ML20155B585
| ML20155B585 | |
| Person / Time | |
|---|---|
| Issue date: | 06/02/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1674, NUDOCS 8806130247 | |
| Download: ML20155B585 (74) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
........................................................... )
ADVISORY COMMITTEE ON REACTOR EAFEGUARDS f
In the Matter of:
338th GENERAL MEETING AFTERNOON SESSION LOCATION:
Washington, D.C.
PAGES:
91 through 141 DATE:
June 2, 1988
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1 PUBLIC NOTICE BY THE 2
UNITED STATES NUCLEAR REGULATORY COMMISSION'S
-3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 6
7 The contents of th,is stenographic transcript of the 8
proceedings of the United States Nuclear Regulatory 9
Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statement or data contained in this transcript.
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
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4 In the Matter of:
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5 338th GENERAL MEETING
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6
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7 AFTERNOON SESSION Frid y, June 2, 1988 8
Room 1046 9
1717 H Street, N.W.
Washington, D.C.
20555 10 The above-entitled matter convened, pursuant to notice, 11 12 at 1:15 p.m.
13 BEFORE:
Dk.WILLIAMKERR Chairman
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14 Professor of Nuclear Engineering Director of the Office of Energy Research 15 University of Michigan Ann Arbor, Michigan 16 ACRS MEMBERS PRESENT:
17 DR. FORREST 4. REMICK 18 Vice-Chairman
. Associate Vice-President for Research 19 Professor of Nuclear Engineering The Pennsylvania State University 20 University Park, Pennsylvania a
21 MR. DAVID A. WARD Research Manager on Special Assignment 22 E.I. du Pont de Nemours & Company Savannah River Laboratorv 23 Aiken, South Carolina
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1 MR. CARLYLE MICHELSON Retired Principal' Nuclear Engineer 2-Tennessee Valley Authority l1 Knoxville, Tennessee 3
and Retired Director, Office for Analysis
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and Evaluation of Operational Data 4
U.S. Nucle r Regulatory Commission Washington,-D.C.
5 DR. HAROLD LEWIS 6
Professor of Physics Department of Physics 7
University of California.
Santa Barbara, California 8
DR. PAUL G.
SHEWMON 9
Professor, Metallurgical Engineering Department Ohio State University 10 Columbus, Ohio 11 DR. CHESTER P.
SIESS Professor Emeritus of Civil Engineering 12 University of Illinois Urbana, Illinois 13 MR. CHARLES J. WYLIE Os Retired Chief Engineer 14 Electrical Division 15 Duke Power Company Charlotte, North Carolina 16 MR. JAMES CARROLL 17 Retired Manager, Nuclear Operations Support Pacific Gas and Electric Company 18 San Francisco, California 19 ACRS COGNIZANT STAFF MEMBER:
20 Raymond F.
Fraley 21 NRC STAFF PRESENTERS:
22 J. Wilson S.
Crockett 23 M. Malsch D.
Scaletti 24 S. Treby 25 O
HERITAGE REPORTING CORPORATION -- (202)628-4888
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(1:15 p.m.)
3 DR. KERRs. Due to circumstances beyond our control 4
Mr. Moeller is not here for this afternoon's session. 'However, 5
Mr. Jamgochian is all set to make a presentation on Emergency 6
Planning, and we are all set to listen.
7 MR. JAMGOCHIAN:
Good afternoon, gentlemen.
My name 8
is Mike Jamgochian, I'm from the Office of Research.
I have 9
with me Dr. Donald Cool from the Office of NMSS.
10 What I'd like to do is to present to the ACRS two 11 rulemakings that the Office of Research has initiated recently.
12 The first emergency preparedness rulemaking for fuel 13 cycle and material licensees.
This was initiated right after 14 TMI.
We published an advanced notice of proposed rulemaking.
15 Later we published a notice of proposed rulemaking.
We had the 16 Sequoyah accident.
And now we're going forward with a notice 17 of final rulemaking.
18 Additionally, we had a prooosed rule that I'd like to 19 discuss with the ACRS relating to emergency planning 20 requirements for fuel loading and initial power operations for 21 reactors.
So two separate rulemakings.
The second is a proposed rule that was just recently 22 23 published in approximately three weeks ago, and the staff is 24 rapidly moving forward with that in order to evaluate public 25 comments and to publish a final rule.
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1 The Commission just published in the Federal Register 2
for this latter rulemaking, a 15 day extension of the public 3
comment period.
4 The first rulemaking, this is entitled -- the title 5
page is Emergency Preparedness Rulemaking for Fuel Cycle and 6
Other Material Licensees.
7 Page one gives you an exhaustive listing of the 8
history behind this rulemaking.
It was initiated in 1980.
It 9
was then determined, because the staff's attention was focused 10 on emergency planning rulemaking for reactors, the staff could 11 not move quick enough in order to publish a rulemaking for fuel 12 cycle and material licensees.
13 It was then established -- directed by the commission 14 to do something and to do it quickly.
So orders were issued in 15 February of 1981.
16 The advanced notice of proposed rulemaking was 17 published in June of 1981.
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18 DR. KERR When did the Commission give an order to 19 do something and do it quickly?
20 MR. JAMGOCHIAN:
I'm sorry, sir?
21 DR. KERR:
When did the Commission issue an order to 22 do something and do it quickly?
23 MR. JAMGOCHIAN:
The staff was directed by the 24 Commission.
Right. after TMI we had a number of hearings with 25 the Commission.
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1 DR. KERR:
No, when was the staff given that order by 2
the Commission to do something and do it quickly?
3 MR. JAMGOCHIAN:
Right after TMI.
4 DR. KERR So the order got lost somewhere.
5 DR. SHEWMON:
No, they did something.
6 MR. JAMGOCHIAN:
The orders were issued in February 7
of 1981, sir.
8 DR. KERR:
I have to assume that you didn't do 9
anything very quickly, so I assume the order must have got 10 lost?
It didn't.
Okay.
11 MR. JAMGOCHIAN:
Right after TMI we had several 12 discussions with the Commission on emergency preparedness in 13 general.
The staff was moving forward promptly for the 14 rulemaking for reactors.
15 At that time it was Commissioner Kennedy who was 16 worried about fuel cycle and material licensees.
He said, can 17 you do a rulemaking just as quickly for these folks.
The staff 18 said, no.
So the Commission then determined orders would be 19 more appropriate.
So, OGC or EOD back then issued orders to 61 20 licensees.
They said, you will establish emergency plans.
21 Those 61 licensees, I believe 30 came back and the 22 criteria was based on license possession limits.
30 licensees 23 came back and just lowered their license possession limit.
24 So, approximately 31, 32 licensees quickly established 25 emergency planning, fsb Heritage Reporting Corporation (202) 628-4888
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1 You will also notice that in July of '85 the ACRS 2
reviewed the proposed rule.
The ACRS, incidentally, voted 3
against publication of the proposed rule, and I'll go into 4
detail as to why you folks did that.
5 In November of '85 the CRGR reviewed and voted for 6
approval of the proposed rule.
7 In January of '86 we had the Sequoyah accident.
The 8
proposed rule was sent promptly to the Commission in March of 9
'86.
The Commission rejected it in September or October of 10
'86.
They said we did not address adequately and detail that 11 they wanted chemical toxicity.
The emergency planning for 12 chemical hazards.
13 We went back and revised the proposed rule, sent it
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14 back to the Commission, they promptly approved it, and it was 15 published in the Federal Register of April 8th of '87.
16 Comment period, the evaluated public comments we 17 received, about 15, 16, 17 public comment letters.
18 The final rule was sent in March of '88 this year to 19 the EDO.
The EDO said, well, we think it ought to be revisited 20 by the CRGR.
We have just come from a CRGR meeting in April of 21
'88, they again have approved it.
22 While we were doing that with the CRGR the ACRS said 23 that they would like to revisit this.
Thus, this presentation.
24 The differences between the proposed rule that the 25 ACRS rejected earlier and the final rule that we were proposing
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1 to go forward with are not very significant, and we will 2
mention those differences.
3 To give you some insight when the ACRS in 1985 voted 4
to reject or voted against promulgation of the proposed rule, 5
you were in company with a number of staff people as well as 6
the Chairman of the CRGR who was then Vic Stello.
This has 7
been from the very beg' inning a controversial rulemaking.
It 8
has not been unusual where many people did not perceive a real 9
need for this rulemaking as well as the ACRS.
10 The next page, the ACRS voted against the proposed 11 rule and in so doing they recognized that the regulatory 12 analysis, the NUREG-1140, was a valuable document, especially 13 for the use by the staff as well as licensees.
O 14 Two, the rule was unnecessary because licensees 15 already required to have emergency plans by the orders 16 published in 1980.
And that's still true.
The orders for 31 17 or 30 licensees are still in tact.
Licensees, those 31 i8 licensees have emergency plans in compliance with the order.
19 This rulemaking, some have indicated, is an 20 administrative task, simply cleaning up our act.
We shouldn't 21 regulate by orders, it should be by rulemaking.
It's more 22 consistent.
It tends to be somewhat of a relaxation from the 23 orders in that it doesn't require as much detailed emergency 24 plans that the orders required.
But this was one of the things 25 that ACRS focused on earlier.
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1 And the third thing the ACRS focused on was that this 1
2 approximately half a million licensee years of operation with 3
no significant.offsite doses.
4 The next page, this focuses on the differences that 5
exist between the proposed rule at the ACRS, Dade Moeller's 6
subcommittee and full ACRS review; and the final rule that 7
we're proposing to go forward with to the Commission.
