ML20153G970
| ML20153G970 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8602280558 | |
| Download: ML20153G970 (92) | |
Text
(k (hhhth(h(hthththdI(hthshchch(hdId!ghthhh
(
G f
9/35 TRANSMITIAL 'IO:
Document Cbntrol Desk, 016 Phillips se AINANCED COPY 'IO: /
/
'Ihe Public Docunent Iban E
llit k%4 DATE:
cc: C&R
!att hs.
FBOM:
SECY OPS BRA!Di papers)
Attached are copies of a Ortnission meeting transcript (s) and related meeting docunent(s). They are being forwarded for entry en the Daily Accession List and placenent in the Public Docment Boan. No other distribution is requested or required. Existing DCS identification numbers are listed on the individual docunents wherever known.
Meeting
Title:
Md Mrs f N sn b koof ded N c.h 4
)
)
b%%3SM Troara m j
2 Meeting Date: 2l(M%
Open (
Closed E
DCS Copies 4
(1 of each checked) p' Item
Description:
Copies M
Duplicate Advanced Original May
'Ib PDR Document be Dup
- Cbpy*
p 1.
TRANSCRIPT 1
1 hhen checked, DCS should send a copy of this transcript to the LPDR for:
\\L3 l \\/1 C1 C A.f
$u 3
2.
l*
3.
4.
(PDR is advanced one copy of each document,
- Verify if in DCS, and two of each SIrY paper.)
Change to "PDR Available."
h N
8602280550 860219 g
7 PDR OWMhnnnlutimilmmmmuummmv0mmMMMMDWMMMMMMMMWMMMk
7 ORIGINAL Ni
. rv
[.Nls
' ?, -
I
?}'A
? UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'>4
~
.r C.~93
'N
- m..
E w. #[
.g In the matter of:
g COMMISSION MEETING i.-
68
'C Staff Briefing on Integrated Safety
-./$
7;g Assessment Program
.. ~ :. r,.
(Public Meeting)
., e,~*s*f.
T. g:
e%eq!
h +4 ;
Docket No.
'.4
.s' s
,2 pp 1.:
,k
~ '
. 44,
~ '
.(
~
ce t,,,,j-F A.
~
.k-,
,.. e e.
s i.s h ',. - 0; r
.. t,*$,,;.
- 9 'lT..rts
e ' :. ;n t
.l Y:.
- .;.,._ 6:
.Q
. '.t
. Location: Washington, D. C.
',1.
Date: Wednesday, February 19, 1986 Pages:
1 - 74
~N
~~
- T:
r.
_, 4;,'h
,'y,
,1
. a,- ;.c9.;9
.e.
y
- if* y'
-gy Q,f
.. e.
ANN RILEY & ASSOCIATES
,y Court Reporters
. 7,
~1625 I St.,
N.W.
/T i
(
l Suite 921
- 4~
'.,. n u
Washington, D.C.
20006
.,,,t j (202) 293-3950
..,",./ M,
+-
~
,,4 [
^
p. m.'
, ' t; '
- ' ar.
O o
1 D I S C LA I M ER 2
3 4
5 6
This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on S
2/19/86 In the C owe i s s i on ' s office at 1717 H Street, 9
N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain f
12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.108, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authori=e.
22 23 24 25
1 1
2 UNITED STATES OF AMERICA 3
NUCLEAR REGULATORY COMMISSION 4
5 6
Staff Briefing on Integrated Safety 7
Assessment Program 8
9 10 (Public Meeting) 11 12 1717 H Etreet, N.W.
13 Room 1130 14 Washington, D.C.
15 Wednesday, February 19, 1986 16 17 The Commission met in open session, pursuant to 18 notice, at 2:05 p.m.,
Nunzio J.
Palladino, Chairman of the i
19 Commission, presiding.
20 COMMISSIONERS PRESENT:
21 Nunzio J.
Palladino, Chairman 22 James K. Asselstine, Commissioner 23 Frederick M. Bernthal, Commissioner 24 Thomas M. Roberts, Commissioner 25 Lando W. Zech, Jr.
i I.
=. -. _.
i 2
1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
.m 2
S. Chilk, Secretary w
t 3
H. Plaine, OGC 4
V. Stallo, EDO 5
F. Miraglia 6
C. Grimes 7
D. Eisenhut 8
9.
10 11 12 13 14 15 i
16 1
i 17 18 19 20 21 22 l
23 I
24 l!5 i
l
1 3
1 PROCEEDINGS 2
CHAIRMAN PALLADINO:
Ladies and gentlemen, would you f
3 please take your seat.
i j
4 Commissioner Roberts has been detained, but he will 5
be joining us shortly.
He asked that we go ahead.
6 The Commissioners are meeting with the Staff this 7
afternoon to discuss the status of the Integrated Safety i
l 8
Assessment Program, ISAP, for operating nuclear pcwer plants.
J j
9 In mid-1984, the Commission approved an ISAP type of program i
10 for four plants.
The Commission's policy was published in the 11 Federal Register in November that year.
12 The pilot program originally proposed would have j;
13 involved an integrated review of four volunteer plants over a 4
1 14 two-year period beginning in early fiscal 1985.
Subsequently 15 the program became limited to a single lic6nsee, Northeast 16 Utilities, with ISAP programs for Millstone 1 and Haddam Neck.
17 In January of 1985, due to budget constraints, it i
18 was decided to defer implementation of the ISAP program.
19 However, Northeast Utilities successfully appealed to the NRC 20 to allow the resources necessary to conduct ISAP for the two
]
21 plants they volunteered.
l 1
22 Presently, I believe, we are funded to complete the 23 ISAP pilot program in fiscal 1986.
In fiscal ' 87, four FTEs j
have been authorized to incorporate the ISAP concept into 24 j
their normal traditicnal licensing activities for operating 25
+.+c-mm+---mymm,m-~.-mw._,,m,,.w yo.w,mm,.m,.,.
mr
,-e_,we-%e-n,-~,,-%---,+
4 1
reactors.
2 Recently the subject of ISAP was raised during the 3
Commission's deliberations on environmental qualification 4
extension requests for Millstone Unit 1.
The Commission 5
decided that there should be a meeting with the Staff to 6
determine how the 1984 ISAP policy was being implemented, and 7
this is the focus of today's meeting.
8 Let me ask if other commissioners have any opening 9
remarks.
10 COMMISSIONER ZECH:
No.
11 COMMISSIONER BERNTHAL:
Well, I have just got an 12 underlying question of why we are going to meet on something 13
(
that we have already decided we are going to kill.
Now I'm a 14 great supporter of this effort.
I frankly would have 15 preferred that it remain in the budget, and I think that the 16 Staff deserves great credit for the way they have handled the 17 program and attacked the problems.
I presume this is going to 18 be a retrospective on how well we did and what we can do in 19 the next six months, and then how are we going to phase it 20 out.
21 CHAIRMAN PALLADINO:
There are four FTEs that arc
]
22 still budgeted in '87.
I would be interested in knowing what 23 we are going to do with the FTEs, and also, I think, we ought 24 to hear from the Staff whether they have any important i
25 information they learned from the ISAP experience that maybe
--L s
a 5
1 we ought to consider for future years.
2 COMMISSIONER BERNTHAL:
Well, I agree with that.
3 Proceed.
4 CHAIRMAN PALLADINO:
Okay.
Any other comments?
5 Then let me turn the meeting over to Mr. Stello.
6 MR. STELLO:
Well, I will return to the question 7
Commissioner Bernthal raised in a minute, and let me just s.
8 summarize what we want to do today.
.I will have Darrell in a i
9 few minutes give you an outline of what we want to cover and, 10 of course, Chris will go in some detail into the program 11 itself.
12 What I want to focus a few comments on, though, is 13 that'I think as we get now near the end of the pilot program, 14 which is scheduled to be finished about the fall of the year, 15 I think although we have made some decisions in terms of the 16 budget, I think it is important -- and I have asked the Staff 17 to go back and look at the experience of the 1 SAP program, 18 look at the strengths, look at the weaknesses, and give an i
19 analysis of where they think we ought to go with it.
20 We expect that the four FTEs that are in the budget 21 that there are clearly going to be some positive things that 22 We learn from the program that we want to use to incorporate 23 into the existing regulatory program.
But I wanted to leave 24 open the question in response to Commissioner Bernthal, I
l 25 although we made a decision this year to do something, it t
6 1
doesn't seem to me that if after we're all finished, this is 2
really a very good program, and that we ought to do it, that 3
that is an issue that's closed forever.
4 I wanted to at least suggest, at least for myself, I 5
have an open mind, and I would urge that the Commission also 1
6 keep an open mind until we're finished.
Maybe this is a 7
program, as it's structured today, even, we could continue.
1 8
I could see significant benefit from the regulatory 9
point of view in continuing a program very much like the one 10 we have, or maybe we need to modify it, but we'll know that 11 when we finish.
12 I don't want to leave the impression that this is an 13 open-and-shut case, decided once and for all that we ought 14 never to do this.
I hope we don't adopt that attitude, and at 15 least allow the opportunity for us to come back to the 16 Commission in the fall of the year and give you the benefit of l
17 the analysis of the pilot program, and then revisit it at that 18 time.
c 19 That is the plan we have at the moment, and I think l
l 20 it is a reasonable one.
After we finish, we can come back and 21 then hopefully persuade all of us, one way or the other, that 22 this is -- if, in fact is a good thing to do, we'll do it.
23 COMMISSIONER BERNTHAL:
Well, Vic, let me make one i
24 other comment here.
I'm reminded by looking at one of my old 25 vote sheets here, which Staff supplied, perceptively supplied,
.n.,
,.n,.,_n_
e,.,r,n-.,,,_,_n_
,.a-
,.s 7
1 that way back when we considered what is a pilot program --
~
2 and I guess I must have voted along with some others that this 3
was to be just a pilot program at that time, this was summer 4
of '84 -- I also expressed the concern that the size of the 5
program and the money at that time that we were trying to 6
budget for didn't seem very realistic, that with budget cuts 7
it could very well face cuts.
8 one of the things that you might want to address 9
here today, because I can't even remember what it was, is the 10 NREP program.
What did that stand for?
11 MR. GRIMES:
National Reliability Evaluation 12 Program.
{' '.,
13 COMMISSIONER BERNTHAL:
All right.
Well, looking at 14 my old vote sheet where I speak of NREP, now that I know what 15 it is again, there was a question at that time as to whether 16 that might be a more effective program and approach.
You 17 might want to comment on what happened with that, whether 18 that may indeed be the best way to go now, or --
19 COMMISSIONER ASSELSTINE:
I think that was phased 20 out in favor of ISAP, wasn't it?
21 (Laughter.]
e 22 COMMISSIONER ASSELSTINE:
There's IREP, then there 23 was UREP, and then there was ISAP.
24 COMMISSIONER BERNTRAL:
What is the difference --
25 you might just want to address that, because it sounded like
8 1
there was a difference at one time.
2 MR. STELLO:
We will cover that in a briefing, but 3
again, I think you are raising a question of where are we 4
going in the future.
5 COMMISSIONER BERNTHAL:
Yes, that's right.
6 MR. STELLO:
We really need to have the benefit of 7
reflecting on what we learncd from this, and not be the least 8
bit hesitant to go back and revisit and do what seems 9
indicated on the basis of looking at that.
10 Let me turn to Darrell and get the first slide up, 11 if we can.
12 (Slide.)
l 13 MR. EISENHUT:
This slide is an outline of the item 14 that we are going to summarize today, including the benefits, 15 some of the background of how we evolved to get here.
Just 16 briefly.
We didn't want to go back in the long history of it.
17 The ISAP process, how it's working, what are the 18 objectives of the program, the scope of the pilot program, and 19 the schedule.
And perhaps, I think, more importantly, the 20 benefits, loosely in terms of benefits here.
21 We will also address -- there was a question at the 22 time of why the environmental qualification extension 23 request.
There was a question about how that's being handled 24 in ISAP.
We will address that also.
25 If I could have the second slide in the package we l
9 1
have handed out.
2 (Slide.]
3 MR. EISENHUT:
This is actually the last slide in 4
the package that came down to the commission previously.
We 5
will use it twice.
6 Up front, I'd like to make some comments before I '
7 turn it over to the Staff for our briefing.
And a couple of 8
recognitions, I guess, is the way I look at them.
9 One is if we look at the history of how we have 10 evolved in terms of the operating reactor backlog, that is the 11 operating reactor actions, which has been many thousands of 12 items, it's just a growing realization, I think, of the Staff 13 that we have got to figure out a different way to do business.
14 Every single time an event comes along, every single 15 time a major incident at a facility, or whatever, we all are 16 prone to develop action lists, action items, which almost 17 invariably will lead to some more actions for each licensing 18 plant around the country.
Every new USI often does.
