ML20205A995
| ML20205A995 | |
| Person / Time | |
|---|---|
| Issue date: | 03/25/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3069, NUDOCS 9903310120 | |
| Download: ML20205A995 (128) | |
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c , f l l l DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S-
-ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MARCH 25, 1999 i
The contents of this transcript of the proceeding ! of the United States Nuclear Regulatory Commission Advisory fI L 's
) :Committ'ee on Reactor Safeguards, taken on March 25, it as I reported herein, is a record of the ciscussions recorded at the meeting held on the above.date.
This transcript had not been reviewed, corrected L and edited'and it may contain inaccuracies. , L l i ! I I l
?
16 1 UNITED STATES OF AMERICA () 2 3 NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 *** 5 MEETING: MATERIALS AND METALLURGY. i 6 *** I l 7 O 1
- 9. USNRC, ACRS/ACNW I
10 11545 Rockville Pike, Room T-2B1 11 Rockville, Maryland ! 12 13 Thursday, March 25, 1999 14 () 15 The subcominittee met pursuant to notice, at 8:30 16 a.m. r 17 l 18 MEMBERS PRESENT: l 19 WILLIAM SHACK, Chairman, ACRS , 20 MARIO H. FONTANA, Member, ACRS I l l 21 THOMAS S.-KRESS, Member, ACRS 22' ROBERT SEALE, Member, ACRS ) 23 24 , 25 ANN RILEY & ASSOCIATES, LTD. O4 Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 j
y 247 1 PROCEEDINGS lr 2 [8:30 a.m] l!k_ l 3 DR. SHACK: The meeting will now come to order. i 4 This is the second day o' the meeting of the ACRS 5 Subcommittee on Materials and Metallurgy. 6 I am William Shack, Chairman of the Subcommittee. 7 The ACRS Members in attendance are: 8 Robert Seale, Mario Fontana, and Thomas Kress. 9 The purpose of this portion of the meeting is to ) 1 10 meet with representatives of the NRC staff to discuss NRC 11 activities related to the status of resolution of the differences between the staff and ASME regarding the use of 1 12 13 the 1994 addenda to the ASME Section III Code for Class 1, 2 l 14 and 3 piping systems; the proposed revision to 10 CFR () 15 50.55a, " Codes and Standards"; and regulatory research 16 activities associated with 10 CFR 50.61, the pressurized 17 thermal shock rule. The Subcommittee will gather 18 information, analyze relevant issues and facts, and 19 formulate proposed positions and actions as appropriate for 20 deliberation by the full Committee. 21 Noel Dudley is the Cognizant ACRS Staff Engineer 22 for this meeting. 23 The rules for participation in today's meeting l 24 have been announced as part of the notice of this meeting 25 previously published in the Federal Register on March 8,
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248 1 1999. ( '\)
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2 A transcript of the meeting is being kept and will 3 be made available as stated in the Federal' Register Notice. 4 It is requested that the speakers first identify themselves 5 and speak with sufficient clarity and volume so that they 6 can be readily heard. 7 We have received no written comments or requests 8 for time to make oral statements from members of the public. 9 Our' opening discussion will be by Ms. Lee on some 10 responses to GL-92-01, Pev. 1. l 11 MS. LEE: My name is Andrea Lee. I am going to be 12 discussing reactor pressure vessel integrity issues. 13 [ Slides.) l l 14 MS. LEE: First I will give a brief background on ' (_p) 15 Generic Letter 92-01, Supplement 1. 16 Then I will note the Owners Group activities that 17 have gone on because of this effort, and the staff's 18 decision to issue requests for additional information. 19 Then I will update you on the status of the 20 staff's review and also the update of the reactor vessel 21 integrity database. 22 I will also corament on our schedule for closeout 23 'of Generic Letter 92-01, 24 Then we will switch to a different topic, which is ; 1 25 the status of changes to the American Society of Mechanical d O\- / ANN RILEY & ASSOCIATES, LTD. Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 ) (202) 842-0034 l 1
249 1 Engineers Appendix G. 2 The original Generic Letter 92-01 was issued as a d[\ 3 result of Yankee Rowe to avoid the surprises that came out 4 of that review. 5 The original response to the generic letter and 6 also the Palisades issues, which I believe most people are 7 familiar with, provided some additional surprises. So the 8 current program that is going on now is addressing those 9 issues. 10 Supplement 1 to the generic letter was isaned in 11 May 1995 and it asked that any and all data be collected by 12 licensees so that they could assess the impact on their 13 integrity evaluations. We also requested that they submit 14 those reports in detail to the staff. () 15 The purpose was to have an integrated and complete 16 database to assess all the U.S. commercial nuclear power 17 plants. 18 Supplement 1 to the generic letter was c'osed out 19 administratively in mid-1996, but there was a clear 20 statement in it to address the ongoing Owners Group 21 activities. 22 There were several reports submitted to the staff 23 from the Owners Group. There were two from the Combustion j 24 Engineering Owners Group, one from the Babcock & Wilcox
- 25 Owners Group, which was a result of an audit of the l
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250 1 Framatome fabrication records, and that audit occurred in ()
%.s' 2 May 1997. There was also a report from the BWR Owners l
3 Group. I 4 The staff reviewed the reports and had meetings 5 with the industry in public to discuss chemistry and 6 surveillance data. Those meetings occurred in November of 7 1997 and February of 1998. 8 From our review, the staff determined that the 9 Owners Group reports had a lot of information and we felt 10 that they weren't being reviewed in a timely manner by the 11 licensees. That prompted the staff to issue RAI packages to 12 PWRs and BWRs. That occurred March through August of 1998. 13 DR. SEALE: Could I ask you why the Westinghouse 14 Owners Group was apparently bulletproof on this inquiry? I ( ) 15 noticed you didn't get any responses from the Westinghouse 16 Owners Group. 17 MR. WICHMAN: When we are talking about Owners 18 Group, we are talking about people that fabricate vessels. 19 Westinghouse never fabricated their vessels. It was either 20 CE or B&W, and in some cases foreign fabricators. 21 DR. SEALE: Thank you. 1 22 MS. LEE: In terms of the status of our review, l 23 all the BWR reviews have been completed with the exception 24 of Monticello, and that is currently being worked because 25 there is new data that was submitted in the (~') ANN RILEY & ASSOCIATES, LTD. l (/ Court Reporters l t 1025 Connecticut Avenue, NW, Suite 1014 ; l' Washington, D.C. 20036 l (202) 842-0034 w i
251 ) 1 pressure-temperature limits report. Most of the PWR reviews 2 are complete and all are in the final stages right now. 3 Prairie Island 1 & 2 and Cook 1 have indicated 1 4 they will be making submittals by summer of 1999. j 5 In terms of background of-the reactor vessel , 1
- 6. integrity database, it summarizes the properties of all RPV I
! 7 . materials beltline information for all U.S. commercial 8 nuclear power plants. ! 9 It has been switched. The original version was l 10 .the classical version. It has been transferred to Microsoft l 11 Access version. The new database diskettes will be posted 12 on the World Wide Web for downloading once the effort is 13 complete. I 14 There will also be an administrative letter issued l () 15 to announce-the availability of the new database. 16 DR. SHACK: I thought this database was going to 17 be merged with the EPRI c.atabase. 18 MS. LEE: We had at least two meetings on that in 19 the past. From the feedback we got back, the industry, for 20 various reasons, was not interested in taking over the 21 database. So it will remain a staff database. 22 DR. SHACK: How often do the people review their ! 23 . pressure-temperature limits? If their vessel embrittles, is 24 that something that is reviewed on a yearly basis? 25 MS. LEE: No , it's not yearly.