8 One, there's a classification system, an emergency 9
classification system.
10 DR. KERR:
Excuse me, I don't want to be a nitpicker, 11 but how did the ACRS do its arithmetic to get 500,000 licensee 12 years of operation with 30 facilities?
13 MR. JAMGOCHIAN:
The ACRS did not let me in on their 14 rationale for that letter, sir.
15 DR. KERR:
That's the number that appears, 16 MR. JAMGOCHIAN:
That is in their letter.
I have a 17 copy of the letter here, if you like.
18 MR. REMICK:
Does include material licensees?
f 19 MR. JAMGOCHIAN:
Again, I would imagine so.
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l 20 you're asking me why the ACPS did --
21 MR. REMICK:
No, does the proposed rule include 22 material licensees?
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23 MR. JAMGOCHIAN:
Yes.
l 24 MR. REMICK:
Which are 20 or 30,000.
25 DR. KERR:
So this was not just a fuel facility.
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1 MR. JAMG0CHIAN:
See, it covers part 30, 40 and 70.
2 MR. WARD:
Do we have the letter here?
3 DR. KERR:
Fuel cycle and other material licensees.
4
.MR. JAMGOCHIAN:
I do have a copy of the letter.
5 DR. KERR:
Thank you.
Go ahead.
6 MR. JAMGOCHIAN:
The proposed rule did not establish 7
a classification system for the emergency.
The final rule, and 8
this is based on the Sequoyah accident, it was the lessons 9
learned, and the task force felt that it was appropriate to 10 have some sort of a classification system very similar to 11 reactors.
So that you have.an alert site area emergency.
12 But we suggested having a general emergency similar 13 to reactors, so we felt that the offsite response is very
' O 14 different.
Certainly, the offsite consequences would be i
15 certainly different.
So therefore we got rid of the general 16 emergency.
17 And the offsite response now at these i'acilities are 18 similar to those that would be required for reactors, the alert 19 status or the site area emergency.
20 The material, we had a requirement that licensees 21 notify the NRC operations, and we didn't have that in the 22 earliet emergency.
23 And also, as a result of a suggestion from EPA, that l
24 licensees notify the National Response Center, if releaces t
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1 We also put in here that the final rule requires 2
certification of coinpliance by licensee with the Emergency 3
Planning and Comaunity Right-To-Fnow Act of 1987, Title III, 4
Public Law 99-499.
This is an EPA law.
5 The fourth point is that the proposed rule required f
6 drills every two years.
The final rule requires quarterly 7
communication check as well as annual exercises.
8 If you recall, right after the sequoyah accident they 9
had a big to do on TV about the ability to communicate with 10 NMSS, Dick Cunningham as well as our region, as well as the 11 state folks, it was -- the interviews on TV were certainly did 12 not look great.
13 So as a result we learned from that and we required r
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15 MR. WARD:
So in the first sentence there, drill is i
16 the eame as exercise.
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Back then, yes, it was considered 18 the same.
Now it is not.
A drill tends to be a smaller focus t
l 19 on, maybe, an element in your emergency plan.
An exercise 20 tends to be a larger event.
21 MR. WARD:
Okay.
22 MR. JAMGOCHIAN:
Back -- in the proposed rule 1984 or 23
'-5, they were used interchangeable; now they are not.
So we 24 just wanted to make this clear.
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25 MR. WARD:
Back then you meant an exercise.
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1 99 (q) 1 MR. JAMGOCHIAN:
Yes, sir.
2 MR. CARROLL:
Does this exercise that there is still 3
a drill every two years?
4 MR. JAMGOCHIAN:
No, sir, it has been cleaned up.
5 But the focus on number four is, we now require it every year 6
instead of every two years, 7
And the last page is a conclusion page.
Obviously, 8
the staff perceived that the Commission wants, and the staff 9
has finally come to an agreement with, and CRGR has to concur 10 in the foct that the final rulemaking package should be sent 11 forward to the Commission for approval and publication.
12 DR. KERR:
This would be applicable to roughly how 13 many licensees?
Ik 14 MR. JAMGOCHIAN:
Approximately 31 licensees.
15 DR. KERR:
So it is not just -- it is primarily fuel 16 facilities, you do not just forward the material licensee -- I 17 mean, it does not include orders of material licensees for 18 small quantities of radioactive material.
19 MR. COOL:
Donald Cool with NMSS.
You are correct.
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20 It encompasses fuel faci]1 ties, and the US-6 conversion 21 facilities which you are probably looking at a fuel type l
22 facility.
It encompasses large material facilities; those who 23 have possession limits above a certain threshold in Curie 24 depending on the kind of Isotopes which they're authorized, but 25 small material facilities, those who had lim'.ted quantity of CE) l l
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1 material would not be encompassed within this rule.
2 DR. KERR:
Suppose a facility has 10,000 Curies of 3
Cobalt 60?
4 MR. COOL:
5,000 Curies, I'm told, is the criterion 5
for Cobalt 60.
A 10,000 Curie facility would be in.
6 DR. KERR Anything above, and you have to have 7
enough -- what do you have to have?
8 MR. COOL:
They would have to either -- one of two 9
things, provide an emergency plan or demonstrate to the 10 Commission that under reasonable and possible conditions that 11 doses to offsite member of the public would not exceed one rem 12 whole body doses equivalent.
13 DR. KERR:
If what?
O k/
14 MR.. COOL:
If there were an accidental release of the 15 facility, fire -- in the case of fuel facility, any type of 16 accidental event would be hypothesized for that facility.
17 MR. REMICK:
How about the case of sabotage of Cobalt la 60.
19 MR. COOL:
As a credible event at that kind of 20 facility it would have to be included.
21 MR. REMICK:
Who determines credibility?
The staff I 22 assume.
23 MR. COOL:
The staff is set of its criteria in terms 24 of the number of Curies.
If the licensee comes in and makes 25 a or attempts to make a case regarding a credible accident, J
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I then the staff is going to evaluate each of those on a case by 2
case basis depending on what the licensee brings in.
3 MR. REMICK:
You estimates this will only affect 31 4
facilities?
5 MR. COOL:
We estimate that there are something on 6
the order of 31 facilities who will actually be required to 7
have a plan.
There are a few more licensees than that right 8
now who are encompassed under this umbrella, something on the 9
order of 40 to 60, I don't remember the exact number right now.
10 Some of those will choose to reduce their possession limits, as 11 was the case with some licensees when the original orders were 12 issued in 1981.
Some of them will come in and wa expect will 13 have an acceptable case that that is not possible for them to O
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14 exceed the one rem whole body dose equivalent offsite, and 15 therefore they would not need a plan.
16 So we estimate that when all tho dust settles,.it 17 will be something on the order of 30 to 31 licensees.
18 Essentially the same set as are now encompasses by the orders 19 that were issued in 1981.
20 DR. KERR:
Well, I know of at least one exception to 21 this, that's the reason I'm asking the question.
I wonder how 22 many universities have more than 5,000 Curies of Cobalt 60.
I 23 know that we do; and I would guess a number dc.
So I think the 24 number is certainly going to be larger than the number that 25 received those orders originally.
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MR. COOL:
Let me make one further clarification.
If 2
your Cobalt 60 is in a sealed source, some type of a radio 3
unit, that would not be included.
It would be unsealed form.
4 DR. KERR:
I can't imagine that anybody has a Cobalt 5
aource that is unsealed.
6 MR. COOL:
Yes, but we have people who make Cobalt 7
sources.
8 DR. KERR:
Okay.
It is not the holder of the source 9
that you're concerned about, but the sealed source.
10 MR. COOL:
That would be correct.
11 DR. KERR:
Sealing includes pellets in stainless 12 steel tubes, is that what you mean by sealed, for example.
13 MR. COOL:
Yes.
14 DR. KERR Thank you.
J 15 That concludes your presentation on that particular 16 proposed rulemaking.
17 MR. JAMGOCHIAN:
Yes, that concludes my presentation 18 on that particular final rulemaking.
19 DR. KERR Are there other questions or comments?
20 Go ahead then.
21 MR. WARD:
Well, I have one.
In our letter of two or 22 three years ago now, we made reference to the national 23 contingency plan required by the Resource Coaservation Recovery 24 Act of 1976 as -- we apparently thought that this covered the 25 need that your doing a cover letter of rulemaking, would you
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comment on that.
2 MR. JAMGOCHIAN:
Actually, I think that reference was 3
. incorrect.
Nonetheless, radiological contingency plans were 4
required by the order.
Now, whether er not the ACRS was 5
correct or whether or not the orders are correct, nonetheless, 6
radiological contingency plans were required.
7 I know for a fact they were required by the order, 8
whether they're required by this law, I don't know.
9 MR. WARD:
But even if they were required by this 10 Act, you would still feel the need for a rule to-clean up your 11 act, as you say.
12 MR. JAMGOCHIAN:
Yes, sir, 13 DR. KERR Is that because you think that other Act 14 is ineffective?-
15 MR. JAMGOCHIAN Again, when I received that letter I 16 thought the ACRS was incorrect, because those words 17 "radiological contingency plans" were exactly what we called 18 them in our orders.
Today you call them emergency plans.
So 1 19 just thought that was possibly incorrect.
20 Nonetheless, licensees have emergency plans.
The 21 Commission has known that.
The emergency plans are fine right 22 now.
The Commission realizes that.
The Commission determined 23 whatever is out there, it is still necessary for the 24 regulation.
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Could you summarize the more important Heritage Reporting Corporation (202) 628-4888
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1 comment, public comment you received.
2 MR. JAMG0CHIAN:
A few comments said this was 3
unnecessary, as the ACRS said, that the industry has been doing 4
fine, why make them spend more money.
