ML20202F475
| ML20202F475 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1529, NUDOCS 8607150175 | |
| Download: ML20202F475 (120) | |
Text
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-: OR GINAL OMSf-/8$ 7 O
UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON PLANT OPERATING PROCEDURES LOCATION:
WASHINGTON, D.
C.
PAGES:
1-108 I
DATE:
TUESDAY, JULY 1, 1986 1
F.
,/
,'l O
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OfficialReporters 444 North Capitol Street 86071501'75 860701 Washington, D.C. 20001 PDR CRS (202)347-3700 52 PDR NATIONWIDE COVERACE
1 PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS TUESDAY, JULY 1, 1986 l
The contents of this stenographic transcript of the i
proceedings of the United States Nuclear Regulatory l
Commission's Advisory Committee on Reactor Safeguards i
(ACRS), as reported herein, is an uncorrected record of i
the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
SUBCOMMITTEE ON PLANT OPERATING PROCEDURES 5
6 Nuclear Regulatory Commission Room 1046 7
1717 H Street, N.W.
Washington, D.C.
8 Tuesday, July 1, 1986 9
The subcommittee convened at 1:00 p.m.,
pursuant 10 to notice, Carlyle Michelson, Chairman of the Subcommittee, 11 l
presiding.
12 ACRS Members Present:
13 O
C.
MICHELSON, Chairman 14 J.
EBERSOLE F.
REMICK 15 C.
WYLIE G.
REED 16 ACRS Cognizant Staff Engineer Present:
17 j J.
SCHIFFGENS 18 i
NRC Staff and Industry Presenters:
19 E.
BUTCHER j
20 D.
FISCHER T.
DUNNING 21 S.
BRYAN F.
ROWSOME 22 D.
FARRAR 23 24 25 O
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1 PROCEEINGS J
2 MR. MICHELSON:
The meeting will now come to l
3 order.
This is a meeting of the ACRS Subcommittee on Plant 4
Operating Procedures.
5 I am Carlyle Michelson, Subcommittee Chairman.
6 The other ACRS members present today are Jesse 7
Ebersole, Glenn Reed, Forest Remick and Charlie Wylie.
8 John Schiffgens, on my right, is the assigned ACRS j
9 Staff member for this meeting.
I 10 The goal of the meeting is to review and discuss 11 the " Proposed Commission Paper on Technical 12 Specifications."
This paper presents alternatives for 13 making technical specifications more usable to licensees and 14 plant operators, as well as reducing both the number and 4
15 ; detail of existing technical specifications.
16 The staff is recommending that the Commission 17 issue for public comment the proposed policy statement 18 attached to the Commission paper to clarify the scope and 19 purpose of tech specs.
The policy statement will serve as a 20 basis for the NRC and industry to implement voluntary 21 technical specification improvements.
I 22 A transcript is being kept of the entire meeting, 23 and it is requested that each speaker first identify himself 24 or herself and speak with sufficient clarity and volume so j
25 that he or she can be readily heard.
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1 We have received no written statements from 2
members of the public.
3 We have received no requests for time to make oral 4
statements from members of the public.
5 Do any of the subcommittee members have any 0
6 l questions or comments that they wish to make at this time?
I 7
(No response.)
8 Seeing none, I would like to proceed then.
Who is 9
going to be the master of ceremonies for the staff?
10 MR. FISCHER:
Ed Butcher, the Branch Chief will 11 start off.
12 l
MR. MICHELSON:
Does he wish to make any comments 13 before we proceed with the program?
(~Jh
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14 i MR. BUTCHER:
Yes, Mr. Michelson.
I would like to k
15 take a few moments to put in context with the overall
- i 16 i technical specification improvement program the policy ly statement which is going to be the principal focus of our 17 18 discussion today, i
19 l Dave Fischer standing at the podium will make our N
i 20 formal remarks and presentation on the policy statement 21 itself.
22 But before proceeding with that, I thought it
]
23 would be useful to discuss the major elements of the 24 improvement program so that we can see how this policy 25 statement fits in context.
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1 Before doing that, I would like to call your m-2 attention to the fact that we do have representatives of the 3
Atomic Industrial Forum with us today who worked with the 4
staff in the development of the reports which describe the 5
necessary changes to our current technical specification 6
operations.
7 I believe on the agenda it may indicate that they 8
were going to have some formal prepared remarks, but it is 9
my ".nderstanding that they do not now and that they are just 10 prepared to answer any questions which the subcommittee may i
11 f wish to address to them.
12 We also have with us members of the staff who are f
13 l familiar and who have had active roles in the entire tech 14 spec improvement program who can respond to all the various 15 different areas where you might have some specialized i
16 i) questions.
l 17 I would like to identify the two major reports 18 which led up to the initiation of our activities to actually 1
19 l
implement technical specifications, and those are the TSIP 1
l Report, which is the report of a project that terminated 20 21 last year on September 30th when they published their report i
22 identifying needed changes to technical specifications.
We 1
l briefed the full ACRS on the results of that program I l
23 24 believe back in February of this year.
25 The second report, which was the report published AU ACE-FEDERAL REPORTERS, INC.
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by the Atomic Industrial Forum, and that was issued and 2
dated October 8th, 1985, that report represented the 3
industry's perspective on needed tech spec improvements.
4 Both of those documents are included as enclosures 5
to SECY paper 86-10 for those members of the subcommittee 6 I which might wish to go back and reference those reports.
7 (Slide.)
I 8
g The technical specification improvement program i
lf can be divided into three elements which we have identifled 9
10 ] on this slide.
0 11 q
That is to the development of a new set of STS, 12 H standard technical specifications, based upon a policy 13 statement to define both the scope and purpose of technical
)
14 specifications.
l 15 In parallel with the development of a new STS, we l
l 16 have an ongoing program of short-term improvements to the l
l
\\
17 3 existing technical specifications which will ultimately be l
ffactoredintothenewrevisedtechnicalspecifications.
l 18 19 l I can give you some examples of the short-term l
)improvementswearetalkingabout, l
20 i
the relocation of fire 21 protection requirements to a separate document from the 22 technical specifications.
That is an improvement which the
)
llstaffhasalreadyinitiatedandofferedtotheindustryand 23 24 any utility which wishes to consolidate fire protection 25 requirements in a single document and have it referenced in O
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1 the FSAR and have it referenced in the license may do so.
2 MR. EBERSOLE:
Would that imply a lesser degree of 3
regulatory attention to so relocate it?
4 MR. BUTCHER:
I don't regard it that way.
To some 5
extent it could be regarded an escalation of regulatory 6
attention ---
7 MR. EBERSOLE:
So either way.
1 8 l MR. BUTCHER:
--- in the sense that it is now a 9 l licensed condition as opposed to before it was a tech spec.
10 As a practical matter, there is not much difference in terms I
i 11 [ of the way you treat it.
12 MR. EBERSOLE:
I am bothered by the word l
13 $
" standard" since plants tend to be different.
/
14 MR. BUTCHER:
And standard technical t
15 i specifications?
4 16 )
MR. EBERSOLE:
Right.
3 17 MR. BUTCHER:
The intent there is to create a 18 document which provides a point of departure for the 19 j
individual utilities.
So it is standard in that sense, that i
20 it represents the point of departure.
We all start from a 21 common base.
22 I can give you another example of the types of I
23 short-term improvements which have in fact already been made 24 and offered to the industry, and that is the changes in 25 surveillance intervals on the reactor protection system.
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We have completed one report and approved that for 2
Westinghouse plans.
Roughly the most significant thing is 3
that it changes channel functional test requirements from 4
l monthly to quarterly.
That is based upon a PRA analysis 5
that was done.
6 We have just completed our evaluation of a similar l
report for the boiling water reactors and we anticipate that 7
8 1,
they would make similar changes.
5 9 !
Reports for Babcock and Wilcox and CE I believe l
R 1
10 l have just arrived to the staff here in the last week or so.
l 1
kit is interesting in the B&W case I believe the request was 11 l
12 for monthly to semi-annually.
l 1
1 13 MR. FISCHER:
yes.
I O
1 14 MR. BUTCHER:
And I am sure the staff will find l
l 15 that quite interesting as a difference from the other l
16 vendors.
l 17 MR. EBERSOLE:
Are each of these changes defended l
1 jbyaPRAwhichisbrokeninto its constituents parts that 18 1
19 l show you don't need to look at it that often?
l 1
l 20 MR. BUTCHER:
I don't know the details of the PRA, 21 but they are justified on the basis of a formal risk l
lt l
22 [i analysis which justifies the extension.
I N
23 [
There are two other areas in which we have 24 initiated efforts in, but we have not completed out work,
)
25 l and those areas relate to definitions or let's say standard I
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1 practice that the staff has used in the past with regard to 2
technical specifications, things like declaring equipment 3
inoperable when it has missed a surveillance interval.
4 There are many members of the staff and the 5
industry that believe that perhaps that is too conservative 6
a position to take, that just because you have not performed 7
the test doesn't indicate that the equipment is inoperable, 8
particularly when there are other evidences right there at 9
the time which would indicate that it is inoperable.
We 10 I don't feel that an administrative oversight should be a 11 basis for shutting a plant down.
12 l There are also some clarifications in the l
13 ( definition of operability, things that relate to missing hl paperwork.
\\
l We have seen cases where a piece of paper was 14 15 :; missed for whatever, and it required the equipment to be o
16 1 declared inoperable which it is believed that that is I
17 j perhaps an overly conservative position to take.
il 18 j When I say " paper" I am thinking in terms of some 1
19 quality assurance pedigree or something like that.
There 20 could be some other remedial actions that make more sense l
21 than shutting the reactor down.
22 MR. EBERSOLE:
May I ask, is there an intent, as I 23 think there should be, to establish the periodicity of the 24 test on the basis of, other than arbitrary time definitions, 25 the benefits and the risks of testing in each case and not n
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just the reactor scram system?
2 MR. BUTCHER:
That is correct.
It is just that we 3
have started with the reactor scram system because that is 4
the one that has had the most analysis and attention and we
]
5 are at the position of being able to do that.
6 Perhaps this is a good time for me to speak to S
7 Q what this program is based upon.
you can see that there are l
8 l elements of the program, particularly the short-term 9 f; improvements, which speak to the use of risk analysis tools l in establishing tech spec requirements.
But when you look 10 i
11 l at the specific criteria for determining what the contents 12 of tech specs will be, you will find that there is not knecessarilyariskelement in those criteria.
13 O
The specific policy statement as it is framed now 1
14 15 is based upon preserving the existing regulations and our l
l 16 existing approach to establishing requirements with a
{
17 recognition that PRA's tend to be to a large extent plant I
18 j specific and that you need to give consideration to specific l
i 19 risk analysis for specific plants, but it is very difficult 20 and probably not practical at this time to define on a l
9 l
21 generic basis a risk criteria that you could use in the very
[
b l
22 l detailed sense that we intend to use these criteria.
]
)
23 1
So we like to think that the criteria as they are l
24 written today are pretty much risk neutral, in other words, 25 they won't increase risk.
To some extent you may get some_
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1 indirect reduction in risk by the fact that roughly 40 2
percent of what is in specs now would not be there.
They 3
would be somewhere else, which would leave operators free to 4
4 focus more on those things which are left.
So I guess you 5
could conclude that you would get an indirect improvement in 6
risk from that.
7 MR. EBERSOLE:
May I ask a question.
In front of 8
all this, I thought you were also going to go back and i
9 determine what should be tech spec'ed and what should not 10 and a basis for declaring that to be so.
11 MR. BUTCHER:
That will be the subject of Mr.
i 12 Fisher's remarks, and that is the focal point of the 4
13 Commission policy statement, to establish specifically O
I' 14 criteria for judging what should be inspected today, 15 assuming of course that we are still operating within the 16 d current regulations.
17 Now it is true that if one were to change the 18 regulations that the criteria could be in fact be different, 19 and if you were to change the regulations, I would say at 20 this point it is fairly likely that you would change them to _.
21 give greater consideration to risk reduction as a legitimate 22 goal of technical specification criteria.
i 23 The last element of the program is kind of like a 24 catch-all, other improvement activities.
In that element we 25 are looking at improving Sections 5 and 6.
Section 5 is the O
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design features of the technical specifications.
It is 2
thought that there is a lot of detailed information in there 3
that is not necessary.
4 In the area of administrative controls, there is 5
some streamlining that can be done there.
It is not clear 6
why it is necessary to have organization charts in the tech 7
specs and things like that.
8 The other activities that we are involved in, 9
there will be some rule changes in order to relocate some of 10 these requirements.
Principally RETS is the most 11 significant, radiological effluent tech specs.
You will 12 require a rule change.
13 We are also looking at the possibility of getting 14 some greater flexibility in surveillance requirements, and 15 by greater flexibility I mean to put some of the 16 surveillance internals under the control of the licensee 17 with some flexibility so that he can schedule surveillances 18 himself.
19 It may be advantageous at one time to do a 20 surveillance on a monthly basis.
It may be because of his 21 maintenance operations it is better to do it on a say every i
22 other months basis.
That is an area where we don't know 23 exactly what can be done there.
It has just been identified 24 as one that the industry would like us to look at.
25 Of course, greater us of PRA in establishing O
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1 specific requirements.
I am thinking about outage times and 2
surveillance intervals there, and that is part of what the 3
Westinghouse project was about on the topical report we have 4
approved, and there are many other activities in parallel 5
going on with that.
6 We want to take a look at the control mechanisms 7
for the requirements which have been relocated from the 8
technical specifications, and by control mechanisms I am 9
talking about our rules for inspecting and enforcing 10 procedures, 50.59 changes to the FSAR if in fact that will 11 become one of the documents where we will relocate 12 requirements to things like that.
13 We also have a major effort to improve the bases 14 of technical specifications, and we have under preparation a 15 standard format content guide for what kinds of information I
16 i should be in the basis of topical reports.
That gives us a 17 lot of trouble and there are a lot of misunderstandings and 18 misinterpretations about what tech spec requirements are, 19 and it is believed that that can be clarified by improving 20 the basis sections themselves.
21 I guess in a nutshell that is the perspective of 22 where the policy statement fits.
23 The development of the new CTS, before we can go 24 forward with that to write a new set of STS, we are asking 25 the Commission to make a statement of policy with regard to O
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what the content of technical specifications ought to be.
2 Unless there are any questions on my remarks, I 1
3 would turn the presentation over to Mr. Fischer.
4 MR. REMICK:
Would this proposed policy statement 5
Appendix B as well as Appendix A to the license, the 6
environmental tech specs?
7 i
MR. BUTCHER:
At this point I believe that our 8
efforts are restricted to Appendix A.
These criteria are 9
designed to focus on Appendix A.
They don't give you much 10 guidance for Appendix B.
11 MR. REMICK:
Now it is my understanding that the 12 things that would be removed from tech specs would be put 13 somehow in something like the FSAR.
Do these then become a 14 commitment?
I thought you said a condition, but wouldn't 15 they really be a commitment by the licensee?
Wouldn' t there -
16 be some document to say that these are a commitment?
17 MR. BUTCHER:
Let me clarify that.
In the case of 18 fire protection, we made the fire protection program a 19 condition of the licence.
We put it in the FSAR which gives 20 it commitment status, but we went one step further and made 21 it a license condition also.
22 Now it can be changed without prior staff approve, 23 but only if it is changed within the bounds of some specific 24 requirements which are set forth in the license condition 25 itself.
l
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1 MR. REMICK:
Okay.
Let's take the other things 2
that might be removed from tech specs and put in the FSAR.
3 I assume they would become a commitment?
4 MR. BUTCHER:
That is correct.
5 MR. REMICK:
Now is there any difference in the 6
level of penalty or enforcement as a result of a violation 7
of commitment versus a violation of tech specs?
8 MR. BUTCHER:
That is an issue which has received 9
a great deal of attention from the staff in recent months.
10 In fact, there is a statement in the proposed policy, a 11 statement by the Commission which would clarify that.
12 It is the intention of the staff that those things 13 that are in the FSAR, relocated to the FSAR would be no less 0
14 enforceable than those things that are left in the technical 15 l specifications.
i 16 We are working with the industry now to develop 17 specific procedures for proper performance of 50.59 reviews 18 and to allow deviations from commitments which are in the 19 FSAR, but it is the intention of the staff that the 20 utilities would be under no less obligation to follow the 21 things that are in the FSAR than they are now when they have 22 the status of a tech spec.