All the
{
19 litany of items, and it literally leads to thousands and 20 thousands of items that are on the plate.
It leads to l
21 something on the average between 40 and 50 actions per utility l
22 per plant today, that is, that's out there.
l 23 ISAP was a program that was somewhat of a rethinking l
j 24 of those.
I remember using the analogy once with the 25 commission that the difference between -- we used in l
10 1
integrating schedules approach, it was just rearranging the 2
boxes in time, each little item, each little requirement, all 3
you do is rearrange them in time and lay them out.
ISAP was a 4
program designed at factoring all this together to try to come 5
up with a solution to all of the open issues before a utility, 6
and in fact, those items that are presently pending before the 7
Staff, to the degree you could look into the future and 8
foresee them and, so to speak, clean the slate -- take an old 9
operating reactor and have all the issues resolved at one 10 point in time.
That was one of the major objectives, and is a 11 major benefit of the program as we see it, that's going to 12 come out of Millstone and Haddam Neck.
13 Another thing that we are really looking at in 14 trying how to factor all this together, of course, is we've 15 got to turn off the spigot in terms of all these individual 16 little requirements.
Different places in different countries 17 around the world approach the problem differently.
Some l
l 18 collect them for 10 years and then look at them and decide 19 what you ought to do to fix the plant.
But we have been in a i
20 mode where each plant around the country has to change one 21 system, then two years later they may change it a little 22 differently, and they may change it a little differently.
23 Plants in the country are just all unique, they are not 1
I 24 standardized.
Those are facts of life and we have to como to i
25 grips with how to handle them.
L-----------,
-- - -- - --- - - - -- -~~ ~ ~
11 1
So we are trying to take the methodology, the 2
approach we get out of the ISAP program, factored together 3
with -- and it will be, we hope, being resolved about the same 4
time our tech spec improvement program is going to be 5
resolved, which would take a clean slate plant, you could 6
change its license to a new set of tech specs to highlight the 7
more important issues, and you also delete, therefore, the 8
lesser significant issues, what I will call purely 9
administrative matters, lccations of all fire dampers or fire i
10 detectors are in the tech specs.
Names and titles of 11 positions in the organizational structure.
Things that 12 require an awful lot of work to change, yet have a very low 13 pay-off in terms of what is in the tech specs.
3 14 We try to take the clean slate, modify the license 15 to have a clean, better package to go forth with, which will i
16 reduce a lot of the unnecessary items, and another benefit wo 17 are going to try to factor in is we are going to try to factor l
~
18 this together with the severe accident evaluation program.
19 Remember, we have a policy statement which, among 20 other things, points out that we have to do a reevaluation of 21 each operating plant to look for outliers from a severe 22 accident. standpoint.
We hope for these two plants the ISAp 23 will in fact suffice; that is, they have done a probabilistic 24 assessment.
We will be looking at these two plants and we arn 25 going to look at them against the severo accident policy an i
t
12 1
it's developed to implement that, to make sure they fit 2
together, to try to make sure that when these plants are done, 3
they are done.
There will be no other major issue pending 4
before them.
5 And if you put all these together, we think the 6
benefits clearly would be indicative of a program that, while 7
it has costs to be carried out for the utility, for the Staff, 8
it may well be when you look at it in the overall context of 9
the alternatives, it may well be a major net savings to both 10 the industry, the Staff, and everyone else.
11 That's generally what we have been striving for.
To 12 put it in perspective with Commissioner Bernthal's question,
(
13 when you take this, though, and you put it down your list of 14 all the items that are as we prioritize them of reduce the 15 backlog and everything else as you go down the list, the major 16 issue is going to be that next fall when we want to take a 17 re-look at this, is where does it stand on the overall 18 priorities.
It is clearly somothing that is desirable, it is 19 clearly something that may ultimately turn out to be not only 20 desirable, but the best way to manage it.
But we have to put 21 it in the context of where the budget stands.
22 Where we came down previously was if you look at the 23 program by itself, the lowest on the list we had and one of 24 the items that got zerced out.
We are going to try to look at 25 the bonefits of it, though, in the overall context of how they
13 1
all fit together at the conclusion of the program, which is 2
now aimed towards the fall of this year.
(
3 COMMISSIONER ASSELSTINE:
What's in it for the 4
Llcansee?
What benefit do they get out of this program?
I 5
MR. EISENHUT:
Well, a couple of things.
You might 6
even say an overall package of requirements, it makes better 7
sense.
It is certainly better and easier to manage, but it in 8
a financial benefit as well.
Clearly if you look at these two 9
cases and look at some of the SEP plants, the reconsideration 10 of these requirements and putting them together in a package 11 may well be more cost-beneficial than has -- in the cases we 12 have seen it has actually been beneficial.
13 CHAIRMAN PALLADINO:
Does this help them schedule 14 their outages better?
15 MR. EISENNUT:
Oh, certainly.
In fact, one of the 16 things, if you look at many of the plants, they have this huge 17 wave of requirements that have always been a year or two 18 away.
If you could somehow come up with a program that starts 19 with a clean table, like a brand new plant, you're clearly l
20 way, way ahead.
You don't have thousands of workers working 21 during each outage.
22 In fact, from my standpoint, I think a utility 23 almost needs to reconsider this kind of program.
The 24 difference has been whether or not the NRC has actually been I
25 receptive to reconsidering the requirements.
That, I think, f
I i
14 1
is the real difference.
2 MR. STELLO:
I think that's a question that's a good 3
question.
Northeast, you recall, did come in and say they 4
thought this was the right way to go about it, and they were 5
enthusiastic.
I think it would be appropriate when we make 6
this reassessment to ask them what do they think this program 7
did for them, what is their view of it, and got their input, 8
since they will have participated in both plants.
And we'll 9
do that, we will ask them to give us their view of the ISAP 10 program as they saw it.
)
11 I don't know that you can sense overall industry 12 reaction one way or the other.
I don't have any clear picture 13 of whether the industry is for or against it.
I got mare of a 14 sense that they are opposed than they are for.
15 MR. EISENHUT Yes, I think the last comment was, 16 you know, it depends upon whether the utilities really believe 17 that we are serious about looking at all these requirements 18 and factoring them together and coming up with a solution that 19 makes sense, or la this another opportunity where things are 20 ultimately going to get very complex, got out of control, and 21 they are going to end up with more and more detailed 22 requirements.
23 So, to somo degroo, it really relatos to the lovel 24 that we are going to be looking at occh of the items.
But 25 from our standpoint wo think it in clearly bonoficial, and tho
15 1
utilities should look at it.
2 Northeast was, of course, as Vic said, very, very 3
strongly behind the program, arguing in favor of it, and we j
4 hope it continues to bear out like it does.
5 COMMISSIONER ASSELSTINE:
Why isn't this program a 6
good candidate for furding through a user fee?
Particularly
)
7 if there is a benefit to the Licensee.
i 8
MR. SIELLO:
User fee is a very complicated 9
question.
I 10 (Laughter.)
11 MR. STELLot It got so much more complicated than I j
12 ever dreamed this morning in terr.s of its --
I i
13 CHAIRMAN PALLADINot Well, let's riot go through that 14 again.
I i
15 (Laughter.)
l i
l 16 COMMISSIONER ASSELSTINE:
It's fresh on my mind.
i
\\
17 MR. STELLO:
I don't know that there is an easy i
i 18 answer.
I think we'd better wait until we'vei had a chance to i
l lo sit down and look at it.
I think we are tak'.ng it apart in so j
20 many pieces tha't I'm beginning to lose track of where we are 21 myself.
I i
l 22 CHAIRMAN PALLADINO:
On what, on the user fee?
l 23 ER. STELLO On the user fee issue.
I think we need j
24 to comprehensively look at it and come back to the i
25 Commission.
In stating a view now, on anything, I think would l
i t
16 4
1 1
be improper, because I am sure I'd be coming back later and 2
- saying, "I wish I hadn't said that, because I'm going to have 3
to tell you I don't agree with myself now."
I 4
It's getting too complicated.
5 MR. EISENHUT:
In fact, though, we do collect hourc 6
and charge like we do on any other plant.
In terms of 7
standard charge per hour, I believe, expended on the progras.
j 8
So that's --
9 COMMISSIONER ASSELSTINE:
Oh, so you have --
4 10 MR. EISENHUTt Cost recovery per item in this plant 1
l 11 would be just like any other plant in terms of the work we are 12 expending on the projects.
(
13 CHAIRMAN PALLADINO:
In terms of what?
14 COMMISSIONER ASSELSTINE:
Do you have it in terms of 15 what you have recovered?
]
16 MR. EISENHUTt The work we have expended per each l
17 project in terms of -- just like OLs.
We charge so many -- we i
18 keep track of how many manhours are expended on licensing 19 reviews.
We do that -- we have been doing that for years.
20 COMMISSIONER BERNTHAL:
But do you collect money, i
21 then, for that?
I 22 MR. EISENHUTI ch, absolutely.
r 23 MR. STELLO The Treasury.
24 COMMISSIONER BERNTHAL Then why are we losing money 25 for a program that's -- or losing the program when it's I
- - - ~
I 17 j
1 funding itself?
I 2
COMMISSIONER ASSELSTINE:
That's right.
How much of i
]
3 the cost of this program has Northeast paid for?
l 4
MR. EISENNUT:
I think Vic said the Treasury 5
recovers it.
6 COMMISSIONER ASSELSTINE:
To the Treasury, thon.
i 7
MR. EISENHUT:
It's a question of -- what you have i
8 to look at it is how much is being charged per hour, and those i
9 are the kinds of things I think you do have to look at.
We 10 have been charging for every OL in the country for every i
j 11 operating reactor.
12 COMMISSIONER BERNTHAL:
Let me see if I understand
((
13 what you are saying.
ISAP pays for itself, the money goes in l
14 the U.S. Treasury?
No?
i 15 COMMISSIONER ASSELSTINE:
How much have we j
16 recovered?
i 17 MR. STELLO:
Part of the license -- our l
18 relationship, NRC people with the Licensee, that part of it, I
10 there's a fee program for.
We have contracts that's not part 20 of it.
Again, we're getting very complicated.
We have a fee I
l 21 structure in place, where money does come in and it already i
j 22 goes back to the Treasury.
Now we are reexamining that issue 23 about how should we proceed, and I'd like to do that l
l 24 systematically, methodically, so that the answers that we give 25 are thoughtful and not off the top of our heads.
And I'm
18 1
afraid that if this conversation continues, that's all you're 2
going to get, is off-the-top-of-the-head responses, and it l
3 will contribute nothing.
4 COMMISSIONER ASSELSTINE:
Fair enough.
Fair 5
enough.
I think it would be useful to get a rack out for this 6
program --
l 7
MR. STELLO:
If you'd like that, there is a fee 8
structure, we'll give you the answer, how much of the -- how 9
much money wu got from Northeast Utility for this program, to 10 the extent we can find that out.
11 COMMISSIONER ASSELSTINE:
Right.
12 COMMISSIONER BERNTHAL:
Well, let me just -- I don't 13 want to talk about this much longer either, but let me just i-14 say that if it turns out that you can identify the cost of the 15 program, and it turns out that a substantial fraction of the 16 expense of the program is already being recovered, there are i
17 some --
i I
18 COMMISSIONER ASSELSTINE:
By the government.
j l
19 COMMISSIONER BERNTHAL:
-- by the government --
I 20 there are some utilities, at least one that's very 1
i 21 enthusiastic about continuing the program.
It's hard for me i
22 to understand why we should be cutting a program when it may 23 aven hold the prospect of paying its own way.
It seems to me i
l 24 we ought to get that straight before we -- we may have a 25 money-maker here, who knows.
19 1
1
[ Laughter.)
2 MR. STELLO:
Look, no matter how much money we get 3
back from these programs, we only have X dollars that Congress 4
allows us to spend.
That's so many dollars and so many FTEs.
i l
5 You use them for this or something else.
If we used all of I
l 4
6 them for this and had cost recovery, we wouldn't be able to do l
7 anything else.
j 8
COMMISSIONER BERNTHAL:
No, but the point, Vic, is 9
that the savings to the government are spurious, if the money l
10 is going into the Treasury.
There's going to be less money j
j 11 goir.g into the Treasury.
12 HR. STELLO:
But we already made that argument.
r
!(
13 What has it bought us?
14 CCMMISSIONER ASSELSTINE:
We have an opportunity to i
15 make that argument in April, I think, and we have committed to 16 do that, and it's at leant an issue we need to consider.
q 17 CHAIRMAN PALLACINO:
Why don't we go on.
But that i
j 18 is a very ir.portant question that we ought to deal with later 19 after the 3taff has had a chance to study it.
I 20 MR. STELLO:
And we will.
