ML20198E469
| ML20198E469 | |
| Person / Time | |
|---|---|
| Issue date: | 11/23/1992 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9212070225 | |
| Download: ML20198E469 (130) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION I
IO BRIEFING ON PROGRESS OF DESIGN CERTIFICATION 1
REVIEW AND IMPLEMENTATION 1
LOCitiOL ROCKVILLE, MARYLAND b3IO NOVEMBER 23, 1992 J
I PagOS:
103 PAGEs NEALR.GROSSANDCO.,INC.
COURT REPORTERS A N D -- T R A N S C R I B E R S 1323 Rhode Island Avenue, Northwest i
Washington, D.C.
20005 (202) 234-4433 l
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DISCLAIMER 3
1 This is~an unofficial transcript of a meeting of
,S the United States Nuclear Regulatory commission held on November 23, 1992 White Flint North, Reckvills, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal raccrd of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
-No pleading or other-paper may be file'd with the Commission i n -- a n y proceeding 'as the result of, or addressed to, any statement or argument contained--herein, except as the Commission may authorite.
4 9
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i 1-UNITED 8TATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION BRIEFING ON PROGRESS _OF DESIGN CERTIFICATION REVIEW AND IMPLEMENTATION i
PUBLIC MEETING Nuclear Regulatory Commission One White Flint North j
Rockville, Maryland i
Monday, November 23, 1992 l
The Commission met in open
- session, I
pursuant to
- notice, at 9:30 a.m.,
Ivan
- Selin, i
Chairman, presiding.
COMMISSIONERS PRESENT:
i IVAN SELIN, Chairman of the Commission
~
KENNETH C. ROGERS, Commissioner-FORREST J. REMICK, Commissioner
).
JAMES R. CURTISS, Commissioner-E. GAIL'_de PLANQUE, Commissioner 4
5 i
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STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:.
WILLIAM C.
PARLER, General Counsel JOHN C. HOYLE, Acting Secretary 4
JAMES TAYLOR, Executive Director for. Operations THOMAS MURLEY, Director, NRR a
WILLIAM RUSSELL, Associate Director for Insp. and Tech. Asssessment, NRR DENNIS CRUTCHFIELD,. Associate
- Director, Advanced Reactors-& License Renewal, NRR S.R. SPECKER, Vice President,-GE Nuclear Energy.
i J.F. QUIRK, ABWR Certification Project Manager, GE R.C.
BERGLUND,- Program General Manager, Advanced Reactor Programs, GE A.J. JAMES, ABWR Tier 1 Project Management, GE WILLIAM RASIN, Vice President and Director, Technical Division, NUMARC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 hrf00E ISLAND AVENUE, N W.
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2 9:30 a.m.
l.
3 CHAIRMAN SELIN:
Good morning.
4 This morning the commission will be S
hearing briefings by the NRC staff, by General i
6 Electric, and also by NUMARC on progress of design certification reviews both for the revolutionary and-7 i
8 for the advanced light water reactor designs. We also j
i 9
expect to be briefed on the status of some major i
i 10 technical policy issues associated with the l
11 implementation of Part 52.
Many of these issues are-12 being resolved in the course of the. ABWR review, l
13 issues that have generic implications for subsequent 14 light water reactor reviews.
As you well know, as i
15 you've heard over and over again, the ' commission 16 considers these issues to be of a very high priority.
l l
17 Based on a number of issues still remaining - to be l
18 resolved with the-advanced blowing water reactor, i-l 19 we're concerned about the schedules. We're anxious-to 20 learn the views of the different parties and plans for l
21 the resolution.
22 The order this morning is first the staff, 23 followed by GE, and then NUMARC.
24 Any comments?
25 Mr. Taylor, would you care to proceed?-
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MR. TAYLOR:
Good morning. With me at the 2
table are Doctor Murley, Denny Crutchfield and Lill 3
- Russell, all from the Office of Nuclear Reactor 4
Regulation.
5 Although we will touch and review the 6
progresc of the review of the evolutionary and 7
advanced reactor work, a great deal of the discussion 8
this morning from the staff, will center on inspection 9
tests, analysis and acceptance criteria, some of the 10 issues associated with that work.
With those 11 thoughts, I'll ask Tom Murley to continue.
12 DOCTOR MURLEY:
Titank you, Mr. Chairman, 13 Commissioners.
14 The picture that the staff is presenting 15 today is mixed somewhat with regard to progress on 16 design certification and implementation. But overall, 17 I remain positive about the large picture and the 18 progress we're making.
We have made and are making 19 steady progress in resolving issues in tho design 20 certification
- reviews, and in implementing the 21 procedures for Part 52.
On the other hand, there are 22 more procedural issues and they're more difficult to 23 resolve than we foresaw two years ago.
24 Up to new, the staff has basically met the 25 schedules presented to the Commission in April,1991.
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We issued the draf t FSER for the ABWR on October 14th 2
this year, just seven weeks after the date that we 3
projected in April, 1991 for the FSER.
But in that l
4 draft, there are 379 open items and 266 confirmatory 5
items, and we are waiting for submittals from GE 6
before we can review and close those items out.
The 7
strictly technical safety issues are largely resolved 8
on the ABWR, and our focus will be mostly on ITAAC for 9
the next several months.
10 Concurrent with the design reviews, the 11 staff is spending a great deal of effort on Part 52 12 implementation policy issues.
You recall in the past 13 two years, we have given recommendations to the 14 Commission on level of design detail, on the tier 1, 15 tier 2 concept and the split between tier 1 and tier 16 2
and the design certification.
We've given 17 recommendations on the scope and format of ITAAC and 18 a design acceptance criteria, which is a subset of 19 ITAAC.
We've given recommendations on the form and 20 content of the design certification rule, and we've 21
_given a paper on the inspection plans which we intend 22 to use for the sign-as-you-go process.
23 We've got several more policy papers in 24 the works which you should see in the next couple of 25 months. The first one, in importance at least, is the l
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form and content of the combined operating license.
2 This is a very important policy paper and it will 3
speak of what we believe should be the methods for 4
verifying ITAAC and the concept of a bridge document, 5
for example.
We will have a paper updating the 6
recommendations that the staff has on ITAAC, and some 7
of those recommendations we'll talk about in general 1
8 terms at this meeting.
But we intend to put them down 9
clearly on paper for the Commission to deal with.
10 Generally, these will be how we're going to deal with 11 generic and programmatic requirements in the context 12 of tier 1
and tier 2.
We will have final 13 recommendations on the technical policy issues that 14 were in the draft papers that came to be known 15 colloquially as the son of 90-016 and the grandson of 16 90-016 issues.
17 We will be preparing a paper on emergency 18 preparedness ITAAC, so that our plans and policies are 19 consistent with the energy bill that was just passed 20 which required energy preparedness ITAAC. That may be 21 included in one of these other papers, but it will be 22 a separate copy.
And also, we will issue in the next 23 few months, a reevaluation of all design certification 24 schedules.
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itself, leading to final design approval.
Associated 2
with this, you'll also see, within a week or two, a 3
draft paper on the advanced concept policy.
This is 4
the liquid metal, gas cooled, PIUS and can-do issues.
5 And that paper itself is heavy with policy issues.
6 The toughest problem we're facing today in 7
design certification is undoubtedly ITAAC.
The staff 8
reviewed early drafts of pilot ITAAC from GE over a 9
year ago.
We gave our thoughts.
We changed some of 10 the concepts, and we basically settled on the format 11 of ITAAC and the concept of design acceptance 12 criteria, approximately about a year ago.
In the 13 Spring, I asked for an independent review in the l
l 14
There were two independent 16 reviews. One was the very senior managers in NRC with l
17 lots of experience, we called the Greybeards.
And 18 there was a separate inspectability review done under 19 Bill Beech from the regions.
They made, I think, I
20 invaluable contributions to our understanding of how i
l 21 ITAAC are to be implemented.
These review groups 22 generally concluded that the ITAAC are workable but 23 more details are needed, especially in describing the 24 tests that should be performed to actually show that 25 the ITAAC are verified.
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Separately, starting in _ ' August, going 1
2 through September, the-industry under NUMARC reviewed 4
3 the ITAAC for the GE ABWR and we observed that.v'ery i
4 i
4 closely.
This industry-group was made up'of members j
j 5
.of utilities, architect engineering-firms'and_other 6
organizations besides GE, and they made important 7
contributions to the
-understanding
'from the l
8 industries' point of view. - And they also, by the way, f
9-made many changes to ITAAC,_ so that's, as much as 10 anything, what has caused the ITAAC finality to be 11
. delayed at GE.
When we receive-the complete set of
_12 the final ITAAC from GE, we will do, in-house, another 13 complete QA audit in-parallel with the normal' staff i
14 review.
And the purpose of this QA a' dit is to ensure 15 consistency among all the ITAAC, ard particularly l
16 completeness in the certification ITAAC.
l 17
'A recent issue in contention - with the l
l 18 industry has been how to treat-generic requirements i
['
19 like
_ equipment qualification and programmatic l
20
-requirements like-QA programs'within,the context-of
[
21 tier 1,_= tier 2, and ITAAC.- We believe--.we have a way-i I
22 to resolve this issue, to the staff's satisfaction at-
_23 least.
And.we will be sending our-recommendations to l
j 24 the commission in January-February - policy. paper.
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sure that all views are reflected.
2 Briefly, we think that the generic and the 3
programmatic requirements can be placed in tier 2 and 4
not in ITAAC.
What we're working on is the l
5 appropriate link between these requirements in tier 2 6
and ITAAC, without cluttering up ITAAC and making 7
ITAAC essentihl3y unworkable.
Bill Russell will talk 8
a bit about that in a minute, but first, Denny 9
Crutchfield will talk about the status of the design 10 certification reviews.
11 MR. CRUTCHFIELD:
Good morning.
12 (Slide) If I coul.d have the first slide, 13 please?
I'd like to cover briefly the evolutionary 14 design status.
15 In August of this year, we issued the 16 evolutionary FSER.
In that document, we had a number 17 of open items. These were specifically related to the 18 son of and grandson 90-016 issues.
There were also a 19 number of vendor-specific or utility-specific areas --
20 vendor specific that would have to be addressed in a 21 particular design that the otaff had in front of it.
22 We are continuing to work with EPRI on those issues.
23 They would like to resolve a number of those on the.
24 EPRI-specific docket, and we are working with them to 25 try and do that.
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With respect to the ABWR, as Tom indicated 2
to you, we did issue the DFSER in August.
It had a 3
number of open and confirmatory items.
We are working 4
very closely with General Electric Company to try and 5
resolve those open issues.
We have sat down with 6
them.
We've gotten a general schedule from them, and 7
GE has told us that by the seventh of December, they 8
expect to get back to us with a chapter-by-chapter 9
specific submittal dates.
That would include e
10 addressing all the open items, would include an update 11 of the SSAR to reflect those closed open items, or 12 their addressing of those open items, and revisions to 13 the ITAAC that specifically related to those 14 particular chapters and
- sections, as well as i
15 addressing the earlier comments, the Greybeard and 16 Beech reviews.
17 So, we will have that by early December.
18 The staff will thmi all down and see what it needs to 19 do to complete the remaining milestones, assign 20 schedules to those, and come back to the Commission 21 and inform them of what that is.
22 COMMISSIONER REMICK:
Excuse me, Denny.
23 What is 7 December, a schedule?
24 MR. CRUTCHFIELD:
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chapter submittals.
2 COMMISSIONER REMICK:
Okay.
3 MR. CRUTCHFIELD:
We are working very 4
closely with them and we hope things will go smoothly 5
enough.
The dates that we continue to carry however, 6
are the 91-161 dates which show a projected design 7
certification for June '94.
Now, that was based on an 8
FDA of December of this year.
So, we are a little bit 9
behind that schedule.
10 I'd like to turn now to the combustion 11 engineering design.
We were about one month late on 12 the 91-161 date for issuance of the draft safety 13 evaluation report to the Commission.
It was SECY 14 331. We issued that on September 28th, rather than in 15 August.
We are due respanses from combustion 16 engineering in January.
As a matter of fact, they've 17 already gotten some of the respon=es in and we are 18 working with them to close a number of -the issues.
19 The DSER had about 600-plus open items and another 130 20 are confirmatory items.
21 So, there's a big piece of work there to 22 close between the DSER and the FSER.
We feel pretty 23 comfortable that with the way things are going with 24 combustion and the trail blazing that we have done with General Electric, that it should be easier to get 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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these things done.
Again, we.show an FDA scheduled 2
for 161 for November of
'93.
That will be tough to 3
make, but the staff is going to try and endeavor to do 4
that.
j
]
5 We've begun the senior management meetings j
6 with combustion engineering where Tom, and -Bill 7
Russell, and I,
and a bunch of the other senior l
8 managers from NRR actually sit down with the 9
combustion senior managers and resolve issues one-by-10 one, where - we send'the staff out'into a break-out I
l 11 session to come back with a resolution, so it can be-12 resolved.
So, those meetings have begun.
They'll 13 probably be' scheduled at six week or so intervals i
i 14 until we get resolution, until we get the'FSER ready i
15 to go.
16 If I could turn now to the passive 17 designs, the EPRI utility requirements document-is l
18 we've got the passive DSER issued in May of
'92.
4 19 There were about 260 or so open or vendor items in 20 that particular document.
We have received their 21 comments in September of '92 on schedule, and we are
)
22 working to complete-the FSER by June of '93.
One'of 23 the key issues and important issues that we're facing 24 in that is the regulatory treatment of non-safety-25 issues.
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We set up three particularly sensitive and 2
important meetings.
The first one was held on 3
November the
- lath, where we could provide our 4
indications of what we think is necessary.
We're 5
meeting again in December, probably the 11th of 6
December, to hear back from EPRI as to their views.
7 The intent is, around the end of January, Tom will sit 8
down with senior representativec of EPRI and resolve 9
this issue.
So, we will have staff resolution of this 10 particular subject area.
11 COMMISSIONER REMICK:
Denny, when you say I
12 you received their comments, does that include their 13 subsittals to open items?
14 MR. CRUTCHFIELD:
Yes, it is.
15 COMMISSIONER REMICK:
Okay.
16 MR. CRUTCHFIELD: What we have done now is 17 prepared packages to go back to.the individual 18 technical reviewers with the DSER sections, the 19 particular material that EPRI has submitted to us to 20 answer the open items and update the DSER as 21 necessary.
So, we now have-those packages working.
22 We are also finalizing the paper, as Tom 23 indicated, that resolves the SECY-90-016 issues and 24 the follow-on issues.
We expect to have that 25 somewhere around the end of this year, early part of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N V'.
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next year.
This will include industr" reviews.
It 2
will also include the views of the ACRS in there._ So, 3
we will be addressing that in a short time frame.
4 Westinghouse AP-600 was received in June 5
of
'92, as you're aware.
We docketed the document, 6
but we did not begin the schedule for the particular i
j 7
review.
We have, nevertheless, continued the review I
8 and as of today, we've issued about 700 questions to i
9
. Westinghouse. Many of these-would be considered to be 10 the traditional round one_ questions.
They go beyond 11 the acceptance review questions.
i l
12 So, Westinghouse has been working it.
We I
13 have been workin
- bat.
We're due to get a submittal i
14 from them Decem'ber the 15th that addresses the open 1
15 issues that we identified in the acceptance review
,j.
16 letter.
It includes principally the ITAAC and its i
17 proprietary documents and other topical reports that la they had.
We expect at that point then to be.able to i
19 sit down,-develop the schedule, based on what we know 20 with remaining milestones with GE,-combustion, EPRI, 21 and the others we have before us.
We hope to get-22 those schedules to you early_next year sometime, in
- 23 the February, March, April time' frame.
24 COMMISSIONER CURTISS:
Denny,-there are 25 two things that are standing in the way of docketing f
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15-1 that application, the ITAAC-and the proprietary-2 information?