23 MR. REMICK:
What is the benefit then to the 24 licensee of putting it in the FSAR7 Is it the fact that he 25 can change it under 50.50. or can one possibly change tech O
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1 specs under 50.50, or is that a no-no?
2 MR. BUTCHER:
No.
One of the conditions of 50.59 j
3 is that it would not involve a tech spec change.
It is out f
4 of the tech specs, it can be changed, but of course it has i
i l
5 to follow the 50.59 process.
6 Now what we are thinking of when I say it is no l
i j
7 less enforceable than it was when it had former status as a i
j 8
tech spec, I am thinking in terms of a case where a utility a
j 9
would change it and not perform their 50.50 evaluation.
10 It would first be a violation of 50.59 to change 11 your plant design without doing the proper analysis, and it 1
j 12 would also be a violation of your license application to i
13 change it.
i 14 These statements that I am giving you now will be 15 working with the industry to make sure that there is clear i
16 understanding on everybody's part before we go forward with l
17 this of what the staff's intentions are with regard to the 18 enforceability of those things.
It is not as clear now as
{
19 it should be.
20 MR. REMICK:
As I understand it, the change would i
21 be done as an amendment to the license.
Would there be an
't 22 opportunity for public hearing on that?
J 23 MR.. BUTCHER:
On an individual license i
24 application, if we go the route being proposed by the staff, l
25 which is a voluntary program of individual license
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amendments filed consistent with a policy statement for 2
criteria from the Commission, there would be an opportunity 3
for hearing on each individual plant.
Now there is an 4
alternative to that which would be a rule-making which would 5
not provide that opportunity.
6 MR. REED:
I don't think Forest got what I think l
7 j
is the best answer to his question.
He wanted to ask what l
8 !
were the advantages of doing what we are doing.
In my 9
opinion, the greatest advantage it that it unclutters the 10 present tech specs in the control room which the licensed 11 operators must work with through the night and it makes it l
12 l
much less difficult for them to try to find out exactly what 13 b they are supposed to do and who they are supposed to call.
14 l And that I think is a major advantage, particularly with 15 standardized tech specs, but perhaps not so much with
'i 16 k earlier custom tech specs.
- l 17 2l MR. EBERSOLE
Let me ask a question.
I am 18 greatly in favor of uncluttering the operators' problems and 19 l getting rid of a lot of the junk that just ties him up for 20 l no particular reason.
On the other hand, have you ever i
21 heard of the operator devising and requiring tech specs 22 which are not being required for the regulatory process?
In 23 other words, his recognition of a needed technical 24 specification which was not there?
25 MR. REED:
Well, I doubt that they would ever ---
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MR. EBERSOLE:
I am trying to test the capacity of 2
the industry to so-called regulate itself and produce tech 3
specs which are not needed, the other side of the coin.
4 MR. REED:
I think we have an example now which 5
will come up on the opposite side of the coin.
6 MR. BUTCHER:
I might make a remark in response to 7
that.
We were looking at the things that the criteria did 8
not pick up in the technical specifications that we 9
identified for systems which we felt ought to be in the 10 technical specifications from a risk perspective, which the 11 criteria did not capture.
i 12 When we proposed that to the industry the answer 13 was we ha'e no difficulty with leaving those in the O
14 specifications because our own internal process would have i
15 i required us to keep the same requirement that you would 16 impose as a technical specification.
So there is some 17 1 indication that the industry can identify risk significant 18 systems.
.9 MR. EBERSOLE:
It gets back to what is the origin 20 of tech specs anyway.
It comes out of the design process in f
21 establishing parametric limits.
I guess the staff has come 22 in with a heavy hand and pretty much narrowed these more 23 than the industry would have wished.
So you have a narrow 24 band width of operation.
25 MR. BUTCHER:
Yes, I think so.
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MR. EBERSOLE:
What were the four systems?
2 MR. BUTC3ER:
Perhaps maybe what we can do is turn 3
to Dave's presentation and he will walk through that.
4 MR. MICHELSON:
Before we do, I have another line 5
of questioning I would like to pursue for a moment since is 6
probably unrelated to what Dave is going to talk about.
j 7
If you will recollect three years or so ago, the i
8 agency implemented a new LER reporting rule, and in the 9
process of formulation of that rule, an attempt was made to 10 reduce the number of LER's that were required from some i
i 11 5,000 a year hopefully to maybe like 2,500 a year.
So some 12 things had to be given up in the process.
Some information j
13 sources had to be given up and there was a great deal of
,O
14 giving and taking to arrive at a new rule.
15 But one of the things in the new rule was a 1
16 requirement that exceeding the limiting conditions of 17 operation in a tech spec, for instance, requires an LER to 18 be submitted.
19 Once you remove some of this material from the 20 tech spec, you also negated the need for LER reporting.
I 21 didn't find this discussed anywhere, and I am sure that the 22 agency understands it, but I am concerned, keeping in mind 23 that about 30 percent of all LER's presently emanate from 24 tech spec exceedances.
Not all of those will disappear with 25 the new tech spec rule, but a substantial fraction of them O
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will.
2 So we are losing yet another source of information l
3 that we are still getting, and we are down now to in some 4
cases very skimpy information on certain systems because all 5
single failures, for instance, were eliminated from the tech 6
spec unless they initiated some fancy scenario.
7 Now if exceedances are also eliminated and a few 8
other tech spec requirements of the reporting rule are 9
eliminated, they in essence eliminated because you took the 10 material out of the tech spec.
We will probably lose I 11 would estimate another 500 LER's a year at least.
Of 12 course, that is nice for the industry because it is cheater 13 not to have to submit them.
C:)
[
On the other hand though, I would like to see some 14 15 consideration on the part of the agency as to the importance fofwhattheyarelosingandsomethoughtgiventoit.
16 I
i 17 find no documentation anywhere considering this aspect of 18 the proposed change, and I am a little disturbed that I 19 don't find it.
Either you don't understand it, or 20 alternatively it is a no-never-mind and, if it is, I would 21 like to know.
22 MR. BUTCHER:
I can assure you that it has been 23 discussed within the staff.
In fact, I guess within the 24 last several weeks we have received comments from our Office 25 of Inspection and Enforcement.
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\\m-1 MR. EBERSOLE:
When you list your pros and cons of 2
this and that in your paper, I never find it discussed in 3
there.
It has some pros and it has come cons, and I think 4
it is worthy of discussion before I would be willing to 5
endorse this kind of a document.
6 MR. EBERSOLE:
What has bothered me in that aspect 7
is that it has almost dried up the approach to the brink of 8
disaster without reporting it because you did manage to 9
climb out some way.
That is not nice.
10 MR. MICHELSON:
And this will remove perhaps more 11 items.
There are a number of things on here that are not 12 clear yet, and they will I am sure be clarified today.
But 13 having clarified this, it is still a problem of lost l
1 14 g information and the potential significance of it, if any.
f 15 j
MR. BUTCHER:
Let me ask Dave if in the second 16 draft of the policy paper, which is now the policy paper 17 which transmits the documents that you have, do we speak 18 more directly to the question of the effect on reporting 19 requirements?
20 MR. FISCHER:
No, we don't.
~
l 21 MR. BUTCHER:
It is an area that we will l
22 definitely look into.
We have discussed it a bit, and our 23 first conclusion, and I don't want to belabor it here 24 because we really haven't thought our way through it, was 25 that what you lose if the 40 percent of the reporting that 1
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O 1
goes with the 40 percent that you take out of tech specs,
]
2 and if our perception is correct as supported by the 3
analysis that we have done, the risk analysis that we have 4
done, this 40 percent is of lesser safety significance.
So 5
it was thought that the reporting of violations of that 40 6
percent was of less safety significance also.
7 MR. KEED:
Isn't it true that that 40 percent that 8
you lose is essentially non-equipment and non-systems type 9
losses because of the kinds of things that get transferred 10 over like chemistry and ---
11 MR. BUTCHER:
And snubbers.
12 MR. MICHELSON:
Well, I was thinking like fire 13 protection.
I would be quite interested in knowing the 14 reliability of fire protection and the kind of problems we 15 are running into, but if you take it out of the tech specs 8
16 the the LER's aren't written on fire protection.
As a 17 blanket quantity I will see no more LER's on fire 18 protection.
That bothers me quite a bit.
If that is i
19 intended, then one should say so and point out to the 20 Commission that we will see no more information concerning 21 the failures of fire protection and probably won't see 22 inadvertent actuations of fire protection and things of that 23 sort any more simply because they are not in the tech specs.
24 I think, and perhaps I am wrong, and if I am point 25 it out, but as a case in point what would I see on fire O
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I protection in the future?
2 MR. REED:
Let's just throw out one that has been 3
recent, sabotage at Palo Verde of fire protection systems.
4 Would that have been reported?
5 MR. BUTCHER:
Right off the top of my head, I i
6 would say if it is not in the tech specs it probably would 7
not have been.
8 MR. BRYAN:
I think sabotage gets reported.
9 MR. MICHELSON:
That would under another category.
10 i MR. BUTCHER:
As a part of the security plan.
I 11 l MR. EBERSOLE:
I think this fire protection and 12 j sabotage and the other aspects are very important, but let i
13 l me ask about something that I think is even more critical.
{}
l 14 i Fire protection demands if it is inoperative or something H
15 that you have a fire to make it useful, just like the design 16 basis accidents.
The systems that mitigate those require 17 that they happen before you need them.
18 I am primarily interested in the systems that are l
19 l dynamic and are in continuous duty supporting the safety of 20 the plant by their dynamic forcing functions to do so.
21 What bothers me is a I see a variety of windows 22 here that may come in that never tell us when a plant 23 descends to such a level of critical support that you don't 24 know that it is left running on one and one not particularly 25 reliable support system, and it is hanging there based on O
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1 the reliability and viability of this one system that is a
2 still hanging in.
1 3
If that isn't reported, I think we have a very 4
basic problem fundamental problem on our hands, how close we 5
get to a loss of dynamic support for the safety function, j
6 and I think we are moving further and further toward a 7
variety of windows that let that objective reporting escape.
8 MR. MICHELSON:
Well, I think you can see that 9
there is concern on the part of the subcommittee, and I l
10 suspect on the part of the full committee as to the 11 importance, if there is indeed an importance to the loss of i
j 12 information that will accompany this removal from the tech 13 specs, keeping in mind that the LER rule was written to be 14 easily administered, was rather simply to identify things j
15 that require reporting, and the LCO's and so forth was a 16 simple mechanism of at least capturing a portion of these 17 failures.
18 That mechanism is now going to be tinkered with as i
i j
19 a result of the tech spec change, and I would like to see it 4
20 discussed and put to rest as to why this is okay.
j 21 MR. BUTCHER:
All right.
22 MR. REMICK:
Going back to the earlier discussion l
23 of taking things out of tech specs and putting them in the
]
24 FSAR, and the fact that the staff will continue the l
25 enforcement as in the past, there must be a category of l
l l
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things in tech specs, and you mentioned organization charts, 2
which are trivial, and I hope that there will be some effort 3
that there will be a third category.
Things may be put in 4.
the FSAR that are important, but there may be things put in 5
the FSAR that are not important and need not be enforced and 4
6 need not be reported and so forth.
7 Is there that third category, or is everything 8
that might be moved out of tech specs and put into the FSAR 9
and now they are tech spec two, you know, we just call them l
10 something different, is there an attempt to get out some of 11 the things in tech specs that are burdensome and can be 4
j 12 changed?
d l
13 MR. BUTCHER:
I'll be honest with you and tell you O
14 that it is our expectation that many of the things that are 15 removed from the technical specifications and placed under 16 control of say plant procedures or the FSAR will ultimately 17 be eliminated completely from either one of those documents f
18 based upon a careful and thorough evaluation using the l
19 procedures which are prescribed by the staff for making 20 those judgments.
21 The difference is that those judgments will be 22 made without prior approval of the staff.
Now they will 23 have subsequent review through our audit process of 50.59 24 implementation and the inspector's auditing of the 25 procedures process.
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So what I am saying in answer to your question is 2
that there is a third category and that we believe 3
ultimately the licensees will see that that category is well 4
exercised.
5 MR. EBERSOLE:
So you contemplate another third 6
step?
7 MR. BUTCHER:
Yes.
8 MR. EBERSOLE:
I rather see there is sort of a 9
continuum of significance.
For instance, let me take the 10 case of the condition of the station battery which dictates 4
11 the operability not merely of itself to do functional needed 12 things, but also the AC power system to do pumping of 13 water.
In short, it is the focal point of the plant dynamic 14 capability in itself.
15 I I am going to suspect that it is going to be given 16 modest, is hardly more that attention compared historically, 17 for instance, against the core spray systems.
18 MR. BUTCHER:
In the technical specifications, we 19 don't propose to change any of the requirements that now 20 exist on station batteries.
21 MR. EBERSOLE:
Well, I am not so sure what the 22 existing conditions are.
23 MR. BUTCHER:
That is what I am saying, to the 24 extent that the existing technical specifications aren't 25 adequate ---
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1 MR. EBERSOLE:
Are you going to go back and 2
examine the adequacy as well as the opportunity to get rid 3
of the ones that are not needed?
This is a double-ended 4
business here.
5 MR. BUTCHER:
That is correct.
This part of the 6
program, the first effort is to remove the chaff from the 7
wheat, so to speak, and leave us with what we can identify 8
and inspect now, and as a longer term perspective, as soon 9
as we get rid of the chaff, we will go back and refocus both 10 in a deterministic and in a risk environment on what is 1
11 left.
12 MR. EBERSOLE:
I guess we may be getting the cart 13 before the horse.
14 MR. BUTCHER:
The idea is that there is much to 15 distract your attention from there now.
We would like to q
16 get it out of the way, and whenever we have gotten it out of 17 l the way we can focus on what is left and what perhaps ought 18 to have been there to start with that wasn't.
19 MR. EBERSOLE:
I would be less optimistic that the 20 second part will get done.
21 MR. MICHELSON:
I guess we had better proceed now 22 and have more discussion at the end of your presentation.
23 Thank you.
24 MR. FISCHER:
Good afternoon.
My name is David 25 Fischer.
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It is a pleasure to be working with you all 2
again.
It seems like just yesterday.
While I miss all the 3
activities and challenges of H Street, I am very fortunate 4
to be working now with the Tech Spec Coordination Branch.
5 The policy statement that we will be discussing is 6
a very important piece of regulation, and it has afforded me 2
7 quite a challenge in itself.
8 I believe that the policy statement as it is 9
currently written is a very good document.
It is well 10 thought out, if I might say so, and represents a workable 11 compromise that the various NRC offices and industry can use 12 to effectively improve tech specs.
13 The policy statement is an important step towards
~ g.
14 !
more efficient regulation and it should result in a modest i
15 improvement in reactor safety.
16 With that I will get started with my presentation.
17 (Slide.)
18 It probably would be an appropriate starting place 19 to describe what the issue is that we are trying to solve by 20 the policy statement.
21 First, the growth in both the number and detail of f
22 tech specs has resulted in tech specs with little or not 23 safety significance distracting operators from tech specs of 24 more immediate importance.
It has also increased the number 1
25 of license amendments for these requirements with little O
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73920101 28 marysimons 1
safety significance.
2 Secondly, the lack of a clear basis in tech specs 3
has caused license amendment delays and conflicting 4
interpretations in the tech specs.
5 That is basically the issue that we are trying to 6
solve.
l 7
Because the Commission recognized the advantages 8
of improving tech specs, it has decided through this policy 9
statement to clarify the scope and purpose of tech specs.
10 (Slide.)
11 The policy statement should provide useful i
12 guidance to both the NRC and industry.
It should serve as 13 an important incentive, and incentive for the industry to 14 participate in a voluntary program of tech spec improvement, a
15 l, 16 It will result in tech specs that focus the 17 licensee's and the plant operator's attention on those plant 18 conditions most important to safety.
It should result in 19 more efficient use of agency and industry resources as well.
20 Now looking towards the slide, criteria one in a 21 sense tries to focus on accident prevention in that it tries 22 to focus on detecting early on abnormalities in the plant so 23 that the operator can intervene and thereby reduce the 24 likelihood of a LOCA.
25 Criterion two focuses on ensuring that the plant O
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(
1 is operated with the bounds of the initial conditions 2
assumed in the design basis accident and transient analysis 3
essentially in Chapters 6 and 15 of the FSAR.
4 So long as certain processed variables remain 5
within the established values, risk to the public is 6
presumed to be acceptably low.
7 MR. REED:
I notice you have already have an 8
argument going on that word up under the purpose, that word 9
"immediate."
