequently, they felt that combining ISAP II and IPE into one program may not provide much incentive to the utilities to participate in such a program. They felt that making ISAP II as a separate program would be more attractive to the industry and consequently they decided to pursue ISAP II as a separate program.
Dr. Siess commented that the results of the survey conducted by the Staff show that most of the licensees do not have much incentive to participate in ISAP II even though it is stated to be implemented separate from the IPE Program.
ISAP II Vs Integrated Schedule Program Mrs. Miller stated that a proposed Policy Statement on Integrated Schedule was published in the Federal Register on November 27, 1987.
Since ISAP II also has an integrated schedule as its end product, the issuance of the final Policy Statement on Integrated Schedule has been delayed pending the Commission's decision on ISAP II. The Staff be-lieves that a better way of promulgating Integrated Schedule would be through a procese like ISAP II. Therefore, they believe that the Integrated S .edsie Progran should be subsumed in ISAP II, if and when it is impl ent..d. Those utilities that currently have or currently working t < arc' an Integrated Schedule Program will not be affected by such a ' cision.
Dr. '.ess asked how many plants have integrated Schedule Programs now.
Mr , Miller responded, to her knowledge, there are four plants that have
,uch programs.
Survey of the Industry Mrs. Miller stated that on November 14, 1987, the Staff briefed the Commission on the status and results of the pilot ISAP and recommended
Generic Items Mtg Mintues April 27, 1988 l
that the benefits of the pilot ISAP be made available to all licensees, j The Commission deferred action on extending the ISAP concept beyond the i pilot program and asked the Staff to determine the industry's interest in participating in such a program. Accordingly, the Staff issued ' j Generic Letter 88-02, dated January 20, 1988, to all power reactor j licensees describing the ISAP II process and requesting them to respond l to the following questions to determine their interest in participating in that program: i
- Would you be interested in participating in ISAP II? If so, in !
what time frame?
- Do you believe that an Industry /NRC seminar consisting of a brief discussion by NRC followed by a question and answer period would be )
beneficial prior to making a ' decision? l l
- Would you be interested in a one-on-one meeting with the NRC to discuss your particular facility or facilities? j I
- If you remain undecided regarding participation, what additional information do you need in order to make a decision?
' Do you have any potential concerns about participating in ISA" II?
- Do you have any suggestions for program improvements or changes?
Survey Results Mrs. Miller stated that of the 56 nuclear utilities, 50 have responded to the questions in Generic Letter 88-02. Results are as follows:
l
' Six utilities, representing 18 units, have indicated that they are j definitely interested in ISAP II. I i
j
Generic Items Mtg Mintues April 27, 1988
- Twenty nine utilit.ies, representing 52 units, have indicated they are possibly interested.
- Eighteen utilities have indicated that they are not interested.
Summary of Industry Comments Mrs. Miller discussed briefly some of the comments received from the industry in response to Generic Letter 88-02 (Attachment C, Page 1).
She said that several licensees expressed interest in attending a '
NRC/ Industry Seminar to obtain more information on ISAP Il prior to making a decision on participating in such a program.
Some licensees expressed concern about the Staff's proposal to implement ISAP 11 through license amendments. She mentioned that subsequent to the survey, this proposal has been eliminated.
One of the licensees suggested that the SEP issues be included in ISAP II. She stated that the Staff does not have any specific criteria for implementing SEP issues at non-SEP plants.
Mr. Wylie asked for additional information associated with SEP issues and the application of these issues to the non-SEP plants. Mrs. Miller responded that SEP was initiated to evaluate the old operating plants and to determine what changes needed to be made to upgrade these plants to meet current licensing criteria. Initially, about 137 issues were included in the SEP, and 10 plants were chosen for this program. All of these issues were evaluated and changes cade to these 10 plants, as necessary. Based on the lessons learned from the first phase of the SEP, the Staff decided that there are only 27 safety significant issues that need to be implemented in other older non-SEP plants.
Generic Items Mtg Mintues April 27, 1988
~
I In response to another question from Mr. Wylie, Mr. Thomas stateJ that the Staff has arrived at a qualitative judgment that implementation of I these 27 SEP issues at the non-SEP plants cannot be justified on a cost / benefit basis. They plan ^^ make such a recommendation to the .
Commissic.. in the near future.