3 MR.
CRUTCHFIELD:
The-topical report 4
information.
We wanted-to make sure we had all the 5
topical reports that they needed to support -their 6
application.
The ITAAC is the key piece holding up 7
our beginning of the review.
8 COMMISSIONER CURTISS: Do we need anything 9
from them on NEPA/SAMDA issues before we start the 10 review?
11 MR. CRUTCHFIELD:
There is a piece out 12 there.
We are working with NUMARC, however.- NUMARC 13 has wanted to take the lead in' the NEPA/SAMDA 14 resolution and we are awaiting =a submittal from them 15 before we can come back to the Commission with.a 16 proposed resolution for that issue.
That will not 17 hold up the acceptance and-beginning of the l
18 scheduling.
19 COMMISSIONER C7TISS:
Okay.
.And have 20 they outlined how they've incorporated operational; 21 experience in the' design?-
22 MR. : CRUTCHFIELD:
That will be-coming in-23
-on-the 15th.-
24 COMMISSIONER CURTISS:- Okay.
25 MR. CRUTCHFIELD: The SBWR application was
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1 received in August.
Our - acceptance review is in --
2 process, and we hope to have the results to the 3
Commission within this month, wjthin the next week or 4
so, indicating what we have found.
We, nevertheless, 5
will continue to work with them, as we have with 6
Westinghouse, regardless of the outcome of that 3
7 particular report. We will work with them to continue 8
our review as applicable, to get questions out to them i
9 as soon as we can.
We're not going to stop working on 10 any of those applications.
11 There are a number of generic technical 12 policy issues that were identified in the last 13 quarterly status reports, and I'll briefly go over a 14 number of them.
The ITAAC, as Tom indicated,_ Bill 15 Russell will be discussing later and talk about our 16 experience to date with the ABWR ITAAC.
17 The diversity question of digital i
18 instrumentation systems, as you'll recall,' our concern i
19 there was a common mode-failure problem.
Based on 20 meetings with industry, based on meetings with the 21 ACRS, the staff-has somewhat changed-its view and it 4
22 now will allow the use of rb ple digital equipment for i
23 dedicated displays and controls.
So, that has been a ~
24 shift in - position based on experience and based-on 25 meetings.
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The level of design detail-and design 2
acceptance criteria, again, Bill will be discussing 3
that.
We have received ACRS letters on the use of 4
design acceptance. criteria.
They pretty generally 5-endorsed radiation protection, piping, and the control 6
room design.
There are some questions.
We need to 7
continue to work with them on the I&C software area.
8 Severe accident closure, our approach 9
there will be to have a balanced approach of both 10 prevention and mitigation, as well as make sure 11 there's an accident management plan in place.
And we 12 are working with this.
We are filing this under 90-13 016 as well as Chapter 19 of the ABWR evaluation.
14 The final issue, as Commissioner Curtiss 15 mentioned, is the - NEPA/SAMDA question.
We have 16 received GE's submittal on that.
That was the 50-17 34 (f) piece.
We are looking at that.
That will 18 likely be-the basis for our finding of the 19 acceptability of NEPA/SAMDAs for the ABWR. ? NUMARC hais
.20 indicated they want to' nork with us.
We've met in May 21 with them, most recently. We are awaiting a submittal 22 from them to discuss in detail what-their proposal 23 will be for industry.
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with.
One -of these, as noted earlier, is EPRI e
4 j
2 believes that the plant safety can totally be assured 3
by complete reliance on passive safety systems.
As I l
4' indicated, we have met with EPRI.
We are going to 5
continue to meet with-them, and we hope to have - a-i C
position, staff position, available by the end of 7
January time frame.
i 8
The multiple steam generator tube rupture l
9 issue is the concern with pacsive systems alone.
It's 10 possible that you could get a secondary back flow into 11 the primary system-and get poor undulation.
It'.s an 12 area that the staff needs'to continue to work.
It 13 doesn't appear to be a major technical hurdle that's 14 impossible to overcome.
j 15 The-final item there is the containment 16 bypass question. This is a particular concern for the 17 BWR because you're concerned about dry well failure if i
l' 38 you get severe accident-pressures and temperatures at :
l-19 bypass containment in the secondary.
20 As Tom indicated, there-are a number of 21 projected Commission papers, briefings, memoranda that l
22 we have before us. The SBWR acceptance review will be.-
{'
23-coming around the end of this month. -He indicated our 24-final positicu on the follow-up items will be in the i
'25 January tix
'ame.
The advanced advance reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W..
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1 19 i
1, 1
schedules, these are the non-light water reactor 2
schedules, will be January of
'93.
The remaining i
3 light water reactor schedules will be timed for a j
4 couple months after that, after -we get a
full 5
assessment of what our workload is.
The final Commission paper on the remaining passive issues in 6
I 1
]
7 the 90-016 document and follow-on documents, there
- I 3
vere a couple of areas where the staff had not taken 9
a position as yet.
We intend to take that position by-10 March of '93 and have it up to the Commission.
11 And
- finally, there is the Part 52 12 construction inspection program we hope to have l
13 finalized. This is the sign-as-you-go program that we i
14 have before us.
We hope to have that finalized-and a 15 paper up to the Commission around the August time l
16 frame.
I 17 With that, I'd like now to turn 'it over to l
18 Bill Russell, to discuss some of the major issues for l
19 completion of the ABWR.
20
. COMMISSIONER REMICK,
- First, Denny, a
21 question, on your next to last slide, the containment l
22 bypass, why is that a particular issue for passive 23 LWRa? You mentioned the-BWR.
I assume you meant-the 24 SBWR.
l 25 MR.- CRUTCHFIt.LD Yes.
t NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
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1 COMMISSIONER REMICK: Why, technically, is 2
that a particular problem, SBWR7
~
3 MR.
CRUTCHFIELD:
The concern is the l
4 specific reliance on much of the passive design i
1 5
systems only, and not the reliance on the active non-6 safety systems.
So, we're more concerned in that 7
arena because you don't have the availability, 8
necessarily, of the non-safety active systems.
9 COMMISSIONER REMICK: I see. Just relying 10 on the -- I see.
11 MR. CRUTCHFIELD:
Yes.
12 MR. RUSSELL:
I'm going to cover what I 13 consider the five major technical areas that need to 14 be resolved in order to complete the ABWR review.
15 The first is the severe accident closure.
The draft 16 final safety evaluation, which we forwarded to the 17 Commission, did not include a detailed write-up in 18 what we're now calling Chapter 19.2.
We have l
19 completed that and we have forwarded it to GE as an 20 early draft, in order to focus the review to date.
21 We are looking, specifically, at the 22 capability of the containment to cope with a spectrum 23 of challenges and meet the performance objectives 24 which we had proposed to the commission.
The 25 challenges we discussed with EPRI, and we reached NEAL R, GROSS COURT REPORTERS AND TRANSCRIDGRS 1323 RHODE ISLAND AVENUE, N W.
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21 1
agreement on the challenges to be considered for this 2
review. There are three areas which we are continuing 3
to work.
The bulk, we have reached agreement on.
4 Those three areas are fuel coolant intoractions, core 5
concrete interactions, and the potential for 6
suppression pool bypass.
7 In each
- case, we're looking at the 8
likelihood of the challenge and whether there are 9
deterministic conditions or requirements which could 10 be put in place, should we conclude that the challenge 11 is credible to meet a
containment performance 12 objectivo of essentially level C for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or a 13 conditional containment failure probability of
.1.
We 14 expect that we can reach closure on these issues.
15 We've had a number of technical.nectings with GE.
16 There is an understanding of what information needs to 17 be exchanged and we hope that we can complete that 18 within the next three months.
19 The second area relates --
20 COMMISSIONER CURTISS:
Could I ask you 21 just quickly, when you go through a determination of 22 the challenges that you're proposing to address here, 23 is your current thinking that those challenges would 24 be identified largely, if not exclusively, out of 25 probabilistic basis?
Or are you also taking - into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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account those challenges that might not lead to the 2
level C or the.1, but nevertheless, deterministically j
3 you believe ought to be addressed?
i j
4 MR. RUSSELL:
It's a combination of both l
5 deterministic and probabilistic, with information from i
6 the research program.
So, it is a complete set of 7
challenges that we have reached agreement on.
There 8
was a white piper that was exchanged between EPRI and l
9 the staff at an. earlier meeting. We agreed with those i
10 challenges.
We are using the PRA, particularly the l
l 11 level two portion, the containment response.
We are I
12 doing sensitivity analyses, uncertainty Analysis, 13 trying to decide what is credible and what is not.
1 14 And so, it's a combination of deterministic and l
l 15 probabilistic review.
j 16 The difficulty that the staff is having is 17 it's hard to ccme to a final judgment when there are i
18 significant uncertainties involved.
It's not clear j
19 that-new research won't identify a new. issue a year i
i 20 from now, and we're trying to identify how we can make 1
21 final decisions in light of that uncertainty.
So, we 22 have chosen, essentially, a technical spproach to try 23 and address these, essentially challenge-by-challenge.
24
-The draft ' write-up on Chapter 19. 2, - which is tho 25-current technical approach we're taking, is about 70 NEAL R. GROSS COURT REPORTERT. AND TRANSCRIBERS -
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pages long.
It has been provided to the ACRS and to 2
GE, and we're using that as a basis for dialogue in 3
our approach.
j 4
COMMISSIONER CURTISS:
Okay.
5 MR. RUSSELL The PRA is the second area
)
6 that is controlling.
We're looking essentially at a i
7 two-part review.
First, as a classic PRA review, 8
where we're looking at quality of the models, the 9
methods, and the data that's used in the analysis.
10 The second part is looking at using the PRA as a tool 11 to assess strengths and weaknesses in the design.
12 We're using importance
- measures, 13 uncertainty analyses and sensitivity analyses to 14 identify the structures,
- systems, components, and 15 human errors which are important contributors to core 16 damage frequency and to risk.
These insights are 17 being factored into specific ITAAC via a process we're 18 using internally where the individuals involved in a 19 PRA review pass information to the technical staff 20 that's responsible for a
particular system or 21 structure review.
That information is then factored 22 into both that chapter as well as Chapter 19.
23 In addition, there are risk insights which 24 are compiled in an appendix - to Chapter 19, the 25 sensitivity stud' is identifying the more important NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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i systems and components which would be used for the f
2 longer term reliability assurance program, would be j
3 q tsed in procurement decisions if there is a particular l
- lb fponent that is risk sensitive that would be l'
reflected then in the procurement specifications for i
6 that component by the COL applicant.
l 7
We're also working on what we are calling
{
8 a road nap.
This is how you go from the safety review 9
using the PRA, back into the various system reviews to j
10 try and capture that information.
So, while the text i
l 11 and the rationale would be explained in either Chapter 12 19 or in the individual system chapters, we are 13 looking at a mechanism for cross refurence for ease of 14 use in the review process.
3 d
15 COMMISSIONER CURTISS:
- Bill, your 16 description of the PRA as essentially a design tool to 17
. aid and inform the design, should I infer from that j
18 that you don't see the need for or you wouldn't 19 propose requiring the PRA to be in either Tier 1 or 20 tier 2, but-outside of the tier 1/ tier 2 frame?
21 MR. RUSSELL:
That's correct.
We are 5
22 looking at using the insights of what's important 23 about the design.
And if it's significant, actually 24 having an ITAAC for it and putting it in tier 1.
If 25 it's an insight relating to system reliability, then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 MH00E ISLAND AVENUE. N W.
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that would be captured but it would go $nto the i
2 reliability assurance
- program, which would be i
3 developed by the COL applicant and then reviewed on a i
j 4
case basis at the time of the COL application.
So, a
5 some goes into tier 1, some goes into tier 2, but we 6
are not using the PRA, per se, by itself.
We're not
)
7 calling for that calculational method.
We're not I
8 locking that in.
It could be. updated using different
.9 techniques in the future, for example.
10 COMMISSIONER CURTISS:
The PRA itself 1
11 though will not --
j 12 MR. RUSSELL:
The PRA itself.
i l
13 COMMISSIONER CURTISS:
-- be included in 4
i 14 tier 2?
15 MR.
RUSSELL:
That's correct.
The 1 -
16 insights and-the factual material that we're learning i
)
17 from the PRA, those results we expect to put into tier 18 1 and tier 2.
19 DOCTOR MURLEY: Could I add c, point, Bill?
i i
20 There's :: ver*/ good reason for that..The f
21 PRA, we' don't expect will be unchangeable.
That is, 22 tier 1 and tier 2, as you know, are-subject to very j
23 stringent change requirements.
We would-want the _ PRA j._
-24
'to be updated as new methodologies and new data become 25 available.-
So, we view that as a - t o o l',
but-the
. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W_-
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,, _. _.. _ -. - _... - _,..._ _..._,._-..-__., a. - _.
n,,
i 26 A
1 insights that flow from that will be in tier 1 and l
2 tier 2, insofar as they effect the design.
3 MR. RUSSELL:
In fact, we have a policy 4
issue that we're proposing to the Commission that 5
would require the PRA to be updated at the time of the i
6 COL to reflect the interfaces with off-site power 7
sources, ultimate heat sync, et cetera, and to reflect i
l 8
procurement decisions in the event that that changes l
9 some of the assumptions about data that went in on l
10 equipment performance.
We'd also expect it to be 11 updated after operation by the COL holder, the 12 licensee, as there are changes made to the facility i
13 that may affect balance of
- plant, which could i
j 14 potentially change transient arrival rates or other l
15 things.
So, we see this as a tool that should be used l
16 over the life of the plant, but it is a tool.
We're l
17 going to regulate the insights and the factual i
i 18 material that come from the exercising of that' tool.
l 19 COMMISSIONER CURTISS:
Yes.
From a l
20 technical standpoint, the approach that you've 21 outlined, I guess in my view, makes a lot of sense.
22 The only remaining procedural question to think about, 23 and we don't need to pursue it here, is that as you i
24 proposed that the PRA be used to irdorm the design 25 itself with the product of that review being reflected NEAL R. GROSS COURT REPORTERS ANDl TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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27 1
in either tier 1 or tier 2 or both, the point will 2
come when the results of that effort, in particular in 3
the design certification proceeding, become the focus 4
of the discussion at that stage.
5 Perhaps some additional thinking on how 6
you focus the review at the design certification 1
7 proceeding on the results, and not drag the PRA into 8
that proceeding might be worthwhile, because 9
obviously, there's a very close connection between the 10 PRA itself and the end product, which is to say the 11 design.
As we found in other contexts, the question 12 of PRA in a legal setting and how you look at the 13 numbers and how they're treated has proven to be 14 nettlesome, and particular in the high level waste 15 context.
So, at some point in the future, it might be 16 worth thinking about how you treat that PRA in the 17 context of the proceeding itself.
18 MR. RUSSEL' :
Yes, we agree.
We believe 19 that we're going to have to have a basis for judging 20 the quality of the PRA, the methods, and the data that 21 was used because it clearly flows that if you have 22 uncertainty about the quality of the PRA, you have 23 uncertainty about the conclusions you're drawing based 24 upon that PRA.
f 25 CHAIRMAN SELIN: Well, as long as we're on NEAL R. GROSS COURT REPORTERS AND TRAGCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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28 1
that for a second, I'd just like to add two points.
2 The first is, in thinking about PRAs, 3
there's a big difference between the algorithms and 4
the data.
5 MR. RUSSELL:
Yes, sir.
6 CHAIRMAN SELIN:
So, one wants to allow 7
the data to be updated, but you'd like to be able to 8
keep track of what the algorithms are.
9 And the second is, at least in my opinion, 10 while I agree with your conclusion that you don't want 11 the PRA to be in the rule per se -- thinking about our 12 problems with the design basis reconstitution, wo 13 would like to keep a configuration control on a PRA.
14 If somebody changes some data, or more importantly, if 15 we decide there's a
better way to calculate a
16 probability, we would like to keep track of when 17 changes are made and who agreed to them.