10 MR. FISCHER:
Yes, we do.
11 MR. REED:
How do you describe immediate?
I 12 (Pause.)
13 MR. EBERSOLE:
It's tough, you can't.
l 14 MR. FISCHER:
Maybe Sam can.
I 15 MR. BUTCHER:
That ja the subjective statement of 16 the purpose of tech specs.
The criteria are an attempt to 17 bring some objectivity to the decision.
18 Immediate in this case would have to be considered 19 to be those things which require operator action to 20 intervene within the time limits assumed in the analysis.
21 So it seems to me that in each of the individual accident 22 analyses the term "immediate" is defined within the context l
23 of that analysis.
24 MR. REED:
Well, I agree with what you just said, 25 but I disgusted with this licensee's lawyer interpretation O
1 i
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of this thing, and the whole thing is disgusting as a matter 2
of fact as far as I am concerned.
It doesn't show much of a 3
responsible attitude with respect to safety and operation of 4
the plant.
"Immediate" you are going to have some trouble 5
with obviously if someone has already put you in the box.
6 MR. REED:
Glenn, if I could see what this is.
7 MR. FISCHER:
yes.
I am not familiar with the 8
document you are referring to.
9 MR. REED:
Well, this is this response from 10 Louisiana Power and Light to George Knighton with respect 11 to saying that their auxiliary spray should not be a tech l
12 spec item.
I f
13 Do you have it?
14 MR. MICHELSON:
He is about to get it.
15 MR. EBERSOLE:
We've got it.
16 MR. MICHELSON:
My copy is without your comments 17 on it though.
18 MR. REED:
Immediate really means to me that it is 19 something related the operation systems out of the control 20 room by the licensed operators, and time frame isn't all 21 that important, but it is important to their actions and 22 activities.
The argument in here is that one hour and 23 twenty minutes is not immediate, which I think is kind of 24 silly.
25 MR. EBERSOLE:
You know, that should be expressed O
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in the amount of time that you have and what you can do 2
within it, or otherwise it doesn't have any meaning.
3 MR. BUTCHER:
Within the context of the criteria, 4
and the criteria are hopefully designed to eliminate those 5
kinds of disputes.
So obviously they haven't by the fact E
that this licensee finds the need to raise that.
6 7
MR. REED:
You will have to do something to that 8
word "immediate" to define.
9 MR. FISCHER:
The third criterion focuses on the 10 design basis accident or transient mitigation.
The intent 11 is capture structures, systems and components that are part 12 of the primary success path of a safety sequence analysis,
~ 13 and these terms of " primary success path" and " safety 14 -
sequence analysis" are defined in the discussion of criteria 15 l three in the policy statement itself.
h 16 MR. EBERSOLE:
Dave, can you tell me now where, 17 for instance, the condition, the capacity and general state 18 of affairs for the station battery would rest?
See, I see 19 in this the flavor of the old LOCA business, the direct 20 failure rather than systems which have an incipient 21 capability to start a cascade that will eventually lead to 22 the loss of all three of these off in the dark corner.
23 Where do I find the station battery condition 24 under these 1, 2,
3 headings?
25 MR. FISCHER:
Three.
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MR. EBERSOLE:
I could interpret that by 2
stretching my imagination, but it is certainly not explicit.
3 MR. BUTCHER:
In fact, when we did a trial 4
application of these criteria, I can find out and identify 1
5 for you which criteria the batteries fell under.
We can do a
i 6
that for any system that is currently in this 1
7 classification.
My recollection is that it was criterion 8
three.
}
9 MR. EBERSOLE:
When you try to do collectively 1
10 something like this, you lose a lot.
11 MR. MICHELSON:
In a more general way is there a 12 definition somewhere of what is meant by a primary success
]
}
13 path?
!(:)
14 MR. BUTCHER:
It is discussed in the discussion of j
J 15 three on page 6.
i 16 MR. MICHELSON:
Where is it in the Commission 17 paper, what page?
You said it was in there and I could read 18 about it.
I read it, but I must have missed it or it didn't 19 help me any.
So what should I be reading to help me?
20 MR. BUTCHER:
It should be in the closed policy 21 statement, and the discussion immediately follows criterion 22 three.
1 23 MR. FISCHER:
It is on page 6, the second 24 paragraph I believe, the last sentence.
25 MR. MICHELSON:
That is in the draft?' I have l
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1 draft one here.
2 MR. REMICK:
Draft 2,
the second paragraph, last 3
sentence.
1 4
MR. BUTCHER:
There are two page 6's and that is j
5 probably contributing to the confusion.
There is page 6 of 6
the enclosure and page 6 of the policy statement, and we are 7
referring to page 6 of the policy statement, which is the 8
first page 6 in your package.
You should have two 9
enclosures there.
10 MR. EBERSOLE:
I want you to just listen ---
i 11 MR. MICHELSON:
Let's not get off of this until we j
12 finish.
13 MR. EBERSOLE:
This is the same topic.
O 4
14 [
MR. MICHELSON:
Page 6 though?
i l
15 MR. EBERSOLE:
It's the second paragraph.
Listen
.1 16 to what it says, and I want to read it because it is 17 important.
"The primary success path of a safety sequence 18 analysis consists of those actions assumed in the design 19 based accident and transient analysis which limit the i
20 consequences of events."
It says nothing about preventing 21 the event initiation at all.
22 MR. MICHELSON:
That definition doesn't help me a 23 bit.
For instance, I have got a room cooler.
Is that a 24 part of the primary success path?
25 MR. BRYAN:
Yes.
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1 MR. MICHELSON:
I own a nuclear plant now and I 2
have got all of these components and I go through the list 3
and I am trying to decide which are going to be tech specs 4
and which aren't.
What kind of a handbook do I use or 5
guidance or something?
I certainly don't get it out of this 6
Commission paper when it comes to asking is the room cooler 7
included or is the fan on a particular device included and 8
whatever.
Maybe it is small stuff, but it is part of 9
present tech specs.
10 MR. BUTCHER:
Let me point out that there was some 11 concern on our part as to whether things like that using 12 these criteria would be drawn into the process, and we 13 initiated an independent study by the industry and ourselves O-i 14 working independently and hopefully with no communications.
fat 15 least my staff was instructed not to communicate.
l 16 The industry would apply these criteria to a 17 l sample plant, Wolf Creek and Limerick, and we also applied 18 the criteria to a sample plant to see to what extent the 19 criteria would capture the systems that we belic;s are 20 necessary when used by two different groups working 21 independently.
22 What we discovered was there was an unusual amount 23 of agreement between the two studies, things like support
)
l 24 systems, which a room cooler would be, it really just 25 supports the equipment that is in the room, were in fact O
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captured by the criteria.
2 MR. MICHELSON:
By this criterion three?
3 MR. BUTCHER:
Yes.
4 MR. MICHELSON:
By this primary success path 5
route.
6 MR. BUTCHER:
The way the system works is that if 7
the equipment in the room is assumed in the accident 8
analysis to mitigate the consequences of the accident, all 9
of the support equipment, necessary service water and 10 whatever that goes with that system is also captured with 11 the system itself.
12 MR. MICHELSON:
And the primary success path 13 studies, is that true?
/~)
k/
14 MR. BUTCHER:
The primary success path is a word 15 that is fairly new.
Really it is a buzz word for accident - -
16 analysis.
17 MR. MICHELSON:
It is undefined, and yet it is a 18 part of a policy, which is a little odd.
19 MR. BUTCHER:
We attempt to define it here.
It is 20 really the safety analysis.
It is a rigorous analysis step 21 by step of how the accident proceeds and which equipment 22 functions to mitigate it.
That is what we attempted to 23 explain here.
24 MR. MICHELSON:
It is generally done though by 25 functions that have to be achieved, and now the question is O
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what does it take to achieve that particular function, and 2
that is where you get into the supporting auxiliaries, the 3
room coolers, the electric power, the cooling water, et 4
cetera, and maybe or maybe not the building air and so 5
forth.
6 So it is not clear, and where are you going to 7
define in sufficient detail so that -- I am not completely 8
stupid on these things, and yet I read it and I couldn't 9
tell.
The paper ought to be good enough for me to be able 10 to read it and tell roughly how to decide whether the room 11 cooler was included or not.
12 MR. BUTCHER:
I think a general comment is that it 13 is not clear how support systems like room coolers are 14 treated.
15 MR. MICHELSON:
And then it gets into deeper 16 things.
For instance, fire protection, and depending on how 17 you view that one, if you are having a fire, I think fire 18 protection is a part of the primary success path, and yet 19 fire protection is being withdrawn altogether.
So there 20 would be an inconsistency in the argument even there I 21 guess.
22 MR. EBERSOLE:
I noticed a consistent use of the 23 term " mitigated" and I have seen this for years and years 24 and years.
Mitigation is identified with safety functions.
25 What is not identified is you don't want to mitigate.
You O
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want to prevent them from starting in the first place, and 2
that is what is lost in all this context.
3 If I have a transient, such as for instance this 4
room cooling system, which results in no transient at all, c
5 that is I manage to start system "B" find you never see any 6
deviation in the room temperatures, it is not reported.
It 7
is a success.
8 The fact that you have got yourself to the last 9
line of defense, irrespective of how reliable you are 10 sitting now on that defense, is not brought out.
So the 11 prevent aspect of tech specs is lost.
12 MR. DUNNING:
Well, criterion two basically is a 13 criterion that says we want the plant to operate within the 14 limits of parameters that were used in the safety analysis.
15 MR. EBERSOLE:
I just did that.
l 16 i MR. DUNNING:
That is a criterion that says you go 17 and operate the plant at temperatures and pressures beyond 18 which you designed it for, and that is ---
19 MR. EBERSOLE:
I just gave you an example of where 20 there was no deviation in any parameter because the aux 21 backup system picked you up and took you through and you 22 never saw a thing, but you did go to your last line of 23 defense without even defining how reliable you were sitting 24 on it.
25 MR. BUTCHER:
Let me back all the way up to my
($)
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beginning remarks because this is a very important point.
2 The prevent aspects of these criteria are in 3
criterion one, as Dave indicated, and the prevention is the 4
prevention of LOCA's.
It is correct that we don't focus on 5
other transients which could be considered initiating 6
events, and that is because the focus of these criteria is 7
on the existing regulations and on the existing licensing 8
phase which is LOCA.
9 So your earlier observation that you would see a 10 lot of LOCA in here is true.
We want to say right up front 11 that that is correct, and these criteria are strictly based 12 on the existing rules upon which we license.
To the extent i
13 that we are not satisfied with those rules, we won't be 14 satisfied with these criteria.
15 h MR. EBERSOLE:
But you working solely in a 0
16 l subtractive context and not in an additive context where it i
17 is needed.
Let me read how I added to the first rule.
I 18 have it down exactly as you have until I get to "or,"
then I l
19 add "or various process parameters which through cascading 20 effects lead to eventual degradation of the reactor coolant _
j l
21 pressure boundary."
l 22 Are you with me?
1 23 MR. BUTCHER:
Yes.
24 MR. EBERSOLE:
And that would pick up the battery.
25 MR. BUTCHER:
Well, the battery, our j
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interpretation is it is clearly covered in three anyway.
2 MR. EBERSOLE:
It is very fuzzy.
3 MR. BUTCHER:
My intent is go back, and we have 4
also received this comment on support systems not being as 5
clearly defined as being under the criteria as they could 6
be.
I have made a note here that the subcommittee had also 7
made that observation.
8 MR. MICHELSON:
There is another area of equal 9
concern, and that is that traditionally the design basis 10 accident is a rather well-defined situation in Chapter 15 of i
11 the SAR, but there is another whole set of accidents which 12 could get a nuclear plant into great difficulty, and that is 13 what I call the pipe breaks outside of primary containment.
14 This is the possibility of various high-energy lines and low-15 energy lines undergoing rupture.
I 16 Now this concern was raised back in '72 in the Jim 17 Busso letter and subsequent correspondence, but that has 18 never been called a design basis accident.
19 The agency came out and said tell us what you 20 would do if you broke a pipe and so forth, but they did not 21 call it a design basis accident.
Yet, there are a number of 22 provisions in the plant to take care of such breaks, t
23 protective provisions, and they are covered in many cases by 24 tech specs.
25 Yet it looks like that whole set now disappears _
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because it is not in your selection criteria.
So it is 2
another concern you might want to list, the treatment of a
3 severe accidents outside of severe accident situations which j
4 occur outside of primary containment, a pipe break being but i
5 one of several that I could name, and for which protective i
6 features haven't been inserted that are routinely surveyed j
7 and so forth.
Isolation valves for these breaks and that 8
sort of thing are routinely surveyed to be sure that they 1
9 are operational.
10 MR. EBERSOLE:
By the way, the reliability of 11 these pipes out there is greatly inferior to the primary 12 loop ---
13 MR. REED:
Well, the tech specs, Carl, are not 14 designed to correct all the deficiencies and design 15 g vulnerabilities that exist or for the proper slotting of 16 wheat and chaff in other areas.
17 MR. MICHELSON:
Well, I am merely pointing out 18 that the items that are in there for this purpose are now 19 covered by tech specs, but I don't know that they will be 20 continued to be covered, and that is what I am finding out. _
t 21 l
22 I appears to me that they would not be covered by 23 these criteria, and if they are not, then that would be 24 another problem I would have with the proposal.
25 MR. EBERSOLE:
Glenn, what are your views of the O
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1 tech specs?
j 2
MR. REED:
Well, I thing they grew like topsy, and 3
I remember the first tech specs even written because I was a 4
member of the Yankee Rowe organization.
In Yankee Rowe days 5
and Haddem days and in the early days they were growing with 6
each new license.
Finally some standardization and some 7
rules came into the picture, and when that happened somebody 8
went overboard with respect to just ballooning them and they 9
ballooned and ballooned and ballooned until the operator can 10 no longer compete with them.
11 MR. EBERSOLE:
They shouldn't balloon, but they 12 ought to be comprehensive.
13 MR. REED:
That's gets to quality, the quality of
~\\
(Al
\\
14 i paper, and I don't know when and how you get to the quality 15 of paper, but I was impressed by the comment that I heard 16, here that they are going to separate the chaff and get that 17 jtoonesideandgettothewheatandthentrytostudythe 18 kernels of wheat.
19 l MR. MICHELSON:
Just as one example though, and 20 perhaps you could put me at ease this way, in the case of 21 boiling water reactors the reactor water cleanup system was 22 in many cases non-seismic and non-QA because it is outside 23 of primary containment but operates at full reactor 24 temperature and pressure and is connected to the reactor 25 through an open six-inch line.
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1 Now in the unlikely event something goes wrong in 2
a pipe or a piece of equipment in that system there are 3
detection systems that detect the elevated temperature, for 4
instance, and close some isolation valves.
Would that 5
detection system be considered a part of a primary success 6
path since reactor water cleanup never really does anything 7 g like that?
This rupture outside of containment is not a 8
design basis event, except under the old Jim Busso letter, 9
and that is as close as it came to ever being thought of 10 that way.
Would that system now be a tech spec?
Presently 11 it is I hope at least in the standards.
12 How would that be captured?
13 MR. FISCHER:
Well, in terms of the degradation of O
\\/
14 l the reactor pressure boundary ---
{;
MR. MICHELSON:
It is not the reactor coolant 15 k
i 16 j pressure boundary out there.
It is not even classified.
It 17 is not classified reactor coolant pressure boundary.
I'm i)goingtobealawyernowandreadyourwordsforwhatthey 18 i
19 say.
This is says reactor coolant pressure boundary and it 20 is not.
21 MR. REMICK:
Carl, what is your monitor doing?
Is 22 it monitoring the reactor coolant temperature or is the 23 monitoring system you are talking about monitoring the flow 24 in the cleanup system or ---
25 MR. MICHELSON:
Neither.
It is monitoring the O
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room temperature.
There is a thermocouple on the wall, and 2
if the pipe breaks it elevates and it closes the isolation 3
valves.
It is not a reactor coolant pressure boundary I
4 rupture.
See, this a non-qualified step out there in many 5
cases.
The reactor coolant pressure boundary only went to f
6 the isolation valves.
7 MR. REMICK:
What is your concern of knowing about 8
that break?
9 MR. MICHELSON:
My concern is knowing that the 10 isolation devices will work, both the valves and the 11 instruments.
12 [
MR. REMICK:
For loss of water, and not the effect 13 on the primary system.