21 MR. EISENHUT I'd like to turn the briefing over to 4
22 Chris Grimes who's been the Director of the project, who's 23 been running it, and Trank MLraglia, the Division Director in l
24 charge is here.
Chris Grimas will go through the briefing, l
l 25 caming back again to the end of the last allde.
f
20 6-1 MR. GRIMES:
Good afternoon, gentlemen.
2 I would first like to go through and review briefly 3
the benefits of the program as we perceived them that 4
motivated us to come up with the ISAP pilot program concept, 5
and hopefully can touch upon a few of the questions that you 6
have raised.
7 As Darrell mentioned, the nucleus of this program 8
was from the Systematic Evaluation Program, in which we found 9
large sentiment that we had done a good job with the 10 differences from current criteria that were identified from 11 the SEP plants, and that we could have done a better job if we 12 had addressed all the other pending licensing requirements and 13 other issues, generic issues, and probabilistic risk insights.
14 And so that was the foundation upon which we built 15 the ISAP program.
It is a comprehensive review of everything 16 we can possibly find that could be considered a safety issue 17 on any given operating reactor.
That consists of the 18 licensing actions that we track so carefullyt probabilistic 19 risk insights that identify areas where there are potential 20 safety benefits that aren't explicitly addr'essed in the 21 regulatory requirements.
22 COMMISSIONER BERNTHAL:
Chris, you ought to keep up 23 with the times here.
I notice that probabilistic risk 24 assessment has been turned into probabilistic safety 25 assessment.
When did that --
21 1
MR. GRIMES:
A habit that I can't get out of.
We 2
changed --
3 CHAIRMAN PALLADINO:
Are they intended to be 4
different?
5 MR. GRIMES:
No.
It's that by any other name, a 6
rose is a rose, and it's a -- probabilistic analysis can be 7
anything from a reliability analysis to a risk assessment to a 8
safety assessment.
9 COMMISSIONER BERNTHAL:
Did the Commission vote on 10 this?
11 (Laughter.)
12 MR. GRIMES:
I would note that the Commission did 13 allow the language to proceed in their policy statement,
(
14 because we were trying to focus on safety benefits, as opposed 15 to risk.
16 I apologize.
17 COMMISSIONER BERNTHAL:
That's no problem.
18 MR. GRIMES:
We also wanted to do a comprehensive 19 operating experience review, because we found that we could 20 uncover weaknesses in plant design or operation by reviewing 21 the history of any given plant's operation.
And, of course, 22 there's the unresolved safety issues and the generic issues 23 that have been compiled in NUREG 0933, which constittite 24 essentially the state of the technology, and the areas where 25 we feel there are potential technology advancements.
And so
22 1
with the commission's approval, we started out with a pilot 2
program review, and in doing this, we have tried to focus cur 3
review effort so that we could establish relative safety, 4
because all too often we focus on an individual issue, and we 5
don't see how the safety aspects of that issue fit in with all 6
the other things that have to be addressed in a plant.
7 We were looking for efficiency.
We felt like that 8
both the NRC Staff and the Licensees could be spending their 9
time in a mere orderly fashion, rather than working in a 10 reactive mode.
We would like the industry as a whole, and the 11 NRC Staff, to get out in front of the problems and stop 12 reacting to problems as they occur.
13 In doing that, we need to be able to sort through
(
14 these things and identify immediate safety concerns.
We have 15 to be able to judge when we've found a safety issue that needs 16 to be acted on independent of an integrated process, and thoro 17 are examples frcm both SEP and, I think even in the Hillstono 18 case more recently, a risk insight or a safety insight, which 19 required immediate action that the Licensee took and the Staff 20 confirmed.
21 And as Darrell also pointed out, a lot of related 22 initiatives that interface with this program -- it we do the 23 probabilistic analysis properly, we can go a long way or maybo 24 oven supersede the objectives of the sovero accident policy.
25 (Commissioner Roberts entered the room at 2:30.)
23 1
MR. GRIMES:
Time will tell as we coordinate the 2
work that we have done with the IDCOR proposal and the work 3
that the Staff is doing to develop our severe accident 4
implementation plan.
And by the same token, by having 5
practical experience in working with plant-specific 6
probabilistic analysis, we hope to provide some more insights-7 into how safety goals can be developed and applied.
8 There are ongoing initiatives related to maintenance 9
improvement.
The outstanding USI activities that are going 10 on.
Here again, we feel that we might be able to provide some 11 practical experience to things like USI A-45 and decay heat 12 removal.
('-
13 And, of c,ourse, we felt that it was important to 14 recognize that there are plant improvements that the utility 15 is undertaking independent of the regulatory requirements, and 16 these related activities, and we want to look at those as 17 being part of the total scheme of things, and part of the 18 total research burden that the Licensees are trying to assume.
19 COMMISSIONER ASSELSTINE:
Chris, on something like 20 A-45 that you mentioned, how do you go about deciding what is 21 sufficient for a specific plant, like one of the two SEP or 22 one of the two ISAP plants in advance of the Staff having 23 reached a decision on how to resolve the issue on a generic 24 basis?
25 MR. GRIMES:
That is fundamentally part of the
i 24 I
1 purpose of the pilot program, is to try and structure the 2
decision-making process so that you can, as best you can, 3
second-guess where some of these related activities are going 4
to eventually come out.
5 In 1983, when we first started developing the i
6 concept of ISAP -- and at that time we called it SEP Phase 3 t
7 i
j 8
COMMISSIONER ASSELSTINE:
Right.
]
9 MR. GRIMES:
I would not have guessed where the 1
10 Commission was going to head on station blackout based on what 1
11 I saw happening at that time.
But I think that we had a fair 12 idea from the plant-specific PRAs that we had at that time
!(
13 j '
where some of the areas for improvement were, and this is i
14 fundamentally what we hope to develop, is a process by which 15 you can do decision-making in advance, and try and get -- the i
16 phrase that we used when we first proposed this program was 17 "the biggest bang.for the buck that you can get."
If a i
18 utility is looking at plant improvements that are related to 19 these issues, and they can go a long way towards resolving l
20 them, then by all means they should be doing that.
We i
21 shouldn't sit and wait for the resolution of generic issues to l
22 make improvements that we can logically structure into an l
l 23 integrated schedule.
)
24 COMMISSIONER ASSELSTINE:
What kind of conclusions i
25 have you reached, if you have reached them, thus far for ee-,m.---,ernm~,w-----
._n-~wr_nwe n.r. m,,,n, - -, - -.. -..
r.-mm,,,-,n-vr-.---.v-e.en-,-
m
25 1
Millstone 1 and Haddam Neck?
2 MR. GRIMES:
Let me get to that -- let me get to 3
that later because --
4 COMMISSIONER ASSELSTINE:
Okay.
5 MR. GRIMES:
-- it is somewhat premature to say that 6
we have got any substantial conclusions, other than to be able 7
to demonstrate to you that we have made some substantial 8
progress.
But let me get to that later.
9 COMMISSIONER ASSELSTINE:
If you can cover both 10 station blackout and A-45, that would be interesting to know.
11 MR. GRIMES:
All right.
12 Finally, I wanted to point out in advance that as
{
13 Vic pointed cut, there are a number of implementation 14 alternatives.
There are a variety of ways that we can take 15 the experience that we are developing and formulate it into 16 either a new programmatic element or into the existing office 17 structure, and that is one of the goals that we hope to 18 achieve from the pilot program, too, is to offer the 19 Commission an effective way to deal with operating reactors, 20 and I would suggest that doing two plants at a time every two 21 years is not going to hack it.
I certainly wouldn't want to 22 embark on a program like that, and I don't think the
~
i 23 Commission would want to, either.
24 So, clearly, this pilot program is going to lay a 25 foundation by which we hope to offer up a recommendation by
26 1
which all operating reactors can take advantage of a 2
methodology, a practice or a procedure that is going to 3
enhance safety as quickly as possible.
And so we are not 4
going to constrain ourselves to trying to find a new program.
5 We are going to look at this experience, hopefully, in a 6
broader view, and develop something from it.
7 Now havina explained to you what our goals are and 8
what we view the benefits of the program to be, let me go back 9
and cover some of the history so that we can explain to you 10 what we promised, and th'en tell you hopefully what we have 11 achieved.
12 Darrell mentioned that the history of ISAP is 13 something torturous, and I would just note that on Slide 3, we 14 list history of how we came to be here today.
15
[ Slide.)
16 It took some time to develop a pilot program and to 17 get it underway, but again the actual implementation is coing 18 much faster now than it was before, 19 The next slide will provide you the number of the 20 graphical depiction of the program.
21 (Slide.]
22 On the left-hand side of this figure is a list of 23 everything that we could conceive of that could be a potential 24 action for a Licensee to take.
Early in the program we were 25 concerned about a large backlog of TMI action plan items, and
27 1
since 1983, substantial progress has been made there, but 2
there are still some actions remaining.
3 COMMISSIONER ASSELSTINE:
Which ones are still 4
outstanding for these plants?
5 MR. MIRAGLIA:
Predominantly the Supplement 1 6
issues, which are the emergency operating facilities, things 7
of that nature.
8 COMMISSIONER ASSELSTINE:
Really?
l 9
MR. EISENHUT:
It's the upgrade, the emergency 10 upgrade to include the final SPDS and specific guidelines.
I 11 MR. GRIMES:
There are half a dozen issues, and they i
12 are all Supplement 1.
Control room design review; safety
~
(
13 parameter display system; Reg Guide 1.97 instrumentation; 14 emergency response facilities instrumentation; and a 15 post-accident hydrogen monitor; control room habitability and 16 BWR vessel level instrumentation are on this list, too, but 17 they are very narrow aspects of those issues.
18 But you will note that those issues from Supplement 19 1 in '83 and '84 were studies to be performed and actions to 20 be defined later, and we are generally consistent with those 21 implementation schedules.
They are not substantially 22 different than we originally planned.
23 MR. STELLO:
Chris, how many other actions ara there 24 besides those half a dozen you read off?
What is the total 25 number of pending actions on the plant?
28 1
MR. GRIMES:
We have identified 80 topics for this 2
plant.
And of those 80, we have got about a half a dozen that 3
relate to 0737.
We have got a few actions that are left over 4
from SFP that were further studies to define optimum 5
corrective actions, and we have reached the point where we can 6
lay those on the table, too, and see how they relate to these 7
other issues.
8 There are a lot of generic issues on this list as 9
well, at least ten of them or more.
10 Getting back to the figure, we distinguished the 11 probabilistic safety assessment and the utility plant 12 improvements so as to make it clear to the industry that we
(~
13 are not trying to impose requirements beyond the regulatory 14 requirements, but to show that they have a bearing, they have 15 a factor that needs to be considered, and this is one of the 16 incentives for the Licensees, is that by showing what actions 17 they have got on their list of things to do, we can compare 18 those and in some cases we have found utility plant l
19 improvements that have a bigger safety benefit than some of 20 the lesser regulatory requirements.
21 CHAIRMAN PALLADINO:
How do you use the PSA, the 22 plant safety assessment?
It's not quite clear how you use it, l
23 MR. GRIMES:
I'm going to get into that --
l 24 CHAIRMAN PALLADINO:
Later?
25 MR. GRIMES:
-- a little later.
_=
39 1
CHAIRMAN PALLADINO:
Okay.
2 MR. GRIMES:
And talk about what we have done with 3
the probabilistic safety analysis for Millstone Unit 1.
4 COMMISSIONER ASSELSTINE:
On the SEP Lessons 5
Learned, to what extent, if at all, are there indications as a 6
result of the recent event at San Onofre Unit 1 about the 7
adequacy of the scope and depth of the review, of the SEP 8
reviews?
Is that being looked at, at all?
9 (Commissioner Roberts left the room at 2:40.]
10 MR. GRIMES:
Yes, we are looking at that right now.
11 We have -- we owe the Commission a final integrated plant 12 safety assessment report for San Onofre.
We intentionally
! {
13 held that report until the incident investigation team's I
14 report was released and we could look at the findings from 15 that review and compare thnm to the SEP review.
16 When we forward the final report for~ San Onofre, we 17 will include some observations about what lessons were learned 18 in the San Onofre event in relation to the SEP review.
19 It is not clear to me right now that we could have 20 identified the sequence of events.
We might have been able to 21 identify some of the contributors to the event, and may even 22 have identified them and not acted in a way to prevent them 23 from having contributed.
But that is something that we are 24 reviewing right now, and we will explain to the Commission.
i 25 COMMISSIONER BERNTHAL:
It's a very important
30 1
question, though, that Jim raises.
You have on the left-hand 2
side -- it's still up there, I guess -- of this slide sort of 3
everything we could think of, and whether or not ISAP would 4
have picked it up apparently is a question.
You can't think 5
of everything, I guess, is one lesson to be learned.
But it 6
really would be worthwhile doing a careful analysis, and I 7
trust you will.