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252 1 MR. WICHMAN: It's as needed. It depends on how 2 far their P-T limits were originally projected to go out to. [%)) 3 DR. SHACK: You give them what, some sort of upper 4 shelf toughness that they work :o? 5 MR. WICHMAN: Appendir G is their guidance for 6 developing P-T limits. Staff As -- what it is, 5.2.3? 7 MS. LEE: MGEB 5.3.2 explains it. 8 MR. WICHMAN: Surveillance data comes into the 9 picture too when they pull capsules. All of these things 10 dictate the need for the revision. 11 DR. SHACK: Appendix G tells them what they are 12 supposed to do? 13 MR. WICHMAN: Appendix G forms the basis. 14 MS. LEE: In terms of schedule for closecut, r~ (T,) 15 because all the data that came out of this effort is being 16 used to update the database, the target date for completion 17 of both Generic Letter 92-01 effort and the closely related 18 effort of updating the RVID is the summer of 1999. 19 Also, NUREG-1511, Supplement 2 will be issued to , I 20 document our closecut. 21 DR. SHACK: Yesterday we heard that there was only 22 one plant that was going to have trouble with the PTS limit. 23 How many plants will have trouble with upper shelf 24 toughness? 25 MS. LEE: There are none. [~')
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i 253 ] 1 MR. WICHMAN: We are revisiting that in license fr 2- ren
- % mace .
3 DR. SHACK: But everybody is okay to 40 years? { 4 MR. WICHMAN: Everybody is okay for 40 years; 1 5 everybody was either above 50 foot-pounds or had submitted 6 an equivalent margin analysis in accordance with Appendix K 7 vt the code. 8 DR. SHACK: How many people had to submit the 9 Appendix K approach? 10 MR. WICHMAN: I think basically everybody by 11 owners groups or topical reports, as I recall, did an 12 equivalent margin analysis or bounding analysis, but a lot 13 of people were above 50 foot-pounds at the end of 40 years. 14 Again, it's an item that we revisit in license renewal O) (, 15 space. 16 MS. LEE: Moving to the last topic, the American 17 Society of Mechanical Engineers has recently worked to 18 revise ASME Appendix G. 19 The scope of the change is to use Kic, the lower 20 bound on static fracture toughness, instead of Kla, which is 21 the lower bound on static, dynamic and crack arrest, in 22 development of the P-T curves. 23 An important point to remember is that all the 24 other conservatisms remain the same in the P-T curves. For 25 example, using the 1/4T flaw or factor of 2 on pressure ANN RILEY & ASSOCIATES, LTD. s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l i
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F p 254 1 stress. l () 2 3 The change was initiated for a number of. reasons. One important reason is that there was a significant [ 4 increase in data since the curve was originally developed in l 5 1974. It improves overall plant safety in terms of opening l 6 up an operating window and reducing challenges to LTOP. l 7 The code case that describes these changes, N-626, l 8 -and the change to ASME Appendix G was approved by Section 9 XI. 10- We have no licensee submittals to date, but any 11 submittals that come in need to be an exemption because they 12 are an alternative to 10 CFR 50 Appendix G. 13 That's all I have. _ 14' DR. SEALE: There is an interesting use of words ( 15 in here. I take it that the Kic is a lower toughness level 16- than Kla. 1 1 17 MS. LEE: No. 18 MR. WICHMAN: It's higher. 19 DR. SHACK: That's why you get relief. 20 MR. WICHMAN: Yes. It's relief for the industry. 21 DR. SEALE: Okay. But it's safety in the sense 22 that you moved the point on the curve and made it legitimate j 23 to move up in your operational plan. 24 DR. KRESS: It's actually a relaxation. J 25 DR. SEALE: It's safety because of the operational I I l t .
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i I 255 1 difficulty of start-up and that sort of thing. Not [} U 2 absolutely safety in another sense. i 3 DR. SHACK: We had some discussions yesterday. We 4 do pressurized thermal shock probabilisticall,, at least a l 5 pseudo-realistic flaw distribution. l Has anybody ever 6 proposed doing this in a similar manner where you use a 7 realistic flaw distribution?
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i 8 MR. WICHMAN: No. In fact, this is strictly 9 deterministic and, if you wish, almost a flaw tolerance
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10 evaluation, because you've have got this 1/4T flaw. You are l 11 not relying on ISI, for example. That could change in the 12 future with advent of Appendix VIII and other things. I i 13 think there is more bang for the buck in this change than 14 there is in perhaps changing the 1/4T flaw to something less
) 15 that we could buy reliably. Then there has been talk of 16 reducing the factor of 2 on pressure.
17 All of these things would help, I guess. I think 18 there is a very considerable relief in going to K1c. The 19 French have been doing this for many years in the 20 development of their pressure-temperature limits using K1c. ' 21 It is really more appropriate, because heat-up is 22 essentially a static process anyway as opposed to a dynamic 23 process, Kla. 24 The concern in using Kla was the so called brittle 25 nugget and a crack running, and that type of thing. We ANN RILEY & ASSOCIATES, LTD. (O_/ Court Reporters t 1025 Connecticut Avenue, NW, Suite 1014 , Washington, D.C. 20036 (202) 842-0034
256 1- _never found any brittle nuggets. 2 DR. SEALE: It is still kind of interesting. You t 1[)Y
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3 say that there is probably more bang in making the Kic 4 change than there is in going to a different flaw 5 distribution. On.the other hand, I guess by the same token 6 you have come to the apparently fairly strong suspicion that 7 you don't have any brittle nuggets, You should be also 8 getting a much better idea of what flaw distribution is as a 9 result of some of these others. 10 MR. WICHMAN: When I said'maybe reduce that 1/4T 11 flaw, Appendix VIII would go a long way toward having more f I 12 reliable inspections, but Appendix VIII has not been ) 13 mandated by 50.55a yet, because.50.55a hasn't been updated l l 14 and out on the street. You are going to hear more about
) 15 that a little later.
16 DR. SEALE: The reason I don't shut up is if there 17 is this opportunity to make these changes, clearly there is 18 also a cost associated'with it, namely, the additional 19 inspection kinds of things. 20 MR. WICHMAN: There would not be additional l l 21 inspections. It would be people that are qualified to 22_ Appendix VIII of the code. 23 DR. SEALE: Still that would require some 24 additional resource expenditure. l 25 Has anyone done a trial assessment of what a more Ot _ ANN RILEY & ASSOCIATES, 1TD.
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257 1 realistic flaw distribution assumption would do?