14 l MR. MICHELSON:
Well, the effect on the mitigating I
..fsystemswhichwillnowgetfloodedwithhotwaterandthe 15 16 reactor building fills with steam and gone unisolated it i
lcouldblowdownthereactoroutsideofcontainment.
17 18 MR. EBERSOLE:
The term for it is a true line 19 LOCA.
It didn't involve the membrane at all, 20 MR. FISCHER:
Mr. Michelson, I believe those j
21 things would get covered and Sam Bryan is looking that up.
22 Another thing that really is important to remember 23 is that we are not taking these requirements and just taking 24 them out of specs and throwing them away.
The requirements 25 are still going to be there.
(")T l
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Some of your concerns, well, it is not going to be 2
a spec, and so then you postulate the scenario, it really 3
isn't fair to do that because before they can go in the 4
trash, they still have to go through a review process.
5 MR. MICHELSON:
Well, I think what would have been 6
awfully helpful to the subcommittee was to have seen the 7
results of the Limerick and Wolf Creek work.
There was a 8
report.
9 MR. BUTCHER:
I was about to ask if you had in 10 fact seen it.
11 MR. MICHELSON:
No. I just asked for them today.
12 MR. FISCHER:
I think you have them now, Mr.
i I
13 Michelson.
O 14 Okay, now I've got them.
15 l And perhaps in looking in it and seeing the a
!examplesoftheapplication, 16 and hopefully this document i
17 somehow is tied to the policy statement, and says well, the 18 policy has been implemented by example.
19 MR. FISCHER:
After I get through the basic part 20 of my presentation, we can put some systems on the board, or 21 put a viewgraph on to show you the types of systems that 22 would come out of specs.
23 MR. REMICK:
But, Carl, before you leave that, I 24 am not sure I understand why that needs to be a tech spec 25 versus an FSAR commitment.
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MR. MICHELSON:
Well only in that if it is an FSAR 2
commitment, is there going to be a commitment to check it 3
every month and that sort of thing?
4 MR. REMICK:
I assume so.
5 MR. MICHELSON:
And if it fails is there a 6
commitment to send some kind of a report that you found the 7
system failed, like you do in the case of regular tech specs i
8 of an LER?
9 MR. BUTCHER:
If it is not a tech spec, I don't 10 believe the LER requirements would go with it.
11 MR. MICHELSON:
And I don't think you will ever 12 know.
13 MR. REMICK:
I think you will find that every item 14 that is in tech specs, you will find a proponent of keeping 15 j it there and proponents of adding.
That is what the problem
!i 16 I has been that Glenn talks abot and I agree.
I l
17 l
I remember the discussions with Bart and Mann when 18 tech specs were in an embryo stage and we talked about only 19 being on things that were measurable.
That is the only l
20 thing that should be in tech specs.
They have gotten out of 21 hand, and I think we come down to every one of our favorite l
l systems to see if there are going to be tech specs because 22 23 we think it is important and there is going to be a 24 proponent of every item in there and there will be l
25 proponents of adding a lot more.
That is what we have been. _
l O
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I going through for the last 20 years.
2 MR. MICHELSON:
I wasn't proposing that that 3
necessarily be in or out.
I was simply asking how does it 4
come under these criteria and whether or not a system like 5
that would come under these criteria since they are not a 6
part of the reactor coolant pressure boundary and they are 7
not a part of the primary success path and so forth.
8 MR. REMICK:
But even if they are not part of that 9
criteria and they are important, I presume they will be kept 10 in the FSAR as a commitment and there will be certain 11 requirements.
12 MR. MICHELSON:
And the question is what are those 13 requirements in terms of are they going to do the same 14 surveillance and so forth and what reporting, if any, is 15 there, you know, who knows about it?
l 16 i MR. BUTCHER:
I can tell you that we are not 17 proposing any additional reporting over and above what is 18 required under the current things that are in the FSAR at 19 this point.
,I 20 MR. MICHELSON:
The additional didn't bother me.
21 It was less, that you no longer get an LER on it.
22 MR. BUTCHER:
That is what I am trying to say, 23 that current FSAR commitments don't require LER's, as I 24 understand the rule, and neither would these.
25 (Slide.)
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MR. FISCHER:
Well, not withstanding these three 2
criteria, the policy statement will require that the LCO's 3
and the surveillance requirements and action statements for 4
essentially four systems must stay in tech specs 5
irregardless of what the criteria would have done to them, l
6 Those four systems are the reactor core isolation j
7 cooling or the isolation condenser if the plant happens to 8
have the isolation condenser, the residual heat removal, 9
standby liquid control and recirc pump trip systems.
10 MR. EBERSOLE:
Those are all boilers.
11 MR. FISCHER:
I don't know that they are all 12 boilers.
The RHR, I believe ---
13 MR. EBERSOLE:
The RHR is valve handled, but all 14 the rest of them are boiler.
15 d MR. FISCHER:
Basically they are boiler.
I 16 MR. MICHELSON:
Why isn't auxiliary feedwater on 17 there?
18 MR. FISCHER:
Well auxiliary feedwater didn't drop 19 out of the specs anyway.
I mean we could list all the 20 systems that got captured by the criteria and say 21 I notwithstanding -- I mean we have criteria for picking up 22 systems.
These four systems dropped out using the criteria 23 and we thought, based on experience and based on 24 probabiJistic risk assessments, that these four as a generic 25 matter ought to stay in specs.
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1 We will come back to some other mechanisms to get 2
these back.
Other systems may need to say in specs, but
]
3 these four didn't get captured by the criteria.
AFW did.
4 MR. BUTCHER:
Dr. Remick, this is the staff's four 5
pet systems, and I suppose that the subcommittee members 1
6 could add their four also.
7 MR. REMICK:
That is such a small list.
I don't j
8 think your policy statement'is clear on what those four 9
are.
What I have just said makes sense to me, but I didn't j
10 read that, and I couldn't for the world think how you picked 11 only those four.
lj 12 MR. MICHELSON:
And I couldn't see how RHR would j
13 ever drop out, for instance.
i 3
14 MR. BUTCHER:
It is the shutdown mode of RHR that i
15 would have dropped out, the cold shutdown mode which ---
l 1G l MR. MICHELSON:
That is what I thought.
I 17 l MR. EBERSOLE:
Where there is only a single l
]
18 suction uptake on the old designs.
i' 19 l MR. BUTCMER:
It will be for both types of l
20 designs.
i 21 MR. BRYAN:
It also depends on how you define i
22 immediacy.
23 MR. EBERSOLE:
RCIC in the vintage of plants, say l
24 1966 to '70 was never a safety grade system anyway.
I 25 MR. MICHELSON:
But RHR always was.
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1 MR. BUTCHER:
And RCIC has always been tech spec.
2 MR. EBERSOLE:
But it has never been identified as 3
a safety grade in particular.
RHR in the mode where you are 4
just cooling the reactor down after trip is not a safety 5
system.
6 MR. MICHELSON:
That could have been identified 7
parenthetically here if that is what was meant.
8 MR. BUTCHER:
The intent was to identify how risk 9
was used beyond -- including these four systems is based 10 upon actual experience with risk calculations which tend to 11 indicate they can be risk significant.
12 MR. EBERSOLE:
This singular suction uptake has 13 led to closures that couldn't be opent3 and the plant could 14 not cool and therefore has to be revert to a more risky mode 15 of cooling on several of the plants.
16 l MR. BUTCHER:
That has in fact happened on several 17 occasions.
18 MR. REMICK:
Just as an editorial comment, I 19 think, Dave, your pointing out the four words, 20 "notwithstanding the above criteria," I think those four 21 words are suppose to capture what you have told us of why 22 you have listed these four, but when I read it that didn't 23 come across.
24 In hindsight now that you tell me why those four s
25 are listed it makes sense, but it is just an editorial O
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comment, that I don't think the public in general is going 2
to know why you have listed those four.
I could be wrong, 3
but I sure didn't, and I suspect that others didn't either.
4 MR. FISCHER:
Maybe we can sharpen those words a 5
little bit.
6 MR. REMICK:
I think your explanation is a good 7
one, but I don't think it is in those words.
8 (Slide.)
9 MR. FISCHER:
Now let me show you basically how 4
i 10 the policy statement will be implemented.
11 The basic process is for each of the NSSS vendors
)
12 to develop revised standard tech specs which will be 13 submitted to the NRC.
We will review it and then endorse it j
14 by a safety evaluation report as we would do on any topical t
15 !
report.
l 16 MR. EBERSOLE:
May I ask a question.
The focus on 17 the vendor, typically the vendor never did even touch aux
{
18 feedwater, although he should have from the outset.
So who i
j 19 does that?
20 MR. BRYAN:
This is the owners groups.
It is not 4
21 the vendor per se that will be revising the tech sp'ecs.
It i
22 will be the vendor owners groups who will be revising them.
4 23 MR. BUTCHER:
They are vendor specific-standards, 24 but generally the spec would be written by an owners group.
1 25 In fact, I believe all the owners groups are just about to I
l i
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I start the process.
2 MR. EBERSOLE:
Well, that would capture the A/E 3
component.
4 MR. BUTCHER:
That is correct.
5 MR. EBERSOLE:
And that might be a lot.
t 6
MR. BUTCHER:
I believe that even in the case of 7
the A/E design system they work with vendor specifications.
8 9
MR. EBERSOLE:
I've asked the question many times, 10 and there is no real heavy imposition by the vendor on what 11 the owner or the A/E wants.
It kind of spoils his customer 12 relation.
I 13 (Slide.)
14 MR. FISCHER:
After we have reviewed and approved l
15 i the vendor specific revised standard tech specs, then the l NRC will entertain license amendment requests from each 16 l
17 l licensee who wants to take this opportunity.
18 When they do submit their license amendment 19 requests they have to tell us where each of the requirements 20 that were in tech specs, where it is going to go to and what 21 controls they are going to have over that, and they have to 22 have improved bases for each of the things that stays in 23 specs.
24 MR. EBERSOLE:
Now this sticks strictly to the 25 subtractive mode, or redistribution mode or whatever is 1
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1 already there.
So it is not really improvement in the 2
overall context.
i 1
3 MR. BUTCHER:
Not in the sense that you would add 4
things to it.
That is not the objective of this program.
5 MR. EBERSOLE:
The word " improvement" generally 6l infers, you know, what is remaining.
7 MR. BUTCHER:
Well, Dr. Ebersole, that was 8
generally the perception that people had when all these 9
things were added, that it would represent an improvement, 10 but both of these studies concluded that in many cases it 11 did not.
12 MR. EBERSOLE:
Certainly in one context I don't I
13 doubt that it does, but it is a narrower use of the word i
r~N 4
\\-
14
" improvement" than I would ---
j 15 MR. EBERSOLE:
More is not always better, and we hi 16 believe in this context it is not necessarily better.
n 17 l MR. EBERSOLE:
I agree.
)
18 MR. REMICK:
But am I correct that if an owners i
19 found in suggesting that certain things be taken out that 20 they might suggest a rewriting of those there or adding 21 things, that that is a possibility, that they could add at 22 that time if they thought that was a consistent logical way l
23 to do it?
24 MR. BUTCHER:
There is nothing in the program that 25 would prohibit adding things to the standard.
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MR. REMICK:
So maybe when they do the bases and f
2 think it through there might be a difference.
3 MR. BUTCHER:
There might well be, and in fact if 4
you read further into the policy statement by the Commission i
5 there is a recognition on the part of the Commission that 6
particularly on a plant specific basis there may be a need 7
to add additional systems over and above what the criteria
{
8 plus these four systems would do.
i 9
We would only at this point propose to do that on a
i 10 a plant specific basis because we don't believe that the i
(
11 generic analysis -- it is just difficult on a PRA basis to i
12 make a generic fourth criteria.
l 13 MR. FISCHER:
Our generic PRA came up with those e
i l
14 essentially four systems.
We also are going to consider 15 risk on a plant specific basis for specific additions.
16 MR. EBERSOLE:
In this context GDC-17 is one of l
l 17 the unique parts of the GDC set at large in that it imposes 18 requirements on non-safety grade subcomplexes.
This is the l
19 switchyard or incoming power, you know, the dual line 1
20 requirement, the switchyard design and so forth.
21 How is this presently handled in the tech specs 22 context where it is recognized as so important to the safety i
j 23 of the plant?
It is not safety grade, but it is an i
24 interfacing system where a variety of requirements are 25 imposed.
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1 MR. BUTCHER:
It is defined as a support system 2
for the primary component, the pumps and the valves and 3
whatever, and it is handled that way.
We don't, as I j
4 recall, propose to remove any of those specifications on the 1
]
5 power system.
2 l
]
6 MR. EBERSOLE:
On the incoming power system.
j i
i 7
MR. BUTCHER:
On the incoming power system.
Now 8
we suggest that you read this to verify that my initial 1
I
)
9 recollection is correct.
t 10 MR. FISCHER:
You should notice that the NRC will 11 give first priority in its technical specification i
12 improvement effort to the review and approval of the revised 13 STS and the plant specific license amendments based on them.
i 14 While the criteria could be applied to custom tech 15 specs, our intention is to initially focus on the vendor i
16 specific revised standards and then the license amendments 17 that come in based on those.
,1 18 We are encouraging through the policy statement 19 that anyone with custom tech specs move to the standard tech 20 specs in order to reccgnize the benefits that we have to 21 offer and they can realize those benefits earlier.
But i
22 there is no requirement that they go to standard tech 23 specs.
The policy statement is strictly voluntary.
24 (Slide.)
25 The next thing I would like to do is point out i
2 l
1 l
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1 some of the significant changes between the first draft of 2
the policy statement that we sent you on May 8th and the 3
second draft that we just sent you yesterday.
4 Essentially there are four significant 5
differences.
The first one relates to the use of risk.
The 6
second draft of the policy statement clarifies that risk 7
evaluations are an appropriate tool for defining additional 8
tech spec requirements on a plant specific basis.
9 I will call your attention to 10 CFR 50.36 that 10 says that the Commission can impose tech specs as it seems 11 appropriate.
4 12 MR. EBERSOLE:
Let me ask a question.
When you 13 use the term " risk" to avoid the obnoxious term PRA, how do l
14 we rationalize that there are outstanding policy statements 15 l to the effect that we won't use PRA in establishing plant i
qchangesandadditions, 16 and it really is a little bit of a i
17 q slight of hand to just change PRA to risk.
That is PRA.
18 How do we rationalize escaping the use of the term "PRA" 19 !
when in fact that is what we are doing?
20 MR. FISCHER:
I think that we may have taken care 21 of that when we put into the policy statement itself a 22 statement to the effect that the Commission will continue 23 research directed toward developing methods to make greater 24 use of risk and reliability considerations for defining 25 future generic tech spec requirements.
i j
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1 We specifically try to tie this in with ongcIng 2
safety goals and the severe accident policy statement which 3
do involve the PRA's that you mentioned.
4 MR. EBERSOLE:
Well, it is a difficult area 5
because PRA in some cases is numeralized judgments, and 6
judgments which are then processed, and it has been 7 !
frequently used to escape having to do things which might 8
otherwise have to be done on a different basis.
9 It seems to me that you would have to say 10 something about your justification for using a probabilistic 11 risk assessment which you call risk in the context that you 12 are going to do in some conservative way and make due 13 allowance for the wide band of uncertainties which go with 14 it.
15 [I MR. BUTCHER:
Dr. Ebersole, I believe that in this a
16 context when these individual plant specific decisions are hmade, they will be made within the context of 51.09 which 17 efwouldrequirearigorousandcarefulanalysisofboththe 18 l
19 cost and benefits and the uncertainties associated with your 20 judgment.
So it is not that you would willy-nilly apply 21 some calculation.
It would have to be a thoughtful judgment 22 well documented.
23 MR. EBERSOLE:
Good.
24 MR. FISCHER:
The second major change in the 25 second draft that you have is that the policy statement now s-ACE-FEDERAL REPORTERS, INC.
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indicates that a standard will be developed for the conduct 2
of 50.59 reviews by NSAC, and that this guide will be given 3
some regulatory status, and as an example, maybe a separate 4
policy statement or a reg, guide or something, but our 5
intention is to try to improve the 50.59 process as part of 6
the policy statement, and not co much that we see -- I mean 7
that is almost a separate issue.
But we are going to try to 8
beef it up and we have obtained a commitment from industry 9
to develop a guide on 50.59 reviews.
10 MR. MICHELSON:
Did you say NSAC was going to do 11 this?
12 MR. FISCHER:
Yes, sir.