In my 18 opinion, outside the rule itself, but in parallel with 19 the rule, so we don't have to go back and say, "why 20 did we go from 10 to the minus 6 to 10 to the minus 5?
21 What happened at that point?"
22 MR. RUSSELL:
Yes, sir, I agree.
We need 23 to address that as it relates to policy issue, how 24 it's going to be used longer term.
25 The staff did have difficulty in shifting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W-(202) 2344 433 WASHINGTON. D C. 20005 (202) 234 4433
29 1
its review focus. That's why this has become somewhat 2
of a controlling path item.
We were focused, early-3 on, more on the quality of the PRA and not what we 4
were learning from exercising the PRA.
That's been a 5
hard learning process, both for us and for General 6
Electric.
7 The third area is the electrical design 8
area.
There are a relatively large number of open 9
We had glite a 10 significant number of comments from the Greybeard and 11 we're also factoring in our lessons learned from the 12 electrical design safety functional inspections which 13 are going on now, which are being done at all plants.
14 Much of the design in this area can not be completed 15 from the standpoint of detailed voltage drop analysis, 16 breaker coordination and other things, which relate to 17 hoth procurement decisions and having an as-built 18 plant in order to be able to do these.
19 So that the area that is somewhat 20 difficult at this point in time is reaching agreement 21 on the particular tests to be performed and the 22 analyses which would go along with those tests and 23 getting that in detail.
This is an area where we 24 think it's relatively well defined.
It's a matter of 25 resources and reaching closure, and we are providing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
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management attention to this area, both by GE and the 3
i 1
2 staff.
1 3
In the area of instrumentation and j
4 controls, it's a two-part review.
The functional i
j 5
review using the standard approaches as laid out in 6
the standard review plan, looking at diversity, this 7
is the potential for the common mode failure.
That-l 8
review is making progress.
The ACRS commented on the i
9 fourth -point of our position on diversity, but I
10 generally agreed with - the analytical approach ' of l
11 identifying potential for common load failure, showing 4
l 12 that the plant was able to handle those with credit 13 for operator _ action and credit for non-safety systems.
j 14 It was more at the system level: actuation from the 15 control room for a minimum set of functions. As Denny l
j 16 mentioned, we are agreeing that dedicated digital 17 would be acceptable, provided it has appropriate 18 quality and reliability.
l 19 There is one issue that is pending with l
20 the GE review as it relates to that point four.
And 21 that is, essentially, whether a _ train of emergency--
22 core cooling should have system level actuation from 23 the control room in order to provide make-up. General 24-Electric has evaluated the events and believes that 25 they can handle common mode failure type events i
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without ECCS if feed water is functional. That is, if 2
it is continuing to operate.
That issue is under 3
review by the staff and we are, at this point, trying 4
te decide whether there are any system interactions 5
between the proposed or postulated failure mode with 6
feed water being interrupted either through a
7 containment isolation or an
. indirect systems 8
interaction, whether that can be addressed by test or 9
whether we should, in fact, require one train of ECCS 10 be provided.
This is ongoing now.
Technical 11 discussions are going on. We hope to reach closure on 12 that issue within the next few weeks.
13 There is still work to be done in the 14 second area related to the DAC for I&c.
There were 15 questions from the ACRS both on the software / hardware 16 integration quality process, that is the methods that 17 are used to develop the software and the hardware.
I 18 would characterize that the technical _ approach has 19 been, essentially, agreed to.
We're probably over 90 20 percent there.
There are some related issues related 21 to environmental qualification, set points within the 22 I&C architecture that need to be addressed that we're 23 still working on.
So, that process is not yet 24 completed.
25-The final area, which is potentially a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RH00E ISLAND AVENUE, N W.
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scheduler item -- it's not a difficult technical issue is the reanalysis that's going on now of the 2
3 structures based upon the EPRI agreed upon tornado 4
wind speed, spectrum, and some other issues that are 5
causing redesign of the upper levels of the structure.
4 6
Those redesigned features are having an impact on the 7
seismic analysis. And so, there is a redesign effort, 8
reanalysis effort, underway by Bechtel on behalf of i
We have conducted an audit in l
10 progress of that work.
We found that it looks l
11 satisfactory.
It's a matter of completing the work 12 and answering a few questions which were documented in 4
13 our audit report.
We expect that this work should be 14 completed by the end of January, but it's going to be I
15 tight, completing and documenting the results of that 16 review, if it doesn't come in until that late.
17 (Slide)
If I could shift now to ITAAC and 18 have the first slide on ITAAC background.
19 I want to just make some general points 4
20 here before I go into the more detailed discussion.-
21_
We're talking about three pieces. We're talking about 22 the certified design description, which would be'in 23 the rule.
This is material which is extracted from 24 the standard safety analysis report, and it includes 25 functional one-line drawings.
This controls the NEAL R. GROSS
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design over the life of the plant.
That is, the 50-59 2
like change process would not be permissible to make 3
changes which would impact the certified design.
4 The ITAAC themselves, it's a three column 5
format.
The first column is the certified design 6
commitment which is extracted directly from that 7
design description.
The second column defines the 8
method of demonstration that the design commitment has 9
been met.
That is, the type of inspection, test, or 10 the analysis to be performed.
And then, the third 11 column is the explicit acceptance criteria for that 12 method of demonstration.
1.,
We sent an earlier Commission paper to 1
14
- you, SECY-91-178, that identified what the staff 15 believed then were the scope of the ITAACs.
- Clearly, 16 we recognize that there would be ITAAC for structures 17 and systems, and this is essentially what we have been 18 working on and has been the bulk of the reviews to 19 date.
We've generated, since that time, the concept 20 of design acceptance criteria. That's been covered in 21 separate papers with the Commission.
But we did 22 identify an area where we are rethinking our approach.
23 This relates to generic and discipline requirements, 24 and I will-specifically discuss our approach to 25 equipment qualification and welding to give you an NEAL R. GROSS COURT REPORTER $ AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
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example, functionally, how we propose to resolve it on 2
a technical basis.
3 COMMISSIONER REMICK:
What is meant by 4
discipline there, Bill?
i 5
MR.
RUSSELL:
It could be equipment I
6 l
qualification which covers all areas in the plant.
It 7
could also be included quality assurance programs or 8
training programs, things which would be implemented 9
by the COL.
10 COMMISSIONER REMICK:
So, it's what you 11 sometimes call " programmatic"?
12 MR.
RUSSELL:
It could be considered 13 programmatic as well.
14 COMMISSIONER REMICK:
Is there a list 15 anywhere of these items that are being discussed as 16 general ITAAC in programmatic or discipline ITAACs, or 17 specific lists?
18 MR. RUSSELL:
That list has been --
19 COMMISSIONER REMICK:
I hear different 20 things from time to time, but I don't think I --
21 MR. RUSSELL:
Yes.
That list has been 22 changing.
At this point in time, we've agrend with 23 NUMARC that we need to focus on those issues which are 24 necessary for design certification first.
The one 25 programmatic in that category is quality assurance.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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The others that I've mentioned are equipment 2
qualification,
- welding, set point methodology, 3
environmental qualification for digital control 4
systems, for example.
It's a liot of about eight to 5
ten.
It varies from time-to-time, and that's the list 6
that we're working of f.
We're going to be updating it 7
and we'll send it to the Commission.
8 COMMISSIONER REMICK:
Would you send us a 9
sample list, just for information?
10 MR. RUSSELL Yes, sir.
11 The last --
12 DOCTOR MURLEY:
Commissioner, in the 13 paper, we propose to come to the Commission with a 14 policy paper on this and that will have the complete 15 list.
But we'll send you a sample to tell you what --
16 MR. RUSSELL:
Yes, to give you an idea of 17 what issues we're dealing with now.
18 COMMISSIONER REMICK Just for my 19 education.
I get confused on what's in it and what 20 isn't.
21 MR. RUSSELL:
Okay. The last area was one 22 that --
23 CHAIRMAN SELIN:
Are you going to cnme 24 back to this?
25 MR. RUSSELL: Yes, sir.
I'm going to come NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE?JUE, N W (202) 2344433 WASHINGTON. D C. 20005 (202) 2344433
a
)
36 1
to that with a separate slide and discuss it in some 2
detail.
3 The last area we identified in SECY-91-178 i
4 was what I'll call safety analysis verification. This i
5 is baulcally because the ITAAC are organized by system i
j 6
and structure, and yet, the safety analysis that we 5
7 performed, in accordance with the standard review 8
- plan, it cuts across systems.
It costs across 9
structure.
Chapter 15 basically is a review of the 10 integrated plan. So, we're talking about how you take 11 the insights from those safety reviews and factor them 12 back in.
And just as I mentioned the approach on PRA, l
13 we're doing the same thing for Chapter 15.
If there 14 is an important assumption in Chapter 15, that would i
15 be identified and would be passed back to the 16 particular system which that feature is in, to make 17 sure that it's captured with the appropriate ITAAC.
18 (Slide)
If I could.have the next slide, 19 please?
20 Some of this has been discussed.
I'll go i
21 through it very quickly.
The most recent phase f
22 submittal on the GE ITAACs came in in May of
'92.
23 There have been meetings, markups of specific ITAAC 24
-since then, and there's been a significant amount of l
25 independent review, including the regional inspector NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS' 1323 RHODE ISLAND AVENUE, N W.
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37 1
review and the Greybeard review that Tom mentioned, as 2
well as the ACRS review.
All of those comments have 3
been sent to General Electric, 4
The industry independent review that was 5
conducted in the September, early October time frame, 6
I actually participated in two days of that meeting in 7
going through a number of ITAAC.
And I would like to 8
characterize my views from that ineating.- And that is, 9
that there was significant value added to the scope 10 which was reviewed.
They made the-ITAAC more 11
~ objective and verifiable.
They eliminated ambiguous 12 language, and they, in fact, have become more well 13 defined.
14 7 do have a concern though that the scope 15 of the review was limited.
It did not go back into 16 the SSAR.
It did not include looking at technical 17 specifications.
It didn't use PRA-insights or severe 18 accident closure kinds of issues.
So, it was a review 19 of that which existed at the time.
It was not 20 additive.
It was not identifying additional things 21-which-should be covered within--the scope of ITAAC.
22 That has been pretty much left to General Electric and 23 the staff to work out.
24 We are hoping - that we can have-some 25 successes: to talk about very soon.
The week of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 13M RHODE ISLAND AVENUE. N W.
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December 7th, in addition to receiving the schedule 2
for the subsequent chapter submittals, we are actually 3
going to start a review of Chapter 9, for which we 1
have had some
- meetings, closing open items in 5
principle, but they are going to come in with an 6
updated SSAR with the revised ITAAc that go with
?
Chapter 9.
We will start a chapter meeting at that B
time.
And so, we will have a feel for the scops or i
l 9
the change that's resulted from our own reviews t.nd 1
10 from the industry reviews, as well as be able to 11 addrest it with completed SSAR material, with the open 1
12 items closed.
10 So, that will be sort of the measure of 14 that chapter. And since it covers quite a significant f
1!!
number of the open items, it should be a fairly good i
16 neast.!e of how close we are on schedules.
And we will 17 factor that in when we're working up the more detailed 18 schedules for the Commission.
i 19 COMMISSIONER REMICK:
What's the subject i
20 of Chapter 97 21 MR. RUSSELL:
That's systems review.
22 (Slide)
If I could have the next slide, 23 pleasei ITAAC lessons learned?
4 s
24 Out of the staff and industry reviews, I'd 25 like to summarize what we think are the important NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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lessons learned to date.
i 2
First is, the quality and completeness of 3
the SSAR, the design description in the ITAAC is 4
essential.
They interact with each other.
They're 5
closely coupled.
Clearly, the SSAR _ is a necessary 6
input to the ITAAC.
And if the SSAR is not complete, 7
if it has open
- items, there are going to be 8
significant questions remaining on the completeness of
-9 the ITAAC that flow from that.
10 We've also learned that it is important to 11 put an emphasis on testing and as-built inspection, to 12 1.ry and minimize the amount of analysis to be done.
13 In the testing area, we're making heavy use of the 14 pre-operational testing programs, -Red Guide
- 168, 15
" Standard Test Procedures for Product Lines," such as -
16 BWR 5 and 6, to try and ensure from past startups of 17 NTOLs, the scope of testing which is appropriate.
So, 18 we are trying to use that as a-part of our review 19 process.
20_
COMMISSIONER REMICK:
What's "NTOL"?
21 ttR. RUSSELL Near-term operating license.
22 Plants which have started-up recently.
23 Me feel _ also, it's _- critical that the 24 analysis methods must be defined in sufficient detail 25 in either the ITAAC or in-the SSAR.
If-the approach-l l
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is to put the detail in the SSAR, then there needs to 2
be a reference which is actually within the ITAAC.
3 So, you may describe an analysis generally in the 4
ITAAC, and then in the SSAR, identify an acceptable 5
method.
The issue is that you can make changes to 6
tier 2.
That would be an issue that we would then 7
review to decide whether it was a permissible change 8
under 50-59.
And if there is a change in the analysis 9
method that could become an issue, you would not 10 maintain issue prealusion at the time that the ITAAC 11 is being demonstrated, i
12 COMMISSIONER REMICK:
Does that present a 13 complication in the pipe stress area where that's a 14 proposed DAC which, presumably, would be an ITAAC in 15 tier 1?
But would there possibly be parts of that 16 that would be in tier 2 also?
17 MR. RUSSELL:
In fact, within the piping 18 analysis method, the bulk of the technical information 19 is contained in tier 2 with commitments to methods and i
20 analytical processes in tier 1,
with acceptance 21 criteria principally being the allowable stress levels 22 in tier 1.
23 And what we have done is, we've identified 24 in addition, benchmarking that can be used so that 25 different computer codes and analytical methods could NEAL R. GROSS 7 JRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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41 1
be used provided they pass the benchmarks.
So, we 've 2
tried to build into tier 2, a mechanism for approving 3
future evolution of codes, for example.
But that is, 4
in fact, the approach that we're taking.
5 We've also found that it is very important 6
to have references to codes and standards be more 7
generic, where they are necessary in tier 1,
for 8
examplef the ASME code.
And put in tier 2,
the 9
details of the addenda, of the addition, code cases, 10 et cetera.
And this is particularly important when I 11 discuss the welding example.
12 (Slide)
If I could have the last ulide, 13 please?
14 The major issues that are pending in the 15 area of ITAAC for completion of the BWR review 16 principally relate to an uncertainty on the staff's l
17 part with respect to the magnitude of the changes i
4 18 which may have occurred to materials that have been 19 previously reviewed in the ITAAC, both flowing from 20 the Greyboard reviews, the independent review by 1
21 Region 4, with other regional input under Bill Beech, 22 and the industry's own review.itself.
23 We still have issues about scope, to 24 ensure that the ITAAC meet the necessary and 25 sufficient standard with appropriate ties to tier 2 NEAL R. GROSS COURT RFPORTtRS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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42 1
material.
I would characterise that the industry 2
focus to date has been more on, "is the ITAAC doable?"
3 "Is it objective?" But they have not been essentially 4
adding to
- scope, and so that this issue of 5
completeness and meeting the necessary and sufficient 6
standard has more fallen to the staff rather than the 7
induntry.
8 The second point is that the definition of 9
ITAAC analysis methods, as I previously discussed, 4
j 10 clearly need to either be in tier 1 or tier 2.
And 11 there are some cases where there are more generic 12 references without the details as to how the analysis 13 will be performed.
This is a case where the ITAAC 14 itself feeds back into the SSAR, where we need more 15 detail in the SSAR.
16 The independent review of the ABWR ITAAC 17 and SSAR, we concluded because of the problems with 18 consistency and quality.
That there really needed to 19 be an independent review when the staff was 20 technically complete.
So, at the point where the 21 technical staff has concluded that particular chapters 22 and systems are complete, we propose at that point 23 when we have the information in also from GE, to 24 conduct en independent review of 100 percent of the 25 ITA)
and the certified design description by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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knowledgeable staff that have been independent of the I
2 development of that process to ensure its quality.