A number of commentors 5
said, why are you using the lower threshold for emergency 6
planning, the EPA protection action guide, why use one rem 7
whole body, why not use the 5 rem whole body, as we tend to use 8
in the reactor.
9 Some of the commentors said, oh, my God, don't get 10 FEMA involved in this, you already messed up on reactors, don't 11 do it again now.
Some were concerned, you know, if you require 12 emergency plans, if you follow the train of thought, then you 13 involve local governments, if you involve local governments you I) 14 involve state governments, if you involve state governments 15 FEMA has to get into the ball game; and once you do that you're 16 going to end up wit!. the same mess you have now with reactors.
17 So we listened to those and the perception was that 18 the emergency plans need not be elaborate; need not be 19 exhaustive; nr.ed not be focused on offsite response such as 20 formal -- this does not require a formal emergency plans from 21 state or local government for these facilities.
It is 22 basically a licensing plant, and arrangements are made with 23 fire, fire engines, fire departments offsite, hospitals 24 offsite, medical offsite.
25 Common sense k'nds of things, nothing elaborate, O
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1 nothing fancy.
2 MR. REMICK:
And it is youte contention that all of 3
the facilities that would be effected by this rule already have 4
emergency plans that are acceptable currently to the Commission 5
and would be under this rule.
6 MR. JAMGOCHIAN:
Yes, sir.
7 MR. REMICK:
Thank you.
8 MR. WARD:
I guess I didn't understand, you said a 9
while ago public comments was why cause the licensees to spend 10 more money, more resources, but are they going to have to 11 change their plans under this rule?
12 MR. JAMGOCHIAN:
Actually if they're going to change 13 them, they're not going to get into as much detail as they did
[)
s' 14 under the order.
The perception, once this was published, 15 right away, why are you messing around with an industry that 16 has been doing fine.
17 People that we received orders were 60 licensees; 30
'18 did something about it.
So the folks that really had to 19 respond to orders were only 30 licensees.
When a proposed rule 20 was published, again, anything published with a title of 21 emergency planning gets public attention, my God, what are they 22 doing now.
23 So when we said, fuel cycle and material licensees, a 24 lot of folks had perceived, well, they are revamping the world 25 again.
And we didn't get any complaints from the 30 licensees O
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I that already were complying with the orders.
It was some 2
states wrote in,~ what are you doing, this isn't necessary, 3
everything is going along fine.
4 So it was mostly the people that were not affected by 5
those orders that wrote in, it is going to cost money,. don't 6
mess with it.
7 MR. WARD:
That's what I mean, who is it going to 8
cost money, that's what I didn't understand?
9 MR. JAMGOCHIAN:
I'm voicing what the commentors were 10 concerned ebout.
It is the staff's perception that this would 11 not cost any additional dollars.
12 MR. WARD:
They misunderstood, the commentors 13 misunderstood.
14 MR..JAMGOCHIAN:
Well, they ran a news release and 15 didn't read the rule.
16 MR. WARD:
Thank you.
17 MR. CARROLL:
What is the rationale on using a lower 18 EPA threshold?
19 MR. JAMGOCHIAN:
The lower -- see, EPA, protective 20 action guides, are triggor levels for taking a protective 21 action.
One rem, in this instance, is used as a point upon 22 which you plan.
We're not saying you have to take protective 23 actions at one rem.
You should plan at a lower threshold.
24 We're requiring a plan; we're not telling anybody to run out 25 and do something as far as protective action is concerned at Heritage Reporting Corporation (202) 628-4888
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I the.one rem level.
We're saying, if there's a potential of 2
getting that kind of dose offsite, you should establish a big 3
plan.
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MR. CARPOLL:
That differs from reactors.
5 MR. JAMGOCHIAN:
Yes, sir.
Since the machine is 6
completely different, a whole lot.
7 DR. KERR:
The implication is that the exposure dose 8
from non-reactors is somehow more, of more concern than an 9
exposure dose from reactors.
10 MR. JAMGOCHIAN:
No, no one has ever said that.
11 Expr3ure dose is an exposure dose.
The point was that you 12 plan, when do you plan; and our focus was using one rem to 13 establish a requirement, to have a plan, not the taking of O
14 protective action.
That's all.
15 DR. KERR:
Does that say one rem, what do you use for 16 a reactor.
17 MR. JAMGOCHIAN:
Reactors by nature are required to 18 have emergency plans.
Clearly, as a potential for getting one 19 rem offsite.
Clearly, as a potential to get 5 rem offsite.
20 MR. REMICK:
Did any of the licensees have a problem 21 with offsite when you referred to one rem offsite, I'm thinking 22 of material licensees, sometimes that's not clearly defined.
23 It's not a clear cut facility like a reactor facility or a fuel 24 cycle facility, it could be a laboratory in a building in a 25 university on a campus, and where is the site offsite in that O
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case.
But-I guess it is moot because you are saying it only x.
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applies to unsealed sources.
3 MR. JAMGOCHIAN:
We did not get any letters from i
4 licensees that said that was a major problem.
et/1 5
(Continued on next page.)
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1 DR. KERR:
The next item.
2 MR. JAMG0CHIAN:
The next item is the proposed rule 3
that was published about three weeks ago.
In fact, the comment 4
period was supposed to end on the 8th of June.
And as I 5
mentioned earlier, it has been extended for fifteen dayn by the 6
Commission.
7 Page one gives some very general background.
As I am 8
sure that we all know, in 1980, the emergency planning 9
regulations were upgraded.
That was a direct result of TMI.
10 In 1982, July of 1982, it was realized that the staff did not 11 do a very thorough job in 1980, and that we completely ignored 12 fuel loading and low power testing.
13 So we proceeded with the rulemaking in 1982, that O(_-
14 said, and that is on page three, that the July 1982 emergency 15 planning requirements requires a finding of adequacy of an 16 applicant's onsite emergency planning and preparedness.
Not 17 any state or local emergency plan as such, just the onsite 18 emergency plan.
And it required a review of an applicant's 19 onsite plan involving some aspects of the offsite elements.
20 Now the rule itself was very general.
And this is 21 almost a quote, the second bullet on page three.
But in the 22 supplemental information, and I do not know why we did it, we 23 included what we would look at as far as these offsite 24 elements.
Typically, I would usually put that in the 25 regulation itself.
But for some reason, we did not.
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1 Nonethe ess, on page four, it lists those offsite 2
elements of the applicant's plan that would be looked at.
Now 3
again, this is not part of the regulation that was put in the 4
supplemental information. But it details what elements, what 5
offsite elements, that the Commission would look at in the 6
onsite for the applicant's plan.
7 First, arrangements for requesting and using offsite 8
assistance.
Second, accommodation at the emergency operation 9
facility for state and local government staff.
Notification of 10 state and local authorities.
Prompt notification of the 11 public.
Adequate emergency facilitiee and equipment.
12 Capabilities for assessing and monitoring potential offsite 13 doses.
Arrangements for medical services.
And emergency Gkl 14 response training.
15 Now age.in, very limited emergency planning elements, 16 and limited to the five percent power and fuel loading.
17 DR. KERR Are these markedly different from what one
'18 would look at if one were looking at the regular emergency 19 plan?
20 MR. JAMGOCHIAN:
Significantly.
21 DR. KERR I know that one would look at more than 22 this, but would one look at any of these?
23 MR. JAMGOCHIAN:
Certainly in much more detail.
24 First of all, we have sixteen planning objectives that one 25 would look at say for full power.
And all of the details that r'T U
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1 are outlined in Appendix E.
You would look at FEMA's approval 2
of state and local emergency plons, detailed emergency.
3 DR. KERR:
What I am trying to find out is whether 4
this list of things would be subsumed in the general emergency 5
plan, or are these completely different?
6 MR. JAMGOCHIAN:
No, they aro the same thing.
7 DR. KERR:
So if you had the emergency plan in place, 8
it would have already taken care of this?
9 MR. JAMGOCHIAN:
Yes, sir.
10 DR. KERR:
So this in a sense fills in a gap during a 11 time period when the emergency plan for the whole thing 12 operating at full power has not been put in place?
13 MR. JAMGOCHIAN:
That is correct.
G l
14 DR. KERR:
Thank you.
15 MR. RCMICK:
Was this not precipitated by a hearing, 16 if I recall, at San Onofre, or Diablo Canyon, where a licensing 17 board I think had ruled that you had to consider seismic 18 effects in emergency planning before you could get a low power 19 license, and the Commission disagreed and put out these 20 guidelines and said we eventually will have rule making?
21 MR. JAMGOCHIAN:
The seismic, I was involved in also.
22 And basically, it was out West.
And they said you had to 23 consider the effects of an earthquake on your emergency plan.
24 And then the Commission said, no, no, we do not want to do 25 that, and published a proposed rule that said do not consider O
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1 the effects of an earthquake on emergency planning.
And then 2
it went-to the courts, and the courts said it is not 3
appropriate.
And so then the Commission dropped that 4
rulemaking, and said we will just listen to the courts.
That 5
is different than this.
6 MR. REMICK:
It 's different?
7 MR. JAMGOCHIAN:
Yos, sir.
8 MR. REMICK:
I see.
9 MR. JAMGOCHIAN:
Yes, sir.
10 We never focused right after TMI about fuel loading 11 and low power.
It was never even in Appendix E or 12 NUREG 0654, which are the planning standards.
It was never 13 even mentioned.
()
14 In 1981, and I do not know why, the staff was told, 15 hey, what about low power and fuel loading, So we went and 16 said here is what we would look at.