13 MR. MICHELSON:
How does that relate to their 14 normal activities in analyzing events for safety 15 significance and so forth?
)
16 MR. BUTCHER:
There were several choices.
We 1ldiscusseditwiththeindustry.
There are several different 17 18 organizations that could do it.
Of course, there is INPO 19 and AIF and many of the different owners groups, and for 20 various reasons it was judged that NSAC would be the 21 industry's choice to do it, so to speak, and I am presuming l
22 that that was motivated by the fact that, as you indicate, 23 the kind of work they do about judging the safety 24 significance of different events and whhtever.
25 It helps to bring some subjective judgment to the O
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1 process of how you apply the 50.59 criteria because they 2
tend to be very subjective, and it is an attempt to put 3
experience with that type of thing into making 50.59 4
decisions.
That is my reaction to the way the industry 5
presented it to us.
6 I need to point out that we have at this point 7
only verbal commitments and discussions that we have had 8
with the industry.
It is my understanding that they will 9 8 file a formal letter with the staff.
10 MR. MICHELSON:
Is INPO going to pick up on self-11 enforcement by looking at the quality of this as part of 12 8 their routine inspection process?
13 MR. BUTCHER:
We don't have a commitment from INPO O'
14 to do that at this point.
It is my understanding that that 15 is an INPO program which has been identified, and in fact iltherehavebeensomemeetingsanddiscussionsandsome 16 f
17 activity, but we don't have a formal commitment from INPO 18 !
that that is what they intend to do.
19 MR. MICHELSON:
When you say that certain items 20 now in the present tech specs will be moved bodily to the 21 FSAR, do you move bodily also the limiting conditions of 22 operation and so forth into the FSAR7 Is that what you 23 mean?
24 MR. BUTCHER:
The idea is that the initial 25 transition would carry all the baggage so to speak with the l
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1 LCO, the surveillance, the action statements and everything, 2
all that would go with it.
i 3
MR. MICHELSON:
That would be in the FSAR now.
l 4
MR. BUTCHER:
For those things that make sense.
5 MR. MICHELSON:
Well, let's assume it is something 6
that does make sense ---
t 7
MR. BUTCHER:
But let me point out that our early 8
studies indicate that very much of what is in the specs 9
don't make sense in the FSAR and it would be better 10 controlled by a plant procedure.
So we keep using FSAR an 11 example, but let's understand that ---
j 12 MR. MICHELSON:
Well, it is okay that it goes into i
l 13 a plant procedure.
It comes out of the tech spec and goes i
14 into another document called plant procedure.
1 15 MR. BUTCHER:
The point is that it is already 16 there.
That is my point.
All of the surveillance 17 requirements that are in the specs, my guess is it is 13 already duplicated in the plant procedure.
19 MR. MICHELSON:
But once taken out of the tech 20 specs, then I am trying to determine what enforceability 21 there is for shutdown and so forth if the LCO requires 22 shutdown in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> or whatever.
Is the utility now 23 obligated to do that because it is in his other procedure 24 but not in the tech spec?
25 MR. BUTCHER:
As Dave indicated, when the O
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1 application is filed they have to tell us where each one of 2
the LCO's went and they would identify it.
Now there is 3
nothing to stop them from using 50.59 and the control 4
mechanisms on procedures at some point after due t
5 deliberation in altering the shutdown requirement.
i 6
MR. MICHELSON:
And if they do that, the NRC only i
l 7
finds out about it once a year, is that right, when they I
8 submit their annual report on 50.59 changes?
j 9
MR. BUTCHER:
Well, in the case of procedures, the 10 resident is there on site.
4 11 MR. MICHELSON:
I realize he is there and he has a 12 lot of things to do and this is perhaps a significant j
13 additional thing for him to have to bird-dog, but is that i
14 the idea though, that the only time you are officially i
15 informed of the change would be in the 50.50 report which I 16 g think the utility makes once a year, isn't that right?
4 R
17 ]
MR. BUTCHER:
I believe it is once a year.
There i
18 is no intent to change 50.59.
So the answer is yes, there
)
19 will be some things that ---
i 20 MR. MICHELSON:
The only thing is by happenstance.__
j 21 or otherwise, because the utility is not obligated to tell
?
22 the resident they are doing it.
He has to find it out by i
23 happenstance.
24 MR. BUTCHER:
My experience has been that he knows 25 pretty much when somebody has been fooling with the i
i l
i j
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procedures.
2 MR. MICHELSON:
Well, depending on whether you are 3
buying or selling, you can make these statements, but right l
4 now let's just say what is required.
It is not required to 5
inform the resident inspector that you make the change.
You 6
could have made the change for as much as a year without 7
informing the NRC.
8 MR. BUTCHER:
That's true.
)
9 MR. MICHELSON:
So the only review is once a year 10 when the NRC is informed, and then hopefully they go through 11 all these changes and find it and say, gee, I need to check i
12 this to see if it was done right.
13 MR. BUTCHER:
You have to remember that that is C
O, 14 what we intended it to be because the perception is or the 15, idea is to take these lesser important things and look at a
16 them once a year as opposed to all through the year.
17 l
MR. MICHELSON:
I know you saying lesser 18
[ important, but perhaps I think of it differently.
I think 19 l
fire protection is very important, and fire protection would f be treated this way, if I understand the process.
20 i
21 MR. DUNNING:
I think it is fair with regard to 22 the fire protection issue that the Commission has made a 23 decision.
There was a generic letter that was issued with 24 regard to the fact that the Commission wanted to have the 25 fire protection program put in the FSAR, defined in the O
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1 FSAR.
2 As a part of this generic letter that was endorsed 3
by the Commission, it talked about resulting in a major 4
reduction in those things that were associated with fire 5
protection that were in technical specifications that could 6
now be removed.
7 So in a sense these actions are going on 8
irregardless of whether this policy statement ever gets 9
issues or not and it was based on a Commission decision.
10 MR. MICHELSON:
That doesn't make it right of 11 l course.
l 12 MR. DUNNING:
It doesn't make it right, of course, 13 l but it ---
14 MR. MICHELSON:
I am not sure the Commission
!I 15 j appreciated perhaps the full implications unless the staff H
16 l carefully defined to the Commission the full implications of r
17ldoingthis.
I didn't understand it quite that way either, h
18 d But thinking about it from a different perspective now, I 19 can see that it could be abused and it is a potentially 20 l troublesome area.
21 I just want to make a point though.
Until I see 22 the final set, I am not sure that these are all 23 # insignificant.
I don't know.
24 MR. BRYAN:
But when you say fire protection, 25 there is a whole spectrum of importance in those O
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1 specjfications.
2 MR. MICHELSON:
That's right.
3 MR. BRYAN:
And the fact that you have a fire door 4
that is not working and you have to station someone there, i
5 you know, it doesn't even register in the same domain as far i.
6 as I am concerned as the failure of a reactor protection 7
system or some device such as that.
4 8
MR. MICHELSON:
I am not going to quibble over the 9
relative importance of all items in fire protection, but I j
)
10 am just using as an example that bodily all aspects of fire i
j 11 protection are taken out of the tech specs, if I understand i
12 it correctly ---
3 13 MR. BUTCHER:
And made a license condition.
i l
14 MR. MICHELSON:
and made a license condition.
f 15 So I was inquiring about well what happens when they do this i
i 16 I or that in terms of surveillance, which I understand they
- t 4
17 still have to do, and if they find a problem, are they still j
18 obligated to shut down or to put fire watches or whatever, j
19 and I thought I understood that, yes, they are still l
20 obligated to do this unless they decide not to under 50.59.
j 21 So if they decide not to, then I ask well, whose 22 looking at these kinds of decisions and when are they even i
7-23 aware of it, and I think the answer comes back that says the i
24 only time the utility makes the agency aware of it is once a j
20 year.
I d
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1 MR. BUTCHER:
That's correct.
2 MR. MICHELSON:
And it is up to the agency at that 3
time to decide whether that was a good decision several 4
months ago or not.
l 5
MR. REED:
I might point out that it is not a hard 4
6 requirement I suspect, but typically the resident inspector 7
is required to get distribution and does get initial 8
distribution of all operating procedures, and they require a 9
distribution of all changes to operating procedures.
That 10 is in-house at plant, but I don't think it is a hard 4
11 regulation, but it is a practice.
Isn't that the case?
It
.I 12 is to my knowledge.
13 MR. BUTCHER:
I don't have any specific knowledge.
14 MR. REED:
Because the resident wants to function 15 with up-to-date and current operating procedures just like 16 the rest of the plant staff does.
4 17 MR. BUTCHER:
We went to all the regions with this I
18 program and met with all the resident inspectors, and the 19 one thing that seems to get a lot of their attention is the l
20 plant procedures, and they seem to be very much up on 21 whenever one of those changed that they took the trouble to 22 understand and review the documentation that went with it.
a 23 It seemed to be a major inspection activity on their part.
24 There was very little concern on the part of the 25 inspectors of requjrements which found their way into the l()
i i
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1 procedures.
They seemed to regard that as a very effective 2
tool.
3 MR. EBERSOLE:
I think the fire protection area, l
4 that we could stand a little bit of enlargement on that.
As 5
you recall, way back in history Reg. Guide 175 was the point 6
of beginning of consideration of separation of cables, and 7
it was a time when the electric people declared that they 8
would predict no fires because of their protective designs 9
that propagate in the general context.
They would localize 10 them, and they presented this concept of limited isolation 11 separation.
12 The introduction of the intrusion fire from the 13 use of whatever, an acetone, completely threw that out the d
14 window, but it set in place prior to that a system of tech 15 specs defining the localized separation requirements and 16 maintenance of tech specs on that.
17 l
Nowadays we are supposed to have, and I hope we i
18 have a concept of a distant facility or a subfacility called
- i 19 the auxiliary control room that will override and be 20 competent in accomplishing safe shutdown even if the 21 original tech spec requirements and separation requirements 22 were in fact inadequate.
l
\\
23 I guess we still carry the burden of carrying the 24 local protection and tech specing it, and I am suspicious l
25 that we don't adequate tech spec the capacity and O
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\\_ /
1 reliability of the distant and remote shutdown f%cility 2
which is the real root of safety in this logic.
3 Could you elaborate on that?
4 MR. MICHELSON:
And could you tell us if that is 5
going to be moved out of the tech spec altogether?
6 MR. BUTCHER:
The remote shutdown system would not 7
trigger one of the three criteria.
8 MR. EBERSOLE:
It is the root protection system.
9 MR. BUTCHER:
Now it is required as a condition of 10 the fire protection plan.
11 MR. EBERSOLE:
Is there a tech spec?
12 MR. BUTCHER:
It does not have a spec on it.
13 MR. EBERSOLE:
Then I don't know that it is going d
14 a to work when you need it or would ever have worked the first 0
15 3 time.
16 l MR. BUTCHER:
Now the current requirements which W
17 j go with the maintenance of the remote shutdown system will 18 go with the fire protection program when it goes to the 19 license condition.
20 Now one of the rules for changing the first 21 protection program without prior staff approval will be that 22 you do not diminish the capacity of the plant to deal with 23 the fire.
So to me it would be impossible for a utility to 24 eliminate the inspection and the maintenance ---
25 MR. EBERSOLE:
But they couldn't degrade whatever r'
I L.3)
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I they have, whatever that is.
2 MR. BUTCHER:
That's right.
I don't see how they 3
could possibly make an interpretation.
They could take the 4
remote shutdown capability given external fires, as you 5
indicate and sell that argument.
6 MR. EBERSOLE:
Right, but in the context again of 7
improving, as we use the word, tech specs I think it is 8
significant that we don't extent that to guaranteeing that 9
that system does do what it is supposed
.o do and
,1 10 maintaining that capability.
11 l MR. BUTCHER:
Again, I guess we felt like we had i
12 g to drawn the line somewhere and we drew the line at design i
13 basis accidents and fires just don't fit that category.
14 l They are dealt with a whole different way in the lI 15 regulations, and in this case we elected license condition W
16 i as the mechanism to control it.
17 4 MR. MICHELSON:
If you move the fire protection h
18 aspects as a body to another document, but you tell me you i
19 l will carry all of the requirements that were originally in l
20 i the tech spec as a part of this body, how does that make the i
21 I operator's life any easier?
22 MR. BUTCHER:
Well, the specific operator himself 23 in the control room would not necessarily be focusing on the 24 fire protection plan.
That is normally handled by other 25 folks, whereas now it is cluttered and mixed ---
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MR. MICHELSON:
So it doesn't really r.ake life any 2
easier for the operator to do this.
3 MR. BUTCHER:
Well, for the overall plant staff it 4
will.
5 MR. MICHELSON:
Well, I don't see where it would 6
make any difference there either, whether it happens to be 7
in document "A" or in document "B"
if I have to do the same 8
things, and how does it change the workload on the staff?
9 MR. BUTCHER:
The perception is that they will 10 meticulously and carefully re-examine all of the things that 11 were removed from the specs.
12 MR. MICHELSON:
I think the perception is that in 13 the process of moving it from "A" to "B" that a lot of it is 14 going to drop away.
15 MR. BUTCHER:
That's correct.
16 MR. MICHELSON:
And I don't see any rules for how i
llyoucan--it looks to me like the whole thing could drop 17 18 away on your three criterion.
19 MR. BUTCHER:
It would drop away, but only after 20 having exercised the control mechanisms on that other 21 document.
22 MR. MICHELSON:
Which are internal company control 23 mechanisms.
24 MR. BUTCHER:
No.
They are specified by the NRC.
25 In the case of procedures, they are included in the ---
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1 MR. MICHELSON:
Well, 50.59 is an internal thing 2
which there are some controls over what you do admittedly 3
and report once a year.
4 4
MR. BUTCHER:
I guess what I am saying is I always 5
regarded 50.59 as an NRC control mechanism.
The criteria 6
that are in there were dictated by the NRC, and so I always 7
regarded that as an NRC control mechanism.
8 The requirements and the controls on how you can 9
change procedures and what types of rules and what types of 10 criteria you use for whether you can make that procedure 1
11 l change are specified in technical specifications and they u
d 12 would stay.
13 MR. MICHELSON:
Are you going to write a new
\\/
14 version of 50.597 It now says you can't change it because j
i 15 I it is in tech spec, but now you are going to pull it out, 16 i and how is that going to be adjusted ---
17 MR. BUTCHER:
Well, we don't propose to write a 18 l new version.
19 MR. MICHELSON:
What you are saying is that it is i
20 not longer part of the tech spec.
So now where is the 21 description of how your 50.59 analysis will be done for 22 something like fire protection which was in the tech spec 23 and has now been removed?
)
24 MR. BUTCHER:
50.59 was for changes to plant 25 design.
It was not for changes to tech specs.
If it were_a O
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1 change to the tech spec, what that meant is you could not 2
change it under 50.59.
i 3
MR. MICHELSON:
But now we can change it.
I i
4 MR. BUTCHER:
That's correct.
5 MR. MICHELSON:
And what kind of criteria?
You I
j 6
said the criteria or the rules are in 50.59, and I can't see 7
that that is the case because it doesn't even treat this j
8 case presently.
9 MR. BUTCHER:
The FSAR is not necessarily the best 10 control mechanism for fire protection because it doesn't a
{
11 trip on the 50.59 criteria.
In other words, it doesn't j
12 increase the frequency of design basis accidents and it 13 doesn't increase the consequences and the other 50.59 l
14 i criteria.
So the FSAR is not the best control mechanism and l
15 that is what I indicated earlier.
It is not the best I
16 control mechanism for many things that are coming out of the
}
17 specs.
18 MR. MICHELSON:
Are you going to write a new I
19 control mechanism of some sort?
l 20 MR. BUTCHER:
We would say that when you have come_
J 21 l
to that point what you do is you use another control 22 mechanism.
In the case of fire protection the control j
23 mechanism we used was a license condition, and in that I
24 license condition it specifies the judgments and how they 25 are to be made.
I
(
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1 MR. MICHELSON:
And that is already in the 2
licensing provisions of all plants?
3 MR. BUTCHER:
It is not in all of them.
It is 4
offered as an option to the licensees.
They ctn have a 5
license condition or a tech spec.
They get their choice.
6 Some licensees have opted for the license ccnditions and 7
others have said I am comfortable with it as a tech spec and 8
I will leave it ---
9 MR. MICHELSON:
Let's assume I just said I am
)
~
10 comfortable with the tech specs.
So now it is not a l
11 licensing condition, and now what do you do?
l 12 MR. BUTCHER:
Then he can't change it.