3 COMMISSIONER CURTISS:
Would you, in that 4
rep"1, intend to go back to the ITAAC working group, 5
the so-called Beech review?
6 MR. RUSSELL:
We've actually formed a 7
group that will be conducted here in headquarters 8
because we think it will take a longer period of time 9
than the sampling that was done.
Both the Greybeard 10 review and the Beech review only sampled a few areas, 11 and so, we're looking at putting an SCS manager in 12
- charge, and running that in parallel with the 13 project's final processing of the final safety 14 evaluation report.
We're anticipating that it will 15 take about two months in order to complete that 16 effort, but that will be done in parallel with the i
17 actual processing in projects of that work.
18 COMMISSIONER CURTISS:
What you have in 19 mind is to bring an independent. set of eyes and ears 20 to bear on the effort, people-who have not been 21 directly involved in it --
22 MR.
RUSSELL:
That's correct.
Both 23 regional perspective and management perspective from 24 within NRR.
25 COMMISSIONER CURTISS And that will NEAL R.- GROSS COURT REPORTMS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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1 include the inspection perspective that you had with 1
2 the Beech review?
3 MR. RUSSELL:
That's correct.
Yes.
4 DOCTOR MURLEY:
I haven't ruled out the i
5 possibility that I might want to ask the Greybeards to 6
take one more look at it to see what we've dane in the 7
six months or so since they've looked at it, but I 8
haven't decided, i
9 COMMISSIONER CURTISS:
Yes.
I thought 10 both the Greybeard review and the working group review 11 were particularly helpful in shaking down a lot of the 12 ITAAC questions --
13 DOCTOR MURLEY:
Yes.
14 COMMISSIONER CURTISS:
-and that 15 perspective that you got from stepping back and taking 16 first the Greybeard and then.
the inspection 17 perspective.
I thought it was especially valuable.
18 MR. RUSSELL:
The last area I'd like to 19 discuss is the technical approach which we envision 20 may be possible for resolution of generic ITAACs, and 21 I will discuss welding and equipment qualification.
i 22 In the welding area, what we propose is 23 that the functional drawings which are a part of the 24 certified design description, which are annotated now l
25 to show the ASME Class 1, Class 2, Class 3, non-class NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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45 i
1 boundaries, be a part of the control mechanism.
2 Clearly, the code requirements for the welds which are 3
within the Class 1 boundaries, are well specified i
4 generically in the tier i design description, within i
5 detail in tier 2 for particular types of welds, as to i
6 What would be the acceptable final non-destructive 7
examination for those we? >.s, whether it requires a 8
visual and a radiograph or a PT of the route pass, for 9
example.
10 COMMISSIONER CURTISS:
You used the term 4
l 11
" controlled mechanism."
By that, you mean tier 1 or 12 tier 2?
13 MR.
RUSSELL:
We expect that in the 1
14 certified design description, we would have textual 15 commitments to the code requirements, for example, for 16 welding of the reactor pressure boundary.
That would 17 be contained then, also, on the functional drawings r
18 and we would actually have inspection requirements 19 that would be in the ITAAC.
In general, the first 20 ITAAC for each system is a
physical walk-down.
21 inspection of the
-facility to confirm that l
22 functionally, it is laid.out in accor6ance with the 23 certified design.
24 In this case, we would also be able to-25 sample -- by inspection this would be done 100 percent NEAL R. GROSS i.
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1 by the COL holder, but the staff would be able to 1
l 2
sample particular welds and confirm that the welding 1
1 3
NDE records existed, such that we could conclude the 4
welds were satisfactory.
We may even choose to send 5
the NDE van up and do our own radiographs, inspection i
6 of welds, for example, as a part of that process.
7 COMMISSIONER CURTISS: But for purposes of 8
design control, you don't have in mind a separate 9
design control document --
i 10 MR. RUSSELL:
No.
i 11 COMMISSIONER CURTISS:
-- apart from what 12 is set forth in tier 1 and the design certification?
13 MR. RUSSFLL:
It's clearly contained in
~
14 tier 1 and tier 2, and this is an area where we're i
15 seeing that there would be an expansion of textural 16 material in tier 2 in order to accommodate this i
l 17 approach.
And we've actually gone through with the i
18 standard review plan, with the codes and~ standards and 19 the code cases and identified for each type of weld 20 what the staff believes would be the minimum 21 information that we would require, and that would be 22 contained in the SSAR in tier-2.
23 COMMISSIONER CURTISS:
Okay.
-24 CHAIRMAN SELIN:
. Before you go on, Mr.
25 Russell,-is there anything special in these welds NEAL R. GROSS COURT REPORTERS AND 1RANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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47 1
that's beyoi.J what has been done in the past?
2 MR. RUSSELL: No. It's just capturing the
-3 commitments ana putting them into the context of an 4
ITAAC, but doing it in a system-by-system approach S
rather than doing it with a generic IL.AC which would 6
relate to welding process or training and i
7 qualification, for example.
Those issues we feel we 4
8 con address with non-destructive examination and with 9
sign-as-you-go process.
10 So, we believe that the more important l
11 issue is the integrity of the weld.
And the other l
12 materials in tier 2 would be subject to inspection in l
13 the normal enforcement process but wranld not raise to 14 the level of an ITAAC.
4 i
15 CHAIRMAN SELIN: So, the reason this is at J
16 an ITAAC level is no longer that the weld has to be I
17 done in a certain fashion, or that it's a certain 18 process.
But now, the inspectors will determine that l
l 19 the welds have been done satisfactorily, or how we 20 will know that these welds have been done
[
21 satisfactorily?
1 22 MR. RUSSELL:
That's correct.
We believe i.
1 23 that the more important issue'iw the non-destructive i
i.
24 examination, quality control aspects of the weld ~
25 through NDE.
There clearly are other processes that i
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are important, that are commitments that are made that 2
are in tier 2.
They would be subject to inspection j
2 and enforcement.
If we found that those had not been it may impact our a' ility to conclude that 4
- followed, o
5 the welding was acceptable.
For example, if you loose 6
control of weld rod and you don't know what materials 7
were used, you can do an examination.
You may have to 4
8 then do a chemical analysis to show that you had the 9
right materials in a weld.
10 DOCTOR MURLEY:
Mr. Chairman?
k 11 MR.
RUSSELL:
But that8s through 12 inspection processes, not through ITAAC.
13 DOCTOR MURLEY:
The reason this is an 14 issue has to be viewed in the context of our 15 experience with Seabrook where the plant was built, 16 constructed, and was ready to operate when there were j
17 some challenges, serious challenges, as to the quality 18 of welds that were done many, many years ago.
We want 19 to avoid that kind of problem.
20 And the way we're doing it,_of course, is-21 the sign-as-you-go process.
But we want to get into 22 the ITAAC, the necessary standards and requirements so 23 that once we determine they've been met, then-it's 24 clear that they're basically unchallengeable.
25 CHAIRMAN SELIN:
Well, that I understand, NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE. N W.
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but let me tell you what's bothering me.
Really, two 2
things that bother me about this.
3 The first is, when we say how will we 4
determine a weld has been done?
These plants may be 5
built over a period of 20 years, 30 years, and I 6
assume that there will be enormous improvements in 7
non-destruction. testing.
Are we going to lock 8
ourselves into 1992 inspection technology? Or are we 9
setting a standard that says outside the rule, we must 10 determine these welds are okay and here's the theory?
11 But we're not set into specific equipment or specific 12 measurements.
There's room for progress in the 13 testing site.
14 MR. RUSSELL:
That's exactly the reason 15 why we want to put this information in tier'2.-
So 16 that if there is a change to the American Welding 17 Standards, that that change can be factored in.
If 18 there are improvements in-NDE examination methods, 19 that can be factored in.
So, what we're defining in l
l 20 tier 2 is an acceptable way, based upon code standard l
21 indicia, and what exists today that the staff would 22 say is clearly acceptable.
So, we're defining an
{
23 acceptable method of demonstration.
l 24 CHAIRMAN SELIN:
But there can be other I
25 methods?
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MR. RUSSELL: But there can be others, and 2
that's why we wanted to put it in tier 2, not in tier 3
1.
4 CHAIRMAN SELIN:
And the second related 5
question is -- I mean, there are hundreds, literally 6
hundreds of inspections, different kinds of 7
inspections, one does in a plant.
How do you pick out 8
those that deserve ITAAC level as opposed to just 9
saying, "we want to make sure the concrete is proper, 10 the static strength of the structures is there," et 11 cetera?
12 MR. RUSSELL: In this cLse, we're focusing 13 on the integrity of the reactor coolant pressure 14 boundary.
In cases of civil structures, we have an 15 ITAAC for these structures and it is essentially a 16 function of their capability to handle the loads and 17 the loadings on those structures which we've imposed 19 as a part of the design process.
And this is where 19 bridging comes in.
20 We expect to look at the engineering 21 that's done against those ITAAC.
That's why that 22 review is being done now on the structural review, so 23 that it would specify what are the capacities and 24 capabilities.
But there is flexibility that would 25 exist to change wall detailing as long as the wall is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
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51 1
able to carry the loads.
And so, that could be done 2
in first of a -- engineering, or there may need to be 3
an as-built reconciliation done.
So, we're actually 4
also approving the methods as a part of our review so 5
that you could demonstrate that that is acceptable 6
from the standpoint of handling those loads.
7 So, we do have nominal wall thicknesses 8
and characteristics of structures that are proposed to 9
be in the structural ITAAC.
So, we would not be down 10 at the level of testing rebar placement or concrete.
11 That's something that's a part of the inspection 12 process.
If we find that the concrete strength is 13 less than that which was assumed in the engineering 14 analysis, it may require that they repeat a portion of 15 the engineering analysis to show that the ca-bp '.t 16 plant is still acceptable.
So, we have a tie back to 17 the
- ITAAC, but we are proposing to put that 18 information essentially in tier 2 or - in ~ the design 19 sign-as-you-go process for the details of engineering.
20-CHAIRMAN SELIN:
-Your answers are pretty 21 plausible.
They're actually better than I 'had 22 expected.
Nothing personal, but I haven't gone-23 through the material.
24 On the other hand, I do want to make sure-25 that we don't lock technology in too early, or we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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52 1
don't reinvent the wheel.
I mean, people have been-2 building concrete structures and pressure vessels for l
3 a long time, We have to balance the ITAAC to be sure 4
that the design is carried out as designed with -- you 5
know, not setting up a whole lot of ITAACs on what are 4
6 standard operating procedures.
j 7
I have the impression you've solved that, 8
but I'm still a little uncomfortable that we not put 9
more than we have to into the certification and into 10 the design review.
It's one thing to say, "this is a 11 new approach in instrumentation.
How we will be sure 12 it's carried out?"
And it's another to say, "we're 1
13 going to put in some pipe which we've been putting in 4
14 for years." I thought Doctor Murley's answer and your 15 answer about it's better to settle these issues, at least have a sufficient set -- not a necessary set, 16 i
i 17 but a sufficient set in advance.
And if we can do 18 better when the time comes up, so much the better.
19 That's also a persuasive argument.
20 MR. RUSSELL:
I agree with your caution.
21 And while we have agreed on approaches to be worked 22 out, we'll see this the week of the 7th of December 23 for the first systems.
We still need to see the 24 details. We need to share that with OGC and taake sure 25 that the language on these first systems and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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approach that we're taking is consistent with the law 2
in Part 52.
3 CHAIRMAN SELIN:
Well, as long as you can 4
do what you indicated, which is ways of measuring the 5
results as opposed to a process review, I'd be fairly 6
comfortable.
I'd be very uncomfortable on a rule that 7
effectively built on the construction process or a 8
welding process.
9 MR. RUSSELL:
No.
These are focusing on 10 results.
In fact, if I could give you the second 11 example which is environmental qualification, we're 12 following a similar approach.
13 COMMISSIONER CURTISS: Bill, before you go 14 on, let me just ask a scheduler question.
You 15 indicated that your schedule for coming to the 16 Commission with your construction inspection program 17 called for that to come up in August of
'93.
You've 18 obviously given a great deal of thought here, at this 19 stage of the process, on what needs to be set forth in 20 the certification or in the related documents, so as 21 to permit you to carry out an inspection in the way 22 that you think you need to.
23 Can you tell me, what is it that that 24 follow-on paper will address because that paper, at 25 least I think, will come after the FDA has issued for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVENUE, N W.
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GE? And is there a need to take a look at having that 2
paper put together in conjunction with what you're 3
doing now?
Akin to what we had with the ITAAC being 4
.very valuable and informing the design, that strikes 5
me as an issue worth looking at.
6 DOCTOR HURLEY :
Yes.
I think that's a 7
good point, Commissioner.
The plan is that we will be 8
looking over the next summer at construction methods 9
and how we will fashion our construction program.
10 One of the things I wanted to do, for 11 example, was make sure we understood the new modular 12 construction techniques that are being developed right 13 now in Japan, for example, for the ABWR to make sure 14 that we understand how the next plants in the U.S.
15 will be built.
We haven't really begun to look at 16 that and that's going to take some time.
But insofar 17 as the need to understand the inspection program is 18 needed by the Commission to evaluate the FDA, then 19 we'll have to get that up maybe a little sooner.
20 We'll keep that in mind.
21 COMMISSIONER CURTISS:
Okay.
22 DOCTOR MURLEY:
There clearly is a
23 connection as you point out.
24 COMMISSIONER CURTISS:
Okay.
Thank you.
25 MR. RUSSELL:
Yes.
Our approach has been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE N W.
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55 1
to define bridging and give examples in specific areas 2
without necessarily having completed the review. It's 3
more a matrix review of what would be the minimum 4
inspection that we would expect to do, in what areas, 5
and why.
To provide guidance in the process and to 6
learn the lessons from recent inspections and look at 7
our construction inspection procedures, our pre-op 8
procedures.
We have generally not done a good job at 9
looking at engineering early on.
We need to build up 10 that area.
So, it's more on the details of how we 11 would be inspecting and we'll look at that to see.
12 We would expect to identify the policy issues of 13 bridging and how that would go much sooner than that.
14 But there clearly are some areas we may have to 15 illustrate that with specific examples.
16 MR. CRUTCHFIELD:
The bridging concept 2
17 will be covered in the form and content paper for the 18 COL which is scheduled for about the February time 19 frame.
20 COMMISSIONER CURTISS:
Right.
21 MR. CRUTCHFIELD:
It will translate the 22 functional requirements identified in the design 23 certification into something that the inspectors can 24 use out into the field, and it's the process we will 25 lay out there.
Some of the details will follow up in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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the later time frame, later in the year.
But we will 2
look at bringing that inspection program up earlier.
3 COMMISSIONER CURTISS:
I lost track of my 4
dates.
The schedule -just -- on the form and content 5
for the COL 7 6
MR. CRUTCHFIELD: COL form and content was 7
about February.
8 COMMISSIONER CURTISS:
February?
9 MR. CRUTCHFIELD:
Yes.
10 DOCTOR MURLEY:
But if we can get it in i
11 January, we'll get it in January.
12 COMMISSIONER CURTISS:
I thought it was 13 January.
Thank you, 14 MR.
RUSSELL:
The approach that we're 15 taking on environmental qualification, by way of a 16 second example, is similar to the approach on welding.
17 We propose to identify the harsh environment 18 boundaries on the functional drawings.
Identify that 19 equipment, for example, which is inside containment, 20 so that the pumps, valves, and sensors are clearly 21 identified in a tier 1 commitment.
We would have to 22 tie in supporting features to that such as cabling to 23 the sensor out to the containment penetration, so that 24 you have a complete path for the circuitry.
25 We would be looking for a text commitment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
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to essentially the equipment qualification rule, plus 2
methods of demonstration by way of test and analysis, 3
and that that would be in the tier 1
design 4
description.