Staff's Proposed Recommendation to the Commission Mrs. Miller stated that although the Staff believes that if ISAP II were not implemented, they would not have a coordinated program to encourage a PRA-based integrated and global approach to licensing and regulation of nuclear power plants, they realize that the resources required to support ISAP II appear to be relatively high. Also, they believe that the number of utilities that ultimately would participate in and benefit from ISAP 11 do not represent a majority. Because of the expenditures and the likely relatively low number of ultimate participants (i.e.,
,less than a majority), ISAP II becomes a lower overall priority item among NRR programs. Therefore the Staff recommends not to implement ISAP 11 at this time. The Staff will further evaluate the feasibility of initiating ISAP II or a similar program in subsequent years.
Dr. Siess commented that the statement in the proposed policy paper j which states that "The number of utilities that ultimately would partic-ipate in and benefit from ISAP 11 do not represent a majority," does not i i
seem appropriate since we do not know how many utilities would ultimate- l ly participate. Also, a large number of utilities expressed interest in attending an NRC/ Industry Seminar to obtain additional information on the ISAP 11 process; after such a seminar, several utilities might decide to participate in ISAP II. He believes that dropping ISAP II without conducting a seminar is a mistake. Also, it seems that several ,
utilities did not want to participate in ISAP 11 because of the pro-vision in Generic Letter 88-02 that ISAP II will be implemented through license amendments. Since that provision has been eliminated by the I
l
Generic Items Mtg Mintues April 27, 1988 Staff after the survey has been completed, he believes that additional utilities might be interested in participating in ISAP II.
Mr. Thomas stated that even after a seminar he expects that only about 20 percent of the utilities would participate in ISAP II. However, if a large number of utilities expressed interest in participating in ISAP II, the Staff could make a stronger argument for pursuing this program.
Mr. Michelson asked if the Staff proceeds with the IPE program, would that change any of the licensees' minds about participating in ISAP II.
Mr. Themas responded he does not believe that it would make much differ-ence.
SUBCOMMITTEE REPARKS ON ISAP 11 Dr. Siess stated that ISAP II is a good process and the Staff should try to implement it at least on certain plants first. After gaining the experience, it may be extended to other plants.
He solicited the opinions of the Subcommittee members on ISAP II.
~
Dr. Renick stated he b'elieves that ISAP II is a good program and it'is unfortunate a majority of the industry did not express interest in participating in such a program. He suggested that the ACRS may want to think about recommending to the Commission that over a period of time ,
all licensees should have a full scope PRA for their plants.
Mr. Ward stated that he believes that ISAP II and IPE should be combined and implemented as a single program. He reiterated his previous comment that each licensee should be required to perform and maintain a full scope state-of-the-art PRA, giving consideration to internal and ex-ternal events. Any new issues identified by the PRA should be combined with the existing list of outstanding issues, and then using the ISAP 11 approach these issues should be prioritized, resolved, and scheduled for implementation.
. \
l l
Generic Items Mtg Mintues April 27, 1988 Mr. Wylie stated he also believes that IPE and ISAP Il should be combined and implemented as a single program. He agrees with Mr. Ward ;
that the licensees should be required to perform a full scope state-of- l the-art PRA.
l After further discussion, the Subcommittee decided to propose to the
~
l full Conmittee the approach suggested by Mr. Ward. !
INTEGRATION OF RELATED GENERIC ISSUES - MR. W. MINNERS, RES Mr. Minners stated that the Staff has been integrating related generic issues for quite sometime, it has been done during the prioritization j and resolution stages and he believes it should also be done during the implementation stage. He provided some examples issues that have been i integrated (Attachment C, Pages 2-7).
Dr. Siess asked who proposes integration of issues. Mr. Minners re-sponded that it is normally proposed by the Task Managers.
Dr. Siess asked whether the Staff has been successful in resolving issues through integration. Mr. Minners responded that he is not sure whether it has been that much helpful. There are some issues such as ;
USI A-17, "Systems Interactions," and USI A-47, "Safety Implications of Control Systems," that have been divided into smaller issues to achieve easy and faster resolution.
Mr. Minners mentioned that Dr. Speis has been preparing a paper to the Connission that explains integration of several matters such as IPE, Generic Issues, seismic issues, etc.
Dr. Siess thanked all participants and adjourned the meeting at 5:45 p.m.
Generic Items Mtg Mintues April 27, 1988
- AP*******************
.N0TE: Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document'Romn, 1717 H Street, N.W., Washington, D.C., or.can be purchased from Heritage Reporting Corporation, 1220 L street, N.W.,.
Suite 600, Washington, D.C. 20005, (202) 628-4888.
4
l LIST'0F DOCUMENTS SUBMITTED TO THE GENERIC ITEMS SUBCOMMITTEE APRIL 27, 1988
- 1. Presentation Schedule.
- 2. Draft Commission Paper on Integrated Safety Assessment Program II (Pre-Decisional Document)
- 3. Generic Letter 88-02, dated January 20, 1988.