13 MR. MICHELSON:
When you take it out of the tech O
I 14 j spec, which is what you are going to allow me to do now, 4
i l
15 j
MR. BUTCHER:
See, taking it out of the tech spec 16 doesn't relate to these criteria.
That was a decision that 17 was made by the Commission as a separate issue.
It was g
18 decided by the Commission that you could accept the license 19 condition in lieu of a tech spec.
20 And if you accept the license condition, the 21 license condition itself specifies the conditions under 22 which you can change the fire protection program.
23 MR. MICHELSON:
Let's assume I left it in the tech
{
24 spec and it is in there today.
4 25 MR. BUTCHER:
yes.
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1 MR. MICHELSON:
But tomorrow this rule goes 2
through and I can now take it out because it doesn't meet 3
the three criteria.
4 MR. REMICK:
It is under the Commission's other 5
actions.
6 MR. BUTCHER:
That's right.
7 MR. MICHELSON:
Yes, it is under this Commission 8
paper, but I don't find it treated.
9 MR. REMICK:
I interpret what they are saying is 10 fire protection is not a good example for tech specs and it 3
11 1 has been handled through another Commission action and has l
12 nothing to do with this.
13 l MR. BUTCHER:
That's right.
It is a decision, and 14 if there were never three criteria, fire protection would 15 have come out anyway.
And let's recognize that putting it 16 as a license condition was not an attempt on the part of the 17 Commission to de-escalate its enforcement in fire 18 protection.
It was the exact opposite.
It was an attempt 19 i by the Commission to upgrade its enforcement of fire 20 l protection.
21 MR. MICHELSON:
I'll have to go back and read the 22 paper.
Maybe it is clearer in the Commission paper.
23 MR. BUTCHER:
I probably shouldn't have brought it 24 up as an example.
I brought it up as an example of a short-25 term improvement to the tech specs which would go forward
/~T V
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1 even if these criteria are never approved.
2 MR. FISCHER:
If I am not mistaken, there are fire 3
protection programs that are now in the FSAR and they do 4
have a license condition on.
Those fire protection programs 5
I believe have some kind of an administrative control 6
mechanism within them on how to make changes to that program 7
above and beyond what might be required by 50.59 which is in 8
the FSAR, and I would even hazard to say, if my recollection l
9 l 1s right, that there are some words in there about reporting 10 requirements related to the fire protection program.
11 MR. MICHELSON:
I think it would be very helpful i
4 12 in the Commission document here, this policy statement, that 13 ;' they address fire protection as a special case and indicate j
x>
14 0 how it is being handled.
15 1 MR. MICHELSON:
It $s not even mentioned.
16 MR. FISCHER:
Well, it is really not within the i
17 scope of the policy statement because the Commission has l
taken a separate action on it.
18 i
19 MR. MICHELSON:
They should so state then in their l
1 l policy that this was an area of separate action not to be 20 21 covered by this policy statement and that is all they need 22 to say and it would clarify the situation.
As it is, as you 23 can see, you can read it either way.
24 MR. WYLIE:
Carl, you mentioned something a while 25 ago in regard to the fire protection and maybe you could
()
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I elaborate on it.
Maybe I misunderstood you, but did you say 2
the fact that it was handled separately that an inadvertent 3
actuations would not be reported?
4 MR. MICHELSON:
As an LER unless they triggered 5
some other LER reportdng mechanism.
6 MR. WYLIE:
Such as?
7 MR. MICHELSON:
Failures of any sort of fire 8
protection would not be reported because there is no l
9 requirement to report them as LER's once you remove them 10 from the tech specs.
)
11 MR. WYLIE:
I think that the problem that occurred 12 at Browns Ferry, for example, where you flooded those areas j
13 and ---
i 14 MR. MICHELSON:
Well, unless it creates a scenario 15 f that triggered another reporting criteria in the 50.73 I i
i l
i 16 guess it is, unless it triggers another ---
17 MR. WYLIE:
Well, that particular one didn't 18 create anything except that it showed a shortcoming that 19 during operation it could have caused a problem.
20 MR. MICHELSON:
I would have to look at it 21 l carefully.
My firsthand guess would be that it would not 22 require an LER once you have removed it from the technical 23 specifications, but I would want to go back and first find 24 out.
25 MR. BUTCHER:
I believe Dave's recollection is ACE FEDERAL REPORTERS, INC.
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i 73920101 75 1
marysimons f(
1 correct that in the license condition there is some 2
reporting requirement that goes with the fire protection 1
3 program.
l l
4 MR. MICHELSON:
That may be.
Okay.
j 5
MR. FISCHER:
Moving right along ---
1 i
6 (Laughter.)
]
7
--- the third significant difference between the 8
draft one policy statement that we sent you in May and the j
9 second draft is that we have added a statement that says 10 that if you are going to move any requirements out of tech i
i 11 specs and into procedures that you should have in your tech 1
j 12 specs the administrative controls over procedures that are j
13 in the standard tech spec.
It is a relatively small point.
14 It is saying it is significant.
15 We want to ensure that if there are plants out 16 that take this split who have custom specs and they don't 17 have that portion of the standard tech spec that says you 18 shall maintain and implement procedures properly, that they I
19 take that out of standard tech spec and move into their 3
j j
20 custom spec.
4 21 We think most everyone has that, but we want to 22 make sure that they at least met that requirement of the l
23 standard.
l 24 The last significant difference between the second j
25 and first drafts is that the second draft clarifles that i
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1 licensees must operate their facility in conformance with 2
the description of their facility and procedures in the FSAR.
3 unless they change the FSAR in accordance with 50.59.
)
4 Failure to comply with the FSAR commitments is a non-j 5
compliance with the license application.
6 MR. REMICK:
Would you repeat that again?
7 MR. FISCHER:
Sure.
The whole thing is that we 8
clarify that licensees nust operate their facility in 9
conformance with the description of their facility and 10 procedures in the FSAR unless it is changed in accordance 11 with 50.59.
Failure to comply with FSAR commitments is a 12 non-compliance with the license application.
13 Now we are not trying to state anything new.
We 14 are trying to clarify that commitments in the FSAR are 1
15 i enforceable, and that if you violate the commitment, you are i
16 violating your license application.
You could probably say 17 that they violated 50.59 as well.
18 MR. REMICK:
Just a question.
Why do you say they-19 are violating their license application versus violating 20 their license?
I don't understand ---
21 MR. BUTCHER:
The license itself carries with it a 22 statement that the plant shall be operated as described in 23 the application.
So the net effect of violating or 24 operating the plant outside your application, the net effect 25 is violating your license.
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1 MR. REMICK:
I guess a person that has a license, 2
he is either in compliance or in violation of that license.
3 Maybe I have never caught those words before, but I didn't 4
know you were in violation of your application.
I thought 5
you were in violation of your license, but maybe it is legal 6
terminology that ---
7 MR. FISCHER:
We will talk to our lawyers about 8
that, Dr. Remick, to make sure.
I think it is tantamount to 9
the same thing.
Maybe the word " application" is superfluous 10 in that.
11 MR. BUTCHER:
The intent is to get to the lowest 12 !
non-compliance which cascades into a non-compliance with 13 your license.
The license says you just operate in I 'l I
N' 14 ]accordancewiththeapplication, and the statement is that 15 it is the policy of this Commission that if you don't s
16 operate it as described in your FSAR, we consider that to be ifoperationnot in compliance with your application and 17 18 therefore you are not in compliance with our license, i
19 l Now I suppose we could have said we will consider 1
20 l it not in compliance with the license right off the top.
21 MR. REMICK:
Well, I don't want to pursue it, but 22 it seems silly because suppose I file and application and I 23 got a license and ten years later I made a modification that 24 was never described in the application, and then say in 25 another two years I have had some kind of a citation based O
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on that that talked about being in violation of-my 2
application, and it doesn't make sense.
It might be in 3
violation of the license which now incorporates thio, but it 9
4 is not a major point, but it is just kind of curiosity of j
i 5
why you say you are in violation of your application.
6 MR. FISCHER:
That is the end of my prepared 7
- remarks, a
8 MR. MICHELSON:
I think we have covered the fire 9
protection as a special case to be handled in a certain 10 way.
How do you handle the security provisions that are in 11 the tech specs, and I assume they would be involved also?
12 MR. BUTCHER:
I don't believe the security 13 provisions are in there now.
I believe that that is a 14 i separate case.
There is a security plan which is also a 15 l condition of the license already.
16 MR. MICHELSON:
But isn't it part of the tech I
i 17 l specs of certain surveillance and certain boundary detection 18 devices and that sort of thing?
I 19 !
MR. FISCHER:
That are not in the specs.
I l
20 j Essentially I see three control mechanisms that we use ---
21 MR. MICHELSON:
But security provisions are not 22 covered in the plant technical specifications?
23 MR. BRYAN:
I think Section 6 of the tech specs 24 says you shall have a security plan and you shall follow the l
25 security plan.
The security plans stands on its own with
!C:)
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1 all the subrequirements that are necessary to make it 2
function.
l
~
3 MR. MICHELSON:
But if you have a security plan 4
and then you define in the plan that I am going to check 1
j 5
this boundary instrument every so many weeks, that in l
6 essence becomes a part of the tech spec if the reference to i
7 it is in the tech spec.
8 MR. FISCHER:
It is very similar to your fire 9
protection plan.
t j
10 MR. MICHELSON:
Is that in any way going to be 11 altered as far as the requirement to do these things or in 12 the requirement to shut down if certain conditions exist?
I 13 MR. FISCHER:
That won't be altered at all by the i
14 policy statement.
I think the policy statement is only 15 (goingtoreallytouchSections3and4ofspecs, and the 1
16fsafeguardsdoesn'tfallwithinthescopeofSections3or4 17 of the tech specs.
18 MR. MICHELSON:
And there is no anticipated change 19 !
in the safeguard tech spec?
20 MR. FISCHER:
But there is a safeguards plan that 21 is referenced in each of the licenses, and there are 22 programmatic controls over that document similar to the way 23 there are programmatic controls over the fire protection 24 plan which are going to be referenced as license condition 25 also.
It is very similar, and we believe that those kind _o_f.
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1 programmatic controls are appropriate.
2 MR. MICHELSON:
Thank you, i
3 (Slide.)
i 4
MR. FISCHER:
Although this wasn't part of my 1
5 formal presentation, I wanted to reiterate a couple of f
6 points that have been made here related to risk, and that is i
l 7
that a risk criterion was not proposed for determining which 8
LCO's LSS, or limiting safety system settings should be 9
retained in the tech specs.
i 10 However, it was used to evaluate the risk 11 significance of relocated requirements and it was i
12 instrumental in requiring that specifications for selected 13 systems, essentially four of them, stayed in specs, and it
(
14 j
y is an appropriate tool for defining additional tech spec i
15 requirements on a plant specific basis.
16 f We used it a lot, and the time isn't here yet to 17 have that fourth criteria on risk.
The Commission will 18 cont!nue research directed towards developing methods for 1
19 greater use of risk and reliability for defining future 20 generic tech spec requirements.
l 21 So we use it generically to add some systems, we 1
j 22 are going to use it on a plant specific basis and we are I
i 23 going to use it later generically when it gets to be time.
24 I just wanted to drive that point home.
25 MR. WyLIE:
Of course, you introduced another I
i
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subject and that is the addition of reliability as a y
2 consideration in tech specs.
3 MR. BUTCHER:
That is a new paragraph that was 4
added there also, and I believe that is what Dave was 5
talking about when he refers to the future.
6 MR. WYLIE:
I mean it really doesn't say anything 7
except you are going to do research and this may or may not 8
come to pass.
9 MR. FISCHER:
Well, we think that really we are 10 headed in that direction with the severe accident policy 11 statement and source term work that is going on.
12 MR. WYLIE:
You mean reliability?
13 MR. FISCHER:
I don't know.
O 14 j
Frank, can you say anything about reliability?
h 15 MR. ROWSOME:
There is research underway in the 4
16 i office of Research on reliability assurance as a possible 1
17 I tool in the context of tech spec reform as one subset and in 18 the context of QA reform and in the context of resolving 19 severe accident policy.
20 It is not yet mature, but in the process of 21 implementing safety goal policy and severe accident policy 22 wo may elect to move in that direction.
We are certainly 23 entertaining that idea.
24 MR. WYLIE:
In the reliability of safety systems 25 kind of thing?
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MR. ROWSOME:
As you know, there are reliability 2
numbers for two safety functions now, diesel generators and 3
auxiliary feedwater in pressurized water reactors.
The 6
4 Commission has shown interest in the safety goal evaluation f
j 5
in at least entertaining the idea of making more extensive
{
t l
6 use of such approaches to regulation, but has made no j
7 commitment to move in that direction.
8 MR. BUTCHER:
The Office of Research has in fact j
9 created some computer tools where you can vary the i
10 reliability of a given component, the assumptions on its j
l 11 reliability and relate that to surveillance intervals and i
1 l
12 allowed outage times and overall risk of the plant.
So 13 there is a desire to couple reliability with the risk l0
{
14 ! analysis tools and technical specification requirements.
We l
j 15 have seen some work in that and it does have a rather i
l 16 p dramatic offeet on what the right surveillance interval l
17 ought to be.
But that sort of work is not at the point
)
18 where it can be factored in as a forth criteria, so to l
l l
19 speak.
I l
j 20 MR. MICHELSON:
I have a general comment relating.
21 to the old 50.36 and then to your policy statement.
50.36 22 had a provision in it that the Commission may include.such 23 additional technical specifications as the Commission finds 24 appropriate.
It had a loop hole that says if I discover 1
25 that I have forgotten something, I have the right to put it O
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1 in.
2 I don't find any indication of a desire for a loop 3
hole of any sort in the case of the Commission policy.
It 4
clearly, unless we are very knowledgeable today, is likely 5
that besides the four systems listed as being perhaps 6
loopholes that need to be filled, there may be others or 7
there may be other things.
Is that covered somewhere?
8 MR. BRYAN:
Page 7 of draft 2 I think speaks to 9
that.
10 MR. MICHELSON:
Oh, okay.
Again I am looking on 11 draft one here.
12 MR. BUTCHER:
It was added in the second draft.
13 MR. MICHELSON:
Okay.
You have got a loophole in 14 there.
l 15 i MR. BUTCHER:
Well, what we attempt to do there is b
i 16 j say that the Commission can find ---
ll 17 MR. MICHELSON:
That takes care of my problem.
I 18 have got to get draft 2 I guess.
I 19 (Laughter.)
i i
20 MR. BUTCHER:
We tried to go one step further, and l
21 I would like to point this out.
What we tried to define is 22 one of the appropriate ways of making that judgment would be l
l 23 the use of a plant specific PRA.
We are trying to go one j
l 24 step beyond what is there currently in 50.36 and say that 25 one of the appropriate tools is the risk analysis.
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MR. REMICK:
Are we in general questions now, r
2 Carl?
[
j i
j 3
MR. MICHELSON:
Yes.
I 4
MR. REMICK:
I would like to go to why is this not f
5 designed to affect Appendix B if licensees are interested in i
i 6
having it affect Appendix B?
If that just not an onerous 7
problem with people like Appendix A?
l 8
MR. BRYAN:
Are you talking about RETS?
J 9
MR. REMICK:
No, I am talking about radiological j
i 10 tech specs in general.
There are lots of things in those,
]
r l
11 and I would think some people find those onerous, and why 12 this doesn't apply to Appendix B7 i
13 MR. BUTCHER:
It was not a part of the original 14 I studies that were done, and there was no specific focus on l
l what is wrong with environmental specs.
The perception that 15 i
i 16 '
I had from working with the industry ' ; that was less of an i
f 17 immediate concern to safety, and for that reason they just 1
18 wanted to get Appendix A out of the way.
It wouldn't l
i surprise me, if we get Appendix A out of the way, if we 19 l
20 don't come back with a siellar petition from industry to 1
21 take a look at Appendix B.
j
{
22 MR. BRYAN:
Most of the complaints and concerns 1
l 23 were with Appendix A.
l j
24 MR. REMICK:
I can understand that, but I would t
i 25 think that Appendix B still has a lot in it in some cases.
i
?
i i
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Another question.
I never quite thought of this 2
before, but our discussion today on the difference between 3
tech specs and conditions of license.
I assume, and am I 4
correct, that this policy statement would not provide a 5
mechanism for somebody to move a condition to the FSAR if 6
they wished to?
7 MR. FISCHER:
That is correct.