It could be that for the mild 5
environments, that is for pipe breaks outside of i
6 containment, that the structural drawings which show 7
the compartmentalization would be annotated to l
8 identify that equipment within that space that 9
performs safety functions would have to be qualified 10 to a particular environment.
Those pipe break 11 analyses have been done, so that information is.
i 12 available in the SSAR.
I 13 We would then propose to use an' inspection 14 walk-down similar to the inspection walk-down that.'s j
15 in the tier 1 requirements now for an ITAAC, that is 16 a system walk-down.
You would-have identified the 17 components active that are subject to harsh-i 18 environment.
-It could be a walk-down where you would if you have through your sign-an-you-go 19 inspect i
20
- process, approved the
- detail, the equipment-21 qualification methodology, and you find that there is 22 an EQ tag hanging on a.particular piece of gear.
If 23 you have confidence in: that from your prior 24 inspections, you may conclude that that's a sufficient 25 basis for the-ITAAC walk-down.
Or you may actually NEAL R. GROSS
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wish to pull. some of the qualification files and 2
records and inspect to ensure that they're qualified.
3 So, we see that we have an mechanism that -
3 4
would either allow us to do this early-on as a part of 5
sign-as-you-go to get confidunce in. how they've 6
handled _ the equipment qualification of particular 7
components more on a generic basis.
But when it comes l
8 to an ITAAC, we would be able to confirm by walk-down 9
_of systems, -that they are indeed - environmentally 10 qualified.
So, if there is an-issue regarding 'a i
j 11 particular component, it's focused on through the 4
12 particular ITAAC for that system.. And we believe with
]
13 this approach, we would not have a need for a generic j
14 ITAAC.
l 15 In the SSAR, we have shared with NUMARC l
16 and General Electric, the approach which we would l
17 propose.
The model we gave them was for seismic i
18 qualification, which. was a part of the equipment 19 qualification approach where we had_ extracted from
'20 proprietary documents and other information that had 21 been provided from GE, the-~ kinds of information we 22 would expect to see--in-tier 2.
We do have to make-23 sure that the design control document is independant.
24-of proprietary information.
So, we tried to make that i
25 split and share those examples with them.
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But we believe that by putting the details 2
in tier 2 and identifying it as "an acceptable way" of 3.
performing the testing or analysia for equipment 4
qualification, and putting the explich requirements 5
in tier 1 of what must be qualiffed, and to what 6
envelope that we would have an acceptable approach and 7
would not require a generic ITAAC, the issue with the i
1, 8
generic ITAAC could be that you would then litigate 9
the process that was followed for equipment 10 qualification, rather than litigate whether the 11 particular hardware was or was not qualified.
12 So, we think that this approach can be 13 used in _other areas, but we have not had the 14 opportunity yet to dialogue with NUMARC and GE on 15 other approaches.
But this is what we have developed 16 thus far, as an approach to generic ITAAC where they 17 relate to design features in the design certification.
18 CHAIRMAN SELIN:
Just two questions.
19 First of all, you.used a phrase before that you and 20 NUMARC had decided to concentrate on those generic and 21 programmatic ITAACs that are required for design 22 certification.
What else is there?
23 MR. RUSSELL:
There are essentially ITAAC 24 that are required at-the-COL stage.-
25 CHAIRMAN SELIN:
-But they're not design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE,. N W.
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2 MR. RUSSELL:
They are 3.ot design.
3 CHAIRMAN SELIN:
Okay. So, they're not--
4 MR. RUSSELL:
It's like training.
You 4
f 5
need to have a training program.
l 6
CHAIRMAN SELIN:
Right.
But they're not-i 7
a part of the certifying.
i 8
MR. RUSSELL:
That's correct.
9 CHAIRMAN-SELIN:
It's almost unfortunate 10 we don't have a separate name for them.
Those are 3
i 11 specific to a given COL.
Each COL would have its own 12 conditions that had to be --
13 MR. RUSSELL:
That is correct.
14 CHAIRMAN SELIN:
determined before i
15 operation could begin.
16 MR. RUSSELL:
Yes.
We're calling those 17 COL ITAAC.
They're ITAAC from design certification i
18 and Appendix C of Part 50 uses the same terminology, 19 but they're not called separately.
20 CHAIRMAN SELIN:- This Agency has a unique 21 insight into how to come up with snappy acronyms, I've 22 noticed over the years.
23-Second, what's left'of generic ITAACs once 24 you've finished this approach?
It sounds to me like l
25 very little, if any at all.
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MR. RUSSELL:
We believe at this point 2
that subject to working these through successfully, 3
working out the details, that there would not be a 4
need for generic ITAAC for design certification.
5 I could also discuss the approach that 6
we're taking to quality assurance and illustrate that 7
with an example that's come up on Watts Bar.
In Watts 8
- Bar, there are missing records for construction 9
activities associated with electrical conduit and 4
10 cable tray supports.
The approach that's being taken 11 is one of evaluating the as-built plant and showing by 12 analysis that the supports are adequate to perform 13 their design function.
14 We would propose to ensure that we have a 15 sufficient set of ITAAC with detail that pulls up to 16 tier 1 by reference, such that if there were a QA t
17 problem that resulted in defective equipment, that we 18 would be able to litigate the equipment as to whether 19 it's capable of performing its design function or not, 20 and not necessarily the QA process.
21 CHAIRMAN SELIN:
Not the rule, in other 22 words?
23 MR. RUSSELL:
Not the rule itself.
24 We would envision, however, that there 25 would have to be a heavy emphasis on quality assurance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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during our inspection processes because we would l
2 necessarily have to rely on documents that are 3
generated from engineering, for example, to go to 4
construction or from construction into - pre-op.
So 5
that we see that building confidence in the adequacy l
6 of the QA problem would allow us to rely on documents 7
and records of completion of activities and would 8
still be important from that context.
But what would f
9 we would like to do was tie the ITAAC themselves to i
10 the actual hardware.
11 So that, in the Watts Bar example, we 12 would litigate the acceptability of the conduit, cable 13 tray supports, and not:the fact that they lost record's 14 someplace that we can't find.-
In other words, we 15 would address it that the hardware is acceptable.
16 CHAIRMAN SELIN:
So, you really are going 17 to try to keep the standard processes-in place as much 18 as possible, and:put.into the ITAAC that which is 19 absolutely, essentially new and not any more than 20 necessary? I mean, build up QA, build up inspection, 21 take care of the process questions on the ground-22 rather than trying to build them into the ITAAc?
l 23 MR. RUSSELL:
That's correct.
'And tie 24 those to the sign-as-you-go process and our ongoing 25 inspection activities.
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CHAIRMAN SELIN:
Okay.
i 2
MR.
RUSSELL:
But keep the ITAAC 3
specifically._for the hardware and not for the 4
processes.
j 5
CHAIRMAN SELIN:
Is it fair ta assume you 6
will stay here for the rest of the morning and if we 7
have questions after the other --
8 DOCTOR MURLEY:
Yes.
9 MR. TAYLOR:
Yes.
10 CHAIRMAN SELIN:
Any other questions you 11 would like to ask this group, realizing they'll be 12 still here at the end of this session?
l 13 Okay, why don't we take a five minute 14 break and prepare for the next session?
15 (Whereupon, at 10: 4 4 -a.m., off the record 16 until 10:49 a.m.)
17
. CHAIRMAN SELIN:
Are you playing offense 18 and defense today, Mr. Rasin?
You have meeting today i
19 now and NUMARC in a half an hour?
20
. MR. RASIN:. No, sir, I thought-maybe I was 21
'a referee.-
4 22 CHAIRMAN SELIN:
Among the GE people, I i
- 23 assume..
]
24~
Doctor
- Specker, you've:
heard the 4
1
- 25 conversation this morning and you can go further into 4
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i
-We're very interested -in ' GE's -
_1-the introduction.-.
1 4
2; viewpoints on the same topics and we'll turn the floor j
l 3
over to you.
4 DOCTOR SPECKER:
Okay.
Thank you.
1-5 We're ver.y pleased to have the opportunity l
l 6
to brief the Commission on the progress of the ABWR' 1
7 design certification ' effort from GE's perspective and:
8 the industry perspective.
l 9
(Slide)
My name.is Steve Specker.
I'm.
I 10 Vice President and General. Manager of' GE. Nuclear j
11 Energy.
At the table with me is Bob Berglund,.who is 4'
12 General Manager, Advanced Reactor Programs;. Joe Quirk,
~
- 13 Project Manager, ABWR Certification Programs; Tony 14.
James, our ABWR ITAAC project manager; and Bill Rasin, 3
l 15 who is Vice' President and Director of the Technical 16 Division of NUMARC.
- 17 (Slide)
If I could have-th'e-next slide, 18
-please.
19 Today we want to, after my brief comments,
~
l 20 talk about a schedule._ ' Joe Quirk will' lead a schedule -
21 discussion and then ' Tony---Jarnes will follow with-the 22' ABWR tier 1 development-brief.
23 (Slide) -Next slide, please.-
t 24
-We'd like to begin byLjust pointing out-
{'
25 ~
and reminding everyone of the high importance that.we NEAL R. GROSS ~
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65 1
place and I think the whole U.S.
nuclear industry 2
places on the ABWR design certification effort.
It is 3
leading the way.
It can restore public acceptance and 4
user confidence.
The ABWR FDA is an essential first 5
step in the NPOC ALWR strategy.
6 I might also add that from my perspective 7
as I travel around the world, the whole wori.d is l
8 watching this process to see if the U.S. has a process 9
which can come to closure.
I think at stake is the 10 competitiven6ss of the U.S.
nuclear industry 11 throughout the world.
So, it has a very high 12 importance from GE's standpoint and the industry 13 standpoint.
14 We are making good progress, I believe, on 15 the closure of technical issues.
I think we heard 16 some of that this morning.
We're very pleased with l
17 that progress.
Where I think we're. having our i
18 greatest difficulties is first time process issues.
19 We are disappointed in the schedule slippages that l
l 20 have been occurring, primarily driven by these process 21 issues.
But you can have our assurance - that we're 1
22 very aggressively supporting the timely FDA issuance.
I 23 It has a high priority from my standpoint and in our.
24-whole organization. -But I-think we all need to-keep i
25 a Very high level of attention, both the NRC staff and NEAL R. GROSS COURT REPORTERS AND TRANSCRl8ERS 1323 RHOOE ISLAND AVEWUE, N.W.
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66 1
the industry, to ensure that we can bring this process 2
through to closure.
3 With that I'd like to turn it over to Joe 4
Quirk to talk about the schedule.
5 Joe?
6 MR. QUIRK:
Yes.
7 (Slide)
Could I nave the next chart, 8
please, chart number 4?
9 This is the first of two charts that I 10 will present.
It focuses on the steps that remain to 11 achieve the FDA and prior to initiating the design 12 certification process. I would like to emphasize that 13 this is GE's view and may not be consistent with 14 staff's thinking on the schedule.
GE views these 15 dates to be aggressive but doable.
16 In discussions with the staff, we have 17 deduced that we may be a ways apart on the FDA 18 issuance.date.
I think the reason for that may be 19 there are some elements in the staff's plan that allow 20 for a parallel ACRS review following FSER issuance.
21 This is an extended period that I believe can be dealt 22 with on a more expedited basis.
23 I'd like to recommend to the staff and to 24 the commission to consider following issuance of the 25 FDA having a phased meeting, a highly focused meeting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
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67 of approximately a week or so to tak'e the FSER with
-1 2
the ACRS-and go through the disposition of-all the 3
open items and to accelerate that review during that 4
week period, instead of perhaps relying on proceeding 5
on a routine frequency of meetings that the-ACRS does 6
where they may have three meetings over a perjod of 7
three months.
I thirk that this would be one way to 8
pull in the schedule and to reach these aggressive but 9
doable dates.
10 So, this schedule calls for closing all 11 the open confirmatory items in the draft FSER by the 12 end of February.
As the staff just presented, we are 13 beginning closure of these chapter items beginning in 14 the week of December 7th.
We will be - providing. a 15 schedule to the staff on our view of how all the 16 chapters will flow then from that point through the 17 end of February where the last of the remaining 18 chapters will be closed, as opposed to all of them 19 coming in at that-time.
20 Then we would follow the February date by 21 one month and submit a verified and upated -SSAR.
We 22 view that the staff then would take a month to perform 23 their conformance review of that SSAR and issue then 24~
-the FSER in May. Then, with special direction perhaps 25 and special guidance, we would hope to-convene the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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ACRS review of. thu ?!SER and complete that activity on 2
an accelerated basis.
3 (Slide)
The next chart, please.
4 Following the staff's response to the ACRS 5
review, we would make conforming-changes to the-SAR 6
that would reflect the final ACRS review comments and 7
the staff disposition of those comments and any 8
changes that have taken place since that time.
- Then, 9
we believe that it would be appropriate for an FDA to 10 be issued in June of 1993.
I would encon. Age the 11 Commission to support an aggressive schedule and to 12 help expedite the FDA issuance.
13 These are my comments on schedule.
Next 14 we'll have a presentation by Tony James on the status-15 of ITAAC.
16 CHAIRMAN SELIN:
Thank you.
17 MR. JAMES:
Good morning.
My name is 18 Anthony James with General Electric and my assignment 19 with GE is to manage the effort to put in placo~the 20 tier 1 material for the ABWR design certification.
21 (Slide)
If I could have chart 6 of 11, 29 please.
23 We have prepared.a presentation for-you, 24 Mr.-Chairman and Commissioners,.that goes-over these 25 subjects. We'd like to provide you with just a little NEAL-R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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background on tha basic underlying-principles that GE 2
is using_ to prepare the tier 1 material.
We'd like to 3
describe for_ you what we see as the various entries in 4
tier 1 and the GE approach to development of_those 5
entries for the ABWR, and-then provide you with our 6
view of the status of that tier 1 development effort, 7
and then to summarize where I think we are.
8 As a footnote to this first chart,_you_
i 9
might note that I'm using exclusively the term " tier 10 1."
That is deliberate because I think the task 11 before us really is to put in place the tier-1 12 caterial.
ITAAC is a very important part of that 13 material, but-is not the only mat.erial-and rather 14 contentious and difficult. issues that we're facing.
15 putting in place the other parts of the tier 1 16 material.
-17 (Slide)
If I could go to the next chart, 18 please.
19 By way of background, the desiga 20 certification is, of course, two tiered.
Tier 1 has 21 always~been viewed as-the. top. level,.most-important 22 aspects of the design and tier 2-is,-in essence,_the 23 bulk of the design that's presented -in.the safety l
l
-24 analysis. report.
To date, of '_ course, _ most of.the 25 effort has been aimed at putting in place the NEAL R. GROSS COURT REPORTERS AND TRANSCR:BEMS 1323 RHOOE ISLAND AVENUE, N W.
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information that is in the SAR and it is only in the 2
last 9 to 12 months that we've really begun to 3
concentrate on the tier 1 contents.
4 Item number 2 on this chart, tier 1 has 5
several elements and I have a subsequent chart that 6
we'll get to momentarily that defines those various 7
elemen&s.
But basically we see tier 2 as consisting 8
of the certified design and the ITAAC material.
We 9
view those as very tightly coupled.
The scope and 10 form of ITAAC is driven in large part by the scope of 11 the certified design.
That's one of the bases upon 12 which GE has been proceeding.
13 Point number 3 on this chart, as has been 14 discussed already today, we are of course the lead 15 applicant in this effort.
On the tier 1 development 16 effort we've had substantial input from NUMARC, which 17 has been both appropriate and useful from the GE point 18 of view, appropriate because in the final analysis the 19 utilities will be responsible for implementing the 20 certified design and executing-the-inspections, tests 21 and analyses. It's also been very useful because they 22 have brought to the table a substantial improvement in 23 the scope and thinking and expertise that's been 24 brought to bear from our side onto this sometimes 25 difficult subject.