And it is basically what a 17 licensee's onsite planning would be, not state and local 18 governments.
19 And I think that it said no finding or determination 20 as to offsite planning would be required for a low power 21 operation.
And then we embellished that or amplified in the 22 supplemental information by listing these things that we would 23 focus on.
24 MR. CARROLL:
As this is structured, would it always 25 be necessary for the licensee to in effect make a two-stop O
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1 eggroech to thie to setisfy the Commission for fue1 1oeding end 2
low power, and then the second step of satisfying for the full 3
power license, or could you do it to say that I do not want to 4
go through this, I want to get the full power and I have got 5
everything that it takes?
6 MR. JAMGOCHIAN:
Well, my perception is if you had a 7
cooperative state, if you had a local government that was 8
cooperating.
And if the licensee really had his act together 9
and perceived that he would go from lou power to full power 10 promptly,.'.t is a whole lot easier getting the local and state 11 plan approved by FEMA, getting the licensee's plan, and doing 12 the exercise and getting it all done at once.
Clearly, that 13 has not been the real world recently.
So therefore, you had to 14 break it out.
15 MR. CARROLL:
But in a favorable climate, I could 16 fight that as a licensee?
I 17 MR. JAMG0CHIAN:
Sure, sure.
18 MR. CARROLL:
And do it all at once.
19 MR. JAMGOCHIAN:
Yes, sir.
20 MR. CARROLL:
Okay.
21 MR. JAMGOCHIAN:
On page four, I listed all of the 22 offsite elements of the applicant's plan that the Commisolon 23 would look to.
On page five, I basically listed the thing that 24 is going to be excluded, and again this was published on 25 May 9th of this year.
[
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1 And we codified.
In other words, we took these 2
offsite elements out of the supplemental information, and we 3
have now put them into the regulation, except that we did not 4
include the fourth one down, the prompt public notification 5
system.
This is basically the sirens that were set up.
6 And the percoption of the Commission is that the one 7
thing that you have, and thi4 ma laid out in 1982, is that you 8
have a significant amount of u
.a during low power to take any 9
kind of protective action.
Clearly, you do not have the 10 fission product inventory, and you do not have the distances 11 necessary for the taking of protective action.
Aoi of you" 12 other systems are operational.
13 So it was felt that if you have the capability to 14 notify state and local governments, and you do have a 15 significant amount of time.
And in the Federal Register i
16 notice, it was noted that you have up to ten to twelve hours.
17 That this fifteen minute notification capability is totally 18 inappropriate and not necessary.
And therefore, it is l
19 perceived that it is not necessary, and therefore was deleted 20 from the codification of these offsite elements.
i 21 Nonetheless, the proposal was perceived by the staff 22 as a timing question.
It certainly was going to require and
~
23 continue to require the capability to promptly notify the 24 public in the case of an emergency.
But not to do it at a low 25 power or fuel loading time, but to do it prior to full power.
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1 So we are not deleLing a requirement.
We are simply 3
2 moving it, focusing on the timing as to when that requirement 3
would in fact be necessary.
That concludes my presentation on 4
this ruling.
5 Are there any questions?
6 (No response.)
7 MR. JAMGOCHIAN:
We have thus far received several 8
comments to extend the comment period, which the Commission has 9
voted on and approved a fifteen day extension.
We have 10 received several comment letters, I would say approximately 11 thirty to forty to date, at least at my office.
At PDR, it 12 takes awhile to get them from the time that they are docketed.
13 My perception is again that anything dealing with
!\\-
14 emergency planning tends to warrant a significant number of 15 public comment letters.
So my perception is that we will be l
16 receiving a significant before the end of the comment period, t
17 DR. KERR:
Are the comments generally saying that you
'18 are not doing enough, you are dt;ing too much, you are doing the 19 wrong thing, the right thing, or can you characterize it?
1 l
20 MR. JAMGOCHIAN:
To give a fair characterization, on l
l 21 an eight by eleven and a half piece of paper, you would say in 22 large letters, "How dare you.
You do not live near this thing.
23 What the hell are you doing, how can you not require me to be 24 notified?"
25 The perception of the public is why dilute a O
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1 capability.
The perception, again just looking at twenty 2
letters, is that the public is upset that we are doing this.
3 DR. KERR:
Are there other questions or comments?
4 MR. REMICK:
Maybe I am getting my subjects mi.xed up 5
again, but at one time was there not controversy by public 6
questioning whether the offsite medical facilities that had to 7
be available for low power operation licensing of whether that 8
should be restricted to just to handling onsite personnel or 9
you should have adequate medical capabilities offsite for the 10 general populace, or do I have my wrong controversy here?
11 MR. JAMGOCHIAN:
No.
There was some controversy on 12 that.
13 And Ed, that was the result, was it not, medical 14 services for onsite persons offsite?
15 MR. POLI:
Yes.
Ed Poli from NRR.
That is a 16 separate issue.
The offsite aspect is a full power issue.
And 17 it has been resolved that there nersds to be more than a list of 18 hospitals.
That there needs to be a primary and back-up, and 19 training, and transportation.
20 MR. REMICK:
So it was not a low power operation 21 issue?
l 22 MR. POLI:
No, sir.
But I will add that I think that 23 you are right that the low power issue first came up at 24 San Onofre.
l l
25 MF. REMICK:
Thank you.
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1 DR. KERR Are there other questions or comments?
2 (No response.)
3 DR. KERR Thank you, gentlemen.
4 MR. JAMGOCHIAN:
Thank you very much.
5 DR. KERR:
The next item, Metal Components, Open, 6
PGS/EGI.
You are going to tell us about the zipper situation, 7
I understand.
8 DR. SHEWMON:
You have got handout four.
I will read 9
from notes which I sent down here at the same time that I sent 10 down those.
11 DR. KERR:
Those notes are in Tab 6.1.
12 MR. IGNE:
It is in handout four.
13 DR. KERR:
I know that I have seen them.
[
14
%R. IGNE:
Page four.
15 DR. SHEWMOP:
I will read though that set of notes.
16 You can follow along, if you want to.
I inverted the order 17 from what Al said some, because the last half of the l
18 presentation will then be given by Warren Hazelton on l
l 19 in-service inspection.
20 I will start with quality of fasteners.
Apparently, 21 there have been a certajn number of impcrted or things that 22 were stamped overseas that were not made here.
And some of 23 these were stamped differently than what they were chemically.
24 And the NRC has gone back and had people, partly through their 25 own work and partly through a bulletin, check into this.
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1 Well, let us read through here.
The government is 2
normally notified that some of.these were made out of different 3
materials, which would be fraudulent and could be dangerous.
4 There is a congressional inquiry.
And the staff people ~who 5
were talking to us were going to go up on the Hill maybe this 6
week or next to respond to that, although other agencies were 7
involved in that.
8 Then there is NRC Bulletin 82-702 that requested 9
information, plus there has been other quality control studies 10 of this.
And partly, there were these mislabeled and 11 fraudulently labeled materials.
Another was that the bolts 12 that they found often did not meet the specifications that they 13 were purchased to.
And sometimes very frequently in these
\\
14 specifications that the deviations were minor.
And in a few 15 cases, they were substantial.
16 Part of that is something that we heard before.
Or 17 at least I bumped into on Palo Verde where they have an 18 inordinately small sample, one and two tons of bolts that they 19 campled for hardness, and that is enough to meet the ASTM spec, 20 which our statistical expert here would assure us was 21 inadequate and the rest of us might even feel in our gut that 22 it was inadequate.
4 23 And so they are going back to the ASTM and working on 24 that.
Their conclusion was that there was a quality problem, 25 but that it probably did not constitute any danger to the Heritage Reporting Corporation (202) 628-4888
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I health and safety of the public, and so they would work on it 2
at about that rate.
3 The next item that we had was erosion and corrosion.
4 It was on December 9, 1986 that this sudden failure at 5
Surrey-2 of a feedwater pipe killed several people.
And this 6
has spurred the industry to go out and look at pipes at other 7
plants, spurred on partly by the NRC, and some by INPO, and 8
more recently by NUMARC.
And also by the fact that as they 9
have looked at other plants, they found a significant number of 10 components which had thin walls which were thinner than they 11 were when they went in.
And in some cases thinner than the 12 code allowable for that component, and in some cases projected 13 to thin to less than code allowable.
14 Of the first 54 plants, 19 found such components, and 15 in some cases several components.
A great majority of these 16 were in PWRs.
Because boilers have actually a minimum oxygen 17 level below which they cannot go in their feedwater or should 18 not go.
And that may have been put there by GE to protect them 19 from something like this.
I am not sure what the history 1s, 20 but it is there.
So one of the 19 had come out of a boiler, 21 and the other 18 were out of PWRs.
22 All plants have now either performed an inspection or 23 have committed to do at their next outage.
And we heard a 24 presentation from a man from EPRI who had developed a coae 25 which took water chemistry and where things were in the plant, O
Heritage Reporting Corporation (202) 628-4888
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And he claimed that 2
this fit the results that they found pretty well, and that part 3
of this would show where you should look in your first 4
inspection, and probably how fast or what other components will 5
start thinning dangerously in years down the way.
6 And sometimes plants were going back and changing 7
water chemistry, and other times they were changing out 8
components as it was convenient.
9 The staff has sent out a 9E bulletin to all licensees 10 requesting information for their program for monitoring.
And I 11 think that we are quite pleased that the utilities have replied 12 as rapidly as they could.
And also, Spence Bush was there as a 13 consultant.
And at the NRC's urging, Section 11 of the ASME
[)
14 code is now taking as part of their inspection that they shall 15 inspect for thinning periodically.