8 MR. REMICK:
Although some tech specs by other 9
Commission are becoming conditions, and the fire protection 10 is one that is moved from being a tech spec, or conceivably 11 move from being a tech spec to being a condition of the 12 license.
13 MR. BUTCHER:
That is correct.
O i
14 i MR. REMICK:
Now the other thing, or two other 15 things, and I am confused at the moment, is this a proposed
! policy statement and is it going to go out for public 16 17 ) comment?
As I read the front page I see it is a draft l commission policy statement that 18 is a proposed policy 19 !
statement, and then it says the effective days upon 20 publication in the Federal Register.
i 21 l Now for some reason that came to me today in 22 thinking it was going to be something to go to the 23 Commission to put out in draft form for comment or is it 24 not?
25 MR. FISCHER:
It is draft because it hasn't gone ___
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1 to the Commission yet I guess is probably the best way to i
2 put it.
It is proposed that it go out for public comment 3
before it receives Commission endorsement and issued in the 4
Federal Register.
l
}
j 5
MR. REMICK:
There is no mention of that, and I i
6 think in this second draft of the Federal Register notice, i
j 7
if that is for comment, if that is the case ---
r 8
MR. FISCHER:
The intention is to go out for i
9 public comment to try to clarify that.
l
{
10 MR. REMICK:
The other thing is just to remind you 3
I 11 that there are 70 to 100 other licensees out there that have 12 technical specifications and sometimes it is helpful to put 13 up there that this is just for power reactors, to add in 1
14 there for power reactors so that a lot of people aren't 15 l reading to find if it applies to non-power reactors or not.
I 16 i MR. FISCHER:
I should have remembered and not l
17 tripped on that.
j 18 (Laughter.)
1 19 MR. REMICK:
In the language it does say power l
20 reactors, but sometimes it is helpful to get that right up i
i 21 front.
22 MR. FISCHER:
We can add that easily.
j 23 Any other general comments?
i l
24 MR. MICHELSON:
Just clarify for me, if the 25 utility comes up with removing certain items from the tech l([)
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1 specs, and the agency says no, you really shouldn't remove j
2 them, does the policy statement say the agency's judgment i
j 3
prevails?
j 4
MR. FISCHER:
No, but I think it is pretty clear 5
in 10 CFR 50.36 that the NRC can keep specs or put specs on
\\
6 things that it thinks are appropriate.
l 7
MR. MICHELSON:
Yes, it is completely already in I
)
8 50.36, but I was just trying to get a feel if that is what I
i 9
you would fall back to.
l 10 MR. FISCHER:
We don't intend to change 50.36 at 11 this time, i
{
12 MR. MICHELSON:
Okay.
You would just fall back to 13 the provision here that says I can always impose a tech l
14 spec.
15 MR. FISCHER:
The only thing we are saying in the 16 policy statement is we are clarifying the point that plant l
17 specific PRA's are an appropriate tool.
i j
18 MR. MICHELSON:
Now each proposed new tech spec l
l 19 would be reviewed the staff?
I 20 MR. FISCHER:
That is correct.
We would get I
21 individual license output.
22 MR. MICHELSON:
Now they may all be standard and I
23 all look like, but they can't all look exactly alike because
]
24 of plant specific features, l
l 25 MR. BUTCHER:
I think we need to clarify that a i
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little bit in that we will do a generic review of the 2
standard first as it is current laid out, and of course we 3
are a good ways from that, at least 18 months from actually 4
processing the first application.
The focus of attention 5
would be on where the plant deviates from the standard.
It 6
is not clear to me that we would perform an in-depth review 7 ! of every single specification.
8 MR. MICHELSON:
But you would start by first of 9
all getting an agreement with the utility owners as to what 10 the standard ought to look like, and then when that is done i
11 1 each individual utility has to make sure the standard I
12 d applies to them.
i i
13 '
MR. BUTCHER:
That is correct.
O n
14 j MR. MICHELSON:
And they would pinpoint to you the 15 j discrepancies or deviations from the standard and you would 16 ) look at those as you saw fit.
17 h MR. BUTCHER:
That is the process by which it is i
18 j done today, and we would envision doing it the same way i
19 l here.
I l
20 l MR. EBERSOLE:
I would like to ask if there is I
21 special attention going to be paid to what I would call I
22 i increasing the band width of parameter limits to improve l
23 safety by Icosening the tight grip you currently have on
]
24 such parameters as pressure and temperature and so forth?
25 I think there has been a recognized tendency in O
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the past, for instance, to hold to a very tight -- well let i
j 2
me say overpower trip set point, and the NRC has pushed that' l
3 down close to the operating set point in the guise of being i
i 4
more safe, but what really has happened is the plant goes i
b more frequently into trips and shutdowns with the net result i
j 6
that you don't enhance safety but you decrease it.
}
7 Is there going to be a general look at this matter I
i 8
that you have in tightening tech specs lost safety rather 1
l 9
than gained it?
I l
4 10 MR. BUTCHER:
That sort of thing would probably i
]
11 come up as one of our short-term improvements and we would 1
1 12 look at it independent of the applications and criteria.
4 13 Now Dr. Rawsome in preparing our comments on i
j 14 response to question four has made the observation that i
f 15 really margins and our use of margins and the tightening up l
i
.i 16 of them has not necessarily had a significant effect on risk 17 in terms of risk reduction, and in fact perhaps it may have f
18 even gone the other way.
l j
19 The analysis, as I understand it, of risk is j
20 relatively insensitive to margins, and perhaps you would
\\
l 21 want to expand on that, Frank, if I haven't stated it 22 correctly.
r 23 MR. ROWSOME:
I think you captured it pretty well, I
24 unless we really want to get into the nitty-gritty.
The i
25 margins and DBA calculations I think are a great candidate -
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for something to be relaxed personally, but to change that l
2 now would be to break a lot of institutional inertia behind 3 l proceeding along in this direction.
4 MR. EBERSOLE:
Wouldn't that be a good thing?
5 MR. ROWSOME:
Not if it got the whole thing 6
derailed.
7 (Laughter.)
l 8
MR. EBERSOLE:
Well, you know, the DBA business is 9
now recognized to be only a tiny fraction of the total i accident potential, and it seems like that would be due 10 i
I 11 l justification for relaxing a lot of those, and then would l
12 h lead to more consistent and uniform and safe plant practice.
d i
13 j
MR. ROWSOME:
One could strengthen that argument O
d 14 q by pointing out that the unreviewed safety question clause h
t l
15 9 in 50.59 is quite a potent tool for constraining changes of 1
l 16 commitments controlled by 50.59 that relate to design basis l
l 17 accidents.
So one could argue that the very things covered l
a o
l 18
! by our criteria as remaining in toch specs would be quite l
\\
19 l
adequately protected if they were controlled by 50.59.
l 20 !
MR. BUTCHER:
And that in why we state that the l
21 I use of the FSAR as the principal alternative control 22 mechanism has to be examined carefully because 50.59 23 criteria do not work well for the things that the tech spec 24 criteria remove from opocs, and that is why we tend to be 25 leaning away from that as the principal alternative J
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document.
2
.' iga in, if I might reiterate the wheat from the i
3 chaff analogy.
Hopefully if we can get rid of the chaff, we 4
will be able to spend more attention focusing on things like 5
the fact that we put a lot of attention to margins even 6
though they are in there, and the criteria even though we
~
7 probably are wasting our time doing it.
That might be the f
a l
8 second phase of this if we can get our attention removed i
l 9
from snubbers and whatever else we are fooling with these f
a f
10 days.
i l
]
11 MR. REMICK:
Has there been any estimate on the 12 number of license amendments that might decrease over time 13 as a result of this change?
1 j
14 MR. BUTCHER:
I was hoping that someone would ask 15 i that question.
i 16 (Laughter.)
17 It is a very difficult thing to get ahold of, i
j 18 license amendments.
I will give you the numbers I can give i
j 19 you that you can translate into an answer to that question.
i l
20 About 40 percent of what is in specs now would be removed, I
i 21 40 percent of the LCO's.
So I guess you could argue that i
j 22 you would have 40 percent less license amendments.
But 1
l 23 statistically we have determined that the 40 percent we are 24 dropping seems to be the ones that generate most of the i
j 25 licensing amendments.
So we think that it will be more than f
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1 40 percent.
2 In the case of surveillance testing, we actually counted up the number of surveillance tests that this 40 3
4 percent entails, and these are preliminary numbers and they 5
haven't been QA'ed and I haven't even read the report i
6 myself, but the engineer who did it discussed it with us 7
this morning and it is about 36,000 tests per year that i
8 would be taken from tech specs.
1 9
Now that doesn't mean that you won't do those 10 36,000.
It j'Ist means that the performance of those tests 11 will be under the control of the licensee much, much more, 12 and my feeling is that in the next couple of years he will 1
13 figure out away of getting rid of a good fraction of those.
14 If you put a cost estimate of $10 a test, which is 15 absolutely ridiculously low, because some of them are just 16 l channel function tests, you quickly get to $360,000 a year.
17 There is a tremendous potential here for resource savings 18 and getting rid of attention diverters.
There is a j
19 tremendous potential here for that.
20 MR. MICHELSON:
you are working on the assumption ___
21 that not only were these diverters of attention, but they 22 should never have been done to begin with.
23 Let's take for a moment the fact that some of them 24 should be done.
Now how are the ones that really should 25 continue to be done going to be separated from those that O
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i shouldn't be done and who is going to review that separative 2
process because it is all being turned over to the utility 3
under something equivalent to 50.59 kind of an approach.
4 You have already admitted that the whole reason to 5
do this is to get rid of much of what is in the tech spec 6
now, this so-called chaff.
l 7
MR. BUTCHER:
What we are trying to do is to I
8 return to the original licensing basis of these plants.
9 Over the years it has kind of crept out beyond that.
We are 10 trying to return to that.
Now c ce we have returned to 11 that, when we can examine the process, and in fact it goes 12 in parallel, examine the question of whether the current 13 regulations are the right ones, and that is being examined 14 through the Commission's policy statement and many other 15 activities.
16 MR. MICHELSON:
The thing that bothers me just a 17 little bit is from time to time we had to deal in detail 18 with utilities because they have gotten into difficulties at 19 Davis-Besse, TVA and several others, and when we starting 20 delving into details we find that things are not as lily 21 white and clean and well run as one might have thought.
22 I would like to be assured that this process is 23 being properly policed wherever it is being done.
I have 24 some assurance it is being policed as a tech spec, because 25 everybody focuses on that document and it has become a part O
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1 of our ritual now and people know what is expected and what 2
has to be done.
3 It appears to be working reasonably well, and I 4
don't think the arguments being present is that it is not 5
working.
The argument being presented is that it it too 6
much work.
So I get a little suspicious and a little 7
concerned as to a good utility will have no problem with 8
your process and they will probably do a great job of it, 9
but some of the weaker sisters might take some short-cuto 10 and how are we protecting ourselves against those short-cuts 11 getting us into deep difficulty in finding out too late?
12 MR. BUTCHER:
Well the industry recognizes that 13 there are some weaker sisters out there than the others, and 14 we all presume that those are the outliers and that the 15 !
majority of the utilities are performing in good faith.
16 h The industry's willingness to get together and set i
17 up good standards for 50.59 reviews and their willingness to 18 present them to us for us to give those standards some 19 regulatory status is an indication that the industry as a 20 whole wants to focus on these weak sisters also.
21 Also the Commission as a part of its budget 22 proposals in its program this year allocated additional 23 resources of the residents to inspecting licensee originated 24 and controlled changes, and I forget, Sam, it was a 25 relatively modest increase in resource, but it was a
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recognition that we want to increase our focus on the 2
licensee.
3 MR. MICHELSON:
We are putting a lot more burden 4
on the resident inspector and the regional offices.
In i
5 fact, almost the entire burden is on them to watch what is 6
going on once it leaves the tech spec.
7 MR. FISCHER:
Actually our comments from the 8
region were very favorable on all these things.
9 MR. BUTCHER:
I believe this additional resource 10 that I am talking about, this additional effort was funded 11 with additional resources for the regions.
l 12 Again, we keep coming back to the question of we a
l 13 believe this stuff is of lesser safety significance and 0
14 therefore it probably warrants less attention.
Now that is 15 E~ lovl Issue here, whether or not these criteria have 16 captured within the current regulations and within the 17 current licensing process those things which are most 18 important with the recognition that they are relatively risk 19 neutral, this program is in terms of increasing or 20 decreasing risk and that the next step in the process of 21 tech spec reform is to go back and take a look at how to 22 make tech specs more risk significant.
23 But the first step is to get rid of the stuff that 24 is there now that shouldn't be there and maintain hopefully 25 the risk neutral situation that we have so that the next _
l i
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1 step will be to make the tech specs no longer risk neutral 2
and make them risk reducers.
3 I suppose we could tackle the two issues together 4
and simultaneously, but there is a perception that it can 5
get done faster with the other approach and that is the 6
approach that we are proposing.
7 MR. MICHELSON:
Are there any other questions?
8 (No response.)
9 Why don't we proceed then.
10 What is next on the agenda besides the break 11 pretty soon?
12 MR. BUTCHER:
I don't think the staff has anything 13 else to present, Mr. Michelson.
If industry and anything
(~/D 14 that they wanted to say.
15 MR. MICHELSON:
The industry I think does want to i
16 make a short ---
17 MR. BUTCHER:
I don't believe so.
18 MR. MICHELSON:
They just want to answer 19 questions.
20 MR. BUTCHER:
Dennie, would you like to make some _-
21 statement?
22 MR. FARRAR:
No.
We are really are not prepared 23 to make a statement.
24 MR. BUTCHER:
They have not seen the proposed 25 policy statement.
So it is difficult ---
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1 MR. MICHELSON:
Do you mean draft two?
2 MR. BUTCHER:
That's correct.
3 MR. FISCHER:
Draft one they haven't seen either.
4 MR. BUTCHER:
They have not seen any drafts.
5 MR. FISCHER:
This is pre-decisional.
We have had 6
discussions with them, but they haven't seen the written 7
words.
8 MR. EBERSOLE:
Is there any way to characterize 9
the individual tech spec tests and other requirements in the 30 context of how much or how little they jeopardize and cause 11 plant transients?
12 MR. BUTCHER:
We have studied that, and what we 13 discovered and we got it confirmed recently with the most 14 recent submittal on changing surveillance intervals, what we 15 determined is that tech specs contribute significantly to 16 E the forced outage, but the way they contribute is because a 17 test has failed and you are forced into an action statement, l that they contributed a fairly small fraction, 18 in the order l
19 of in the case of the B&W submittal, if I am quoting it 20 correctly, about five percent of the total spurious plant 21 trips come from testing of the reactor protection system and 22 one would expect that that is a significant part of it.
23 I am told that other studies have indicated that 24 most of the scrams that you get associated with testing are 25 testing on the BOP and on the secondary side, in other
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1 words, licensee controlled testing. But the tech specs j
2 themselves as structured are not participating that many 3
4 Sam, you folks studied that in the TSIP program, 5
and can you bring any light to that question?
How many i
6 spurious scrams are we getting out of tech spec dictated 7
testing?
8 MR. BRYAN:
I can't really address that.
The 9
industry people claimed that it was fairly significant 10 though.
11 MR. BUTCHER:
I believe you did some independent 12 work which indicated that it wasn' t quit.e that significant.
13 The last industry submittal again was t he B&W report and the 14 reactor protection system, I ran the numbers very quickly, 15 and it was something like five percent, that they expected 16 to get a five percent reduction in spurious trips by I
17 extending their surveillance interval from monthly to semi-18 annually.
19 MR. EBERSOLE:
I would have thought it would have 20 been more.
21 MR. BUTCHER:
I would have thought so also.
I e
22 just recently Gttended an international conference and I t
28 askedythe same question of other member countries.
There 24 was the perception there across the board that it was a 25 higher number, but when the studies are actually done and l()
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you sit down and study it, what you determine is that it is 2
really not as high as you would think.
3 MR. EBERSOLE:
To aid you in this adjustment and 4
improvement of tech specs are you looking at the Japanese 5
practice?
6 MR. BUTCHER:
We are looking at all of the 7
practices, and in the policy paper, which the policy 8
statement is an attachment to, we talked about the 9
experience that we have from other countries and in fact the 10 testing at power aspects and can we reduce testing at power 11 based upon their practices.
12 That is an ongoing program.
We have entered into 13 an agreement with the CSNI and the OECD to work in that area 14 in cooperation with the other countries.
f 15 MR. EBERSOLE:
The pait:t of this ef fort is not 16 really the large, beautiful word improvement, but it is 17 really reduction and simplification of tech specs.