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[g 1
(Slide)
If I could please move to the 2
next chart, number 8 of 11, 3
.This chart is a little busy, but what I've 4
tried to do here is-summarize the various elements 5
that we see forming tier 1.
The structure of this l
6 chart is the left-hand column is the five types of 7
information that we see being in tier 1 and the middle 8
column is the summary of the descriptive entry that 9
goes with each of that type of material.
Then the 1
10 right-hand column identifies what, if any, ITAACs are j
11 being developed for that entry.
So, if I could 12 briefly go.through this chart row by row.
13 The first entry in tier 1 is the plant 14 systems.
This forms by far the bulk of the technical 15 information that will be included in tier 1, not only 16 in terms of the description of the' design, by also in 17 the ITAACs that will be-established for tier-1.
l 18 The descriptive material for these plant i
19 systems is following.the guidance that we think we 20 have that it concentrate on the principal design 21
- basis, principal characteristics.of the-various i
22 systems that-form the total ABWR that's being 23 certified.
The ITAAC that we've developed' on the
~
24 basis of that material-are aimed very largely at 25 confirming the configuration and function of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N!W.
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4 72 1-systems.
We think the top. level design descriptions 2
aim at the principal characteristics of the system and 3
the ITAAC are linked to that in the sense they rhould 4
be aimed at confirming that the as-built facility in 1
5 fact has that configuration' and that performance 6
characteristic.
In other words, the ITAAC and the 7
certified design, we think, are coextensive.
8 Item 2-on the-chart is the design 9
processes, otN. wise known as design acceptance 10 criteria, which in our view are really ITAAC aimed at 11 the design process in those cases where design detail 12 is not available at this time.
The descriptive a
13 entries for the design processes represent a. summary j
14 of what's in the SARs, as was already discussed this 15 morning.
There's a substantial amount of technical 16 information in the SAR on these subjects and the tier 17 1 descriptive entry will summarize that material'. The 18 ITAAC that go with that, of course, are aimed at 19-verifying that the design processes that have been 20 certified are, in fact, implemented as the design 21 process proceeds.
22 Item 3 is called interfaces which is 23 really the interface ITAAC that are cal' led for by the j
24 Part 52 and these affect or apply-to the interfaces-l 25 between the scope of the design which is being NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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certified and the scope of the design which is outside 2
of the certification but will be provided on a site 3
specific basis by the applicant.
Part 52 does call 4
for the applicant to define the interfaces across that 5
boundary and also to put in place ITAAC that will 6
confirm that those interfaces are adequately addressed 7
in the total plant design.
8 The descriptive entry for those types of 9
interfaces is again a summary of the SAR material and 10 the ITAAC entries are structured in such a way that 11 they ensure that the site-specific applicant 12 adequately addresses the interface requirements.
13 Item 4 is the generic issues.
I will go 14 into that a little taore 11: another chart that I hava, 15 when I get to it momentarily.
But the basic approach 16 that the industry has been proceeding on on these 17 generic issues to date is that they really are not 18 appropriate tier 1 material. That's a bit categorical 19 and there are exceptions, but as a broad statement we 20 don't view these construction processes and 21 procurement processes to be suitable tier 1 material.
22 But I would expand on that a little in our subsequent 23 chart.
24 The fifth type of entry that goes into 25 tier 1 is the site parameters.
That's issues such as NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE, N W.
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seismic cikacteristics that were assumed in the t
2 design, the design basis tornado that was assumed, l
3 nieteorological conditions, et c6terc, et cetera.
g.
l 4
Those will be repeated in tier 1, extracted more or 5
less verbatim from the safety analysis report.
At 6-this time we do not anticipate any ITAACs on that
]
7 subject.
8 By way of a summary-for that chart, it's l
9 worth noting that that does lead to a considerable 10 amount of information in tier 1.
The original GE 11 submittal of the. total package in May contained 12 getting close to 1,000 pages of mate _'ial.
So, we are
{
13 talking about a very substantial body of-technical 14 information here.
i 15 (Slide) If I could, please, move to chart j
16 9 of 11.
17 This chart addresses the generic issue j
18 which staff discussed in some detail before.
I think 19 it would be useful-to go through this because we 1
20 believe this issue does touch some of the. core issues 21 associated with the whole implementation of the Part l
I 22 52 process.
So, I would like just to spend a minute 23 going through this chart, f
24 By way of definition, generic issues as we i
l 25 envision them are those detailed construction of NEAL R. GP.OSS j
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1 procurement activities such as welding, equipment I
2 qualifications; setpoints, concrete properties, et 3
cetera, et cetera.
And we believe if you had an l
4 exhaustive list of those subjects, there would be 3
5 several dozen items in that list.
The issue that has 6
b W n contentious frankly in the last six to 12 months 7
between us and staff is just how should those subjects 8
be treated in tier 1 and ITAAC.
Our answer,
). gain 9
simplistically stated, is not at all.
10 The next set of six --
11 CIIAIRMAN SELINt Can't get much simpler 12 than that.
But are you going to comment on how your 13 views agree with or differ from the staff's views?
14 MR. JAMES:
Yes.
I was hoping to do that 15 at the end of this chart.
16 But I would like to just go through the 17 six points that I have there under " Basis," which is, 18 in a nutshell, the arguments and reason _ and rationale it for why we don't think those items should wally be 20 addressed in tier 1.
21 First of
- all, all the necess 22 commitments are in the SAR.
There's no debate as to 23 whether we-are or are not committing to doing 24 everything right in this area.
We believe the SAR 25 contains a full complement of commitments to these NEAL R. GROSS COURT REPORTERS AND TRALORIDERS 1323 RPODE ISLAND AVENUE N W, (202) 234 4 433 WASMNOTON. D C 20005 (202) 2344413
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issues, adherence t codes, standards, methodologies, 2
whatever is necessary for the staff to make a safety 3
finding on the subject.
4 Second point, many of the methods and 5
details here are as-built, as-procured dependent. For 6
example, qualification of equipment in terms of the 7
radiological consequence is to non-metallict. in a pump 8
depend where those non-metallics are with respect to 9
the radioactive fluid that the pump might be 10 processing.
You don't know that until you've procured 11 it.
12 So, it, in our view, is not possible at 13 this time to define specific technical details on 14 these subjects.
There is an as-procured, as-built 4
l 15 dependency which really leads straight into the third 16 point here, that it makes it virtually impossible to 17 specify precise unambiguous acceptance criteria.
Of 18 necessity and unavoidably, if you are writing 19 acceptance criteria for this stuff, it ends up being 20 imprecise.
Equipment is qualified to the environment 21 that it will experience, imprecise acceptance criteria 22 like that.
23 Fourth item in my list I think essentially 24 touches on the question you asked, Mr. Chairman, of 25 just how many of these items are going to be treated NEAL R. GROSS COURT REPOR1ERE AND TR'NSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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in tier 1, if any at all.
Our view is that to date 2
there's really be no concise articulation of the 3
selection criteria, which of the several dozen issues 4
should or should not be dealt with in tier 1 which 5
always raises the possibility that in any subsequent 6
discussions, given that it's difficult to justify the 7
selection process, there's dangers that some or all of 8
them will end up in tier 1.
9 So, for those reasons, we think this is 10 not tier 1 material.
Items 5 and 6 are our views of 11 why that's okay.
Verification will occur by the Part 12 50 QA processes.
The debate we're having with the 13 staff is not do these processes get checked or don't 14 they.
Everybody agrees they will get checked.
Our 15 view is they will be checked by all of the QA 16 processes that derive from the Appendix B
QA 17 requirements in Part 52, which is specifically invoked 18 by Part 50.
So, tha debate is not whether they get 19 done.
They will be done.
Our view is they should be 20 done under the Part 52 processes and the structured 21 implementation of those processes as defined by the 22 acronym SAYGO, the sign-as-you-go process.
23 Point six here _I think is also important.
24 We view'the NRC' staff's authority to monitor, control, 25 discipline implementation-of these -processes under l_
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Part 50 as undiminished.
We think they have the full 2
spectrum of authority that currently exists for 3
enforcement of QA under Part 50, all the way from 4
enforcement conferences, fines, all the way through 5
license suspension and license revocation.
6 So, again, it's not -- there's an attitude 4
7 prevelant amongst some that if it doesn't get checked 8
by ITAAC, it doesn't get checked at all and there's no 9
method of enforcing it, to put it in colloquial terms.
10 We think that is not the case.
Y" 1)
So, for all those reasons, that's why we 12 think it is not necessary for generic issues to be 13 covered in ITAAC. Now, there was the development that 14 Mr. Russell talked about earlier that occurred late 15 last week.
We are in the process of formulating our 16 opinions as to what that proposal really involves.
I 17 have to tell you our first reaction is one of caution.
18 It certainly represents change and it's basis for 19 moving ahead and developing some details.
But we see 20 potential problems there that can only be resolved 21 when we sit down and write specific examples out.
4 22 One thing we've learned the hard way in 23 this ITAAC development effort is that the path between 24 agreeing in concept on something to getting to the 25 point where we have documentation defined and agreed NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 AHODE ISLAND AVENUE, N W.
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I to, that's a long path with many opportunities for 2
perturbations along the way.
Our concerns center on 3
the concept of just how much is going to be referenced 4
in tier 1.
Mr. Russell said this morning there would 5
be references to codes and standards and other aspects 6
of a particular generic issue.
We're concerned 7
references in tier 1 raise up the tier 1 status.
Some 8
of these lower level documents, from a legalistic 9
point of view, can cause problems because the whole of 10 the document can be raised if we aren't careful.
11 The other thing that's not clear, as Mr.
12 Russell has briefly mentioned, the fact that there 13 vill be some linkage between the execution of the l
l 14 ITAAC on say a system configuration,_ some linkage i
15 between that and the EQ of the equipment in that 16 system.
It's not clear how that linkage is to be
- 17 defined and what it would mean.
18 So,
-our reaction is
- caution, it's 19 progress, but we need to work on some examples to see 20
_our way through this one.
21 CllAIRMAN SELIN:
I'd like to stop you and 22 talk not about EQ but about welding because: I think 23 some differences are on the table and I want to make l
24 sure'I understand them correctly.
Both you and the 25 staff has said, "We don't want to handle welding as a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 MHODE ISLAdD AVENUC, N W.
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generic issue."
So that's a start.
j 2
But if I understand you correctly, you're 3
saying, " Things like welds would be handled under our j
i 4
standard QA processes," et cetera.
And the statf has i
5
- said, "No, we're going to handle welds on a specific 6
basis, not as generic issue, but we're going to get i
7 into pressure vessel welds and agree in advance as 8
part of the ITAAC what results we will need from, say, i
}
9 non-destructive testing to agree that the welds have i
10 been done properly."
I think it's an important 11 difference because this is not a bilateral deal.
It's 12 not just you and the staff.
We have many outsiders 13 who also are a part of the process and they ascurance 14 in advance about what it will take to satisfy the 15 world in general about when the welds-will have been 16 done satisfactorily or not.
Just saying the staff 17 will figure out how to do inspections and we can stop i
18 it doesn't answer the question.
19 Doctor Murley brought up the point, the 20 Shoreham example, where it would have;been better off 21 if everybody, all parties had hsd an understanding-i 22 about a sufficient set of tests to decide the welds i
23 were okay, to go on.
Now,-am I missing something on 24 this or is there a difference or you just' haven't 25 decided whether there's a difference or not?
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MR. JAMES: Well, I guess we haven't quite
~
2 decided.
We understand the staff's need for linkage 3
of important issues like velding because of historical 4
considerations into ITAAC and the umbrella of the 5
necessary and sufficient. We understand all that, but 6
we would like to see how that will get implemented 7
before we figure it would be the right way to go.
8 CHAIRMAN SELIN: My own view is one should 9
be very leery of something that says,
" Trust us.
10 We'll figure it out," even if us is the NRC, not the 11 vendor.
I don't like the idea of generic issues.
I 12 like the idea of getting down to specific 13 considerations of where it is necessary to decide in 14 advance what is sufficient, not necessary. We decided 15 that these are sufficient conditions.
Better 16 conditions may come up-later.
But in some of those 17 key cases, I think the trust that the public has put 18 in us to allow us to do Part 52 in the legislation 19 requires that the conditions be known in advance 20 before the certification, certainly before 21 construction begins.
That sounds to me more like 22 ITAAC and less like Part 50 QA or full I&E authority.
23 So, it will be.very interesting how that 24 works out as you and-the' staff go into these 25
' approaches.
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MR. JAMES:
I understand, Mr. Chairman.
2 I think it's worth stating one more time though, that 3
it is very dif ficult in advance for the literally 4
millions of things that get done.
As you go to a 5
plant today and ask yourself to prove that the plant 6
equaled all the commitments were made, this literally 7
is many of them and it's impossible to redefine those.
8 CHAIRMAN SELIN:
You clearly have to pick 9
out a few key points which are specific to the design 10 and not just general construction or general 11 mechanical engineering.
But based on our history, 12 whatever set you come up with, welds sound as if 13 they're in that set.
14 MR. JAMES:
(Slide)
If I could please 15 move to the next chart, 10 of 11.
16 I think I've taken more than my time here, 17 Mr. Chairman, so I won't go through this chart item by 18 item.
It is an attempt for the five types of tier 1 19 entry to summarize where we are.
You can see from the 20 numbers that the bulk of the material -is plant 21 systems.
22 My summary statement on this chart is 23 given that we can move ahead on the generic-issues, 24 we,-GE, don't see any show stopper issues.
There's i
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would be irresolvable in our opinion, given that we 2
move ahead on the generics.
3 COMMISSIONER REMICK:
In your use of 4
generic issues you're including the so-called 5
programmatic and discipline also under that name?
6 MR. JAMES:
I'm concentrating largely on 7
certification, which is really mainly the generic 8
technical issues of welding and the ones I listed. we 9
have not beun -- our view is we concur with staff that 10 most of the programmatic issues, we believe, are COL 11 items.
So, we have not been concentrating on those.
12 COMMISSIONER REMICK:
Okay.
13 MR. JAMES:
(Slide)
So, if I could please 14 go briefly to 11 of 11, to summarize.
15 We do think there's been substantial 16 progress.
It might not sound like it this morning, 17 but if you look at where we were a year ago, I think 18 between us we've made substantial progress in defining 19 scope, content, form of the tier 1 material.
I think 20 it's true there'c a lot of details remaining.
That's 21 details that have to be resolved by engineer to 22 engineer discussion on particular systems and 23 particular issues.
24 The design process entries we all agree 25 need some additional work.
My impression from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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people working on that is that they don't view those 2
as critical path.
There's work to be done, but it's 3
achievable.
- Then, the last item is the generic 4
resolution, one which we've discussed.
j 5
Of my whole presentation, Mr. Chairman, 6
item 2 here would be endorsed 100 percent totally by
)
7 all participants.
There really is a lot of detail 8
work remaining to be done to close out tier 1.
l 9
That concludes my presentation.
I 10 CHAIRMAN SELIN:
There's been a lot of 11 chatter by observers of the industry about how this 12 process has thrown considerable doubt on whether an 13 ITAAC-based standard certification can work or not.
14 I've heard a lot of work to be called for and that 15 management will have to do its job, et cetera, but you 16 haven't given up on the basic Part 52-concept, have 17 you?
18 MR. JAMES:
No.
I think Part 52 in terms 19 of ITAAC and tier 1 is a workable process, but I think 20 it's got to be recognized that the total verification 21 of the plant is a sum total of inspection, tests, 22 analyses in ITAAC plus a
considerable body of 23 verification work that must still be handled under the 24 Part 50 processes.
That, I think, is the core issue 25 here.
Most of our debates have been just where do you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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draw that line.
But as long as we can draw that line 2
in a reasonable place, I think it's workable.
3 I have to tell you, the input GE gets from 4
the industry is that this generic issue is potentially 5
a make or break in terms of the perceived usefulness 6
of Part 52.