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[d 2 3 MR. WICHMAN: It has been looked at. Reducing the factor of 2 on pressure has been looked at or is being 4 looked at. Also, this has been looked at for quite 5 sometime. There is a certain amount of relief involved in j l 6 this. This was a much less controversial change to make and I i 7 I think provides more relief than going to a somewhat 8 smaller flaw, but I can't quantify that. 9 DR. SEALE: With all of the interest in reducing 10 burden presumably by way of identifying and relaxing ) I 11 unnecessary conservatism -- and that's a judgment call -- l 12 we've heard the idea of harvesting the low hanging fruit, 13 namely, doing the things that are easy, the things that we 14 do have the database for both in terms of the information ' q()t 15 necessary to modify the assumptions in the calculation, and l l' 16 secondly, an understanding of what the consequences might be l 17 in terms of doing that. I 18 My only comment would be that this is probably not 19 the last time you are going to hear of somebody wanting to 20 come up with the idea of maybe harvesting some more low 21 hanging fruit. So it seems to me it might be worthwhile to 22 take a look at these different effects and get an idea of 23 where -- 24 MR. WICHMAN: It is currently being looked at by 25 Tim Greasebox's committee in Section XI. Plus I think you
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258 1 heard Mike Mayfield allude to it the other day as perhaps () 2 3 part of'the fallout of this integrated look at the PTS rule, 50.61. There will probably be some things that can 4 " improve" the-P-T limit,.give further relief on P-T limits. 5 DR. SEALE: It will change. Whether or not.it 6 improves is something we have to figure out. 7 MR. WICHMAN: I think the more we know the more we 81 can reduce some of the conservatisms involved. K1c still
'9 provides a very, very considerable margin. There is a white 10 paper on the subject.
11 DR. SEALE: I don't want to belator the point. -I 12 thought I would try to learn a little bit more here. 13 DR. SHACK: Coming back to this database question, 14 there is some difference between the EPRI database and your () 15 database. Your. database only contains the data that people 16 actually submit as part of their package and the.EPRI I 17 database contains a wider range of data. Is that the 18 difference? 19 MR. WlCHMAN: It's a wider range of data. The 20 data that we have in our database has actually been used for 21 P-T limits, PTS, et cetera, et cetera, and it's traceable. 22 I'm not sure that all the industry data may fall in that 23 category. 24 DR. SHACK: John Fair is going to update us on the 25 ASME Working Group. ANN RILEY & ASSOCIATES, LTD. O- Court Reporters
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l 1 259 ) l 1 MR. FAIR: Good morning. I'm John Fair with the )
- ( 2 Office of Nuclear Reactor Regulation. I'm going to be
-3 discussing the piping seismic design criteria in the ASME' l 4 Code.
5 [ Slides.] I 6 MR. FAIR: This is an update of a briefing that 7 you had about a year ago. So what I will try to do is go 8 briefly over the background, the discussions on the research 9 study that was conducted by the NRC, the work done by the 10 'ASME' Code, and a brief summary on where we stand right now 11 on the issues. 12 The topic is the 1994 addenda to the ASME Code. 13 There was a significant relaxation of the piping seismic 14 design' criteria in which the staff had concerns with the 15 technical adequacy of the data evaluations that supported 16 this change. Su we did not endorse the change rules at that l 17 time. 18 To go through the background of how these changes 19 occurred, dynamic testing was performed in the 1980s. In 20 1991 there was a Special Task Group assigned to look at the
'21 conservatism in the current design rules on piping. As part 22 of that Special Task Group, an evaluation of the test data
~231 that was performed in the 1980s was done.
24' NRC staff members were members of this particular 25 Task Group and we had concerns at that time with the data i
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r l l- 260 1 evaluations that were going on.
~'i 2 l [Y
?~ Although this Task Group report did not recommend 3 the changes to the Code, the work that was done there'was l 4 used as the basis for the changes that were adopted in the ! 5 1994 addenda to the Code. 6 As these rules were going through the Code, the 7 NRC members of the various committees and subcommittees 8 voted negative all the way through the main committee. 9 After the rules were finally passed, the NRC sent 10 a letter to the ASME telling them that we could not endorse 11 the rules at this time. This was in December of 1994. 12- We followed that letter up with a letter in May of ; 13 1995 which detailed the technical concerns that we had with 14 the rules. This was a very detailed letter with several () 15- attachments, which included che NRC staff technical 16 concerns, the technical concerns cf the researchers that the 17- NRC had contracted to look at the rules, and technical 18 concerns of a peer review group that was also part of the 19 research effort. 20 As a result of that, the ASME formed another 21 group, the Special Working Group on Seismic Rules, in ; 22- September of 1995 to evaluate 'che NRC's concerns as well as 23 some other concerns they had received after the rules were 24 published. 25 The staff and our contractors participated in
;, ANN RILEY & ASSOCIATES, LTD.
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c-261 1 these meetings as observers and the staff briefed this i
/ 2 subcommittee in June of 1998.
b) . 3 What I will do now is highlight the major areas of 4 technical concerns that we identified in our May 24th 5 letter. 6 Recognizing that in the letter itself there are 7J numerous amounts of specific technical concerns raised that 8 are being addressed by the Special Working Group, the four 9 main concerns that we highlighted in our letter were: ! 10 There was insufficient test data to support a 11 conclusion that piping system collapse cannot occur. 12 The relevance of this is the new seismic rules 13 were a significant relaxation in terms of stress criteria
'14 over the old rules; the stresses on their own are well above
() 15 the yield stress of the piping, and the only technical l 16 justification for the rules is that the types c failures of l 17 piping systems during earthquakes are fatigue type failures 18 and not collapse type failures. Looking at the test data, 19' we believe there was evidence of collapse type failures 20 occurring in the test data and that the data itself did not 21 support the conclusion that there is no piping system 22 collapse possible. ' 23 We also had concerns with the evaluation of the 24 test data. The data evaluations involved extrapolating the 25 data to cases that weren't tested. We had identified some T 10R7 RILEY & ASSOCIATES, LTD. s_sl Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
-(202) 842-0034
E 262 1 errors in the data extrapolations and some technical ';%E) 2 concerns with some of the data extrapolations. 3 There was also a concern that the test data was 1 4 used to establish the criteria, and a margin was developed ' 5 to evaluate against the test data. We had a concern that 6 there was no real technical basis presented for this margin 7 value. As the data:was being evaluated, at first there was ! 8 a higher margin selected as the target value. %nen the data 9 evaluations were showing lower margins than originally 10 expected in the piping systems in the component tests based i 11 on some of the extrapolations, chey selected a lower margin 12 of safety for evaluating the test data again. There really l 13 wasn't a technical basis for that margin of safety that was 14 selected.
~
() 15 DR. KRESS: Is there ever a technical basis for
- 16. that? From what I've seen, it's always a judgment call:
17 what margin are you comfortable with? j .18 MR. FAIR: Let's say the normal code design 19 practice. There are fairly well established criteria such 20 as material yields, and you maintain a margin against yield i i 21 or something like that, j 22' DR. KRESS: The level at which you maintain it is 23' a judgment call.
- l. 24 MR. FAIR: That's correct, but the value itself is !