8 MR. GRIMES:
It's not going to be a very easy thing 9
to do, because San Onofre was one of the SEP plants where we 10 did not have a plant-specific probabilistic analysis.
We used 11 surrogate analysis.
12 COMMISSIONER BERNTHAL:
I see.
{"
13 MR. GRIME'S :
And it is not clear at this point 14 whether or not if we had done that review, would we have 15 identified the vulnerability in the check valves.
My 16 inclination is that we probably would have used generic 17 failure rates for the check valves.
18 COMMISSIONER BERNTHAL:
Yes.
19 MR. GRIMES:
Would we have looked at the failure of 20 the feedwater heater.
The Licensee had put that on the top of 21 his list of things to fix in the outage that was supposed to 22 occur eight days later.
We probably would have said, " Yeah, 23 that looks like a good thing to do," but we would never have 24 guessed that a feedwater event would have occurred coincident 25 with the degradation in the feedwater heater.
And that's the
31 1
kind of logic that we are going through right now to try and
~
x 2
reflect and see whether or not if we had done it differently, 3
could we have done a better job.
4 MR. EISENHUT:
But I think, as Chris said, you can't 5
hold too much weight on it, because things like the check 6
valve, where you have a whole series of check valves in 7
series, once you get past say three in a PRA, typically the 8
common mode consideration gets you, but you have to look at 9
that and say would that have stuck out?
Probably not.
And 10.
then check valves in the secondary side is something we 11 typically have not regulated -- in fact, haven't regulated at 12 all.
A lot of things on the secondary side.
Because it's
(
1, 13 non-safety equipment.
14 So it doesn't, from a design standpoint, doesn't 15 even end up on the list on the left.
It ends up only those 16 items where we do regulate are over there now, or wh'ere we are 17 considering requirements, or plant-specific issues.
18 Now if we'd had a big problem with some of these i
l 19 factors and considerations, it might have risen to the level.
i 20 I don't think you can hold out hoping too much that we'd flag 21 it in a program like this, that kind of problem.
I don't 22 think it will.
23 CHAIRMAN PALLADINO:
One thing, though, that events 24 like Rancho Seco and San Onofre have shown is that we have 25 multiple component failures at about the same time.
Do we
__-,,,.,---,---.--..n
~ - - - - - ~ -
-~e
---v
~
-m
32 1
have any mechanism to -- or do you look at concurrent failure 2
of a number of components?
3 MR. GRIMES:
We do that with the probabilistic 4
analysis.
5 CHAIRMAN PALLADINO:
You do?
6 MR. GRIMES:
Yes, we look at the failure rates that 7
are assigned to specific components.
We try and determine 8
whether or not the failure rates are reasonable by reflecting 9
on the operating experience review that we have done for that 10 specific plant.
11 We also reflect on events like San Onofre and say 12 where do I need to look hard at the uncertainties in those 13 failure rates?
And that's part of what we hope this process
(
14 can lead to, is a review process that carefully reflects on 15 what all this information is telling you.
16 How can you second-guess some of these events ahead 17 of time?
18 MR. STELLO:
Let me again suggest that we're doing 19 something I get nervous with when we start to talk about 20 something we haven't yet done.
We have not performed the task 21 in front of us.
Take what we learn from San onofre, compare 22 that with what we did in the SEP, look at where our weaknesses 23 are and why.
24 Now up until now I haven't heard the word " design" 25 mentioned.
" Design."
And it appears from what I understand
33 1
that the fundamental problem of San onofre check valves is a m
2 design problem where the check valve at part load conditions 3
hung too low.
We clearly don't get into that kind of design 4
review detail in either the SEP or the ISAP review, component 5
by component, nor can we expect to do it with the resources we 6
have.
So we have to visit the question of how to make sure 7
that that gets done.
8 Even what I've said causes me to pause.
We need to 9
do the work first and then come back and tell you, and we 10 haven't done it.
We are speculating.
11 COMMISSIONER BERNTHAL:
What happens on the 12 right-hand side of this thing?
You put all the input that you
('
13 can think of on the left.
You go through thi's process, and on 14 the right then there's some decision on requirements.
Is 15 anything like that now -- and you may have examples that I'm 16 not aware of -- but are all such decisions and new 17 requirements then au*;omatically subjected to the manual 18 chapter as it's being revised on backfit?
I assume that that 19 is the case.
20 MR. GRIMES:
That is the case where the Staff and 21 the Licensee disagree on the corrective action.
But in this 22 process we are going to allow the utility to take the list of 23 issues and propose corrective actions and then only focus on 24 those areas where we want to agree that we'll disagree.
25 COMMISSIONER BERNTHAL:
I see.
34 1
MR. GRIMES:
That was one of the lessons learned 2
from SEP.
3 MR. STELLO:
This is a voluntary program.
We have 4
not mandated.
He's agreed to come in and take this list and 5
look at them.
Then if there's something that we want to 6
impose as a requirement, then 51.09 applies.
7 COMMISSIONER BERNTHAL:
But you have had no cases 8
yet where you have decided that something ought to be done, 9
and --
10 MR. GRIMES:
We are right at the point now where we 11 are getting ready to sit down with the Licensee and go 12 through the list of issues and say, "Okay, what do you think
('
13 you need to do, and what do we think needs to be done," and
\\_
14 compare notes, and then let them make a formal proposal.
And 15 I'll get to that when I talk about the integrated assessment 16 process.
17 COMMISSIONEE ASSELSTINE:
On the left-hand side, the 18 far left-hand group, all the items you put on the table, 19 anywhere in there do you identify or does the Licensee 20 identify say some of the kinds of safety improvements or 21 modifications that other countries have done to improve the 22 level of safety in their plants?
Or do those only come up in 23 the context of individual generic issues, for example?
24 MR. GRIMES:
They come up in the context of possible 25 corrective actions.
35 1
COMMISSIONER ASSELSTINE:
Okay.
2 MR. GRIMES:
For example, in the Millstone case, 3
they have a substantial vulnerability to long term decay heat 4
removal.
Depending on the way that we can wrestle with some 5
esoteric issues like sabotage in this context, they may 6
consider one of the alternatives to be a bunkered system.
7 Fortunately Northeast isn't making the presentation behind me, 8
so they can sit in shock and wonder.
But the -- clearly some 9
of the other design alternatives that foreign countries are 10 considering is something that we could consider as a possible 11 corrective action to resolve some of these issues, and then 12 sit down and debate about it and see what benefits we could 13 argue for and against.
14 COMMISSIONER ASSELSTINE:
It always struck me as one 15 of the advantages of that kind of approach is then the 16 Licensee could say, "And if we do this, then here's what we 17 think it ought to relieve us from in terms of these other 18 specific issues."
Whereas if we had to make individual little 19 fixes to deal with all of these things, the cost would be more 20 than what we are offering in this consolidated package.
21 MR. MIRAGLIA:
It solves more issues sooner, 22 perhaps.
23 MR. STELLO:
That's precisely what the word 24
" integrated" means.
25 COMMISSIONER ASSELSTINE:
Good.
Good.
And that's
36 1
happened?
2 MR. GRIMES:
And that will happen on the right-hand 3
side.
4 COMMISSIONER ASSELSTINE:
Okay.
All right.
5 MR. GRIMES:
Another point I would like to make 6
before I go on is the concept of National Reliability 7
Evaluation Program was very similar to the severe accident 8
program.
That was to do plant-specific probabilistic analysis 9
for each operating reactor, identify their dominant 10 contributors to risk and then do something about that.
And so 11 in that respect, NREP constitutes that part of this total 12 package that is the risk insights, the safety improvements,
,("'
13 and the other probabilistic findings that are added to the 14 list of issues to consider.
15 It's --
16 MR. STELLO:
Chris, is it fair to characterize what i
17 we are doing now as a process for which it is far more 18 encompassing, and NREP is only a part of it?
19 MR. GRIMES:
I believe that that's true.
And I 20 think that it's also related to severe accident implementation 4
21 program, too, because that might have been viewed as the 1
22 successor to NREP as well.
But clearly the original intent
{
23 described in Task Action Plan 2.C.2 was to continue the 24 process of doing plant-specific probabilistic analysis, to 25 look for vulnerabilities in the plant designs.
I
_=
37 On the next slide it summarizes the steps for the 1
2 review process for ISAP and then I will briefly go through and i
3 explain to you for each of these specific tasks where we have 4
-- what we have accomplished so far.
5
[ Slide.)
6 This is, I think, an oversimplification of the 7
process, but it's the easiest way that we could think of to 8
explain the process.
9 Starting with the screening review on Slide 6, 10 following the implementation of program with SECY 85-160 on 11 May the 6th, Northeast Utilities completed the results of 12 their screening review and submitted their proposal on May 13 17th.
14 We met with them several times to discuss their 15 list.
We asked them to add some more generic issues that were 16 identified as high in NUREG 0933, and we issued a final list 17 of issues to be addressed and an evaluation date of July 31st, 18 1985.
19 CHAIRMAN PALLADINO:
And this is the left-hand side 1
20 of the diagram?
21 MR. GRIMES:
This is the entire left-hand side of 22 that figure.
The summary below shows that the issues that we 23 found pending that were not routine licensing actions -- that 24 is, we do a reload review when they change the fuel design, 25 and there are reload reviews that have been done for both 2
-,-,,,,.,,,.--.--,_,,_,,__-~,.~--,,---,.--..,_..c,_,
38 1
Millstone and Haddam that have complicated my, life a little 2
bit.
But that is not the kind of thing that belongs in this 3
program.
It's something that you periodically do, anyhow, and 4
the resource constraints and the time that we have to take to 5
do that are predictable.
6 CHAIRMAN PALLADINO:
This is what, reload?
7 MR. GRIMES:
Yes, fuel reload review, review of the 8
analysis for --
9 CHAIRMAN PALLADINO:
Are you going to include that 10 in here?
11 MR. GRIMES:
No, we don't include that in here 12 unless --
13 CHAIRMAN PALLADINO:
Not on the left side, but you 14 would when you put together the schedule?
15 MR. GRIMES:
When we look at the overall 16 implementation schedule, if there are things that are related 17 to fueling, we would, but.most likely you wouldn't find things 18 that are related to a routine activity like refueling in the 19 scope of this program.
There are some activities that you 20 just periodically have to go through as a part of the 21 operation of the plant, like refueling the plant, or allowing 22 for spent fuel, and where do you keep it.
Those kinds of 23 things have to be dealt with on a routine basis, rather than 24 the concept here was to --
25 CHAIRMAN PALLADINO:
But during the refueling outage L
39 1
you may be able to do a number of things that are on your 2
ISAP program.
3 MR. GRIMES:
That's true.
There again, that is 4
independent of the refueling activities.
Certainly you have 5
space limitations and a manageable size of work force on the 6
plant site that are going to be constraints for how much more 7
work you can do beyond the normal refueling activities.
So it 8
is a consideration from that aspect of scheduling.
9 But we identified 39 existing requirements for 10 Millstone Unit 1 that needed to be resolved, and 46 for Haddam 11 Neck.
We identified 10 generic issues or possible regulatory 12 requirements, and I think when we put this list together, it 13 included station blackout and ATWS, and now we have the rule 14 to deal with for ATWS, and the same for Haddam Neck.
15 Actually, I'm not sure whether we identified that as 16 a new requirement or as an existing requirement, and then the 17 Licensee identified 31 plant improvements for Millstone 1, and 18 12 for Haddam Neck.
Part of the difference there reflects the 19 Licensee's need to plan the outage for Haddam Neck in the 20 middle of the pilot program.
We did Millstone first; then we 21 will do Haddam Neck.
22 They defined the scope of work for the outage that 23 they are in right now that addressed a number of things that 24 they might have otherwise addressed in an integrated 25 assessment, but we couldn't -- we had to wait for the
40 1
probabilistic analysis to be done.
So they carved the scope 7.
2 of that work out and went ahead and implemented corrective 3
actions.
4 COMMISSIONER ASSELSTINE:
Now those plant 5
improvements, those are things that they want to do to benefit 6
reliability or whatever, and not directly in response to any 7
specific NRC requirement?
8 MR. GRIMES:
A common example that most utilities 9
refer to is retubing the condenser.
10 CHAIRMAN PALLADINO:
Is what?
11 MR. GRIMES:
Retubing the condenser.
That is a 12 cubstantial resource investment that they view as a high 13 priority from the standpoint of plant reliability, and that is 14 sometning that they usually put near the top of their list.
15 So, in sum, we came up with 80 topics for Millstone 16 Unit 1 and 70 topics for Haddam Neck as a result of our 17 screening reviewing.
18 Shortly thereafter Northeast began submitting the 19 topic reviews for Millstone Unit 1, and between August 13th, 20 1985 and November 25th, 1985, they submitted evaluations for 21 each of the 80 topics that we identified for Millstone Unit 1.