If the ITAAC end up with a lot of 7
imprecise acceptance criteria on a lot of these 8
generic issues, there are those in industry that would 9
say that severely dilutes the perceived benefits of 10 Part 52 in terms of stabilizing and making the 11 licensing process predictable.
12 CHAIRMAN SELIN:
I think we would agree 13 with that, although the conclusion -- I still think 14 different conclusions can be drawn from that 15 observation.
I think we all agree that we don't want 16 to see thrown into Part 52 that which need not be 17 there or making ITAACs for things that are just 18 standard construction or inspection.
But we don't 19 want imprecise acceptance criteria.
That would i
20 undermine the whole concept of what you're talking 21 about.
22 Any questions for GE?
23 COMMISSIONER CURTISS:
Two comments and 24 two questions.
25 I
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articulated here, but at the same time there is also 2
a growing and perhaps parallel concern that in the 3
process of implementing the certification process, as 4
we are doing in the context of individual vendor 5
design reviews, that we not approach that in a way 6
which would shift an undue burden to the COL applicant 7
to address issues that when Part 52 was promulgated we 8
anticipated would be addressed at the outset.
9 I don't believe this particular issue, the 10 generic ITAAC issue, it seems to be is not really ripe 11 at this point for a lot of informed discussion at the 12 Commission level.
That's my own personal view.
You 13 still have some additional work to do with the staff.
14 But if you consider that at this point in time the COL 15 applicant is going to bear an important burden not 16 just on the questions arising from the coupling of a 17 preapproved design and a preapproved site, the so-18 called interface questions, the site-specific 19 questions, but in addition will bear the burden for LO developing the design detail in the DAC context, the 21 design acceptance criteria have the effect of shifting 22 the design responsibility to the COL applicant at the 23 COL stage, and perhaps, although this is less clear to 24 me at this point in time because I'm not sure what's 25 envisioned, but perhaps a considerable burden in the NEAL R. GROSS COUHT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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context of what has been referred to as the bridge 2
document.
3 So, I share your concern that we not 4
unduly dilute the effect of the design certificate at 5
this stage.
Indeed, I think there's a parallel.
You 6
pointed to Part 50 to rely on on these process 7
questions.
We've done that on the technical side, on 8
the substantive technical issues.
Part 50 provides 9
the framework for resolving or setting forth _. the 10 approach that we're going to take on substantive 11 technical issues.
But I do believe there is also a 12 concern there with respect to how you balance the 13 burden between the certification stage and the COL 14 applicant beyond those things that were strictly site 15 specific.
That's my comment.
I didn't put it in the 16 form of a question.
17 Let me ask just two related - questions 18
- here, not on the generic ITAAC issue, but more 19 generally.
You spoke to the experience that you've 20 had in the context of formulating ITAAC in the stage l
21 that you're in, the design. review stage.
NUMARC's 22 letter of late August, and this came I think prior to 23 a lot of the effort that you've undertaken,- takes the 24 position that we ought. to retain the option of 25
' approving an FDA without having the ITAAC.
Now, what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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I hear you saying is that the process of preparing the 4
2 ITAAC at the same time that you prepared the design, 3
with the informing that goes on between the ITAAC and 4
the design, has been a critical part of developing the 5
design and the ITAAC.
Is it still the industry's view 6
that we ought to consider issuing an FDA without 7
having the ITAAC?
8 MR. QUIRK:
We decided to roll up the 9
sleeves and get on with this.
So, all our activities 10 since those discussions have been focused at including 11 closure-of ITAAC for the FDA and changing the SAR to 12 reflect those closures.
13 COMMISSIONER CURTISS:
Okay.
Any other 14 cr.anents?
15 MR. RASIN:
- Yes, I will note that there 16 has been that discussion that a lot of the ITAACs were 17 developed along with the design detail in the review.
18 But I also point out from the staff's presentation the 19 difficulty presanted by trying to finalize the ITAAC 20 with open items still remaining in the SSAR.
So, it's 21 still our view what while clearly these two issues are 22 unrelated, that it would be possible to issue an FDA 23 without the ITAAC being completed signed off.
24 However, the design would have to reach a point where 25 the staff was confident that the ITAAC could be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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finalized and representative of that design.
2 COMMISSIONER CURTISS:
Okay.
Second and 3
wholly unrelated question to what we've talked about 4
so far, but I do have an interest in the matter.
I've 5
looked at your operational reliability assurance 6
program and in reviewing that it looks to me like what 7
you envision at this stage and for the COL applicant 8
is that a COL applicant would essentially comply with 9
the maintenance rule.
If we were to simply say that 10 the licensee is to comply with the maintenance rule, 11 would that accomplish the sum and substance of what 12 you have in mind with your ORAP program?
13 MR. QUIRK: Well, I think the ORAP program 14 goes a little further in that it brings into it the 15 data and the assumptions that we've used, for example, 16 in our PRA, things like that.
So, in addition to 17 what's proscribed by the maintenance rule, we -- also 18 include key assumptions that have been instrumental 19 and influential in our design process.
20 COMMISSIONER CURTISS:
Okay.
21 MR. JAMES:
I was going to add, if I 22
- could, just slightly on your first
- question, 23 Commissioner, from my perspective, at times being down 24 in the trenches on this one.
I think for ABWR in' 25 terms of the relationship between tier 1 development NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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and tier 2 development, it really has been a highly 2
interactive process.
I think it would be difficult to i
]
3 argue that the FDA and ITAAC could be totally 1
+
4 decoupled because of the pioneering, learn-as-you-go l
s 4
5 nature of BWR.
I think there is an argument that can a
6 be made that if the process is well understood and
[
i 4
j 7
certification after certification is going through a i
i J
8 well understood process, that then decoupling becomes 9
a legitimate subject.
i 10 COMMISSIONER CURTISS:
Okay.
i 11 COMMISSIONER ROGERS:
I :- W o n d e r if you 12 could comment _on the Advanced Reactor Corporation's 1
l 13 new piping design standards and how they might 14 ultimately be incorporated in your certified design.
i 15 How do you see that? Do you see that as in the offing 16 or simply not what you're looking=at right now?
17 MR. QUIRK: I think that we have developed 1
position on the ABWR certification program that 18 a
j 19 reinforces what the ARC piping effort is all about.
i i
20 I don't think we go as far as they plan to and in the i
L 21 interest of time that's a decision we'd have to make.
22 But I think that our strategies have aligned and as j
23 far as we are going is consistent-with their t
24 programming.
25 CHAIRMAN SELIN -
Well, thank you' very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS -
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1 auch.
I.
2 COMMISSIONER REMICK:
One moment.
3 CHAIRMAN SELIN:
I'm sorry.
4 COMMISSIONER REMICK:
That's all right.
5 If I recall, your application had a fair 6
amount of proprietary information.
If I al=o recall, 7
you were going to look and see if you could minimize 8
that.
I'm curious about the status.
Do you still 9
foresee that there would be any proprietary 10 information in tier 17 11 MR. QUIRK: No. By definition, there will 12 be - no proprietary information in tier 1.
You're-13 right. At one time we did have a significant quantity 14 of proprietary information and we have identified as 15 one of the process issues with Part 52 the treatment 16 and handling of proprietary information is-very 17 important.
GE has gone back and reassessed all the 18 proprietary information that has been submitted and 19 has accumulated on the record.
We have reduced that 20 volume.
We've declassified much of the information.
21 So, we have reduced the information to as low -- you 22 know, the minimum set of proprietary information that 23 we can do at this_. time.-
I would say we cut it to 24 maybe five percent.
If you were to look at the SAR 25 volume and say, "Now, what percent of that SAR volume s
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would be proprietary information?" my estimate is 2
about five percent, which is a small reducible size.
3 For that
- then, we think that the industry J
l 4
recommendation in this area that's been given to the
]
5 staff through the NUMARC channel is to replace in the J
6 SAR the proprietary information with non-proprietary 7
information that describes the key elements of that 8
information without providing the details, and then to
.i i
9 pull back the proprietary information as an example of i
j 10 how that could be met.
11 COMMISSIONER REMICK:
I see..
The five 12 percent, how does that compare relatively with the 13 GShR submittal?
Less?
i i
14 MR. QUIRK:
Less, yes.
I would say maybe 15 three times that.
16 COMMISSIONER REMICK:
I see.
Thank you.
17 CHAIRMAN SELIN:
Could I follow-up on.
18 this? One of the things that I've been thinking about 4
19 is to use the proprietary information the way we use
~
20 classified-information in public policy making.
In I
21 other'words, the open information would be sufficient 22 to make a judgment *Jithout the proprietary information 23 and the proprietary information would serve to give 24 those who have the clearance, the staff, further 25 confidence that by digging deeper we don't find.that i
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superficial argument is false.
Even though without 2
access to the proprietary information could still look 3
at the certification and say that holds up.
In other 4
words, there might be some detailed confirmation or 5
assurances not available if you're not part of the --
6 don't have access to the proprietary information, but 7
you could still see the arguments are more than 8
plausible that they appear to hold up.
9 MR. QUIRK:
That's the objective.
10 CHAIPNdi SELIN:
Okay.
Anything else?
11 Fine.
12 Thank you very much.
By the way, there's 13 an old story about an economist is somebody who sees 14 something that works in practice and tries to figure 15 out if it's theoretically possible. Given how much of 16 your design is actually being built, I hope we're not 17 in the same situation.
18 DOCTOR SPECKER:
We're not.
I assume you 19 we're not.
20 CHAIRMAN SELIN:
Very good.
21 We now have a NUMARC presentation.
22 MR. RASIN:
Yes, Mr. Chairman.
I was not l
23 playing offense or defense.
I really was refereeing.
24 We concluded on the basis of our recent 25 discussions that for the efficiency of Commission time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUF, N W.
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and business there was no need for the industry to 2
give a separate panel presentation.
I would like to 3
make a few statements --
4 CHAIRMAN SELIN Of course.
5 MR. RASIN:
-- about where we view the 6
process et this poirt in time.
7 While we are working on a few final 8-certification issues that have been noted here, the 9
proprietary information, the production and use of the 10 design control document, the tier 2 change processes, 11 a few details like that with which discussions are 12 proceeding, we'd like to make a concentrated statement 13 today on our view of ITAAC though.
14 It is an important area, certainly a 15 critical part of the success of Part 52.
We believe 16 significant progress has been made over the last year.
17 As has been noted, there is some significant-work to 18 do.
19 Industry's interest in this has been noted 20 here from two points of view.
Upon submittal of GE's 21-ITAAC in June of 1992, a small group cf senior utility 22 managers reviewed selected portions of that and-23 concluded that there was -a tremendous amount of 24 imprecision and a tremendous concern with the ability 25 to objectively demonstrate compliance with the ITAAc NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W _
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as written.
That coupled with the concern mentioned 2
by Commissioner Curtiss of the shifting of the risk 3
and responsibility amongst the parties, being the 4
vendors and the utilities or owner / operators, led us 5
to believe that a more detailed industry involvement 6
in the ITAAC development and review process was 7
necessary.
So, it was for that reason that we 8
8 undertook the review that we commissioned this end of 9
the summer and concluded on october 2nd.
10 The review we conducted lasted 26 days and 11 that was 26 straight days, generally 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day, 12 and we felt - that it was very important that we 13 expeditiously get on with that so as not to prove a 14 burden to GE or the staff in pursuing the very 15 aggressive schedules that we were going forward with 16 at that time.
17 The -review consisted of a total of-30 18 people from 14 companies.
That included 19 representatives from the EPRI ALWR program and from 20 INPO as well, the Department of Energy representatives 21 from GE's Nuclear Start-up Group, and of course the 22 appropriate legal counsel.
23 We looked at approximately 70 percent of-24 the ITAAC in great detail, including specifically the.
25 design acceptance criteria-eleraents.
All major areas NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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and engineering disciplines were encompassed within 2
the review.
While the initial aim was to review just-3 the ITAAC, we found that it was so important to couple 4
that with a look at what was actually in the tier 1 5
design description
- that, in
- fact, that was 6
incorporated into the review and the interplay between 7
the two played an important role.
8 In addition to the GE review, because 9
wanted to gain as much experience and pass this on as 10 rapidly as possible to other applicants, we strongly 11 encouraged the other vendors to participate in this.
12 review.
Not only participate on looking at the GE 13 ITAAC, but in fact we reviewed five systems from the 14 ABB Systems 80+ design and two systems from the 15 Westinghouse AP-600 with the same group to demonstrate 16 a consistency of review and to try to translate-the 17 philosophy.
18 The conclusions from our review was that 19 generally the ABWR submittal was in agreement with 20 What we understood the scope to be in the statement of 21 considerations for Part 52.
We felt that the tier 1 H
22 design descriptions in the ITAAC needed to be 23 substantially rewritten so that the ITAAC entry was li t
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clear demonstration of compliance.
2 For the safety-related portions of the 3
plant, we believe that the end result of the review z
4 was a one for one consistency with the ITAAC that GE 5
and the staff had felt were appropriate.
For the non-6 safety system portions of the plant, we did have some 7
differences of opinion on the scope and felt that 8
there was some detail included that was not necessary.
9 In performing its work, the review group 10 asked two fundamental questions.
Is the design 11 parameter or attribute a salient, significant and 12 important design parameter that has safety 13 significance? And what is the impact or the effect of 14 freezing this design attribute with the only method of 15 change through a rulemaking procedure, and is such a 16 result appropriate?
Getting to your question, Mr.
17 Chairman of what do you freeze at what point in time.
18 As noted by the staff and GE, there were 19 public meetings with the NRC staff along the way which 20 we felt was very helpful to the process, so we could 21 all understand what one another was doing and what was 22 the purpose and thrust of this review.
23 As a result of the review, we believe from 24 the system-specific standpoint that although GE has a 25 lot of work to do, that the end result, ITAAC, will be NEAL R. 'ROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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a good process thht, in fact, will be a practical 2
implementation of Part 52.
We are concerned with the 3
generic and programmatic ITAAC that has been discussed 4
here today and I don't need to go into anymore detail.
5 We believe we may have found a way to satisfy the 6
staf f's concerns or the staff's needs while at the 7
same time taking-into account the industry concerns i
8 with the non-specific acceptance criteria of such a 9
generic ITAAC.
We hope to work out the details of i
10 that in meetings with the staff and GE in the very f
11 near future to assure that, in fact, that solution is 12 a practical one.
i 13 We note that as we proceed on from the GE 14 design it will be important to reconsider some of the l
15 scope from the standpoint of the passive designs.
In 16 our quick look at AP-600, there seem to be some 17 questions about will we have additional factors to 18 consider as we set the scope of that and that perhaps i
19 it wouldn't flow exactly from the evolutionary j
20 designs.
21 With that, we intend'to continue to work 22 with the staff and the vendors _to come up with a set 23 of ITAAC in which the utility customers have w
24 confidence, as well as to proceed on.to work on the 25 other Part 52 implementation issues, not only with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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certification but with early site permits and the 2
combined license process.
3 We would note that it is through the open, 4
constructive and candid dialogue processes that we've 5
been having with the staff on these issues that 6
progress has been made and that continuation of these 7
discussions, we believe, if done in a time frame 1
8 consistent with the objectives _ of the Commission 9
schedules and the NPOC strategic plan, can result in 10 a final successful certification and implementation of 11 Part 52.
12 Thank you.
13 CHAIRMAN SELIN:
Thank you for your very 14 positive statement, Mr. Rasin.
First I'll ask my-fellow Commissioners if ~
16 they have further questions, either for GE or the.
l 17-staff.before we close up.
18 I'd just like to make a couple of closing 19 comments.
It was a very positive meeting this 20 morning.
It's just difficult.
There's really no.way i
21 to get around it.
I'd like to repeat a number of l
22-principles which are implicit in what's going on.
o l
23 The first is true theology.
To -- avoid 24 theoretical arguments about whether ~one could or 25 couldn't do an FDA without ITAAC-and questions like 4
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i
- that, I'm very pleased with Mr.