16 So the staff did not quite know whether they need to 17 put our rule on it.
There is a GAO rule on the street that
'18 says that that group thinks that the NRC should take a firm 19 stand and put out a rule.
The staff sort of felt that the 20 industry has responded quite effectively and quite rapidly, and 21 they will watch it to make sure that it gets done.
But after 22 that, they did not see a need for a rule.
23 (Continued on next page.)
24 25 O
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1 Finally, boric acid reactor coolant you boil off the 2
water and you get high concentrated boric acid solutions and 3
this will corrode basically carbon steel bolts.
And the 4
utilities in some cases feel, well, gee, if the leak in the 5
primary system doesn't violate the tech spec, it's okay, and 6
this has led to some dangerous situations of thin bolts.
And 7
so the staff is now going back, and there is a generic letter 8
out which says that you shall have a program fer finding, 9
evaluating and fixing leaks in bolter joints in the primary 10 system, and that seems to be going along well.
11 Finally, then, we heard a presentation on in-service 12 inspection for BWR shell welds.
These are the ones down in the 13 irradiated part.
In the older BWRs they can't be inspected
(')
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14 satisfactorily.
The staff has given them a waiver for the 15 first time or first 10 years, but are reluctant to give one for 16 the full 40-year life, and why don't I let Warren proceed to 17 talk about that.
We heard a presentation.
l 18 Are there any questions then on the items I have l
19 covered, or comments from the other two members who were there.
20 DR. KERR:
Did the wall thinking come as a surprise?
21 DR. SHEWMON:
Yes.
If you start looking at it, it's 22 a phenomena people had heard of and when EPRI started looking l
23 for data, there was a reasonable amount of information they 1
24 could get from German and British labs who had studied this, 25 more often from fossil plants.
1 1
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1 But in the sense of it not being in the ASME code, 2
and not being something that anybody looked for regularly, it 3
clearly was a surprise.
4 MR. CARROLL:
Let me make the comment that I think 5
most utilities were looking for wall thinning and piping 6
systems with two-phase flow.
The surprise about Surrey was 7
that it occurred in the feed water system with 11guld flow.
8 DR. SHEWMON:
The staff like to call erosion 9
corrosion in the sense that it really -- the rapidly moving low 10 oxygen water will dissolve off the protective oxide layer.
And 11 if you have higher oxygen or if you have a little bit of chreme 12 or do things like this, a little less rapid flow, it doesn't 13 occur in single phase.
7-V 14 Go ahead, Warren.
15 (Slide) 16 MR. HAZELTON:
The staff has been sort of looking at 17 the adequacy of the reactor vessel examinations over the past 18 several years, and we came to the conclusion that we were not l
19 satisfied with what was going on.
And there is several aspects l
20 to this, and they are sort of intertwined.
21 One aspect is that the code has been changing, and we l
22 find that some PWRs have been taking advantage of the 1
23 particular part of one code addition that they liked, and 24 getting away with doing less than we think the code really l
25 intended.
O Heritage Reporting Corporation (202) 628-4888
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So what we really believe is that in-service 2
inspection of all accessible shell welds in the reactor vessels 3
should be performed during each 10-year interval.
With 4
effective examination techniques somebody should be able to 5
prove that they can find a problem.
6 If we take a look at the credit that was taken fer 7
the early safety analyses for in-service inspection, we came to 8
the conclusion that not enough examinations were being done to 9
fit the improvement and reliability that was assigned to it.
10 We had a situation where PWRs have complete access to 11 the reactor vessel and there's no problem.
But based on the 12 current and past additions of the code, they could reduce 13 examination significantly below what we think ought to be done.
14 In the case of older BWRs, in-service inspection has 15 just been performed on a very small sample of the welds; i
16 perhaps 5 or 10 percent of the total weld length.
We consider 17 that NDE has improved since WASH-1400 and the other studies, I
18 and we think the reactor vessel welds should be examined better i
1 19 now, and with -- more of them should be examined.
l 20 To give you -- try to give you a quick story of this 21 complicated situation, the original code people were thinking 22 that maybe if they'd look at 10 percent of the length c,f each 23 longitudinal shell weld and 5 percent of each circumferential l
24 weld, that might be an interesting sampling.
And they used the 25 same extent of ISI during each 10-year interval.
O Heritage Reporting Corporation (202) 628-4888 I
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So every 10 years they would do this amount.
- Now, 2
some people were looking at it as we'll do 5 percent of this 3
weld this time.
Then we'll do another 5 percent of it the next 4
time and so forth.
However, in some cases they're going to do 5
the same 5 percent over and over and over.
6 Now, the current code says that the first time you do 7
it, the first 10 years inspection, you should do essentially 8
100 percent of every shell weld, but on the second, say 20 9
years and subsequent, you just take a look at one beltline 10 circumferential and one longitudinal weld.
11 So we have proposed that the code should be changed 12 to make, or all intervals they should do essentially 100 13 percent of every shell weld.
And that that currently has
'd 14 passed the voice vote of the main committee, and I think we're 15 going to get that change in the code.
16 Now, this is going to impact BWRs more than PWRs, 17 because basically a PWR takes everything out of the pot, and 18 has an empty pot, and they put in a big internal tool and they 19 can do anything they want to look at.
20 BWRs are a different breed and it varies with the 21 agent of BWR.
The first nine or 10 of them, the insulation 22 attached to the vessel was nonremovable in the core region, and 23 they were trying to do some manual examination through nozzle 24 ports of whatever welds they could reach.
It was very 25 difficult to do examination from the inside of the BWR, and it O
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1 is not designed to remove all the internals, and there's lots 2
of stuff that's in the way, particularly jet pumps are filling 3
up the area that you normally want to put remo:e equipment in.
4 The next group of plants attach the insulation 5
somewhat differently, and they put some mechani. cal tracks down 6
the longitudinal welds and the adjacent, and then they looked 7
at adjacent circumferential welds from these tracks.
So they 8
were able to look at a little bit.
9 For some BWR/5s and all BWR/6s they now have at least 10 three feet or more clearance outside the vessel so they can 11 look at essentially all the welds from the outside very good.
12 Now, if they are going to significantly increase the 13 extent of examination of the old BWRs, they're going to develop O
k#
14 some internal tooling, robotics and so forth, and so we expect l
15 that people are going to do that.
l 16 Now in the old days, even with the 5 percent, 5 17 percent and 10 percent situation, and particularly when it came 1
~18 to the '77 code where it said we're supposed to do 100 percent l
19 of every weld, BWRs came in and said, hey, we can't do that, so i
20 we want relief from the code, it's impractical.
And so we took l
l 21 a look at it and we thought that it was all right.
Of course, l
22 or relief is given for a 10-year interval.
l 23 So we though that safety would not be compromised 1
24 because it was still early in the plant life, and we had shop
'S and preservice examinations, and we didn't anticipate any
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1 service-induced failure mechanism.
Then the early calculations 2
predicted little or no radiation effect on the material, and we 3
couldn't conceive of any sever transients like PTS transiente 4
on a BWR.
And besides, they said if technology advances so we 5
can do it, why we'll be happy to do it.
6 DR. KERR:
Warren.
7 MR. HAZELTON:
Yes.
8 DR. KERR:
The Lullet where you say that it was 9
impractical to do the examination required, this occurred 10 because GE had designed the vessel before the '77 code change 11 occurred?
12 MR. HAZELTON:
That's basically correct, yes.
13 DR. KERR:
So they didn't anticipate that this
()
l 14 examination would be required.
15 MR. HAZELTON:
You can say that, but some of those 16 couldn't even meet the '74, okay, except the code had words in 17 saying, if it's not practical to do it, you don't have to.
Or l
18 if you can't do it, go to the NRC and they'll give you relief.
19 So they --
20 DR. SHEWMON:
And Warren, then, also the last three l
21 of those bullets have now changed.
22 MR. HAZELTON:
That's what I'm going to say.
We've 23 changed our thoughts on a lot of this, and this I'm going to j
24 talk about next.
l 25 Since those days we have some -- these are the bases
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1 for our current staff concerns.
Our present knowledge predicts 2
significant irradiation damage to vessel material in BWRs, but 3
that's different.
4 Now, recent technology suggeet that stress corrosion 5
cracking or corrosion-fatigue cannot be ruled out in BWRs.
It 6
looks more probable now than it did to us 10 - 15 years ago.
7 And now we've had recent relief requests are for the 8
second 10-year interval.
In other words, they don't want to do 9
their 20-year examination.
That means that they're homa free 10 for 30 years which seems a little long.
11 Now industry has had no programs known to the staff 12 for developing the techniques, the robotics, and so forth.
13 that's necessary to go in, and so if we continue to grant
, ()
14 relief, why obviously there is no motivation for anybody to l
15 develop techniques.
16 MR. CARROLL:
On your first bullet there, I guess 17 I've always thought of situation with BWRs/PWRs as sort of 18 apples and oranges given the neutron flow that you see in the 1
19 BWRs.
l 20 MR. HAZELTON:
Yes.
21 MR. CARROLL:
Particularly the water.
22 MR. HAZELTON:
Right.
l 23 MR. CARROLL:
What's behind the present knowledge 24 predicting --
25 MR. HAZELTON:
The present knowledge comes about O
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because we now have received a lot of data from actual u
2 surveillance samples and actual BWRs, and we find, to our 3
surprise, that in BWRs the -- some of the low fluents, perhaps 4
becsuse of a low dose rate, gives a lot more radiation damage 5
than you culd predict from the curve that we have for PWRs.