18 MR. BUTCHER:
Simplification, reduction, and I 19 like to use the word " cleanup."
It is not very 20 sophisticated.
We are trying to clean the specs up so that 21 we have a nice neat document to begin to work with.
What we 22 have now is cumbersome to the point where it is difficult to 23 work with.
24 MR. BUTCHER:
I protest that.
I think it is an 25 improvement.
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1 MR. FISCHER:
I think it is an improvement, too.
2 (Laughter.)
3 MR. EBERSOLE:
Well, let me give you an example.
4 1
4 Is there any way of your attempting to identify the quality 1
5 of the tests that you do, and I will take a case in point.
]
6 You test a valve and you really get only an indication in a 7
bi-stable contest that it did open or it did shut and you 8
have acquired a vast pile of statistics that said it did it 9
a million times or whatever.
Yet you and I both know that l
10 those exercises were no more than passive, unload exercises j
11 that befuddle the mind as to the true reliability of the 12 valve to execute its function under duress.
That is a low 13 quality test.
14 -
MR. BUTCHER:
We are attempting to focus some 15 attention in that area by the rewriting of the basis 16 section.
One of the requirements for the contents of the 17 basis section is that for the surveillance test it must 18 include a description of why that test or how that test 19 demonstrates the functional requirement of the system.
20 Now there are going to be some tests where the 21 justification won't be very good, and the answer is the test 22 doesn't very well demonstrate the functional requirements of i
i 1
23 the system.
24 Hopefully when the basis identifies that fact, we 25 will be able to focus our attention on how to change the (2) 1 ACE-FEDERAL REPORTERS, INC.
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1 test.
2 MR. EBERSOLE:
I thought this was on of the great 3
things that came out of the Salem case.
We had scrammed for 4
years, but we never knew with what margins we were scramming 5
until they disappeared entirely.
6 MR. BUTCHER:
And I believe we have tech specs now 7
that say you have to measure that response time ---
8 MR. EBERSOLE:
But that is all.
That philosophy 9
hasn't spread, for instance, to valves or to pumps or to 10 anything else.
11 l
MR. BRYAN:
We are trying to improve the human 12 factors aspects for tech specs.
13 MR. BUTCHER:
Oh, that is one area for sure.
14 l MR. BRYAN:
You know, the layout, the ease of use, 15 I the how it is stated, all of these good things that go into i
16 making them quite usable for the operator.
So we are doing 17 the basis upgrade, we are improving the human factors and it 18 should be much better and improved over what we currently 19 have there for use.
20 MR. BUTCHER:
There are all indirect improvements 21 to safety.
Some of the format changes, I as never a 22 believer that you could change the format and come up with 23 something much better than you have.
I was absolutely 24 flabbergasted when I saw what the B&W folks proposed for a 25 format change.
I have never seen a tech spec page before O
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1 that I could open and in 10 seconds understand what the hell
.i 2
the requirements were.
.i l
3 (Laughter.)
4 They have some up with a new format which is I
i 5
really is quite an eye opener which I have become a believer j
6 since I have seen that, and hopefully we can get some of 7
that down to the ACRS to look at.
8 MR. REMICK:
Those things are really long 9
overdue.
Those documents are unbelievable to find 1
10 anything.
I think there is a potential improvement long-
)
11 term, too.
I have heard over the years, and I assume it is 12 true, that people have claimed that there were improvements 13 that they would like to make, but they were in tech specs, 14 and to change the tech specs required a license amendment i
]
15 and all that hassle and it just wasn't worth it for the 16 improvement.
17 Now maybe if these things are improved where there 18 is a little bit of greater flexibility, then maybe we will 19 see some improvements that are initiated by the operators 20 because there are people out there trying to do a 21 professional job and a logical job and so forth.
Maybe we.
22 will see some of these things that in the past the 4
23 formalities precluded them from doing, realizing that there f
24 are some weak sisters who won't, but there will be many 25 people who I think will take advantage of it.
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So I am hoping there are those secondary positive 2
benefits that will be seen over a period of time.
3 MR. BUTCHER:
I believe that is end of our 4
remarks, Dave; is that correct?
5 MR. FISCHER:
Yes.
6 MR. MICHELSON:
If there aren't any further 7
comments at this time, what I would like to propose to the 8
subcommittee is that we take a 15-minute break and then come 9
back and discuss around the table what kind of message we 10 want to take forward to the full committee, and for that 11 purpose I would like the staff to stay so that they know 12 what presentation to make to the full committee.
13 MR. DUNNING:
Would you like us to excuse 14 ourselves and then you can call us back?
15 MR. MICHELSON:
Oh, no, no.
This is all public.
16 [ Anybody who wants can stay.
It is just that we will not 17 record the deliberations since the presentations are over.
18 So if there are any words yet to be put on the 19 record, now is the time to get them because when we come 1
20 back form the break we will just have a discussion of what i
21 to take to the full committee.
22 So are there any other comments?
23 MR. REED:
I would just like to repeat I think 24 this Waterford letter of June 20th, 1986 and draw your 25 attention to it as a challenge to your tech spec activity.
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1 I am happy the utility has taken this position with respect i
2 to something so related to safety of the primary system.
3 MR. WYLIE:
You are talking about the word 4
"immediate."
1 5
MR. REED:
Yes, hiding behind the word "immediate" 6
and not recognizing it, and I am sure you guys are going to 7
watch-dog this transfer and split up of tech specs so that 8
these kind of things don't get away.
9 MR. WYLIE:
There have Deen words used in other 10 areas, and mainly I believe it is in the design criteria, 11 like time limits consistent with the safety analysis which 12 gives you the breadth ---
13 MR. BUTCHER:
I think that was the essence of my fj 14 answer to Mr. Reed's question.
It has to be called on the 2
15 basis of each particular transient scenario you are looking 16 at.
Immediacy is not 10 minutes, 5 minutes, an hour or 17 whatever.
18 MR. WYLIE:
"Immediate" I think brings up a can of 19 worms.
20 MR. EBERSOLE:
I think you have to use a time.and..
21 a succession of events.
22 MR. WYLIE:
Within the safety analysis.
23 MR. EBERSOLE:
I mean time flows and things can or 24 cannot happen, and pure time doesn't mean anything.
25 On that particular letter, I might cull out the O
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1 interesting aspect of it.
Everybody, you know, was all 2
shook up about Palo Verde not having any PORV's.
So they I
3 have got this, what I regard, as a borderline system to do t
4 pressurizing, including tiny orifices, and a very long time i
S to depressurize.
6 And here is this Waterford Station with the same 7
configuration denying that depressurization is a safety.
i 8
function whereas Palo Verde says it is and it is trying to 9
qualify apparatus to do it.
Already we have a conflict even 10 between the utilities.
11 But then if you go back in history, the PORV's 12 with the in series block valves that were with them were 13 never qualified in a safety context.
They were devices to 14 minimize the actuation of the only device on the 15 pressurizers which was the spring release safety release, i
16 and that was the only dynamic device on the pressurizer that 17 had a safety characteristic.
18 So historically depressurization via the PORV has 19 never been a qualified function.
In fact, it is improper to 20 try to attempt to use in the bleed and feed mode because the 21 environment created by the bleed and feed act will 22 presumably destroy the function of either the PORV or its 23 associated block valve.
24 So here we are in a never-never land about 25 depressurization as a safety grade maneuver to be done with
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safety grade equipment.
Are we going to improve this?
2 MR. REED:
Not under the tech spec clarification 3
activity, but that is a big argument, Jesse, and you and I 4
have got lots of things going in other locations on that 2
5 argument.
The tech spec people, that is not their job.
6 MR. BUTCHER:
To the extent that the use of the 7
PORV is taken credit for in any design basis accident j
8 mitigation sequence, it gets folded into the specs and to i
9 the extent it is not it doesn't.
10 MR. EBERSOLE:
The design basis accident is so l
11 beat to death, aIs phrase to describe the serious events.
It i
12 doesn't include an a DC power failure which is one of the I
13 most difficult, and I mean an impossible situation to get 14 -
out of.
15 F MR. BUTCHER:
We are not here to defend, and when 16 I say "we,"
this particular group is not here to defend the 17 l concept of design basis accident regulation to not defend i
18 it.
I 19 MR. EBERSOLE:
It is just there.
I 20 MR. BUTCHER:
Right, it is just there, and we are l
j 21 attempting to make the best we can with it with the 22 recognition that in the future that regulatory philosophy is 23 under the microscope right now.
24 MR. EBERSOLE:
Yes, right.
25 MR. REED:
I don't know that I made this statement f
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73920101 107 marysimons 4
1 before, but I think I will make it now.
I followed the tech 2
spec improvement program work, and I was impressed by the 1
3 cooperation between the utilities under the AIF umbrella and j
4 the NRC people and the recognition right up front of the 5
operator's burden in dealing with tech specs and his 6
immediate, and we don't want to use that word, his immediate i
7 action or position where he has got to do something.
8 The effort was supposed to take, as I recall at 9
the outset, about six months and they are supposed to have 10 finished essentially by last September.
11 l
We haven't quite made that, although in the early 12 days it looked like you were going to make it.
The early l
13 motion was very fast on the whole activity.
14 l MR. BRYAN:
I was on that group and we actually f
i 15 did finish the improvement in the six months, and by i
16 September the 30th we finished our final report.
17 MR. BUTCHER:
The goal was to finish the report in i
18 September, and it actually was, and then there was a program l
19 plan prepared to implement the report.
I don't have the i
1 20 schedule with me, but we are in fact on schedule.
We were j
21 scheduled to meet with the ACRS on July the 3rd, and in fact l
22 I guess we are two days ahead of the current schedule for
]
23 implementing the program.
24 MR. REED:
I know you did make the early part of
}
25 it, and I didn't know what the rest of the schedule was.
l([)
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MR. BUTCHER:
And we hope to stay on schedule, 2
although when we presented the program plan in the Executive l
3 Summary of the program plan to the EDO we claimed that it 4
was an impossible schedule and that we would not meet the 5
schedule but we vrould set it as a goal anyway.
But so far 4
6 we have been able to stay on top.
i 7
MR. MICHELSON:
Are there any other comments from 8
the subcommittee members for the record?
i 9
(No response.)
I 10 If not, then we are adjourned.
i 11 (Whereupon, at 3:15 p.m.,
the subcommittee 12 adjourned.)
13 b
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PROPOSED COMMISSION POLICY STATEMENT ON TECHNICAL SPECIFICATIONS i
PEESENTED TO ACRS SUBCOMMITTEE ON PLANT OPERATING PROCEDURES JULY 1, 1986 I
BY l
TECHNICAL SPECIFICATION COORDINATION BRANCH l
l DIVISION OF HUMAN FACTORS TECHNOLOGY i
0FFICE OF NUCLEAR REACTOR REGULATION i
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f TECHNICAL SPECIFICATION IMPROVEMENT PROGRAM i
l BACKGROUND
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DEVELOPMENT OF NEW STS
' Q SHORT TERM IMPROVEMENTS TO EXISTING STS j
OTHER STS IMPROVEMENT ACTIVITIES I
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PURPOSE THE PURPOSE OF TECHNICAL SPECIFICATIONS IS TO IMPOSE RIGID i;
CONDITIONS OR LIMITATIONS UPON REACTOR OPERATION NECESSARY TO OBVIATE THE POSSIBILITY OF AN ABNORMAL SITUATION OR EVENT GIVING RISE TO AN IMMEDIATE THREAT TO PUBLIC HEALTH AND SAFETY.
i i
CRITERIA O
INSTALLED INSTRUMENTATION THAT IS USED TO DETECT, AND j
INDICATE IN THE CONTROL ROOM, A SIGNIFICANT ABNORMAL i
I DEGPADATION OF THE REACTOR COOLANT PRESSURE BOUNDARY OR; t
2.
A PROCESS VARIABLE THAT IS AN INITIAL CONDITION OF A DESIGN I
BASIS ACCIDENT OR TRANSIENT ANALYSIS THAT EITHER ASSUMES j
THE FAILURE OF OR PPESENTS A CHALLENGE TO THE INTEGRITY OF A FISSION PRODUCT BARRIER OR; 1
3.
A STRUCTURE, SYSTEM, OR COMPONENT THAT IS PAPT OF THE PRIMARY SUCCESS PATH AND WHICH FUNCTIONS OR ACTIVITIES TO MITIGATE A DESIGN BASIS ACCIDENT OR TRANSIENT THAT EITHER j
ASSUMED THE FAILURE OF OR PRESENTS A CHALLENGE TO THE INTEGRITY OF A FISSION PRODUCT BARRIER.
)
l i
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,V THE BASIC PROCESS REVISED VENDOR-SPECIFIC STS NRC ENDORSES REVISED STS VIA SER LICENSEES SUBMli LICENSE AMENDMENT REQUESTS (1
IDENTIFIES LOCATION OF RELOCATED REQUIREMENT IDENTIFIES CONTROLS FOR RELOCATED REQUIREMENT IMPROVED BASES FOR REMAlfilNG TECHNICAL SPECIFICATIONS NRC REVIEWS AMENDMENT REQUESTS BASED ON THE CRITERIA AND THE REVISED STS
O SIGNIFICANT CHANGES TO THE POLICY STATEMENT SINCE DRAFT 1 USE OF RISK AN APPROPRIATE TOOL FOR PLANT SPECIFIC ADDITIONS j
FOR DEFINING FUTURE TS REQUIREMENTS STANDARD FOR THE CONDUCT OF 10 CFR 50,59 REVIEWS ADMINISTRATIVE CONTROL OVER PROCEDURES 1
ENFORCEAEILITY OF FSAR COMMITMENTS O
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CONTROL MECHANISMS 1
PROCEDURES ADP!NISTRATIVE CONTROL REQUlFEMENTS IN TECHNICAL SPECIFICATIONS (REQUIRES REVIEW AND AUDIT)
FSAR Q(d 10 CFR 50,59 PROGRAMMATIC DOCUMENT (E G.,
CA PLAN)
SEPARATE ADMINISTRATIVE CONTROLS 4
O e
THE USE OF RISK TO EVALUATE THE RISK SIGNIFICANCE OF RELOCATING REQUIREMENTS TO RETAIN THE REQUIREMENTS FOR SELECTED SYSTEMS (GENERICALLY)
AN APPROPRIATE TOOL FOR PLANT SPECIFIC ADDITIONS FOR DETERMINING FUTURE GENERIC TS REQUIREMENTS FOR MAKING SHORT-TERM TS IMPROVEMENTS O
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30% REDUCTION IN LCOs W1 2
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IMPROVEMENT IN SAFETY THROUGH THE DEVELOPMENT OF MORE OPERATOP-ORIENTED TS IMPROVED TS BASES l
REDUCED ACTION STATEMENT INDUCED PLANT j
., TRANSIENTS REDUCED TESTING AT POWER MORE EFFICIENT USE OF NRC AND INDUSTRY RESOURCES l
p 9
l
1 INTRODUCTORY STATEMENT ACRS SUBCOMMITTEE ON PLANT OPERATING PROCEDURES, JULY 1, 1986 The meeting will now come to order.
This is a meeting of the ACRS Subcommittee on Plant Operating Procedures.
I am Carlyle Michelson, Subcommittee Chairman.
The other ACRS Members present today are Jesse Ebersole, Glenn Reed, Forrest Remick, and Charles Wylie.
John Schiffgens, on my right, is the assigned ACRS Staff member for this meeting.
The gcal of the meeting is to review and discuss the " Proposed Comission Paper on Technical Specifications." This paper presents i
l alternatives for making Technical Specifications more usable to licensees and plant operators, as well as reducing both the number and detail of existing Technical Specifications. The Staff is recommending that the Commission issue for public comment the Proposed Policy Statement, attached to the Commission Paper, to clarify the scope and purpose of Tech Specs.
The policy statement will serve as a basis for i
the NRC and industry to implement voluntary Technical Specification l
improvements.
A transcript is being kept of the entire meeting and it is requested that each speaker first identify himself or herself and speak i
with sufficient clarity and volume so that he or she can be readily
)
heard.
I I
}
O i
Plant Operating Procedures 2
i l
We have received no written statements from members of the public, i
We have received no requests for time to make oral statements from members of the public.
i Do any members of the Subcommittee have questions or comments they wish to make about the proposed agenda?
Let us proceed with the meeting.
I call upon Mr. E. Butcher O
I
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