22 I wo~uld note that that is probably the fastest 23 response that I have ever seen to that large a number of 24 issues.
But there again we have to temper that judgment with 25 the lead time that they had from the time that we originally
41 1
envisioned the concept of ISAP.
So they had done a lot of 2
legwork.
But they pulled it together very fast.
3 All right.
We have right now a draft avaluation 4
that we are going to return to Northeast that tries to clearly 5
define specific issues related to each of those topics, 6
specific corrective actions or areas where there is an 7
uncertainty that needs to be resolved.
And that will be the 8
list of issues that we will address in the integrated 9
assessment.
10 Since the slide was prepared, we have an outline 11 schedule for Haddam Neck by which we would complete the 12 integrated assessment by the end of September.
The Licensee N
13 has proposed to complete all of their topic evaluations by 14 June the 30th, and they began with the first topic evaluation, 15 which was submitted on January the 15th for Haddam Neck.
16 On the probabilistic safety assessment, Northeast 17 submitted the summary report for the Millstone Unit 1 18 probabilistic safety study, as they refer to it -- the last 19 thing we need is another acronym for probabilistic analysis.
20 They submitted it on July the 10th.
We had contractor support 21 to review the analysis.
22 Here again, we had a running start because we had an 23 IREP study for Millstone Unit 1, interim reliability 24 evaluation program.
And so we were familiar with the systems 25 and the event trees and event sequences and so forth.
So the l
i
~
=,
,-,.---,,--,,,--c,,-,,-.--._----------,--,------m y
m..---. -. - -, - - -
-m
..--e
42 1
review went more quickly than I would expect a typical plant 2
review to go.
And we will get more experience in the time it 3
takes to do a plant-specific review when we do Haddam Neck's 4
PSA review, starting this fall.
5 One of tha most significant findings from this 6
activity was the vulnerability the plant had to long-term 7
cooling, which constituted 64 percent of the cumulative core 8
damage frequency.
9 Part of that was, we found, a result of certain 10 assumptions that they made in the analysis.
They short-cut 11 the event sequences by assuming when the suppression pool 12 temperature gets to a certain level you lose all MPSH.
It 13 didn't reflect other actions that could have been taken to
{
14 maintain MPSH for the pumps, and when those were factored in 15 along with some other immediate actions that the Licensee 16 took, we perceived that the number, when they recalculate all 17 of the changes that will be made, will look more like the IREP l
18 figure, which was on the order of 3 x 10 to the minus 4.
They 19 originally reported 8 x 10 to the minus 4, which was somewhat 20 unsettling.
21 There also are three other issues that came out of 22 our review that we have added as specific issues to consider 23 in ISAP, and those are isolation condenser reliability, 24 because of its paramount importance in a number of the 25 dominant accident sequences; capability to restore the main
43 1
condenser because of its -- the benefit that it plays in a 2
number of the event sequences; and the contribution of safety 3
relief valve failures to a number of the event sequences 4
there.
We need to look at the reliability of the valves and 5
what's caused some of the experience that leads to their 6
unreliability in the event sequences.
7 Those are issues that we are trying to articulate 8
right now, as issues to be~ addressed in the integrated 9
assessment, and they will also be reflected in our evaluation 10 report that we will submit to the Licensee for their review.
11 With respect to Haddam Neck, the Licensee is at this 12 moment, I expect, completing the analysis and working on 13 preparing a summary report which is scheduled to be received 14 in March.
I believe that it was within the last four to six 15 weeks that they sent us a report that they had identified a 16 vulnerability in the plant design in the process of going 17 through the structure that probabilistic analysis related to 18 the failure of air-operated valves for diesel cooling.
It 19 seems they rely on AC pcwer.
So the diesels were inherently 20 deficient with respect to the design of their support 21 systems.
That is another example of the benefits of doing a 22 plant-specific probabilistic analysis, and going through and 23 laying the plant design out in a logical fashion.
24 They have already taken action to correct that 25 particular vulnerability, and then when they submit the
44 summary report, we will go through another exercise of looking 1
2 for vulnerabilities that look like serious safety concerns to 3
see whether or not any other actions are warranted in the near 4
term.
5 COMMISSIONER ASSELSTINE:
Why wouldn't something 6
like that be picked up as part of the initial licensing review 7
in simply making sure that if you've got an emergency AC power 8
supply system, that it doesn't rely upon normal AC power to be 9
able to function for the support systems?
10 MR. GRIMES:
Sometimes those issues are identified.
11 I know that in the course of doing licensing reviews myself, 12 we have identified issues like that as we go through the
(
13 review.
But we don't perform 100 percent design review when a 14 plant is licensed.
We do an audit to see whether or not the 15 system functions, and even a good system is not going to be 16 perfect, totally perfect.
And so design flaws like these 17 sometimes show up in operating experience where you try and 18 simulate as best you can the circumstances under which the 19 equipment is going to be used.
But in a lot of cases like the 20 diesels, you don't simulate everything like the suppor.t 21 functions.
And that is why the Staff has been working on ways 22 to encourage the utilities to do plant-specific probabilistic 23 analysis, because it gives them a chance to lay these things 24 out and discover flaws like this.
25 COMMISSIONER ASSELSTINE:
Yes, I appreciate the
45 audit nature of the licensing review, but I guess what I'm 1
2 wondering is why wouldn't the licensing reviewer ask a more 3
general question of that type and put the burden on the 4
Licensee or the Applicant to make sure that he's fully 5
reviewed the design to identify those kinds of 4
6 vulnerabilities?
7 MR. STELLO:
He already has.
8 COMMISSIONER ASSELSTINE:
Now.
9 MR. STELLO:
That responsibility.
10 COMMISSIONER ASSELSTINE:
Yes.
Okay.
i 11 MR. STELLO:
He already verifies that it's 12 consistent with the requirements of which that is, but that
,7 ~
13 doesn't mean that he's perfect, either.
14 COMMISSIONER ASSELSTINE:
Okay.
15 MR. STELLO:
And when that does happen, it just says 16 that he has failed in doing the job as well as he ought to, 17 and there's a breakdown in the system that he has.
18 CHAIRMAN PALLADINO:
But if we were dealing with 19 standardized plants, we'd begin to learn all about that 20 particular --
21 MR. STELLO:
Either all of them would be that way or 22 none of them.
23 COMMISSIONER ASSELSTINE:
How long did this 24 situation exist at Haddam Neck, in terms of the support?
25 MR. GRIMES:
So far as I can tell, from the time the
--,..-~..-,*---.<-+---w
46 1
plant was originally licensed.
We haven't gono into the 2
details yet.
We were going to wait until we get the review of 3
the probabilistic to see exactly where some of the -- some of 4
the underlying information.
5 COMMISSIONER ASSELSTINE:
Okay.
6 MR. GRIMES:
But there was experience in the 7
systematic evaluation program where we uncovered design 8
difficulties or differences from what we thought the original 9
design was supposed to be.
10 CHAIRMAN PALLADINO:
And the review process itself 11 has evolved significantly since the days when Haddam Neck was 12 reviewed.
13 MR. GRIMES:
We've gotten a lot smarter at how to 14 ask questions.
15 COMMISSIONER ASSELSTINE:
Yes.
Okay.
Maybe I'm 16 misperceiving it, but it sort of strikes ce as sort of 17 fundamental that if you've got an emergency pcwer supply 18 system, you don't want that system to have to depend upon the 19 main power supply system that isn't going to be available when 20 you have to turn the emergency one on.
It seems sort of --
21 CHAIRMAN PALLADINO:
It's hard to get attention to 22 those kind of problems early on.
23 MR. EISENHUT:
You're talking over 20 years ago.
24 COMMISSIONER ASSELSTINE:
Yes, I guess so.
25 CHAIRMAN PALLADINO:
It's still a good question.
I
i 47
[
1 I
1 don't mean to imply it isn't a good question.
l 2
MR. GRIMES:
That's one of the more difficult parts s
l 3
about trying to do a review of a design when you think you 1
I 4
have asked the right questien about how the system is supposed 5
to function, and then in a probabilistic analysis you can see 6
how that works.
You can see that, you know, the 7
interrelationship in this is an exanple of a system's 8
interaction proble: that we are trying to wrestle with, too.
9 COMMISSIONER ASSELSTINE:
Yes.
l 10 MR. GRIMES:
It's not clear -- it's not abundantly 11 clear right now whether or not even if we had asked the l
12 question, we would have found it, depending on how the power J
- {'
to the buses is supplied by the diesel that supplies power to 13 j
14 the valve.
15 COMMISSIONER ASSELSTINE:
Yes.
E 16 MR. GRIMES:
There was this very simple solution 17 that in the event of an accident probably could have been r
i 18 taken, and that is go out and open the valve when the diesel i
19 doesn't start.
If you're smart enough to recognize that the i
20 reason the diesel didn't start was because the valve didn't 21 t
i i
22 MR. STELLO:
There's one other area that we probably 23 ought to give a lot of credit to Northeast as a leader in how 24 they go about doing their analysis.
They have an enormous l
25 in-house staff, and involve the people in the plant, which has i
l l
t
48 1
yet an additional benefit of doing the PRA, just the way they 1
j 2
go about it, over and above having it done for you.
And I
}
j 3
think we ought to give them some credit for the way they go 1
4 about it, because I do think they do a very good job.
i
}
5 MR. GRIMES:
One of the other questions that you 1
6 asked is how do we use this analysis to prioritize or rank l
7 issues.
And there are two answers to that:
8 The Licensee's answer is they are developing a 9
priorization scheme that will factor in the quantitative i
j 10 results of this analysis as a part of their ranking l
j 11 structure.
But it also considers other things like ALARA
}
12 considerations for the operators that have to install the
{ f~'
13 equipment, other scheduling constraints, reliability and i
14 maintainability, and the broader issues associated with how i
15 you rank individual actions.
16 CHAIRMAN PALLADINO:
Well, what do you do?
Do you 17 go through and make safety assessment -- probabilistic safety 18 assessment fcr various scenarios, and then find that this is 19 an important component in the particular --
20 MR. GRIMES:
Northeast's approach is to taka the 21 calculated reduction in core damage frequency -- I have to be 22 careful here, because I am not quite certain about the way 23 they come up with the number, but it's a risk reduction number 24 from the probabilistic study that then is put in an arbitrary 25 scale that simply says that there is a risk improvement
49 1
potential that goes from something like zero to lo.
2 That then is laid next to other scales that are 3
similarly fixed so that they are comparable, and then you get 4
a composite number.
5 I have done quite a bit of work with the integrated 6
scheduling processes.
There are a whole lot of softwaro 7
programs that are marketed on how you can come up with 8
importance functions for individual actions.
That's why there 9
are two answers to this question.
10 The Licensee's got his way of calculating his 11 importance function, and it is very different from the way 12 other utilities do it.
The Staff reviews it in a qualitative 13 sense, looks at the uncertainties in the probabilistic 14 analysis, and ultimately makes a judgment how these -- whether 15 or not these things have been stacked properly.
16 We don't think that it is feasible, at least at this 17 point, to prescribe guidelines on how the Staff is going to 18 decide whether or not the priorization scheme is right or 19 wrong.
It's probably neither; it's probably either adequate 20 or not adequate, and it will be a judgment.
21 (Commissioner Roberts entered the room at 3:15.]
22 COMMISSIONER ASSELSTINE:
How do you go about 23 assessing and weighing uncertainties to -- in that process?
24 You said you look at the uncertainties when you look at their 25 formula, or whatever.
50 1
MR. GRIMES:
When they have applied their formula,
~
2 they will come out with a ranking that shows something on the 3
scale from 1 to 10.
Based on all the work we have done with 4
the probabilistic analysis, we will have a, you know, first 5
cut reaction that says, " Yeah, they're pretty close, or l
6 they're not, or they missed it entirely."
7 Then after that, when we go down and look at the 8
individual actions by our experience we know where some of the 9
major uncertainties are in probabilistic analysis.
That is i
10 something we have learned in working with them.
11 We can't quantify it but, for example, where you do 12 an external events probabilistic analysis, you don't
{
13 immediately lump those together with the internal events.
You 14 have to weigh the larger uncertainty in the external hazards.
15 Similarly with fire analysis.
They have done a very 16 comprehensive job at defining all the possible, you know, fire 17 sources, and if they do an internal events fire hazards study, 18 that has to be viewed differently from some of the broader 19 brush fire hazards study that identifies selected locations j
20 for fires and has very broad uncertainties in terms of the I
21 potential for fire hazards and things like that.
22 So, there again, it's a judgment based on having 23 reviewed in detail the Licensee's analysis.
24 CHAIRMAN PALLADINO:
Chris, you implied or you said f
25 that there are a lot of different ways of doign this ranking i
51 1
of reduction in risk.