6 In other words, low fluids for a long time appears to 7
be worse than for a shorter time.
So the -- as we call it, the 8
elope of the curve has changed.
9 There is another possible effect there, and that is 10 it could be that the material is operating at a lower 11 temperature in the BWR, giving a higher amount of radiation 12 damage for the same fluents.
13 But anyway, we have lots of data indicating
()
14 significant damage.
15 DR. KERR:
There does appear to be a dose rate 16 dependents in the --
17 MR. HAZELTON:
Pardon?
18 DR. KERR:
There does appear to be a dose rate or 19 dependents.
20 MR. HAZELTON:
People are arguing about what's the 21 reason, but there isn't any doubt about the fact that the data 22 we have received from BWR surveillance capsules is say about 23 twice the damage that we would have predicted for the same 24 fluents.
25 DR. KERR:
Yes, fluents alone, okay.
Thank you.
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1 MR. HAZELTON:
We did a lot of thinking about this 2
and a lot of talking.
We decided that we wanted to push this 3
subject up the management chain and see what people thought 4
about it.
So we reviewed it with Sterosticki when he was here 5
with Murley and with Stello, and they all said, hey, yes, it 6
looks like you ought to do something.
It looks like what's 7
going on isn't good enough.
So what are you going to do?
8 So he said, well, we're going to go ahead and 9
basically we're talking about staff action at that time.
It 10 was felt that we should require augmented in-service 11 inspection; that is, augmented over the code based on Reg Guide 12 1.150.
In other words, we do a better job.
We should propose 13 a provision to the code to require 100 percent'every 10 years.
14 We've done that.
~
15 Then we should discuss with the BWR's owners group 16 increasing the extent of the examination of BWRs; what's going 17 to be required and so forth.
And we have met with them.
We 18 have told them that we are planning to initiate this; that we 19 are getting a package to go to CRGR, and we fully intend to 20 stop giving wholesale relief to BWRs.
21 So the industry is aware of this, and we have 22 prepared the draft CRGR pachage.
23 DR. SHEWMON:
Warren.
24 MR. HAZELTON:
Yes.
25 DR. SHEWMON:
A nine-mile point convinced people that O
Heritage Reporting Corporation (202) 628-4888
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(/
1 you could have stress corrosion cracks through wall and leaks 2
because somebody started looking at leaks.
If you have a leak 3
in the core mid-plain of a ENR, you see it only as condensate; 4
is that right, because the temperature would completely 5
evaporate it?
6 MR. HAZELTON:
That's what I would guess.
7 DR. SHEWMON:
So now you're up to five gallons or 8
whatever it is, or significant level before --
9 MR. HAZELTON:
Yes.
10 DR. SHEWMON:
Okay, thank you.
11 MR. CARROLL:
I'm not sure that's right.
You're 12 talking about inside the vessel?
13 DR. SHEWMON:
I'm talking about other -- you're not (G
14 sure whether it would evaporate off the hot vessel, or whether 15 it would show up, whether the limit of five gallons per --
16 MR. HAZELTON:
It would have to condense and end up 17 in the --
18 MR. CARROLL:
So it's an unidentified leak?
19 MR. HAZELTON:
It's an unidentified leakage, that's 20 right.
21 MR. CARROLL:
And that's a gallon a minute or a few 22 gallons a minute, or something like that?
23 MR. MICHELSON:
How do they handle the problem of 24 certain PWRs that operate with continuous ventilation of the 25 containment, which a few of them still do?
O Heritage Reporting Corporation (202) 628-4888
1 131
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1 DR. KERR:
I couldn't hear you.
2 MR. MICHELSON:
I said, how do you handle the problem 3
on PWRs who are continuously ventilating the containment during 4
normal operation.
How do you -- if it's only the vapor phase 5
that you're talking about, if it doesn't get condensed before 6
it gets into the ventilation st eam, it's gone.
z 7
DR. SHEWMON:
I think they monitor the sump there.
8 MR. MICHELSON:
Yes, that's the way it might show 9
what condense and comes up.
It may be a very small fraction, 10 depending on the ventilation arrangement through that cavity, 11 you know.
12 MR. CARROLL:
I bring it up here though, PWRs any 13 longer --
<-)
\\-
14 MR. MICHELSON:
Not many.
I just wondered on those 15 that still are ventilating, how they work that.
16 DR. SHEWMON:
I don't know, but I guess my concern 17 was that we don't have, you know, the bald-headed inspector 18 sort of, or the guy who looks after what makes puddles on the 19 floor.
That's not going to help us here.
20 MR. HAZELTON:
One slide here that I was going to r
21 show and maybe I should show it, I made the statement that 22 stress corrosion cracking or corrosion fatigue is, shall we l
23 say, less improbable than it used to be, because we've been 24 seeing a lot of cases of stress corrosion cracking in the low l
25 alloy steel, the same composition as reactor vessel steel, and
(
l Heritage Reporting Corporation (202) 628-4888
132 g(>
1 we had GE come in and give us a little story, and this is their 2
summary.
3 Of course, we've had problems with the feedwater 4
nozzles in PWRs, but that's high cycle / low cycle fatigue 5
problems, start in the cladding and went into the base metal.
6 And then the steam generator tube sheet, the German BWR, I 7
don't know what that was, but they attributed it to incomplete 8
local post weld heat treatment.
9 In other words, you take this reactor vessel material 10 and you don't give it a proper post valve heat treatment, you 11 don't temper it, nor do you reduce the residual stresses so the 12 propensity for stress corrosion and cracking is much higher.
13 Now, Garigliano steam generator shell that had cracks
(,')
14 all the way through it a few years ago, same thing; they 15 thought it was incomplete post local post weld heat treatment.
16 A PWR steam generator shell, same material, we've had problems 17 at both Surrey plants, and both Indian Point plants, all the 1
18 steam generators show cracking of this earth weld that was the i
19 final closure weld where the post weld heat treatment was done, 20 perhaps inadequately.
21 And GE concludes that all low alloy teel stress 22 corrosion cracking related to high welding residual stresses.
23 We've had situations where in safe ends where we've had 24 cracking of Inconel 182, and the cracks have progressed right 25 into the nozzle base material.
So we know it's possible with l
l (2) i Heritage Reporting Corporation (202) 628-4888 l
133 1
crevices and high stresses, so it's not as improbable as we 2
used'to believe.
3 Regarding what we're trying to do for the BWR 4
situation, this is much more complex than the PWR, but 5
basically we need to inform them formally that we're going to 6
limit the time period during which relief from code 7
requirements will be granted, and we suggested some time 8
limits.
These are sort of pulled out of the air on the basis 9
of our thoughts in talking to some industry people on how long 10 it would take to develop the robotics to go in and do a good 11 job.
And this is part of the CRGR package that is going in 12-which is, of course, clearly very predecisional.
But we're 13 going to give you an idea.of the kinds of things we are O
14 thinking of.
E3 15 (Continued on next page.)
16 17 18 19 20 21 22 23 24 25 O
Heritage Reporting Corporation (202) 628-4888 1
FT
134 1
So sort of in summary, the new code requirements 2
should be implemented and should be implemented right away.
3 That is next time that PWR examines a vessel, they should 4
examine 100 percent of all of the wells that the new code will 5
read.
6 On BWRs, we are going to have to take the same basic 7
approach.
Except that we are going to have to determine what 8
is technically possible and practical, taking into due 9
consideration the areas that we are worried about.
And we are 10 going to take a tough line.
That is that it has to be really 11 impractical or practically impossible, not just inconvenient, 12 for us to give relief.
13 And we believe also that people who go in and examine O
14 reactor vessels, both PWRs and BWRs, should be required to 15 demonstrate that they can find cracks, and to demonstrate the 16 effectiveness of their techniques.
Now the code is putting in 17 some new requirements in this regard, and we believe that those l
18 should be implemented just as soon as possible.
19 DR. SHEWMON:
What la your advice for getting 20 somebody to take a new addition to the code like that and apply 21 it to an old plan?
22 MR. HAZELTON:
You go through the CRGR, and tell the 23 CRGR this is what we are going to do and why, and the usual l
24 thing.
And we write the generic letter and tell them to do it.
25 DR. SHEWMON:
So a generic letter then is a backfit
)
Heritage Reporting Corporation (202) 628-4888 i
m
135 r
_3.
.d /
1 to whatever, a forced modification.
2 MR. HAZELTON:
That is the way that we have done it.
3 There are other ways to do ic, and I am.not an expert on all of 4
the ways that it can be done.
But that is the way that we have 5
done it on the BWR pipe.
6 DR. SHEWMON:
Are there any other questions?
7 DR. KERR:
Do you propose any sort of communication 8
from this group to someone as a result of this?
9 DR. SHEWMON:
No, the staff hae not asked for one.
10 And I think that it is moving along well enough without getting 11 involved.
12 MR. HAZELTON:
I will admit that we have been 13 discussing it, and we thought that it would be very nice if the 14 ACRS felt that this was important enough to write a letter and 15 say that you agreed with what we were trying to do.
We think 16 that we would like it, and we think that it would help us.
17 DR. SHEWMON:
Fine.
Thank you very much.
'18 MR. MICHELSON:
Could I ask a quick question while we 1
19 have an expert available?
20 DR. SHEWMON:
Sure.
21 MR. MICHELSON:
As I understand from the presentation l
22 that was made at the subcommittee, that there are certain attachments to the vessel, which I recall are inconel 600, is 23 24 that correct?
l 25 MR. HAZELTON:
Yes.
l ()
Heritage Reporting Corporation (202) 628-4888 i
I t__
136
()
's /
1 MR. MICHELSON:
And certain cracks have been found in 2
those attachments that have propagated to the base metal, is 3
that correct?