Quirk's answer, 2
i 2
especially in contrast to the answer I got a year ago 3
to the same question.
4 The second is the necessity for achieving 5
precision in these questions.
These truly are tests 6
and if they're not precise they just fuzz up a problem i
7 which will come back to bito us later.
So there, I 8
think we all agree that ITAACs that are imprecise are i
9 worse than no ITAACs at all, since they give the
-l I
10 impres..lon that the problem has been thought out when i
a 11 they haven't been thought out.
12 The
- third, and this is commissioner 13 Curtiss' point, we want to do as much in the design as i
i 14 is possible to do in the design.
We want to do as 15 much on the general basis as is possible to do on a-16 general basis, not only to avoid the necessity to do 17 in 20 or'30 or 2 or.1 combined operating license 18 applications what can be almost for once and for all, 19 but to achieve the standardization that everybody 20 believes is possible.
So, we are very intent on 4
21 seeing that things don't get put-off to the col that 22 can be handled at the -- I'm avoiding generic because 23 that has unpleasant overtones, but at the general i
j.
24 basis of the certification basis.
That's for both 25 efficiency and standardization.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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1 But in saying all that, we have to provide 1
2 for some ability to update the technology as is i
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3 appropriate and the tier 2 seems like a pretty-good l
4 piece where there is some threshold so that you can't-j 5
just casually put in a new computer model instead of i
6 an old one.
You will have to certify that it complies 7
with the design cortification.
But we're looking for i
8 a balance between not freezing everything in 1980 I
9 technology, but not casually just changing things as 10 they go along.
I i
11 But we are pushing as.hard as-we can ta 12 get as much done at the certification level and on the l
13 general = level as possible.
Wo.are conscious, Mr.
+
14 James, of the necessity not to reinvent the wheel, not l
15 to put into ITAAC that which is standard inspection, l
l 16 verification, construction, et cats /,
We're trying l
17 to really stick to what's new in thesu processes for 4
18 the ITAAc and not just take what's been -done 19 satisfactorily in the past and call it an ITAAC out of l
20 bad habit.
{
21 I'd J'ke to come back finally to Mr.
i 22 Rasin's last point, which is 'the essential building of 23 public credibility.
I'd like to emphasize,--and I's.
l 24 not trying-to be pedantic.
This is not a dialogue, f
25,
it's a polylogue.
I mean there. are many parties "Y
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102 1
involved.
Maybe the reason for gettin9 direement on 2
welds in advance is necause it's been contentious in f
3 other issues.
Maybe we all know how to verify welds, 4
but we want to make sure that the general public can 5
feel that issues that hav.s been contentious in the 6
past have been %ddressed properly.
7 Furthermore, there is the serious 8
consideration that in doing a certification we're 9
going to be making decision which in the Part 50 way 10 wouldn't be made for another ten years.
In other 11 words, until the specific construction.
Not only the 12 construction permit were
- issued, but during 13 construction.
So, we have to advertise, we have to 14 call attention to the fact that these issues, although 15 they may seem arcane or technical, could have critical 16 impact on five or ten or 20 plants that won't be built 17 for another decade or so.
Once they're settled here, 18 the local people don't get a chance to look at them.
19-So, they need to be thoroughly aired, even if that's 20 hard work, even if it's unpleasant and even -if it 21 means opening up a lot of proprietary information or 22 other information that you'd like to keep private.
23 So, what I'm trying to say is it's ha'rd 24 work, it's painful.
There is a grand scheme to tie 25 these things together and I just hope we don't lose NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234 4433 WASHINGTON, D C. 20005 (202) 234-4433
103 1
track of that as we go through.
It's going to be c 2
very difficult six months, 3
Any other comments?
4 Fine.
Thank you very, very much for your 5
presentations.
6 (Whereupon, at 11:40 a.m.,
the above-7 entitled matter was concluded.)
8 9
4 10 4
-t 11 '
12 i
13
)
14 15 16 1
17 18 19 20 21 22 23
)
24 25 NEAL R. GROSS tVRT REPORTERS AND TRANSCRIBERS 1323 RHODE lALAND AVENUE, N.W.
(204 234 4433 WASHINGTON, D C 20005 (202) 234 4433
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i CERTIFICATE OF TRANSCRIBER j
This is to certify that the attached events of a meeting-f' of the United States Nuclear Regulatory Commission entitled:'
TITLE OF MEETING: BRIEFING ON PROGRESS OF DESIGN CERTIFICATION REVIEW AND IMPLEMENTATION PLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING:
NOVEMBER 23, 1992 were transcribed'by me I further certify that said transcription 4
i is accurate and complete, to the best of my ability, and that the j
transcript is a true and accurate record of the foregoing events, i
E d44-ed bA.,
V 4
PETER LYNCH Reporter's 'name:
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NEAL R. GROSS COURT REPORTERS ANo TRANSCRit!R$
1323 RH006 ISLANo AVENUE, N.W.
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(202) 234-4433 wAsNewoTow. o.C. 2ooos; (202) 232-ee00 -
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i PROGRESS OF DESIGN CERTIFICATION REVIEW AND IMPLEMENTATION l
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l NRR BRIEFING TO COMMISSION NOVEMBER 23,1992 i
i AGENDA I
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INT MODUCTION T. MURLEY STATUS OF DESIGN CERTIFICATION REVIEWS D. CRUTCHFIELD e
IMPLEMENTATION ISSUES LESSONS LEARNED W. RUSSELL i
s A
e
I EVOLUTIONARY LWR DESIGN CERTIFICATION REVIEW STATUS e
GE ADVANCED BOILING WATER REACTOR
' DRAFT FINAL SAFETY EVALUATION REPORT (DFSER) ISSUED TO COMMISSION FINAL DESIGN ' APPROVAL.(FDA) COMPLETION DATE CONTINGENT UPON-GE CLOSURE OF DFSER OPEN ITEMS DESIGNLCERTIFICATION PROJECTED FOR JUNE 94 e
ABB/CE SYSTEM 80+
DRAFT SAFETY EVALUATION REPORT ISSUED TO COMIbn l
m FINAL DESIGN APPROVAL SCHEDULED FOR NOVEMBER 9E DESIGN CERTIFICATION PROJECTED FOR MAY 95 j
t j'
]
'f i
i i
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PASSIVE LWR REVIEW STATUS j
e EPRI. UTILITY. REQUIREMENTS DOCUMENT (URD) FOR PASSIVE LWRs-RECEIVED.EPRI COMMENTS ON DSER IN SEPTEMBER 92 WITH SCHEDULED.FSER COMPLETION IN JUNE 93 1
e WESTINGHOUSE AP600 i
APPLICATION RECEIVED IN JUNE 92 i
i NRC ACCEPTANCE REVIEW COMPLETED.IN AUGUST 92 ADDITIONAL.INFORMATION NECESSARY TO ESTABLISH FORMAL
-SCHEDULE i
i
'GE SIMPLIFIED BOILING WATER REACTOR APPLICATION RECEIVED IN AUGUST 92 4
NRC ACCEPTANCE REVIEW IN PROGRESS l
i i
1 GENERIC TECHNICAL AND POLICY ISSUES
/ EVOLUTIONARY AND PASSIVE LWRs)
L I
.e INSPECTIONS, TESTS, ANALYSES AND ACCEPTANCE CRITERIA-j (ITAAC)_
i t
e DIVERSITY _OF DIGITAL INSTRUMENTATION SYSTEMS l'
l 4
- e LEVEL OF DESIGN DETAIL / DESIGN ' ACCEPTANCE CRITERIA j
l e
SEVERE ACCIDENT CLOSURE 1
.j 1
e
' NATIONAL' ENVIRONMENTAL POLICY ACT SEVERE ' ACCIDENT i:
MITIGATION DESIGN ALTERNATIVES (NEPA/SAMDA) i j
i i
l
PASSIVE LWR TECHNICAL AND POLICY ISSUES t
REGULATORY TREATMENT OF NON-SAFETY SYSTEMS MULTIPLE STEAM GENERATOR TUBE RUPTURES f
e CONTAINMENT BYPASS 4
i i
)
4 1
i-i
1 j
PROJECTED COMMISSION PAPERS, MEMORANDA, AND BRIEFINGS ON ADVANCED REACTOR ISSUES TOPIC PROJECTED COMPLETION 1
-SBWR ACCEPTANCE REVIEW I
11/92 FINAL COMMISSION PAPER ON RESOLVED SECY 90-016 FOLLOW-ON 12/92 ISSUES ADVANCED REACTORS' SCHEDULES 1/93 COMBINED OPERATING LICENSE (COL) FORMAT AND CONTENT 2/93 (APPROX) r
.lNCLUDING VERIFICATION OF ITAAC " BRIDGE" ISSUES i
FINAL COMMISSION PAPER ON REMAINING PASSIVE POLICY ISSUES 3/93 PART 52 CONSTRUCTION INSPECTION PROGRAM 8/93 (APPROX) l
}
MAJOR TECHNICAL ISSUES FOR COMPLETION OF l
ABWR STANDARD SAFETY ANALYS!.S REPORT (SSAR?
REVIEW AND CLOSURE OF DFSER ISSUES SEVERE ACCIDENT CLOSURE PRA ELECTRICAL DESIGN DETAILS I
i e
INSTRUMENTATION AND CONTROLS (l&C) SOFTWARE DAC i
STRUCTURAL REDESIGN i
f.
ITAAC BACKGROUND CERTIFIED DESIGN DESCRIPTION EXTRACTED FROM SSAR INCLUDES FUNCTIONAL DRAWINGS CONTROLS DESIGN OVER LIFE OF PLANT ITAAC FORMAT CERTIFIED DESIGN COMMITMENT METHOD OF DEMONSTRATION THAT DESIGN COMMITMENT HAS BEEN MET; INSPECTION, TEST, OR ANALYSIS ACCEPTANCE CRITERIA ITAAC SCOPE (SECY 91-178)
. STRUCTURES AND SYSTEMS
. DESIGN ACCEPTANCE CRITERIA GENERIC AND DISCIPLINE REQUIREMENTS SAFETY ANALYSIS VERIFICATION (ROAD MAPS)
ITAAC REVIEWS GE MOST RECENT PHASED SUBMITTAL-(5/30/92)
REGIONAL INSPECTOR REVIEW (7/28/92)
~
"GREYBEARDS" REVIEW (7/31/92)
ACRS REVIEW (8/12/92) 1 RESULTS OF STAFF /GREYBEARDS/ REGIONAL REVIEWS TO GE (8/12/92)
INDUSTRY lNDEPENDENT REVIEW (10/2/92) 4 1
ITAAC LESSONS LEARNED e
-QUALITY AND COMPLETENESS OF SSAR/ DESIGN DESCRIPTION /ITAAC IS ESSENTIAL i
e SSAR AND ITAAC REVIEWS ARE CLOSELY COUPLED SSAR NECESSARY INPUT TO ITAAC EMPHASIS ON TESTING AND AS-BUILTINSPECTION ANALYSIS METHODS MUST BE DEFINED IN EITHER ITAAC OR SSAR l REFERENCE TO CODES AND STANDARDS MADE GENERICALLY IN ITAAC:WITH.. EDITION / ADDENDA IN SSAR i
i I
t 4
I
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I i
MAJOR ITAAC ISSUES FOR COMPLETION OF ABWR STANDARD SAFETY ANALYSIS REPORT (SSAR)
REVIEW AND CLOSURE OF DFSER ISSUES e
MAGNITUDE OF THE CHANGES TO ABWR ITAACs FROM THE NUMARC/ INDUSTRY REVIEW e
DEFINITION OF ITAAC ANALYSIS METHODS IN:SSAR 1
e INDEPENDENT REVIEW OF ABWR ITAAC AND SSAR APPLICATION OF GENERIC ITAACs SUCH AS ENVIRONMENTAL QUALIFICATIONS, REACTOR COOLANT SYSTEM PRESSURE BOUNDARY' WELDS, AND l&C SET POINT METHODOLOGY
i GE NUCLEAR ENERGY BRIEFING ON PROGRESS OF DESIGN CERTIFICATION REVIEW AND IMPLEMENTATION i
November 23,1992 S. R. Specker, Vice-President, GE Nuclear Energy I
R. C. Berglund, General Manager, Advanced Reactor Programs
]
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J. F. Quirk, Project Manager, ABWR Certification Programs A. J. James, ABWR ITAAC Project Manager l
l i
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Contact:
J. F. Quirk (408) 925-6219 1 of11 i
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L COMMISSION BRIEFING MONDAY, NOVEMBER 23,1992 GE PRESENTATION i
I t
l GE Nuclear Energy Overview S.R.Specker i
i i
Schedule Discussion J. F. Quirk i
ABWR Tier 1 Development A. J. James 3
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1 2 of 11 i
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4
i ABWR OVERVIEW / STATUS ABWR design certification (DC) can restore public acceptance and user confidence ABWR FDA is essential first step in NPOC ALWR strategy Timeliness of FDA needed to confirm US process in place and continue international leadership GE is disappointed by schedule slippage but is aggressively supporting timely FDA issuance Continued NRC staff and industry management attention needed I
3 of 11
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i ABWR CERTIFICATION PROGRAM OVERVIEW Remainino Steps to FDA and Desian Certification i
All open and confirmatory DFSER issues 2/28/93
~
l
-(including Tier 1/ITAAC) resolved j
i i
GE submits verified and updated SSAR 3/31/93 l
(including Tier 1) j NRC verifies SSAR 5/1/93 i
i FSER issued 5/1/93 i
4 I
ACRS review complete (special emphasis) 6/1/93 a
i l
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i 4 of 11 i
1
k ABWR CERTIFICATION PROGRAM OVERVIEW i
i Remainino SteDS to FDA and Design Certification (cont.)
r Conforming changes made to SSAR 6/1/93 FDA issued 6/1/93 i
[
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j Commission support needed to expedite FDA 1
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4
ABWR TIER 1 DEVELOPMENT DISCUSSION TOPICS 4
i
Background
Tier 1 entries - GE approach Status of ABWR Tier 1 effort 4
Summary l
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c ABWR TIER 1 DEVELOPMENT BACKGROUND i
- 1. Design certification is tiered Tier 1 - top level Tier 2 - SAR design
- 2. Tier 1 has several elements Certified design ITAAC i
7 of 11 1
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TIER 1 ENTRIES - GE APPROACH Tier 1 Contents Descriptive Entry ITAAC Entry
- 1. Plant Systems Principal Features Configuration / Function
- 2. Design Summary of SAR implementation i
Processes Verification t
- 4. Generic issues No Entry No Entry
- 5. Site Parameters Repeat SAR No Entry l
i 8 of 11
{
j
1 TIER 1 ENTRIES - GE APPROACH Definition: Generic issues - detailed construction and procurement activities, e.g., welding, equipment qualification, setpoints, concrete, rebar, painting Issue:
How should generic issues be treated in Tier 1 ITAAC?
Industry:
'Not at all 4
i Basis:-
All necessary commitments in the SAR l
As-built / procured dependency Acceptariae criteria definition problematic
-Selection criteria undefined Verification will occur via Part 50 QA processes 3
NRC has full spectrum of I&E authority i
i Status:.
Ongoing GE/NRC/ industry discussions; making
. progress 9 of 11 3
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STATUS OF TIER 1 EFFORT
?
Tier 1 Entry Number Status j
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- 1. Plant Systems 86 Moving to closure; many details open i
)
- 2. Design Process 4
Good progress but more work needed 1
- 3. Interfaces 6
No significant discussions; foresee few difficulties r
- 4. Generic issues O
Potentially troublesome issue I
- 5. Site Parameters 1
Foresee no difficulties i
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ABWR TIER 1 DEVELOPMENT
SUMMARY
l l
- 1. GE/NRC consensus in place on many of the basics Substantial progress on many issues A lot of details remaining l
Design process entries need more work I
Generic ITAAC needs resolution l
- 2. Timely Tier 1 close-out requires intensive effort by all parties 4
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