L l l 25 fairly well established. What we had here was a handful of I l (~' ANN RILEY & ASSOCIATES, LTD. Court Reporters b 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 u
f l i 263 1 test data in which the test data had a considerable amount (}
\_/
2 of data scatter. The margin was compared to the minimum 3 value of the test data. The ques
- ion was, did they do an 4 adequate evaluation of the potential data scatter to l 5 establish this margin? ;
6 DR. KRESS: Okay. 7 MR. FAIR: Also a general area of concern was the 1 8 fact that all the testing that was evaluated in terms of a I 9 margin were component tests. As you saw last time, these j l 10 were cantilever tests and there was a general presumption i 11 that these were conservative compared to system tests, but 12 there was nothing done to establish a technical basis for ! 13 that assertion. 14 The reason we had a concern is that when you go (Qj 15 from a component test like this to a system test, there are 16 other loads in an actual piping system such as thermal type i 17 loads that could impact the overall margin. 18 I will go quickly over this. I think you had a 19 fairly detailed discussion last time on the research program 20 that was established with ETEC in 1993. 21 It included an independent evaluation of the test 22 data. That was discucaed in the previous group. l 23 Independent analytical studies of test margin 1 24 extrapolations were performed. These were done by the Cal 25 Tech researchers. l ("} ( ,/ ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034 , l
264 1 The program a?so included a peer review group of I ()
%j 2 experts looking over the evaluations.
3 The program was completed and the results 4 published in NUREG-5361. 5 The review concluded that the technical basis for 6 the rule changes in the 1994 addenda was not complete. 7 Following the publication of the NUREG, ETEC 8 continued to provide some technical support to the Special 9 Working Group that had been formed to look at these 10 concerns. 11 As I said before, after the NRC identified its 12 concerns and other people had identified concerns with the 13 1994 rule change, the ASME set up another working group to 14 take a look at the technical concerns, rx l is ,) 15 The Special Working Group has basically relied on l 1 16 the data evaluations performed by ETEC, because it takes a 17 lot of effort to do the data evaluations when these is test 18 data, and the members simply don't have the resources or 19 time to do the detailed evaluations. 20 The group did vote to adopt the margin definition 21 proposed by Dr. Kennedy, which I believe he presented at the 22 last meeting. This was the 1 percent failure probability 23 margin capacity of 2. This was based on his risk evaluation 24 to keep piping from becoming a predominant risk factor in 25 the seismic PRAs. l l (~'} ANN RILEY & ASSOCIATES, LTD.
's / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
265 1 They also voted to investigate a proposal by s t'
%-)
1 2 Dr. Kennedy to include a minimum value for the Code bending 3 stress index. If you will recall from the last 4 presentation, when he did a data evaluation of the EPRI test 5 ' data, it turned out that the margins for weld joints were 6 much lower than they were for elbows. He made a proposal 7 that they raise the stress index on the weld joints in order 8 to get them consistent with the elbow test data. That is 9 still going on. They are still reviewing that proposal. 10 They are also reviewing some fairly recent data 11 provided by the Japanese with some additional testing and 12 data evaluations.
'13 DR. KRESS: This is the shake table? {
14 MR. FAIR: Shake tests. Similar type of tests to l f' (h) s_. 15 what EPRI did. l l 16 There is also a brand new proposal that was 17 forwarded by Dr. Matzen of NC State University which j i 18 involved a finite element evaluation of some elbows. The 19 preliminary indications are maybe there are some 20 conservatisms in those elbow stress indices. Therefore, l l 21 instead of raising the other indices to get the data 22 consistent with the elbow indices, they may reduce the elbow 23 indices to get the data consistent with the other and keep 24 the stress allowance the same as they were previously. 25 DR. KRESS: Do you know what code he used? [~ ANN RILEY & ASSOCIATES, LTD. j \ms Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
266 1 MR. FAIR: I believe he used ANSIS in his () 2
'3 evaluation.
lDR . KRESS: That's not a dynamic code, is it? 4 It's a static code. 5 MR. FAIR: What is being done is static analysis.
-6 This is strictly look'ing at static collapse of the elbows.
7 DR' KRESS:
. He's not trying to do the dynamics.
8 MR. FAIR: No. 9- As I said, there was some recent data testing and
- 00 evaluations done by the Japanese. One of the areas they did 11 'was some specimen tests for fatigue ratchet. The fatigue 12 ratchet data show a significant reduction in fatigue life 13 .due to ratcheting at very low cycle regime. i 14 The significance of this is in evaluating the' test l f l (;3,/ 15 data, in order to extrapolate the data to other conditions l
l 16 not tested, you have to have some kind of a correlation for 17 fatigue failures. Some of the previous correlations used 18 the shape of the fatigue curves to do this correlation. If 19 the fatigue failures are significantly different than what 20 you-would get with the shape of the fatigue curves, you 21 could be off on the data extrapolations. 22 When ETEC was doing their program for the data j 23 extrapolations that were presented last time, they did two l
.24 types of analyses. They did an analysis of fatigue failures {
25 using the shape of the fatigue curves for the damage O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite'1014 Washington, D.C. 20036 (202) 842-0034
E 267 1 calculations. (,~ 2 The other evaluation was to do a maximum
%s) 3 displacement type evaluation. The intent of this was to try 4 to bound the possible effects of the ratcheting. We still 5 believe that those are reasonable bounds, the displacement 6 studies that were presented last time.
7 To summarize the status of these issues, I believe 8 that the Special Working Group members do concede that 9 collapse is a potential failure mechanism and that the rules 10 have to cover this potential failure mechanism. 11 ETEC has done the rigorous technical evaluation of 12 the existing test data. The ETEC evaluation has addressed 13 the staff concerns with the deficiencies in the previous 14 data evaluations, (q f 15 Dr. Kennedy provided a risk-based approach to 16 establish the minimum required margin. We think that covers 17 the concern we had with at least having a foundation for the l \ l 18 basis for the margin. l l 19 He also had proposed some system redundancy and l 20 nonlinear factors to go along with that which we haven't yet 21 endorsed. These redundancy and nonlinear factors 22 essentially reduce the margin required out of the component 23 tests. They have a presumption in them that the system will 24 be more conservative than the components. 25 Those data evaluations are still ongoing. These
/
O ANN RILEY & ASSOCIATES, LTD. h Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
268 1 were judgment values by Dr. Kennedy. There has been no
/T 2 resolution of what these values could be or might be.