Are the variations so great that you 2
get significantly different answers?
3 MR. GRIMES:
It becomes essentially a numbers game, 4
because you can manipulate the numbers a variety of different 5
ways, but ultimately if you have got a system that's 6
consistent, rational, you are going to come out with the same 7
answer, regardless of what kind of number scheme you use.
8 There are programs that are marketed that use matrix 9
solutions for X number of attributes and Y number of benefits, 10 and will give you one number for an action that considered a 11 hundred different inputs.
But if we've done our review 12 reasonably, we will be able to just look at the list at the
'T 13 and and decide whether or not all those number-crunching 14 exercises have any value.
15 CHAIRMAN PALLADINO:
If I use a different matrix 'r o
16 procedure, would I get a different relative number or about 17 the same number?
18 MR. GRIMES:
Ultimately all we're interested in is 19 are they concentrating their efforts first on the most 20 safety-significant actions.
21 CHAIRMAN PALLADINO:
Yes, that's right.
22 MR. GRIMES:
You know, if you can't agree on whether 23 or not actions 5 and 6 ought to be reversed or not, you're not 24 being efficient and, remember, one of the objectives is 25 efficiency.
52 1
If they have decided they want to do one action 2
before another, and ultimately in the scheduling activities it 3
doesn't make an appreciable difference, then we shouldn't be 4
spending our time concentrating on it.
We ought to be looking 5
at a bigger, broader --
6 CHAIRMAN PALLADINO:
I wasn't thinking of that close 7
a comparison, but at least the extremes, this is the most 8
important, and that is the least important.
9 MR. MIRAGLIA:
I think that is what Chris is saying, 10 is that the set is probably the right set.
You might argue 11 whether it should be three, four, five, or reverse the order 12 of those.
But it identifies at least the right set of
(~
13 requirements.
14 COMMISSIONER ASSELSTINE:
What they don't want is 15 the most significant contributor being the one that's done in 16 1990 and 1993.
17 MR. GRIMES!
Yes, if the answer comes out the 18 inverse of what you expected its tilen clearly you have got to 19 go back and look at how to crunch in the numbers.
But by and 20 large, if they do a reasonable job of assigning some safety 21 benefits, using the numbers from the probabilistic analysis, 22 they are eventually going to come out on the order that is 23 reasonable.
24 COMMISSIONER BERNTHAL:
Tell us about the 25 significant finding.
53 1
MR. GRIMES:
The significant finding was the 2
vulnerability to long term cooling, and that even with a 3
redundant safety grade cooling system, that system is 4
vulnerable to MPSH by virtue of the way that a Mark I plant is 5
designed.
They limit the pool level so that you don't blow 6
Water all over the inside of the torus and shake it down, but 7
by the same token, you want those cooling pumps to have lots 8
of water on it.
And in the short term the Licenses took 9
action to alert the operators to the vulnerability, to change 10 the surveillance on the pumps, to make them more reliable, and 11 they are in the process now of looking at the design of the 12 plant with respect to some major upgrades to improve heat 13 removal capability, like increasing the size of the heat i
14 exchangers or replacing pumps or doing other things.
15 Ultimately because of the operator's awareness of 16 this problem, if they get into the situation, they know that 17 they've got an ultimate out to dump water in the torus as fast 18 as they can after the event has occurred, so as to avoid the 19 pool dynamics problems and they can increase the MPSH manually 20 by a variety of different ways.
But they wouldn't have known l
21 to worry about that if we hadn't gone through this exercise of 22 looking at the uncertainties and the requirements that you 23 assume for pump operability in the PSA.
24 MR. STELLO:
Chris, in the interest of time, so we 25 don't run out of questions, maybe there are a couple of points
54 1
that have to be covered on Slides 12, 13 and 14 that pretty s
2 well summarize it.
So maybe you ought to move on to Slide 3
12.
Do we have Slide 12?
4 MR. GRIMES:
Could we have Slide 12, please.
5 While he is putting that slide up, let me just 6
mention the total count we've got now for topics to address at 7
Millstone is 84, of which it appears about 22 of them are 8
probably resolved, so it will focus our review on 62 topics.
9 CHAIRMJLN PALLADINO:
84 --
10 MR. GRIMES:
84 topics total, because we added four 11 new issues.
12 CHAIRMAN PALLADINO:
I see.
13 MR. GRIMES:
Resulting from the PSA and operating 14 experience review, and because of the review process, it would 15 appear that about 22 of them are probably resolved just by the 16 exercise of doing a topic review which will narrow our focus 17 somewhat.
18 CHAIRMAN PALLADINO:
So you're saying the original 19 80 grew to 847 20 MR. GRIMES:
Uh-huh.
21 CHAIRMAN PALLADINO:
More or less.
Okay.
22 MR. GRIMES:
With respect to the environmental 23 qualification issue which the Commission debated this past 24 November, at that time we indicated that we were reviewing the 25 plant-specific probabilistic analysis, and that our perception
55 1
was that there was a small safety benefit for the valves for s
2 which North 6ast Utilities had requested an extension, and we 3
were going to complete that evaluation and determine whether 4-or not exemptions were warranted for these valves.
5 Slido 13 shows the chronology of how we get to that 4
l 6
point, and I would like to point out that since that time the 7
Licensee has completed their evaluation and they have 8
submitted a formal exemption request, comparing to the new 9
version of 50.12.
10 CHAIRMAN PALLADINO:
What sort of criteria are you "11 going to use to evaluate that exemption request?
12 MR. GRIMES:
We are going to use the criteria 1
1 13 expressed by the Commission in the new version of 50.12, one 14 of the six attributes for whether or not an exemption should 15 be granted.
16 COMMISSIONER ASSELSTINE:
That's the version of the 17 rule we just approved a couple of months ago?
i l
18 MR. GRIMES:
Yes.
19 MR. EISENHUT:
Yes.
20 MR. GRIMES:
It identifies the various bases upon 21 which the Staff can grant an exemption.
I think in this case 22 what we focused on is the modification required would not 23 serve the underlying purpose of the rule and that is to 24 provide the safety function for the environment involved.
25 On that basis we have drafted up exemptions for
~ _ _ _ - _._ _ _,___
\\
56 1
eight of the 11 valve operators, and we are in the process of
.m 2
puttiny that package together in order to act on the exemption 3
request.
4 However, for three of the valve operators, we don't 5
perceive that they can pass the test, that doesn't serve the 6
underlying purpose of the rule, and we have looked at the 7
probabilistic analysis and found that there is a small but 8
quantifiable safety benefit.
We want to compare that in the 9
integrated assessment to related issues.
In this case we are 10 talking about the recirculation valve, the LPCI loop selection 11 valves and the recirculation loops, and the condensate 12 transfer valve that provides water from condensate storage 13 tank, I believe, to the hotvell.
14 CHAIRMAN PALLADINO:
Where are you reading from?
15 MR. G2IMES:
I'm reading from Slide 14.
16 MR. EISENHUT:
Chris was just giving you a feeling 17 of what the items were and where they stand and our 18 preliminary conclusions.
I want to point out we are not quite 19 there yet in terms of deciding what to do.
20 COMMISSIONER ZECH:
But that's a very significant 21 benefit from ISAP, it sounds like to me, if you conclude that 22 which is, I think, very important.
23 MR. GRIMES:
Well, we have reached the point where 24 we have determined that we think we have passed the acid test 25 for an exemption basis for eight valves.
But we haven't
-n--,-.,
~r--
57 1
carried it through the process for the sake of efficiency, 1
2 because we have got three valves where we want to look at them 3
again in the big picture and say, "Do these things relate to 4
some of the other issues?"
And also to look at them from the 5
standpoint of in this case the only cost -- I shouldn't say 6
the only.
The costs that we need to consider in relation to 7
taking this action is the installation cost, the ALARA that it 8
would take in order to put the valve operators in, because the 9
Licensee has already purchased the valves.
10 The incremental safety is small, based on the 11 quantitative benefit calculation, but I note that in all three 12 of these valves, it related to cooling capability, and I
(
13 explained before, that long term cooling capability was the 14 dominant contributor to risk, so we are not precluding right 15 now that we might not want the Licensee to go ahead and fix 16 these valves.
i 17 COMMISSIONER ZECH:
But you are saying -- I think 18 that what you are saying is that there is a possibility that I
19 without the ISAP program that you would not grant an exemption 20 for any of these 11; and with the ISAP program in place, the 21 analysis has taken place, and your review also, it is possible 22 that you will grant exemptions for eight of the 11, which to i
23 me is a rather significant benefit of the whole program.
24 MR. GTELLO:
I think that's a fair comment, that if 25 it had not been for ISAP, we would have probably had to say, t
. ~ _ _,.
58 1
you know, to have them qualified, and not gone any further.
2 But I think it's only the beginning of a process that I think 3
is interesting.
4 COMMISSIONER ZECH:
I agree.
But we should -- if 5
that's true, though, we should look into that and see how we 6
can improve our own assessments and our own requirements.
7 MR. STELLO:
That's precisely the point.
Well, thus 8
far, you know, we have emphasized implementing things that 9
were on our plate that are requirements that are pending.
I 10 think that there is an equal need to examine some things that 11 we have done for which experience has shown us may detract 12 from safety as well.
I think I'd probably put Davis-Besse,
(
13 that steam and feedwater isolation system, pretty close to 14 that category of a requirement that maybe really isn't doing 15 the job we intend it to.
And if we had a process like this in 16 place, that would be a perfect time to raise the question.
17 Should that particular control system be in, in terms of its 18 relative benefit versus the problems it can create.
19 COMMISSIONER ZECH:
But the point is, I think, that 20 the analysis and the ISAP procedures perhaps deserve to be 21 reviewed for our own benefit to see where we could make 22 perhaps a better analysis along the same line.
I think that 23 is significant.
24 MR. STELLO:
And that is precisely what I said I 25 wanted to do and have a report back to the Commission in the
59 fall, and I suggest that we should keep an open mind --
1 2
COMMISSIONER ZECH:
We should benefit from this 3
example.
4 MR. STELLO:
Right.
5 CHAIRMAN PALLADINO:
I know it takes a lot of 6
expenditure on the part of the Licensee.
What sort of 7
expenditure of staff power and supporting dollars is it taking 8
to do what you're doing on Haddam Neck and Millstone 1?
9 MR. GRIMES:
We explained before that that is going 10 to be part of our evaluation.
We have recently reorganized.
11 I have got all the staff that I was orignally promised now, 12 but we are also doing SEP follow-up reviews and other things, f
13 so that the total staff level is not actually working 100 14 percent of their time on ISAP.
So we are going to sort out 15 how much time it actually took us to do the reviews for Haddam 16 and Millstone and make that a part of our --
17 CHAIRMAN PALLADINO:
Yes, that would be very 18 important in trying to assess resource needs for this kind of 19 activity.
20 MR. GRIMES:
It clearly ought to be a part of --
21 MR. EISENHUT:
In the ISAP branch today, doing the 22 review, granted there is some -- a certain fraction of it goes 23 elseuhere, but the number of people in the branch and the 24 total number of technical assistance dollars is what?
25 MR. STELLO:
Mr. Chairman, you'll get that answer.
60 1
It's a good question, and if we can't answer the question, how 2
many resources are we putting into something, then we have got 3
to go back and look at that.
4 CHAIRMAN PALLADINO:
Okay.
5 MR. STELLO:
But we will get you an answer.
There 6
ought to be a way in which it goes back to the RMS system and 7
just pull it out and we know how many contractor dollars there 8
are.
We'll get back to you, write you a note.
9 COMMISSIONER ASSELSTINE:
On the exemption requests, 10 assuming that there had not been an ISAP program, is there 11 anything to preclude No'rtheast from coming in with exemption 12 requests on these, the eight or the 11 operators?
What was it 13 about the ISAP program?
Was it the fact that they had done 14 the PRA that gave them a quantitative basis to justify the '
Is that --
16 MR. GRIMES:
Yes, I believe that that was 17 fundamentally the motivation, but --
18 COMMISSIONER ASSELSTINE: Okay.
So it would be done 19 in a plant-specific PRA.
That was the important factor that 20 provided them the information to justify their exemption 21 request.
22 MR. GRIMES:
That's right.
23 COMMISSIONER ASSELSTINE:
Okay.
24 MR. GRIMES:
Also if you look back through that 25 history you will see that the timing was fairly ripe for them,
.. = _.
~
l 61 1
too, because they were getting their probabilistic analysis
]
2 results just about at the time where they had to make their 3
last decision point on EQ.
J 4
MR. STELLO:
I think that's a simple answer.
It may 5
be too simple.
6 CHAIRMAN PALLADINO:
What was that?
7 MR. STELLO:
That is maybe too simple an answer.