- 4. SECY-87-219, Integrated Safety Assessment Program, dated August 31, 1987. .
l
- 5. Summary of April 7,1988 NRC Staff Meeting held with NUMARC on ISAP II.
- 6. Industry Responses to Generic letter 88-02, i
- 7. Previous ACRS Comments to the Commission on the Integrated Safety l Assessment Program, dated iluly 15, 1987. l l
- 8. Memorandum from R. Bosnak to K. Kniel, Integration of NUREG-0933 l Issues, dated May 27, 1986. !
- 9. Presentation Material Provided to the Subcommittee during the Meeting.
l 1
l ATTACHMENT A
, _ . . .. -. u _. . . _ . _ . _ . ._
,. '. - PRESENTATION SCHEDULE -
ACRS SU8COMMlTTEE MEETING ON THE GENERIC ITEMS APRIL 27, 1988 ROOM 1046, 1717 H ST., N.W.
WASHINGTON, D.C.
ACRS CONTACT:. Sam Duraiswamy .
202-634-3267 NOTE:
- Presentation Time should not exceed 50% of the Total Time allocated for a specific item. The remaining 50% of the time is reserved for the Subcomittee questions and answers by the Staff.
- Number of copies of the presentation materials to be submitted to the Subcommittee: 25 copies.
TOTAL PRESENTATION ITEM PRESENTER TIME ACTUAL TIME I. EXECUTIVE SESSION -- 15 mins 1:30 - 1:45 pm II. ISAP II Melanie Miller 165 mins 1:45 - 4:30 pm (NRR)
- a. Description of ISAP II
- b. Results of the Survey
- c. Staff's Recomenda-tions to the Comission III. INTEGRATION OF RELATED Karl Kniel 60 mins 4:30 - 5:30 pm GENERIC ISSUES (RES) J
- a. Issues that have been Integrated so far
- b. Issues in the process of being Integrated or Expected to be Inte-grated
- c. RES Reaction to the ACRS Coments in-cluded in its report to the Comission Dated April 12, 1988 IV. SUBCOMMITTEE REMARKS -- 15 mins 5:30 - 5:45 pm
- ADJ0 URN *** 5:45 pm A TTMCHM E Air 8
s 10
SUMMARY
OF UTILITY COMMENTS MUCH INTEREST IN ATTENDING AN NRC/ INDUSTRY SEMINAR CONCERNS LICENSE AMENDMENT UTILITY COST OF IMPLEMENTATION RESOURCE ECQUIREMENTS OVEREXTENSION WITH IPE AND ISAP II LEVEL OF NRC REVIEW AND THE PROCESS PROPOSED 54 WEEK SCHEDULE DUPLICATION OF EFFORT BETWEEN ISAP 11 AND IPE WHETHER UTILITY INITIATIVES WOULD RECEIVE APPROPRIATE PRIORITY CAN SEP ISSUES BE INCLUDED UNCERTAINTY ABOUT IPE GENERIC LETTER Arreenuta r c i C-I
_a. _.
o p* - L[ 0:) JL m
r e , ,
h )) m t 62 o ,
34
((
n 1 33 i 2 3
y 6 K. K.
r l e
F 7 II Y H 6 II t
l e
p m
o c
r o . .
))
y 51 l 34 l ((
a ,
33 i 1 t
r 6 , K. K.
a F 2 II p . H 4 II I
rI e
he tl ib ea T
d en . .
si ) ,) )
s 2 )9 1 ed 5 63 5 re ( (( (
dz 3 33 3 di 4 ar ema S 3 K. , K. K. K.
E F I 1 II7 I U bm H I 3 II3 I S u S os '
I t s e e C dr u I na s R u s E ot I N f a E h r G et r j o , , , ,
) ))) ) )
V D es a 7 . 885 0 5 E
E T
wse M ( 2 135 5 5 1 ((( ( (
L A sc n 3 0 233 3 2 3 B D no i 1 A I rr ,9 4 T L O
ep c
d e ]
8 J. K. K. K. K. K.
I 87 III 7 S nn r ) I I 16 III I
I 6 I
I N oo e 6 O ci v 5 C t o (
l a C 3 F az O ci )
it s K.
Y ni ( I R hr e I A co u [
M ei s . , . . , ,
M t r s ) ) ) ) ) ))) ) ) ) ) ) )
U p I 3 3 6 6 4 . 277 2 2 0 9 9 S e / 5 ( ( 5 5 1 3 se ) (
134 5 5 5 4 4 2 6 1 ( ( , ((( ( ( ( ( ( (
oh s 3 3 3 3 3 233 3 3 3 3 3 3 ht ( 2 1 3 w m 4 so f
t e K.