V ' 3 There is also a concern in his proposal on the 4 elbow data, that they excluded one of the tests, which is 5 Test Number 37. That happened to be a thin walled stainless 6 steel elbow with a heavy mass on it and very low frequency 7 system which was tested near to point of collapse, and the 8 test was stopped before it actually collapsed. 9 This is an outlier in terms of margin; it has a 10 very low margin, much lower than most of the other elbow 11 test data. There still has not been any adequate i 12 explanation of why this particular test was low compared to 1 1 13 all the other tests. So this is still an issue that is to I i 14 be resolved. j p i ( s_- 15 DR. KRESS: It looks like the concerns expressed 16 by NRC were pretty well out of it. I 17 MR. FAIR: It depends on who you talk to. We 18 think they were, but some of the industry thinks that the l 19 evaluations going on are still validating their original l l 20 judgments. 21 The evaluation of margins is ongoing for piping l 22 systems right now. 23 DR. KRESS: Yes. I must admit I was trying to 24 refresh my memory on the 1 percent probability of the 25 capacity. I don't recall exactly where that came from. O k,,/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
'l 269 1
1 MR. FAIR: He started off with the margins that i ( ) '2 are supposed to be in the seismic PRAs. He selected a value 3- .such that you didn't want piping to become a predominant 4 risk factor in the seismic PRA studies that had been 5 performed previously. He back-derived a value of capacity 6 factor.from that. 7 DR. KRESS: Using the probability of a LOCA or 8 initiating event? 9 MR. FAIR: He started off with a fixed margin 10 number that came out of the studies and then, using that 11 number, he back-derived a capacity factor that you need in 12 piping so that you wouldn't exceed that. As far as the 13 details of his evaluation, I don't think I.will attempt 14 that. 15 I was going through the original four concerns 16 that we had raised. The last one was the margin on the 17 actual systems. That.is still being discussed in the 18 Special Working Group. Issues such as loads due to seismic 19 anchor motion and concurrent thermal loads have not been 20 resolved as of yet. 21 There was one other thing that was beyond the four 22 issues that I put on my previous slide. ETEC in their final 23 report identified a concern with a lack of high temperature 1 j 24 test data for carbon steel, that there may be a problem that 25 all the testing has been done at room temperature. The ANN RILEY & ASSOCIATES, LTD. x Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
g l 270 1 presumption is the margins would be the same at temperature 9() 2 as at room temperature, and there is a concern that maybe 3 for carbon steel this may not be the case. This issue has 4 not yet been resolved either, 5 DR. SHACK: So it's basically still work in 6 progress. 7 MR. FAIR: Still work in progress. I think there 8 are still a lot of tough issues to be resolved before this 9 is done and finished. 10 DR. SEACK: Since nobody is designing a reactor, 11 what impact would this have on operating reactors? Would 12 they go in and start changing supports? 13 MR. FAIR: I believe they would probably try to 14 use it to resolve issues. At all plants you are constantly '() 15 coming up with problems or identifying new problems on the 16 piping systems where somebody finds a missing support or 17 something has not been put in the right place. They l 18 probably would want to use it as evaluation criteria. They i 19 may want to use it to further remove snubbers off existing l 20 piping systems. 21 I guess the other was with the advanced reactors 22 there was a request at one time to use this new criteria, 23 which was not accepted at that time by the staff. 24 MR. DUDLEY: I have a process question. Do you j 25 have a feel for when the working group will be in a position ANN RILEY & ASSOCIATES, LTD. A Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 g L
271 1 to make a recommendation,to the review committee? A 2
) follow-up question to that would be, at what point should 3 the ACRS take another look at this?
4 MR. FAIR: I hesitate to even make a guess. I 5 think their original intent was to have that done by now, 6 but'the technical issues are very tough. I'm not even going 7 to hazard a guess on that. I don't think they are close to 8 final resolution, but I think some of the hierarchy in the 9 ASME think they are close. I will just leave it at that. 10 DR. SEALE: The working group is a creature of the 11 ASME, as I understand it. 12 MR. FAIR: That is true. 13 DR. SEALE: They are the people that have their 14 hand on the throttle. I guess there are kind of competing ! O l ( ,) 15 pressures. Certainly there is a strong pressure to get it 16 right. There is also a strong pressure to not say " oops!" l j 17 MR. FAIR: Exactly. 18 DR. SEALE: There is a reason for unwillingness to 19 go either way on this. 20 DR. SHACK: Is the Japanese program ongoing? You 21 can only look at the original data so long and so often. I 22 MR. FAIR: Yes, it is. They are still in the 23 process of doing data evaluations. They have the data. I 24 don't think they have released it formally to anybody. 25 DR. SHACK: Not even the working group, then. O ANN RILEY & ASSOCIATES, LTD.
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272 1 MR. FAIR: They have presented it at the working g.s ,(v) 2 group, but I don't think they have actually given the data 3- to anybody. 4 DR. SEALE: Are the elements of their test 1 5 programs such that they do focus on these issues? l l 6 MR. FAIR: I think their focus is not necessarily l 7 on those issues.
}
8 DR. SEALE: Obviously they have other things they 9 want to test. 10 MR. FAIR: l An example is the way they did their j 11 component testing was to support the components vertically l 12 from deadweight. So they didn't have this deadweight force ! l 13 that could drive something into collapse. When they did 14 their testing, they were all neutral loads; seismic tests
. (,
p) 15 were all about a zero mean, so they concluded that there was l l 16 no collapse in their tests. The way they set the tests up, 17 we would have predicted there would be no collapse. 18 DR. SEALE: Is their test program broader than 19 just nuclear? Are they looking at concerns in the 20 petrochemical industry and things like that as well? 21 MR. FAIR: I really can't answer that. I'm only 22 familiar with the data they are bringing into the Special 23 Working Group. 24 DR. SHACK: In the collapse load argument you just 25 made, was that the Japanese, or was that the way the ANN RILEY & ASSOCIATES, LTD. f'/) A- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 1 273 1 original tests were done for the EPRI tests so there was no 2 collapse in those tests?
.(
3 MR. FAIR: No. The Japanese tests were t 4 horizontally excited with a support in the vertical 1 5 direction so that you didn't have any existing deadweight on l 6 the system. In the EPRI tests.they were vertical 7 cantilevers with horizontal excitation with no additional z 8 deadweight support. So some of them had fairly significant I j 9 deadweight stresses, such as Test 37. That is the one that I 10 went closest to collapse. As a matter of fact, it would i 11 have collapsed had they not stopped the run _ amaturely. 12 DR. SHACK: So the Japanese tests won't really , i 13 give you any extra insight on that because of the way they 14 have set them up. ' l 60 15 ! ( ) MR. FAIR: Not on that particular issue. 16 Dr. Kennedy did do a statistical evaluation of 17 what he calls ultimate moments capacities. His evaluation 18 came up very similar to the EPRI tests in terms of maximum 19 dynamic moments. 20 DR. SHACK: So there is a consistency there at 21 least. 22 MR. FAIR: Consistency in the data, yes. 23 DR. SHACK: Any additional questions? 24 [No response.] 25 DR. SHACK: Thank you, John. ANN RILEY & ASSOCIATES, LTD. ! k Court. Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
274 1 Next we have Tom Scarbrough.
.{ ) 2 .MR. SCARBROUGH: Good morning. My name is Tom 3 fScarbrough. I've talked to you all several time before on 4 motor operated valve issues and today I get to talk to you
-5 ~ about.a new rule.that we are working on, in-service testing 6 and in-service inspection.
7 [ Slides.] 8 MR. SCARBROUGH: What we are going to talk a 9 little. bit about today is the supplement that we have 10 prepared to the proposed amendment tx) 50.55a that was issued 11 in December of 1997. There have been some additional 12 discussions and a decision to go out with a supplement for 13 public' comment. 14 First of all, 50.55a requires owners to construct, () l15 inspect and test their components in accordance with the 16 ASME Boiler and Pressure Vessel Code with certain conditions 17 and limitations. 18 It also requires licensees to update their ISI and 19 IST programs every ten years. That is the subject of the 20 discussion that we are going to have some more of. 21 DR. KRESS: Does it specify the components? l 22 MR. SCARBROUGH: Yes. It gets down to Class 1, 2 23 and 3. It does it by that classification, l
~
24 In December of 1997 the NRC published a proposed l l 25 . amendment to 50.55a to update it to more recent editions. I ANN RILEY & ' ASS"!ATES, LTD. A) Court Reparters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 L (202) 842-0034 u.