4 MR. HAZELTON:
That is correct.
In the case of 5
Susquehanna, the one up at the top, yes.
6 MR. MICHELSON:
Had it gone through the cladding and.
7 to the base metal?
8 HR. HAZELTON:
The only one that I know of, the only 9
case that I know of, is the Susquehanna.
And that one, I 10 looked into.
It cracked from both sides, and it sort of went 11 into a V, and the cracks met very, very near the base metal.
12 MR. MICHELSON:
But not into it yet?
13 MR. HAZELTON:
No.
14 MR. MICHELSON:
Okay.
15 MR. HAZELTON:
The plate was in it.
If it haa gone 16 into the base metal, then they would have to use a different 17 welding technique.
So I kind of insisted that they prove that 18 it did not go all the way into the base metal.
So that one did l
19 not.
20 MR. MICHELSON:
In time, I guess that it might have.
21 MR. HAZELTON:
It could have, yes.
22 DR. SHEWMON:
But there have been, have there not, a 23 couple of cases where the crack started in the stress and 24 proceeded in the base metal?
l 25 MR. HAZELTON:
Yes.
I mentioned that, but I did not O
Heritage Reporting Corporation (202) 628-4888
137 g(.)
1 harp on it.
There are at least two cases that I know of where 2
cracks have started in inconel weld metal and did not stop when 3
it got to the base metal, that it kept right on going.
4 MR. WARD:
How is that different from what Carl just 5
asked about?
6 MR. HAZELTON:
It is just a different component.
he 7
was talking about a vessel.
And these other cases have been 8
inconel at the end of the nozzle, the safe end area.
9 MR. MICHELSON:
Some of these attachments are 10 supporting the whole core, you know.
Not the ones that failed 11 nececsarily, but the attachments.
12 MR. HAZELTON:
We are concerned, and General Electric 13 also expressed their concern of the areas of attachments of k>
14 these supports.
They think that that is a possible problem.
15 MR. MICHELSON:
Well, let me get to my real question.
16 I just wanted to be sure that I understood you the other day.
17 MR. HAZELTON:
All right.
18 MR. MICHELSON:
We have also gone tnrough now our l
19 first meeting on the ABWR, and went through the list of l
20 materials, and the construction of the vessel and so forth.
It l
l 21 is essentially providing the same material and the sa ae l
l 22 arrangement on the ABWR as we had on the older vessels.
23 And what I was wondering is are there not better 24 materials, or is it just a heat treatment control that we hope 25 to keep us out of trouble?
l
('n u)
Heritage Reporting Corporation (202) 628-4888 1
138
)
1 MR. HAZELTON:
Yes, there are better ones than have 2
been used.
3 MR. MICHELSON:
And what would they be?
Well, you 4
would have to look at the application, I guess.
5 MR. HAZELTON:
George, do you remember, were you 6
involved in the advanced BWR examiration and review?
Nc.
7 MR. MICHELSON:
Well, I assume that somebody who 8
knows materials has looked at the AEWR.
9 MR. HAZELTON:
We are in the process, yes.
10 MR. MICHELSON:
And you will review them from the 11 viewpoint of the experience that you were pointing to us in 12 subcommittee.
13 MR. HAZELTON:
Yes.
14 DR. SHEWMON:
One of the things, I have not attended 15 your meetings, but has GE committed themselves to hcw many 16 sections they will make up the vessel mid-section out of?
17 MR. MICHELSON:
Yes.
18 DR. SHEWMON:
And is there still any ASME or other 19 standard on how you should design a vessel ct well joint to 20 make it more easily inspectable?
21 MR. MICHELSON:
Yes.
I do not remember in what 22 detail.
They did go into the fact thst, of course, the center 23 section of the vessel, the plate that makes up the exposed area 24 around the core, is going to be a single piece non-welded.
25 Now one of the things that we recognized is that we O
Heritage Reporting Corporation (202) 628-4888
139
(')
1 did not have any experts on metallurgy at the meeting, and GE 2
did not either.
And GE is quite anxious and interested in 3
providing such'an expert to come.
And our next meeting is just 4
before full committee in November.
5 And I was hoping that you would be able to go to that 6
meeting, and they will bring their metallurgists to the L
7 meeting.
And that you will be there, and you are the only one 8
who could converse with them effectively.
And we will go 9
through the materials of the vessel, because that is an 10 important area, and they will give you any details that you 11 would like.
12 DR. SHEWMON:
You are still going to end up making it 13 out of theoretic material.
You may have a different b) 14 composition butter.
That is small enough that you could change s
15 it.
And you are going to be driven back, but can you inspect 16 it.
17 MR. MICHELSON:
The inspection is much easier, 18 because these are non-jet pumps.
19 DR. SHEWMON:
That is something that has been driven 20 more by the Japanese than the U.S.
21 MR. MICHELSON:
Well, ABWR will be internal 22 circulation pumps.
23 DR. SHEWMON:
Well, not so much that as just the 24 inspection of joints.
25 MR. MICHELSON:
They provided a two foot gap between Heritage Reporting Corporation (202) 628-4888
1 i
140
()
I the vessel and the insulation for outside inspection.
2 DR. SHEWMON:
Well, I am thinking of piping too, but 3
okay.
4 MR. MICHELSON:
Yes.
So if you can possibly come on 5
the 15th and 16th of November, we are going to get into the 6
materials.
7 DR. SHEWMON:
We would be pleased to be here.
8 DR. KERR:
Is there further discussion or questions?
9 MR. HAZELTON:
I would just like to make an informal 10 statement.
As I am planning to retire this coming July 1st, 11 this will probably be my last appearance before this august 12 group. I just want to say that it has been fun for the last 25 13 years.
(~)T 14 DR. SHEWMON:
Thank you very much, Warren.
15 What is your pleasure about writing a letter?
I do 16 not have one drafted.
It would not be too hard to put one 17 together.
Dave, do you have a feeling?
~18 MR. MICHELSON:
What would it accomplish, what would 19 be the reason for writing a let'r '?
20 MR. HAZELTON:
Well, to support the program.
21 DR. SHEWMON:
I think that is basically it.
22 MR. MICHELSON:
But does the program need support, or 23 would it otherwise do any differently?
24 DR. KERR Mr. Hazelton expressed some interest in 25 having a letter.
And it seems to me that if we could support (3
V Heritage Reporting Corporation (202) 628-4888
141 j
1 what you are doing, that it would be worthwhile.
2 DR. SHEWMON:
The letter would basically say that 3
cracks in pressure vessela have gone from incredible-to 4
credible.
And as a result, we would encourage what they are 5
doing I think.
6 MR. CARROLL:
I do not think that you would want to 7
say it quite that way.
8 MR. MICHELSON:
I was thinking more in terms of the 9
discussions that we have had in the full committee meetings 10 where we do not write a letter unless there is a real reason to 11 write a letter.
Now if there is a compelling reason why this 12 program would otherwise go under or something, we can take a 13 look at it.
Gk/
14 DR. KERR We will let you draft one.
15 MR. MICHELSON:
And we will take a look at it.
16 DR. KERR:
If it is a compelling letter.
17 MR. MICHELSON:
I did not detect anything from the 18 subcommittee that was pressing.
19 DR. SHEWMON:
No.
This has been started by the 20 staff.
It did not originate with us at all.
We have just been 21 watching.
22 DR. KERR A fifteen minute break.
23 (Whereupon, a recess was taken, to reconvene in 24 executive session.
This page ends the recorded session of 25 today's proceedings.)
O Heritage Reporting Corporation (202) 628-4888
-3 1
CERTIFICATE 2
3 This is to certity that the attached proceedings before the 4
United States ?!uclear Regulatory Commission in the matter of:
5 Name:
ACRS FULL' COMMITTEE 6
7 Docket Numbor 8
Place: Washington, D.C.
9 Date:
J,une 2, 1988 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a f)'
s-15 true and accurate record of the foregoing proceedings.
16
/S/
M i
17 (Signature typed):
18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 i
24 25 l
C:)
Heritage Reporting Corporation (202) 628-4888 1
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ACRS PRESENTATION G/2/88 BY MIKE JAMG0CHIAN O
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BACKGROUND
- AUGUST 1980 - EMERGENCY PLANNING REGULATIONS UPGRADED O
"JULY 1982 - EMERGENCY PLANNING REQUIREMENTS ESTABLISilED IN FUEL LOADINE AND LOW POWER TESTING 06/02/88 2
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JULY 1982 EMERGENCY PLANNING REQUIREMENTS REQUIRES A FINDING OF ADEQUACY OF APPLICANT'S ONSITE EMERGENCY-PLANNING AND PREPAREDNESS O
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- GOVERNMENT STAFF NOTIFICATION OF STATE AND LOCAL ORGANIZATIONS O
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' ADEQUATE EMERGENCY FACILITIES AND EQUIPMENT CAPABILITIES FOR ASSESSING AND MONITORING-POTENTIAL OFFSITE DOSES 1
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06/02/88 5
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O INTEGRITY OF REACTOR VESSELS ISI 0F ALL ACCESSIBLE SHELL WELDS SHOULD BE PERFORMED DURING EACH 10-YEAR INTERVAL WITH EFFECTIVE EXAMINATION TECHNIQUES INCREASED ISI REQUIRED TO ASSURE THAT FAILURE OF THE REACTOR VESSEL IS AN INCREDIBLE EVENT (WASH-1285 &
WASH-1400)
EVEN WITH DESIGN ACCESS, PWRs COULD REDUCE EXAMINATIONS BASED ON CURRENT CODE OLD BWRs, IS! HAS BEEN PERFORMED ON A SMALL SAMPLE OF WELDS NDE HAS IMPROVES SINCE WASH-1400 WAS PUBLISHED.