We 8
had this particular program that got all of the attention that 9
it had to allow us to feel comfortable with the judgment that 10 we tend to not have devoted the time and energy to do the job, j
11 as well as the Licensee.
So I think this is on both sides.
I 12 think the existence of it made us feel a lot more comfortable
~
(
that we had that in-depth understanding, and we haven't made 13 14 the decision yet, you realize we haven't come down either way.
15 COMMISSIONER ASSELSTINE:
Yes.
16 MR. STELLO:
But the process that was there, I 17 think, added a great deal to it.
I think it would be too i
18 simple to say if somebody just had a PRA, that that by itself 19 would give them a basis, although I don't want to minimize 20 that, either, because I think it does add a great deal.
4 21 COMMISSIONER ASSELSTINE:
Okay.
22 MR. STELLO:
But I thinP. there's a whole lot more 23 here than just PRA.
24 CHAIRMAN PALLADINO:
Vic, I hate to keep pressing on 25 something you said you don't have the answer for, but I stf.11
62 1
would like to get a feel.
Are we talking about four or five s
]
2 people in our organization?
3 MR. STELLO:
Just give him a guess, call it a guess, 4
and we will supplement it.
And if you're wrong, we can say 5
that we told you now we sight be wrong.
So go ahead.
6
[ Laughter.)
7 CHAIRMAN PALLADINO:
Are we talking a dozen people, 8
two dozen people, four people?
9 MR. GRIMES:
We're talking -- right now I have a 10 staff of, I believe, 14 people, including secretaries, and I 11 think I have spent on the order of about --
12 MR. EISENHUT:
The budget for the branch is one 13 point we 14 MR. GRIMES:
Yes, the budget was on the order of 15
$L.4 million.
t l@
MR. ETSENHUT:
It's going to be within certainly the 17 first crder.
There's 14 FTEs, and $1.4 million has been le allocated to the program.
That's the resources we have given 19 Chris and said run the program.
Granted, he's got some other 20 things to do, but they're all going to be second order.
21 New recognize --
22 CHAIRMAN PALLADINO:
I'm not going to draw 23 significant conclusions from that, but it gives me a feel for 24 25 MR. EISENHUT:
Well, 1 mean maybe he's building a
63 1
swimming pool, I don't know, but those are the resources I
~
2 havo givsen him.
Unless he puts them somewhere --
3 MR. STELLO:
Don't kid about stuff like that at this 4
table.
There will be an investigation tomorrow.
5 (Laughter.)
1, 6
COMMISSIONER BERNTHAL:
Vic, we're changing the 7
rules for material false statement.
You don't have to worry 8
about that.
i l
9
[ Laughter.]
1 i
10 CHAIRMAN PALLADINO:
But we don't know what we're 11 changing them to.
12 (Laughter.)
4
(
13 MR. STELLO:
I don't know what material falso 14 statement is doing in an investigation.
That's a different 15 issue.
i 16 CHAIRMAN PALLADINO:
I was going to suggest that we 17 18 MR. STELLO:
Let me also remind the Chairman that i
19 although these are estimates, recognize that if we didn't have 20 this, we'd be spending some time on these plants and some 21 FTEs, too.
l 22 CHAIRMAN PALLADINO:
Yes, I appreciate that.
l 23 MR. STELLO:
And that's why we need to supplement 24 the record, to give you a better answer.
j 25 CHAIRMAN PALLADINO:
Well, one of the reasons for' i
l y____,_,____m
,_m_------..___,m._-._-.
64 1
asking the question is, I noted in my opening remarks that we 2
have got four FTEs set aside for fiscal '87 to do something, 3
and I was just wondering what do you see doing in --
4 MR. STELLO:
I tried to answer that right at the 5
beginning by saying it's clear to me that no matter whether we 6
decide we ought to revisit and have a complete ISAP program 7
for t'..e future of some kind, but it's going to be -- and in 8
fact is clear now -- that we are going to learn a great deal 9
of how to go about doing other reviews and we are going to 10 take that experience and use those four FTEs to integrate into 11 the rest of the regulatory program how to take the benefit of 12 what we learned from these two reviews and put those into the
{'
13 regulatory process.
14 Now that may be the right answer and that's all we 15 need to do, but again I plead let's keep an open mind and 16 visit that when we're finished.
17 CHAIRMAN PALLADINO:
- Well, I,
for one, have learned 18 a lot about this activity that I didn't know before, even 19 though I thought I knew quite a bit a. bout it, and it certainly 20 is a very complex and involved program, but it seems to be 21 giving insight that can be very valuable both to the regulator 22 and to the people being regulated.
And I think we do want to 23 keep on top of what you learn from it, and give un any 24 guidance or recommendations.
25 MR. STELLO:
I support where we are today.
I don't
65 1
want to change where we are today, but I would plead with thu 2
Commission, keep an open mind, because I hope that after we do 3
this report, if it does suggest that we ought to do something 4
a little bit different, that we are willing to go back and 5
revisit the issue and do what's right.
I don't know what's 6
right.
I'll tell you in the fall.
7 CHAIRMAN PALLADINO:
Okay.
I was going to ask you 8
if you have any final words of wisdom, and --
9 MR. STELLO:
That was it.
10 CHAIRMAN PALLADINO:
-- apparently you did and you 11 gave it to us.
12 Any other comments or questions on this?
13 COMMISSIONER BERNTHAL:
Well, I have got a broad 14 question that I guess is related to where we started here 15 today.
If this ISAP thing goes, I recall in various contexts 16 talking about -- let's see, we talked about SMART freezes, 17 SMART PRAs, whatever that all means.
But basically we have 18 talked about using staff's engineering judgment to try and 19 pick out those so-called outliers -- a term I hate -- the 20 plants that you think really are the ones that need a close 21 look.
I don't care wehat the acronym is, I don't care whether 22 it's under severe accio.ent policy, SMART, PRA, or what it's 23 called, but it seems 1.o me that that is a sensible objectivo 24 for this agency to be pursuing.
25 If this thing goes, how are we going to do that?
In
66 1
there going to be a mechanism that you have in mind to attack 2
this problem of making sure that however many there are -- I 3
think at one point somewhere in this stuff you said 11 4
plants.
I don't know whether it's three plants or 15 plants 5
that need a close look.
-- but what are we going to do?
6 MR. STELLO:
Well, if you continue this program, 7
this meaning ISAP that's in place today --
8 COMMISSIONER BERNTHAL:
That's a big if.
9 MR. STELLO:
I said if.
I only can answer it that 10 way.
-- then you by oLfinition have the probabilistic 11 assessment done.
12 COMMISSIONER BERNTHAL:
Right.
13 MR. STELLO:
Recognize that we are now already 14 approaching, I believe it's near 30 PRAs -- somebody told me 15 27 the other day.
16 MR. EISENHUT:
Yes, we were just looking at that.
17 If you look at it, there's an awful lot of plants that have 18 already got it.
It's just too early to tell how it's all 19 going to fit together.
20 MR. STELLO:
We have really not dealt with this 21 issue of how far any particular utility ought to go with a 22*
PRA.
I suspect there are some that are close enough that you 23 don't --
24 COMMISSIONER BERNTHAL:
The PRA, that was one 25 element that was
67 1
MR. STELLO:
No, no, I was trying to answer the 2
outlier PRA, SMART PRA judgment, that part of the question 3
first.
If you did this, you have the answer.
We're getting a 4
great deal closer to having a fairly substantial number of 5
PRAs done for which there are a lot of similar plants in 6
applicability.
The generic application of PRAs done 7
generically, one has to be careful.
6 The next part of the question is, given you don't 9
have this, then that's part of what we want to look at as well 10 in the fall.
But you do recall -- as I recall, in the severe 11 accident policy statement, we have committed to come back to 12 you to answer that question, as I recall, two years from the
(
13 date of the policy statement.
Am I wrong?
14 MR. EISENHUT:
No, that's correct.
And that comes 15 up this summer, I think, June or July of this year.
And the 16 policy statement asked that you either have to do something 17 like a probabilistic assessment or --
18 COMMISSIONER ASSELSTINE:
Surrogate.
19 MR. EISENHUT:
-- you use a surrogate approach.
But 20 you somehow have either got to argue you've looked across for 21 those significant contributors or else you can reference plant 22 that you can say you're comfortable with that one.
So we are 23 trying now, we are developing that program and we are trying 24 to look and see how these things can fit together.
25 MR. STELLO:
As I recall, we owe you the answer to
O 68 1
that very question, I think it's -- I don't remember whether 2
it's this summer, but I think it was two years from --
l 1
i 3
CHAIRMAN PALLADINO:
Well, it's coming up and 4
4 t
i 5
MR. STELLO:
You're going to see some of it in 6
connection, and I don't remember --
l i
4 7
COMMISSIONER ASSELSTINE:
It was last year, wasn't 8
it?
9 MR. EISENNUT The paper is coming down.
i i
10 COMMISSIONER BERNTHAL:
Now what about -- the PRA is 11 only a piece of this.
j 12 MR. STELLO:
That's right.
~
13 COMMISSIONER BERNTHAL:
This is an integrated safety i
14; assessment program.
Commissioner Zach has talked, for I
l 15 example, about developing a systematized set of indicators for
~
j 16 operating experience, and while there may be some disagreement l
1 17 here on how formalized that ought to be, it's clearly i
)
18 something that goes into and should go in the Staff's
!l 19 assessment and does go into ISAP.
There are great advantages, I
20 it seems to me, to sort of start from the beginning, put it 21 all in a basket and go through it systematically.
What about I
i 22 the rest of it?
PRA is one piece.
I 23 MR. STELLO:
Maybe we ought to continue to do ISAP.
3 4
24 We'll answer that in the fall.
But until we've done this, I I
l 25 am not prepared to answer it.
1
b 69 1
MR. EISENNUT:
But operating experience was one of 2
the inputs --
3 COMMISSIONER BERNTHAL:
Yes, I did.
4 COMMISSIONER ASSELSTINE:
But in terms of the 5
integrated look, this is it.
I mean there are elemer.ts of 6
this in different places.
If you want to pull it all 7
together, take an integrated look at safety at the plant, put 8
all the issues out on the table, ISAP is it.
That's the one 9
initiative --
10 COMMISSIONER ZECH:
Didn't I see something along the 11 line in something I read recently that the ISAP concept was 12 going to be incorporated in the operating reactor program for
(
13 fiscal year '87?
14 MR. STELLO:
That's what the four FTEs are.
We know 15 that we want to do at least that much.
Now how much more or 16 how we want to chang what w'e're doing it, or modify it, I said 17 I want to do the study that I have asked the Staff to do, have 18 available, and answer that question some time this fall.
19 COMMISSIONER ZECH:
In spite of the program, it 20 completes, I guess, in fiscal year 1986 that the concept and 21 the benefits, as I understand it, will continue in our 22 operating reactor program; is that correct?
23 MR. STELLO:
That's correct.
24 MR. EISENHUT And that's why we kept in the budget 25 the four FTEs.
70 1
CHAIRMAN PALLADINO:
And also -- go ahead.
2 COMMISSIONER ZECH:
If I may, at this point, I think 3
I saw in the five-year plan, which we were just reviewing, 4
that the living schedule which you referred to for the future, 5
I think it says by 1991 we will have 50 percent of the plants 6
have a living schedule or something like that.
My question is 7
what part does ISAP play in that living schedule, if any?
8 MR. STELLO:
I think the living schedule is a 9
necessary part of ISAP as well.
10 COMMISSIONER ZECH:
But will the concept of ISAP go 11 into that living schedule?
In other words, as Commissioner 12 Bernthal points out, the analysis we put forth, we should
{~
13 continue the benefits, it seems to me, of this program.
14 MR. STELLO:
Yes, but --
15 COMMISSIONER ZECH:
From our own standpoint.
16 MR. STELLO:
But ISAP is much more comprehensive 17 than just the living schedule.
The living schedule is to 18 simply take, without the benefit of this real integrated look 19 of everything, and make the judgments in trying to look at 20 those things for which we know just by looking at them if 21 the Licensee is doing a complete redesign of his 22 instrumentation system, that we ought not to be talking about 23 some particular modifications of instrumentation next year, 24 and then knowing in two years he is going to rip it out.
That 25 was a real case that I cited that I'm aware of.
71 1
What we want to do is say, hey, don't bother to do 2
what we told you, put it off and get that done when you do 3
your other job.
Integrate them.
It would be a lot more 4
efficient, and you don't have to disturb your instrumentation 5
system twice.
That's what I call the integrated living 6
schedule, by looking at the items on the plate.
But it i
7 doesn't involve the kind of systematic integrated process that 8
Chris was describing.
It's a part of it, but not nearly as 9
complete.
And maybe when we add what we're going to do with 10 the four FTEs and we add living schedules, that might be 11 another answer.
I don't know.