275 1 will talk a little more about which editions in just a f') 2 minute. But basically bring it more up to date to the V 3 current editions of the Boiler and Pressure Vessel Code, and 4 also the newer ASME Code for operation and maintenance, 5 including nuclear power plants, of what they call the O&M 6 code, but still retain the update requirement. 7 DR. SEALE: What is the difference between bullet 8 2 and bullet 3? 9 MR. SCARBRCUGH: Bullet 2 is what is in the rule 10 right now. That is 50.55a right now, that they have to 11 update every ten years. In December of 1997 there was a 12 proposed amendment to 50.55a to bring up the 1989 code, 13 which was endorsed and what is on the books now, to the 1995 14 code. That is what was proposed in 1997 in that proposed () 15 amendment. Everything else would basical]/ stay the same, 16 but there were a lot of things of that nature. BrGically 17 bring it up to date from 1989 to 1995. 18 As part of that discussion that went along with 19 the issuance of that proposed rule was DSI 13. That had to 20 do with how we interact with the industry in terms of codes 21 and using codes and things of that nature. 22 There was a stakeholders meeting in Chicago, and a 1 23 lot of the discussion involved how we endorse codes and how I 24 we update codes. One of the items that came up in the 25 discussion was, do we really need to continue to update IST . i l l [T ANN RILEY & ASSOCIATES, LTD. \s/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 276 1 and ISI programs every ten years to the latest code, or are. i b) 2 they good enough? Can we just' continue with what we have? 3 Based on that discussion and the interaction that ; 4 took place regarding that issue, we decided to supplement i 5 that 1997 proposed amendment in just the one limited area of I 6 should we eliminate the 10-year update. 7 We prepared SECY-99-017, which explained this and 8 all the pros and cons in terms of eliminating the 10-year 9 update, and presented it to the Commission. We are waiting 10 fcr the Staff Requirements Met.'o to be returned. We have 11 seen the draft, and it says go forward, look at these 12 issues, come back to us, deal with the burdens and the 13 benefits more fully in the final rule. We plan to do that. 14 We are on hold right now waiting for the specific language (O
,/ 15 of the SRM to tell us where we go from here.
16 In terms of the current 50.55a, it_has been on the 17 books'for quite a long time. As you can see, it is still
-18 for Class 1, 2 and 3 components. It requires construction 19 to the 1989 edition of Section III. Parenthetically we say 20- that the proposed rule would update it to the 1996 addenda, 21 but there is no update requirement associated with Section 22 III. So that really is not affected by the supplement we 23 are talking about.
24- In terms of inspection, the current regulations, I 25 it endorses the 1989 edition of Section XI for ISI, and for ANN RILEY & ASSOCIATES, LTD. Os Court Reporters ) 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l-l
p 277
- 1 metal containment and concrete containment it endorses the
!fx l A- / A 2 1992 edition of Section XI for ISI. { 3 For in-serve testing for Class 1, 2 and 3 pumps
]
i 4 and valves, it references the 1989 edition. Then it cross i 1 5 references. Because the OM code'was just sort of in its 6 infancy when that occurred, a cross reference to any 7 references to OM documents in Section XI really means the 8 1988 addenda to the OM standard. ; I 9 That is what is on the books right now; that is ' 10 what is out there right now that is currently required. 11 I want to give you a little background of what was 12 in the rule that was published in 1997 from an ISI and IST 13 point of view. There are some other Section III areas that 14 are also in that 1997 proposed rule, but I won't get into A) ( 15 those because they are not affected by the supplement. 16 Basically, what the proposed rule in 1997 did was 17 incorporate by reference the 1995 edition with the 1996 l 18 addenda of Section XI for ISI requirements for Class L 2 19 and 3 components. 20 It also had a requirement that PWRs perform 21 volumetric examinations on their high pressure safety 22 injection systems for weld examinations. 23 It also expedited the implementation of Appendix 24 VIII of the 1996 addenda of the code, which has to do with 25 qualification for performing ultrasonic examinations.
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F l 278 1 Also, for IST, in-service testing, it incorporated IT 2 by reference the 1995 edition with the 1996 addenda of the Q 3 OM codes. Now we are fu ching over from the Boiler and 4 Pressure Vessel Code for IST into the OM, because the OM 5 code is taking over that area. 6 We also added a requirement that licensees 7 supplement their stroke-time testing for motor-operated 8 valves with the design-basis programs, because we found that 9 stroke-time testing wasn't really adequate for 10 motor-operated valves. 11 Also, it permitted implementation of several 12 specific code cases. There is a new code case called OM 1, 13 which has to do with improving the performance of 14 diagnostics on motor-operated valves in lieu of stroke-time A (_,) 15 testing, and also various portions of OM code editions that 16 were permitted to be implemented. 17 Those are basically the areas of ISI and IST that 18 were in the December 1997 proposed rule. 19 We are working on the actual Federal Register 20 language of the supplement now, and that is going through 21 the chain as we await the final SRM language. 22 In terms of the supplement, right now what we 23 would propose is that we would eliminate the requirement for 24 licensees to update their ISI and IST program every ten 25 years. I I [~*
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l. !: 279 L 1 We would establish a baseline. This is an area f j ) 2 .that we would specifically deal with as part of public L 3 comment. What is the right baseline? That is a question we 4 want to finalize, but right now the current thought is the 5 1989 edition for IST as well as ISI. However, for the
-6 containment structure components, cal containment and l
7 concrete containment, we would still continue with the 1992 I l 8 edition, which is in the rules right now. l 9 Also we would apply Appendix VIII qualification 10 standards for ultrasonic examination. That also would be ) I 11 part of the baseline.
]
l 12 This is sort of the baseline that we are proposing j i 13 Eas we go out for public comment; we are specifically going 14 to ask:for comment in this area.
) 15 We are going to allow voluntary implementation of 16 later editions. The current'thcught process is we continue 17 to review more recent editions of the code, endorse them in 18 the regulations, and licensees could voluntarily pick them 19 up. That would then be their code of record and they would 20 be' responsible for following it just as if they were doing 21 the 1989. code. That would be an option that they could do.
22 In the future, our thoughts would be that 23 licensees would sort of follow the same process they are 24 doing now. A new licensee coming on would pick up the code 25 that was referenced one year prior; they would sort of get a l ANN RILEY & ASSOCIATES, LTD. O-s- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 i
l-280 l-1 one-year grace period, and they would pick that up. .
'2 That would make sure that the construction matched
- i. 3 the operation. 'You wouldn't have something going way back 4 in time to 1989 when you would have the plant constructed in 5 2010 or something. That would make sure they match, but 6 they would not be required to periodically update; once they 7 were' assigned that.particular edition of the code, they 8 could continue that for their life.