THE REACTOR VESSEL WELDS SHOULD BE EXAMINED WITH THE BEST AVAILABLE TECHNOLOGY O
1
/
O EXTENT OF EXAMINATION ORIGINAL CODE:
1974 EDITION AND EARLIER 8
THE DESIGN BASIS,FOR ACCESS AT MOST PLANTS INITIAL ISI REQUIREMENT FOR MANY PLANTS VOLUMETRIC EXAMINATION OF AT LEAST 10% OF THE LENGTH OF EACH LONGITUDINAL SHELL WELD AND 51 0F EACH CIRCUMFERENTIAL WELD SAME EXTENT OF ISI DURING EACH 10-YEAR INTERVAL.
SEQUENTIAL SAMPLE OF DIFFERENT WELDS O
CURRENT CODE:
1977 THRU 1986 EDITION IST INTERVAL, 100% OF EACH SHELl. WELD 2ND AND SUBSEQUENT INTERVALS, ONE BELTLINE CIRCUMFERENTIAL AND ONE LONGITUDINAL WELD PROPOSED CODE:
ALL INERVALS, ESSENTI AL 100% OF EACH SHELL WELD O
/
J (J
METHOD OF EXAMINATION PWR - INTERNAL TOOL FROM VESSEL FLANGE BWR - EXTERNAL CONCEPTS (MANUAL, TRACKS OR CRAWLERS)
EXISTING DEGREE OF ACCESS AT BWRs FIRST 9 - 10 BWRs, INSULATION ATTACHED TO VESSEL (NON REMOVABLE IN CORE REGION) - MANUAL EXAM THROUGH N0ZZLE PORTS NEXT GROUP 0F PLANTS, INSULATION ATTACHED TO BIOLOGICAL SHIELD, TRACKS DOWN LONGITUDINAL SEAMS, ADJACENT CIRCUMFERENTIAL WELD EXAMINED.
BWR-6, DESIGN ACCESS FOR ESSENTIALLY 100% OF VESSEL WELDS TO SIGNIFICANTLY INCREASE THE EXTENT OF EXAMINATION WILL REQUIRE DEVELOPMENT OF INTERNAL TOOL TO SUPPLEMENT EXISTING EXTERNAL CONCEPTS BWR VESSELS ARE MUCH LARGER THAN PWR, COMMERCIAL TOOLS WOULD HAVE TO BE MODIFIE6, O
/
STAFF BASES FOR GRANTING RELIEF 7s G
RELIEF WAS FOR FIRST 10 YEAR INSPECTION ONLY.
PERFORMING CODE REQUIRED EXAMINATIONS WAS CLAIMED TO BE' IMPRACTICAL AT THIS TIME.
ACCESS FOR EXAMINATION OF BWR CORE BELTLINE WELDS IS DIFFICULT AND EXPENSIVE TO PROVIDE.
SAFETY WAS NOT CONSIDERED TO BE COMPROMISED BECAUSE:
STILL EARLY IN PLANT LIFE SHOP AND PRESERVICE EXAMINATIONS
()
HO SERVICE INDUCED FAILURE MECHANISM PREDICTED EARLY CALCULATIONS PREDICTED LITTLE OR NO RADIATION EFFECT ON MATERIAL NO SEVERE TRANSIENTS (PTS TYPE) !DENTIFIED COMMITMENTS FOR FUTURE EXAMINATIONS !F TECHNOLOGY ADVANCE PERMITTED.
O
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1 BASES FOR NEW STAFF CONCERNS
)
PRESENT KNOWLEDGE PREDICTS SIGNIFICANT IRRADIATION DAMAGE TO VESSEL MATERIAL IN BWR, RECENT TECHNOLOGY SUGGESTS THAT STRESS CORRCSION CRACKING OR CORROSION-FATIQUE CANNOT BE RULED OUT IN SWRS.
RECENT RELIEF REQUESTS ARE FOR THE SECOND TEN YEAR INTERVAL BELTLINE WELDS WOULD NOT BE SUBJECT TO EXAMINATION FOR.30 YEARS.
INDUSTRY HAS NO PROGRAMS KNOWN TO THE STAFF FOR DEVELOPING TECHNIQUES, TOOLING, OR SPECIAL EQUIPMENT TO PERFORM THESE EXAMINATIONS.
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/~T GRANTING RELIEF ELIMINATES MOT!YATION AND MAINTAINS STATUS k/
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LOW ALLOY STEEL CRACKING EXPERIENCE IN DWRS 1
i (GE
SUMMARY
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CLAD FEEDWATER N0ZZLES IN BWRS j
- HIGH CYCLE / LOW CYCLE FATIGUE STEAM GENERATOR TUBE SHEET IN GERMAM BWR 1
INCOMPLETE LOCAL POST WELD HEAT TREATMENT i
GARIGLIANO STEAM GENERATOP SHELL (BWR-1) i INCOMPLETE LOCAL POST WELD HEAT TREATMENT 2
1 l
PWR STEAM GENERATOR SHELL 3
VERY HIGH WELD RESIDUAL STRESS l.
POOR WATER QUALITY INTRUSIONS ALL LOW ALLOY STEEL STRESS CORROSION CRACKING EXPERIENCE i
ARE RELATED TO HIGH WELDING RESIDUAL STRESSES i
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BWR RELIEF REQUESTS O
ORIGINAL CODE, DESIGN ACCESS 20% OF EACH CIRCUMFERENTIAL WELD 40% OF EACH LONGITUDINAL WELD CURRENT CODE, UPDATED ISI PROGRAMS 100% OF ONE BELTLINE CIRCUMFERENTIAL WELD 100% OF ONE BELTLINE LONGITUDINAL WELD OLDER BWRS, ACCESS IS NOT AVAILABLE FOR MANUAL EXAMINATION OF THE ENTIRE CIRCUMFERENCE, NEWER BWRS, POLE TRACK ARMS HAVE A LIMITED CIRCUMFERENTIAL TRAVEL O
LICENSEES REQUEST RELIEF BECAUSE THE SPECIFIC SHELL WELDS REQUIRED BY THE CODE CAN NOT BE EXAMINED, AS AN ALTERNATIVE, EXAMINATIONS ARE PERFORMED ON OTHER VESSEL WELDS.
THE EXTENT OF EXAMINATION AT SOME PLANTS MAY EXCEEDS THE CODE REQUIREMENT.
THE ORIGINAL CAllBRATION BLOCKS MAY NOT MEET THE REQUIREMENTS OF THE CURRENT CODE DESIGN ACCESS WAS NOT PROVIDED TO EXAMINE THE N0ZZLE-TO-VESSEL WELDS TO CURRENT CODE REQUIREMENTS BWR-6, MINOR OBSTRUCTIONS AND GE0 METRIC LIMITATIONS PREVENT EXAMINATION OF 100% OF ALL SHELL WELDS O
4 RbCOMMENDATIONS O
1.
BWR LICENSEES SHOULD BE INFORMED THAT THE NRC INTENOS TO LIMIT THE TIME PERIOD DURING WHICH RELIEF FROM CODE REQUIREMENTS WILL BE GRANTED.
2.
SUGGESTED TIME LIMITS ARE:
FOR PLANTS WITH LESS TH/N 5 YEARS OF SERVICE, CODE EXAMINATIONS CANNOT BE OSTPONED AFTER 10 YEARS; FOR PLANTS BETWEEN 5 AND 10 YEARS OF SERVICE, RELIEF MAY BE GRANTED FOR UP TO 5 YEARS FROM THIS DATEJ FOR PLANTS WITH OVER 10 YEARS OF SERVICE, CODE REQUIREMENTS CANNOT BE FURTHER POSTPONED AFTER 4 YEARS FROM THIS DATEJ AND, AFTER THE INITIAL INSERVICE EXAMINATION ALL RV BELTLINE
(])
SHELL WELDS SHALL BE EXAMINATED AT NO LONGER THAN 10 YEAR INTERVALS, COUNTING FROM THE DATE OF THE FIRST COMPLETE, EFFECTIVE EXAMINATION.
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STAFF ACTION REQUIRED AUGMENTED 151 BASED ON REGULATORY GUIDE 1.150 IN GENERIC LETTER 83-15 PROPOSED A REVISION TO ASME SECTION XI IN AUGUST 1987 TO REQUIRE THE EXAMlHATION OF ESSENTIALLY 100% OF EACH SHELL WELD DURING EACH 10-YEAR INTERVAL.
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DISCUSSED INCREASING THE EXTENT OF EXAhlNATION AT SEVERAL MEETliiGS WITH THE BWR OWNERS GROUP ASME MAIN COMMITTEE APPROVED PROPOSED CODE REVISION IN MAY 1988, SUBJECT TO LETTER BALLOT STAFF HAS PREPARED DRAFT CRGR PACKAGE ON EXAMINl. 10N OF VESSEL WELDS i
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SUMMARY
e THE PROPOSED CODE REQUIREMENTS SHOULD BE IMPLEMENTED i
OLD BWRs, THE STAFF MUST DETERMINE WHAT IS TECHNICALLY FEASIBLE AND PRACTICAL AFTER THE INDUSTRY DEVELOPS TOOLING PERFORMANCE DEMONSTRATION IS NECESSARY TO DETERMINE EFFECTIVENESS OF EXISTING TECHNIQUES O
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