I A.
8 K. K. 3 J. ,7 K. K. K. K. K. K. K. K. , K.
I I F I 7 III I I I I I 6 I e I I I I I I H I 86 3 III I I I I I 5 _
us I sg . _
sn ii _
d .
en
. si _
of _
h t e _
h . ) ) ) _
ft y b a b o t ( ( ( _
s i 3 3 3 nt r _
ie oc o E H E t i E _
i T G T G T tl r O I O I O _
af P I N H I N H N 1 I I I I I I I I _
de i r _
l oe sl nb oa ct S _
ee . M _
hh o E tT N T I )
s e 4, w . u N os s A 3, he s L su I P 2, s /
es m N ) ) ) 1 li e O 1 2 4 (
b t I . ( ( ( ) )
a) I T 3 2 6 1 1 2 1 2 3 t r C ( (
sj o r A I. 2 2 3 4 4 1 1 1 2 5 7 8 9 1 2 j
o l.
i a hm a I
A. A. A. A. A 8 M A. C. C. C. C. C. C. C. C. D. D.
T( M T I I I I I I 1 1 I I I 1 I I I I I U{;UY no ot 8 g
} cy,?)3J
=C nC C[L p
k
f:
E < {"062
)
8 4
(
3 K.
I I
)
. 4
) ) (
3 7 2 3 4
( ( 2 3 3 D.
K. K. I I I I I I I s
e u
s s
I r )
o ,
3 j , ) ) (
a ) 8 4 2 M 8 4 3
( ( ( 2 i
n 3 3 3 4 1 K. K. K.
3 4 4 D.
d 3 I e I I I 7 - 7 I 7 r I I I 6 A 6 I 9 e
v ]
o )
C 6
) 2
(
s 3
(
e ,
u K. )
s ,
I 2 s ) , , ) , , ) ) I ) ) (
I 5 ) ) ) ) 2 ) ) 3 0 [ 3 3 2
/ 5 4 4 8 8 3 6 6 4 4 1 2 2
) ( ( ( ( ( ( ( ( ( ( ( (
s 3 7 3 3 2 2 2
(
3 3 3 3 3 3 2 3 0 3 m 1 6 9 7 D.
e K. B. K. K. K. K. K. K. K. H. K. K. E. K. 7 K. 6 6 I 4
3 t I I I I I I I 4 I I I I I , I I - 7 I - - I -
I I 5 I I I I I I 5 I I I I I 9 I I 8 6 I 8 8 I 8
) ) ) ) ) ) ) ) )
y a b b b a b b b b _
t ( ( ( ( ( ( ( (
M (
i r U 3 3 3 3 M 3 3 3 3 3 3 U
o I H E E E E I E H E E E E E i D G T T T T D T G T T T W T r E I O O O O E O I O O O O O T
O P M H N N N I I N M I N H I I I I I N N N I L N N o
N e
)
u s
t s n I
) )
o / 1 1 c m ) ) ) ( (
( e 5 6 ) 7 2 1 4 1 1 t 1 2 2 1 1 1 5 1 5 1 V I
( ( ( (
E r 3 1 8 1 2 1 1 2 6 2 3 2 2 2 3 3 I. 3 3 3 I. 2 2 3 L o 8 A. A. A. A. D. D.
8 j C. C. E. E. E. E. F. F. H. K. K. K. K. D. D.
A a D. F. 1 I I I I I I I I I I I I I I I I I I I I T M I I 1 I I I I I I I I I I I I I
I I
I I
I I
I I
I I
I I
I I I I I S Ia 5UI cN S Eo _
p E '( Ih [s
$? _
/ _
> b
. m2<y O3 W e .
- d. -
2 1
I. 3 5
2 7 1 6 0
9 ,
7 6 6 5 5
3 7 E. ,
I 7 7 I 3 s ,
e ]
u )
s 8 s (
I 3 r K.
o j I _
a I M [
3 n 3 i , 2 3 3 d 3 e 1
- 1 3 E. 4 ,
4 r - I 1 3 7 e C 1 C I 1 3 F
6 H v
o C ,
) ]
s )
( 4
(
e 3 u ]
4 s
I
/
)
s s [
K.
I I
8
[
2 2 3
( , .