9 DR. SEALE: What about a revision to an existing 10 plant that would require an operating license amendment, a 11 tech spec amendment, or something like that? Would that be l j i 12 governed by the version of the plant originally, or would it l 13 require the latest version with the one-year? ' 14 MR. SCARBROUGH: Under Section III, I think they 3 are allowed to use the more recent editions for
~
15 16 construction, but they are only mandated to what was under 17- construction. They could use the later ones, but they 18 wouldn't be required to use them. The baseline would be 19 established, and the baseline would be the requirement. ; 20 Dk. SEALE: I'm talking about some fairly 21 significant modification. 22 MR. SCARBROUGH: That is something we probably 23 need to deal with. If there is a major license amendment, 24 does it_ reopen the issue of would they be considered a s future licensee? I guess that would have to be dealt with. ANN RILEY & ASSOCIATES, LTD.
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i 281 1 That's a good question. My first thought would be they 2 wouldn't have to, but if it was something very significant, 3 would it be appropriate to pull them up to something more 4 recent? 5 DR. SEALE: What about license renewal? 6 MR. SCARBROUGH: They would keep going with this. 1 7' Larry. ! 8- MR. CAMPBELL: My name is Larry Campbell. I'm in 9 the Quality Assurance Vendor Inspection, Maintenance and 10 Allegation Branch, or whatever it is called now. 11 Under Section XI licensees can replace steam 12 generators and do major modifications to their piping 13 systems as well. Section XI currently permits them to use 14 the original construction codes or later editions of the
, 15 construction codes provided that later edition is endorsed 16 by the NRC via 50.55a. So licensees do major mods like 17 replacing generators and major modifications currently under 18 the provisions of 50.55a.
19 MR. SCARBROUGH: So typically they would not be 20 _ expected'to update. 21 'That is what we are drafting in terms of our 22 proposed supplement. 23 DR. SHACK: Eliminating the requirement to update, 24 that is just a judgment that it's too burdensome?
~25 MR. SCARBROUGH: Yes. That is what is driving ANN RILEY & ASSOCIATES, LTD.
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1 282 1 this. After all the years of experience and the changes () t i 2' that we are seeing in the code more recently, are those ! 3 changes significant? If you look way back at 50.55a and the
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4 same considerations, there were discussions of a maturing { 5 code. There were things like that talking about having you 6 update every ten years to pick up more recent improvements 7 in the code. Over the past few years.we haven't seen a lot 8 of significant changes in the code. There are some changes 9 and some improvements. 10 DR. SHACK: The requirement for a performance 11 demonstration, it seems to me, . is a major change. The 12 requirement-for a performance demonstration of the ISI. You 13 are just sort of assuming that after that there won't be any 14 more? () 15 MR. WICHMAN: We are talking about voluntary 16 updates in terms of Section XI. That would be mandatory. 17 MR. SCARBROUGH: That is part of the baseline. 18 MR. WICHMAN: That is the baseline. l t 19 DR. SHACK: My problem is with the argument you 20 have seen this major change in the'ISI requirements between l 21 1989 and 1995, and now you are saying it's mature and you 22 are not going to have to worry about it anymore. 23 MR. SCARBROUGH: I think it is set forth in the 24 SECY paper. 25 Geary Mizuno from OGC, l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p 283 l l 1 MR. MIZUNO: Geary Mizuno, Office of General
- l' 2 Counsel.
l % 3- The staff's paper indicated that there would be 4 sort of two paths for future endorsements. One would be 5 where the NRC staff found that the code was acceptable for 6 use but did not have any specific requirement that was 7 necessary to assure adequate protection. In that case they 8 would simply endorse it for voluntary use. However, if 9 there vere provisions that the NRC staff determined were 10 necessary for adequate protection, those would be mandated; 11 they would not be voluntary; we would take action to mandate l 12 it. 13 I would imagine that if you had something similar 14 to PDI occur five years from now, that would be a provision l () 15 that would be mandated by the NRC staff in a future rule. 16 DR. SHACK: But it would take a future rule rather 17 than the requirements you have now to de the update on a 18 scheduling basis. 19 MR. MIZUNO: That's correct. Five years from now, 20 .were there to be a provision similar to PDI that the NRC 21 staff determined to be necessary for adequate protection, 22 the NRC would have to go through a rulemaking. It would 23 have to address the backfit rule, demonstrate it was 24 necessary for adequate protection, provide public comment, 25 and go through the entire rulemaking process to get l { l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 l
284 1 incorporation by reference of this new provision, and the () 2 3 rule would mandate as opposed to open for voluntary use of this specific provision. 4 MR. TERAO: Dr. Shank, this is David Terao. Geary
'5 is right, but I think what is being misunderstood is the
~
6 fact that we will still periodically update 50.55a. I think 7 that is what Geary Mizuno was referring to. It will take a 8 rulemaking to backfit provisions later on that the staff 9 feels are necessary for safety, but we would do it under'our j 10 routine 50.55a updates. 11 When we endorse later codes editions and addenda, 12 we will review those codes and editions and addenda, and if 13 we feel that there is a significant enhancement in that code 14 for a particular safety issue, we would then put into the s () 15 50.55a update under the backfit consideration a requirement 16 that utilities would have to update to that. 17 DR. SdACK: Every one of these would then be 18 subject to a backfit analysis. 19 MR. TERAO: Correct. 4
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20 MR. SCARBROUGH: That is'one reason why we think i 21 ' establishing the baseline is very important, because after 22 this,.everything is going to be under the backfit 109 rules. 23 DR. SEALE: That's a heck of a batting average. I 24 MR. SCARBROUGH: We are preparing the Federal 25- Register. Notice with the this new language, and we (~h ANN RILEY & ASSOCIATES, LTD. ( )-- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
y i 285 , .. 1 specifically ask for comment in these areas, what I call. l /m
'2 issues.
3 Potential effect'on safety, including reductions 4 -in effectiveness of the ASME code. 5 Selection of the proper baseline. 6 .The regulatory benefits :tnd burdens noe only to 7- licensees, but also vendors, insurers, states, and the 8 .' standards organizations. 'So there-is quite a bit there. l 9 The burden on licensees actually to update. We 10 get various estimates of how significant the burden is in
'11. terms of monetary and time and resources. So we would like !
12 to real'_y focus that and find out how significant is this k 13 burden in the overall scheme of burden that is applied to 14 them. () 15 The potential effect on the number and detail of 16 licensee submittals. Are we going to get a lot more relief 17 ' requests? Are we going to get less? Is it going to be 18- about the same that we.get now, or is that going to change 19 significantly? 20 The changes to the range'of the code editions that 21- are applied. If the inspectors are going to have this whole
'22' hodgepodge of parts and pieces of more recent editions of 23 the code than 1989 that they have to deal with, it is going L .24 to be much more confusing.to them.
25 The potential effect on licensing actions. Does O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 10?.4 Washington, D.C. 20036 (202) '842-0034 l
e 4 286 1 this open the door for more-license amendment type of issues I L [~') 2' to come up? 'Does it affect the regulatory guides in terms LV i 3 of how we endorse various codes and code cases? Or will it l 4 affect the risk-informed programs? If there is not the ! 5 cen-year update, is that going to undermine some of the 6 risk-informed initiatives that are out there? ! 7. Then we come oack to the . st ates again. What is 8 the potential effect on-the states'and other organizations 9 that rely on the code? Is there going to be a mismatch
. 10 between the NRC and what the states require.