12 COMMISSIOllER ZECH:
Well, I'd submit that if you do
(
13 see the benefits from the ISAP program, that perhaps when wo 14 get into the living schedules, either from our standpoint or 15 the utility's standpoint, we may indeed want to factor in some 16 of that process.
17 MR. STELLO:
Yes, and I also quite frankly said I la intend to ask the utility for his comments and what he thinks 19 about it, and I'd like to find an opportunity to get a broader 20 feel from the industry, what do they think.
I really must say 21 I am confused in terma,of the feeling, does the industry think 22 this is a good idea, we ought to go about it, or --
23 CHAIRMAN PALLADIllO:
From liortheast Utility's 24 experience --
20 MR. STELLO:
They are warmly enthusiastic about it.
12 1
COMMISSIONER ASSELSTINE:
And the others are sort of m
2 watching to see how it turns out?
3 MR. STELLO:
Yes.
They're nervous.
They get 4
anxious about any time the government says, "We're here to a
5 help you."
6 (Laughter.)
7 CHAIRMAN PALLADINO:
I'm sorry, Jim.
Go ahead.
l 8
Just one question.
We have funded the pilot program 9
through fiscal
'86.
10 MR. STELLO:
Right.
11 CHAIRMAN PALLADINO:
Will we fulfill all our 12 requirements by the end -- for these two plants?
('
13 MR. STELLos If we finish by October '86, fine.
If 14 we don't, then we're going to adjust the resources to do 15 that.
But we will fininh.
16 CHAIRMAN PALLADINO:
But you think you are pretty 17 close?
18 MR. STELLO:
My judgment is we will.
19 HR. EISENNUT:
We will finish this program.
20 CHAIRMAN PALLADINO:
Excuse me, Jim.
21 COMMISSIONER ASSELSTINE:
It's still a little 22 unclear to me, and maybe you can either respond now or do so 23 in writing, either one is okay, how if it takes 14 people to 24 full-blown ISAPs for two plants or somewhere in that 25 neighborhood, what you are going to be able to accomplish with
73 1
four people in terms of trying to fold these ideas into the 2
regular program.
I'm not really sure I understand what four 3
people are going to be able to do.
4 MR. GRIMES:
Can I suggest that -- first of all, I 5
would like to offer a little explanation, and then I'd like to 6
7 COMMISSIONER ASSELSTINE:
Sure.
8 MR. GRIMES:
-- ask a favor.
The explanation is 9
that 14 people are not just doing ISAP.
We do a lot of other 10 stuff.
As a matter of fact, we work on integrated schedule 11 methods with respect to hopefully giving you a policy 12 statement on how integrated schedules fit in.
But I noted
(
13 that on the Commission list of activities, I owe you an annual 14 report the end of March, and Vic has already promised that I 15 was going to send you a note to explain our resource use and 16 allocation.
If I could make the two of those coincide and 17 give you an annual report that clearly lays out how we have 18 used resources thus far and what our projection is to complete 19 the two pilot plants, that would make life a whole lot easier 20 for me.
21 COMMISSIONER ASSELSTINE:
Sounds like a good deal to 22 me.
And talk about what you're going to be able to do 23 realistically with four people.
24 MR. STELLO:
It also eliminates the hazard of 25 quessing.
~
74 1
CHAIRMAN PALLADINO:
Okay.
Anything more?
I found s
2 this very enlightening, and I very much appreciate the very 3
fine presentation.
l 4
Thank you, and let's stand adjourned.
5 (Whereupon, at 3:40 p.m.,
the meeting war i
6 adjourned.)
7 i
8 f
1 l
9 l
i
[
]
10 11 r
13
(
14 l
i 15 16 i
I 17 l
I 18 i
F 19 l
20 j
21 ii 1
22 23 l
i
~
24 i
l 25 l
l
[
l
(' '
t 1
CERTIFICATE OF CFFICIAL REponTEH i
2 3
4 5
Th6s la to certify tnat the attached phoceed6nga G
before the Un6ted States Nuclear Regulatory Commission in the 7
matter of COMMISSION MEET!!;G 8
9 Name of Proceeding +
Staff Briefing on Integrated Safety Assessment Program (Public Meeting) 10 11 Occket No.'
12 Place: Washington, D. C.
13 Date: Wednesday, February 19, 1986 14 15 were held as herein appeart and that th6s le the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Ccmmission.
~
I '3 (Signaturo) f.,,,,
(Typed Name of Hoporter)
Ann'Riloy to 21 22 23 Ann H i ley 4 #444ec i a t es, Ltd.
24 25
ffkkkd '
INTEGRATED SAFETY ASSESSMENT PROGRAM COMMISSION BRIEFING FEBRUARY 19, 1986 ISAP BENEFITS ISAP BACKGROUND ISAP PROCESS s OBJECTIVES PILOT PROGRAM SCOPE PILOT PROGRAM SCHEDULE ISAP BENEFITS EQ EXTENSION - VALVE OPERATORS CONTACT:
C. GRIMES X 27775 ISAP BENEFITS COMPREHENSIVE a COORDINATED EVALUATION LICENSING ACTION BACKLOG PSA INSIGHTS OPERATING EXPERIENCE GENERIC ISSUES a US!s ESTABLISH RELATIVE SAFETY EFFICIENT RESOLUTION OF RELATED ISSUES IDENTIFIES IMMEDIATE SAFETY CONCERNS RELATION TO OTHER INITIAT!YES SEVERE ACCIDENTS a SAFETY GOALS MAINTENANCE IMPROVEMENTS OUTSTANDING USIs PLANT IMPROVEMENTS IMPLEMENTATION ALTERNATIVES CONTACT:
C. GRIMES k
X 27775 --
. j$S.h.
f ISAP BACKGROUND SECY 84-133, MARCH 23, 1984 PROPOSED FOUR PLANT PILOT PROGRAM CONGRESSIONAL REPORT, MAY 18, 1984 SEP EXPERIENCE ISAP CONCEPT SECY 84-133A, OCTOBER 1, 1984 STATUS OF AUTHORIZATION CONSTRAINT POLICY STATEMENT, NOVEMBER 15, 1984 49fB45112 SECY 85-160, MAY 6, 1985 ALTERNATIVE TWO PLANT P! LOT PROGRAM IMPLEMENTATION PLAN i
l t
I CONTACT:
C. GRIMES X 27775.
.._.a..
...._-------._-.-_.-.____.,_.__.a._s_a a
_.u._,.___.
_________a e
Ii l.ls i
~
l lilllill "!l l
g E
l l
lii
= ll
=
4-i l llli l
ll i
l il li'
,i ili i
i ill li
.i l
l ii si il
.4
ISAP PROCESS
\\
SCREENING REVIEW IDENTIFY OPTIMUM SET OF PLANT-SPECIFIC TOPICS EVALUATE BASES FOR SPECIFIC DEFERRALS.
TOPIC REVIEWS EVALUATE PLANT AGAINST CURRENT CRITERIA IDENTIFY SPECIFIC DIFFERENCES PROBABILISTIC SAFETY' ASSESSMENT IDENTIFY PLANT-SPECIFIC VULNCRABILITIES EVALUATE DETERMINISTIC ISSUES
(
OPERATING EXPERIENCE REVIEW IDENTIFY TRENDS AND PRECURSORS EVALUATE STRENGTHS AND WEAKNESSES INTEGRATED ASSESSMENT EVALUATE E ISSUES LICENSEE PROPOSED CORRECTIVE ACTIONS PUBLIC COMMENT AND PEER REVIEW FINALIZE SET OF ALL CORRECTIVE ACTIONS PRIORITIZE ACTIONS CONTACT:
c C. GRIMES X 27775
~[,
,m SCREENING REVIEW
~
NU SUBMITTAL MAY 17, 1985 SCOPE EVALUATION ISSUEB RY NRC JULY 31, 1985 MILLSTONE 1 HADDAM NECK EXISTING REQUIREMENTS 39 46 NEW REQUIREMENTS le 12 PLANT IMPROVEMENTS 31 12 TOTAL 88' 70
(,
W CONTACT:
C. GRIMES k.
X 27775,
i i
TOPIC REVIEWS MILLSTONE 1 NU SUBMITTALS AUGUST 13, 1985 - NOVEMBER 25, 1985 COMPOSITE EVALUATION IDENTIFYING SPECIFIC ISSUES
~
WILL BE COMPLETE IN FEBRUARY 1986.
HADDAM NECK f
SCHEDULE TO BE DETERMINED l
t l
CONTACT:
l C. GRIME 0 l
k' X 27775 l
". s 1.
PROBABILISTIC SAFETY ASSESSMENT MILLSTONE 1
SUMMARY
REPORT SUBMITTED JULY 10, 1985 DRAFT CONTRACTOR REVIEW ISSUED IN SEPTEMBER 1985 FINAL CONTRACTOR REVIEW ISSUED ON DECEMBER 31, 1985 PSA USED TO CHARACTERIZE SAFETY BENEFITS FOR 21 TOPICS SIGNIFICANT FINDING - LONG TERM COOLING HADDAM NECK
SUMMARY
REPORT SCHEDULED FOR MARCH 1986 CONTACT:
C. GRIMES X 27775 _
':~ j
- i
~
OPERATING EXPERIENCE REVIEW MILLSTONE 1 DRAFT CONTRACTOR REVIEW ISSUED ON AUGUST 19, 1985 NU COMMENTS SUBMITTED OCTOBER 3, 1985 NO SIGNIFICANT TRENDS OBSERVED HADDAM NECK CONTRACTOR REVIEW WILL BEGIN IN SPRING 1986 CONTACT:
C. GRIMES X 27775 l
4 INTEGRATED ASSESSMENT
~ '
MILLSTONE 1 IDENTIFY ALL ISSUES IN FEBRUARY 1986 COMPLETE INTEGRATED ASSESSMENT IN MARCH 1986 ISSUE DRAFT REPORT IN MARCH 1986 DEVELOP SCHEDULES BY APRIL 1986
~
ISSUE FINAL REPORT IN JULY 1986
(
HADDAM NECK TENTATIVE COMPLETION SCHEDULE FOR DRAFT REPORT -
SEPTEMBER 30, 1986 CONTACT:
C. GRIMES X 27775 '
~ - -
VALVE OPERATOR EQ 06/13/83 QUALIFICATION OF 28 OPERATORS IDENTIFIED 12/28/83 AS POTENTIAL ISAP TOPIC 04/05/84 EXTENSION TO MARCH 1985 02/28/85 NU REQUESTS SCHEDULE EXTENSION 03/28/85 EXTENSION TO NOVEMBER 1985 07/31/85 MOV EQ IDENTIFIED AS ISAP TOPIC 1.17' 09/30/85 NU REQUESTS EXTENSION FOR 11 OPERATORS, TO BE RESOLVED IN ISAP
(
10/30/85 SECY 85-345 RECOMMENDS DENIAL BASED ON EXCEPTIONAL CIRCUMSTANCE CRITERION 11/20/85 COMMISSION ORDER GRANTS EXTENSION FOR RESOLUTION IN ISAP, BUT NOT LATER THAN l
1987 OUTAGE.
l l
01/17/86 NU REQUESTS EXEMPTIONS FOR 11 OPERATORS l
CONTACT:
C. GRIMES i
X 27775 -.
ISAP BENEFITS COMPREHENSIVE & COORDINATED EVALUATION LICENSING ACTION BACKLOG PSA INSIGHTS OPERATING EXPERIENCE GENERIC ISSUES a USIs ESTABLISH RELATIVE SAFETY
~
EFFICIENT RESOLUTION OF RELATED ISSUES IDENTIFIES IMMEDIATE SAFETY CONCERNS
~'
RELATION TO OTHER INITIATIVES SEVERE ACCIDENTS 8 SAFETY GOALS MAINTENANCE IMPROVEMENTS OUTSTANDING USIs PLANT IMPROVEMENTS IMPLEMENTATION ALTERNATIVES CONTACT:
C. GRIMES X 27775 9
p::t,:.:.',..
?m l
MILLSTONE 1 ENVIRONMENTAL QUALIFICATION DEFERRAL HISTORY SAFETY SIGNIFICANCE RELATIONSHIP TO OTHER PROJECTS l
9 CONTACT:
C. GRIMES X 27775.
-: ~.
VALVE OPERATOR EQ
, ~,
(coni)
SAFETY SIGNIFICANCE SAFETY FUNCTIONS PSA FINDINGS MITIGATING DESIGN FEATURES RELATIONSHIP TO OTHER PROJECTS SEISMIC DESIGN CONTAINMENT LEAK TESTING SYSTEM RELIABILITY FOR C001.ING PRELIMINARY CONCLUSIONS EXEMPT EIGHT OPERATORS REPLACE THREE OPERATORS CONTACT:
C. GRIMES X 27775,
.