3 _
m 2 6 2 2 1 8 7 e A. 5 C. 4 4 5 2 t I - 0 1
3 3 5 1 5 E. 2 , 1 ,
4 . 3 3
I I I - - - - I - 9 - 8 - 7 7
8 6 I B A A B B B I 8 1 - 6 - 6 8 2 8 2 A 1 8 2 _
] ]
) ) -
a b
( ] (
) 3 2 3 3
)
y E E E E T T T 3 ) _
t T O O b i O N N O E --
r N (
N [ [ [
T M 3 o ( P P O U i I I I O O W I N I P H E P r I S S S R R O S I
S I
S I I I I I ( D O G T P L U U U S S S S S E R O D D L U U U U U U U U I O R E M D H N D S _
M
. E o T N I e N S _
u A E
)
t s s L P
U S
S n I o / N I c m O C
( e I I t T V I C R E
E r A N 1 E L o K 2 7 8 7 3 0 3 4 5 6 G B j S 2 1 1 1 3 3 7 8 9 7 8 2 A a A. A 4 4 4 4 4 4 4 4 2 T M V T A A
A A
A A
A 1
6 8
1 W _
A A A A A A A 8 8 B C C
- E N
7 1
UNW Ng ,w ,
g 2C:g.Ow o W _
. =D
- t
- * , .8w
~
b.
1 I
I.
5 2 t 1
c.
1 2
2 1
b.
1 4 0
2 3 5 2 - F 1 A H s
e u
s s
I _
r o
j )
a 7 M b. ( ,
2 1 n a. ,
i 1 1 3 I.
d 5 2 ,
S e 2 2 B. 2 9 F r 5 1 I 1 4 H e
v o
C
)
s
(
e u
s ,
s , )
I 6
/ a. (
) 2 1 s ,
( 1 5 m I. 7 e , 5 6 , ,
4 t 5 9 4 2 6 2 B. 6 - 8 8 7 F I 6 3 4 3 3 1 1 4 B 6 4 6 H
) , _
y a _
t ( _
i r
3 M M 1 4 1 M U U U _
o H E P I I E E E H I H i G T O D D T T T G D G r I O R E I E O O I O I E I _
P H N D M L 'M N N R N H M H _
. S o E N U S
e S u I
) s t s S n I R o / O e
c T
( s C t A .
V I F _
E L
B j r
o 2
5 1
9 4 8 5 N
A M
2 S
, E) _
A a 3 5 3 1 7 0 5 6 1 2 2 3 U F T M 2 2 4 5 6 7 7 7 1 1 1 1 H H w 5mN $ zC ?80
- l o .
\
Summary of Related Unresolved Generic Issues Issue No. Related Issue No.
~
A-3, 4, 5 67.5.1 & 2 A-17 A-47, 43, 106, 128 A-29 A-45 A-3 0 .., 128, 48, 49 !
A-40 A-44 23, 128, A-45, B-56, IPE A-45 84, 99, 124, A-29, IPE A-47 A-17, 135 i A-48 121 1 23 A-44, IPE 29 62 43 A-17 48 A-30, 49, 128 49 A-30, 48, 128 51 62 29 66 67.5.1 & 2 A-3, 4, 5; 135 70 84, 94, A-45 75 115 79 82 SSMRP 83 84 A-45, 70 86 87 II.E.6.1 93 124. II.E.6.1 94 70, R.G. 1.99 l 99 A-45, 105 j 101 1 102 !
103 I 105 99, II.E.6.1, IPE 106 A-17 113 115 75 ;
121 A-48, i 122.2 124 1 124 93, 122.2, 125.II.7 125.11.7 '
124 128 A-17, A-30, 48, 49 130 134 135 67.5.1 & 2 B-5 B-55 B-56 A-44, II.C.4 B-61 8-64 (-h
. - ., -3 ,
. .. ,s-
- Issue'No. Related Issue No.
C-8 II.E.4.3, App J .
I.A.4.2(4) - ... _
- I.D.3 I.D.4. HF 5.1' ~,
I.D.5.(3)
I.D.5.(5) HF 5.2 I.F.1 II.C.4 B-56, HF 0 II.E.4.3_ C-8, App J ,
II.E.6.1 87, 93, 105 II.H.2 II.J.4.1 HF 1.1 HF 4.1 HF 4.4 HF 5.1 I.D.4 HF 5.2 1.D.5.(5)
HF 8 II.C.4 i
P C-1 l I
-- gr-#-ee--- +,.r wm- ..py ,,-. gyg---=o.<m-,-+y. -
egg,y.. gm ngg-mis v- wy+e,p9yy- p g-m--p.m-e--p ,,w.-vow .
w-9-e-qg-g,.c m agr9 -g-:-T-e-e , p y + 9a 9- g q-9-' y-ty ps--,r+gPp-Q $ M' e f -