11 Application of portions of the code. It's called 12 cherry picking. Are people going to pick and choose the l 13 pertions of the code that they want? We have some language 14 in there to try to minimize-that, to focus people on using () 15 the entire code as endorsed by the regulations as opposed to 16 ' coming in with individual requests for pieces of the code.
]
17 So those are some of the areas. We recognize that 18 all these areas have to be dealt with and resolved before we 19 go final. 20 Next we have this ambitious schedule. It is 21- already out of date. This is the schedule we put in the
- 22. .SECY paper.
23: We had hoped to have the supplement published for
- 24 public comment by April-5. Therefore it should have already 25- been down at.the Federal Register at least a week ago, and ANN RILEY &' ASSOCIATES, LTD. \ -Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
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p 287 1 L. it-is still sitting on my desk. We have to finish with the { 2 SRM, get that issue _ resolved,-finalize the concurrences from l 3 the Office Director and get the EDO to sign.it. So we still
.4 have some more work to do.
5 We have-scheduled a public workshop on May 27. It 6 is going to be in Two White Flint Auditorium. We have. 7 invited NEI and ASME. They have indicated they are going to 8 participate to talk about all these issues that we have. 9 raised in terms of pros and cons and the benefits and the 10 burdens. We hope that will be a very informative workshop. 11 Our goal originally was to try to finish up, by 12 late summer, complete consideration of all these comments l 13 and put it all together, and in September have the offices 14 concur and present the final draft in October to ACRS and () 15 CRGR, and then November submit the final rule for Commission 16 approval, and then publish by the end-of the year. 17 We don't think we are going to make the end of the 18 year now, but our goal is on the fast track and to get it 19 done at.least by early next year. We will have to see how 20 the schedule goes in terms of public comment and resolving 21 those. 22 That is_where_we are. I will be happy to answer 23 any other questions. I appreciate the guys coming over and 24 helping me out here. l 25 DR. SHACK: I guess my initial reaction is all the l i ( ANN RILEY & ASSOCIATES, LTD. (~'i s,s/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L I
L 288 1 effects seem to be negative except for reducing the burden 2 on the update. The ASME code is a consensus document. ( 3 Changes to the program don't.get made unless it is sort of a 4 consensus of the community that there is a purpose in 5 changing them anyway. To update this-every ten years 6 doesn't seem to me a horrendous burden. The utilities will 7 have already made their input to the consensus process. 8 MR. SCARBROUGH: There is a lot of discussion on 9 how significant the burden is. There are various views on
.10 that, and that is something we want to focus on. Other 11' people have said that they think it's a significant burden, 12 and other people have said, just like you have said, that it
-13 is not a significant burden. We really need to nail that 14 down,. because we are getting conflicting points of view. To
() 15 really finalize this, we really have to know what the 16 program is. In terms of the feedback we are getting from 17 the Commission, they really want to know what are the 18- benefits and the burdens associated with this proposal. 19 DR. SHACK: Is-there some other benefit that I am 20 missing?
. 21: MR. SCARBROUGH: I think burden probably is the 22 main benefit. They do'this now; they update; they come up 2:3 to the latest code;-all the consensus documents are put 24 .together. I think the primary benefit is a burden 25 reduction.
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F 289 1 DR. SHACK: Is this something that the industry
'2 has been pushing, or did we volunteer to do this?
(%)h 3 MR. SCARBROUGH: We heard from NEI that this was
~
4 something'that they were interested in. They thought this 5 was very important to them. l 6 We were ready to go out with the 1997 rule. It
-7 was finished. The comments had been resolved and it was 8 ready to be final. There was some input from the industry 9 that this issue on the updating was very important and 10 needed to be resolved as quickly as possible. So we held up 11 issuing that to deal with this issue, and they felt it was 12 important enough to hold up the full rule package to deal 13 with the supplement issue.
14 DR. SHACK: It seems to me you will have a () 15 -significant burden on NRC, because I would assume that as a 16 matter of fact many of the utilities would voluntarily , 17 implement. I would expect to see a tremendous patchwork of
- 18 programs resulting.
l- 1 19 MR. SCARBROUGH: Yes, and that is something we are 20 concerned about in terms of a lot of cherry picking where 21 you take the best parts and leave off the comprehensive pump i' 22 test. Or you leave off parts that are more difficult to i 23 perform but give you a lot more information from a 24 confidence point of view. They might try to just pick and 25 choose. ANN RILEY & ASSOCIATES, LTD. O, ' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
290 i 1 We tried to put some language in the proposed rule (~D 2 to try to indicate that that is not the preferred approach; w.] l 3 that is going to be a much more difficult path to follow. 4 If they pick up the complete later endorsed editions of the 5 code as endorsed with the limits and conditions, then that 6 would be without prior approval. They could do that without 7 coming in, but if they only pick and choose, then they would 8 have to come in through a relief request process, and that 9 is much more burdensome for them as well. We are going to 10 try to discourage that as much as we can, but we know there 11 is going to be a tendency to do that. I l 12 Does anybody else have any comments? 13 DR. SEALE: I can understand your concern. 14 DR. SHACK: If we are going to do inspections, it
<~
( )x 15 seems to me one would like to do effective inspections. 16 Otherwise you are wasting people's money, time and exposure. 17 MR. COZINS: This is Gary Cozins from NEI. NEI 18 has been mentioned several times in this discussion. It 19 might be worthwhile putting some perspective on it. 20 Part of the logic of the thought on approaching 21 this is our plants are safe today. Every time we go through i 22 a 10-year update it is an expensive process. I've been told j 23 by many licensees it's on the order of about $1 million per ! 24 plant for update. I don't know if anybody else has numbers l 25 that would confirm or deny that, but that is my l(} ANN RILEY & ASSOCIATES, LTD. ! 's / Court Reporters 1 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034 l I
g 291
.1; understanding. So it-is a fairly significant resource.
2 The point is today we are safe. Do we.need to l 3 implement all these new requirements that may be in'a new 4 update to continue to be safe? Is there something that we 5 don't have presently? So there is this-balance. We have 6 defined what is safe.
.7 If there is something that is necessary for 8 adequate'public health and safety, then the staff has the 9 obligation to impose that upon licensees. That process 10 still is in the works. The question is, we have gone from 11 the-safe level. Do we need to go to a different level that j 12- may or may not.be' safe?
13 Then we talk about the differences that may exist 14 presently between licensees within a licensee's plant itself 15 on the different editions. That is the present status 16 today. That is not a change. No plant out there has a 17 singular edition applicable to everything. They have come 18 in for changes in the code where it has been beneficial to 19' the plant and gotten exemptions from the staff, or 20 modifications,.to implement' changes that have occurred in 21 the-code that have not been yet endorsed by the staff. So 22 right now we have a patchwork. I don't believe that will 2 3.. change in the future any more.than it has to date. 24' It is a little bit of a hassle,~but we do need to 25 keep good records that will assure us that we understand j
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292 1 'what requirements cy) to which code. [N ,d 2- DR. SHACK: It is one thing to have construction 3 requirements from one edition to.the code and inspection
~L 4 requirements. It would seem to me that would patchwork a 5 lot more.
6 MR. COZINS: We have come a long ways in' time. 71 The question is, are we safe today? That's the real 8 question. And do we need to change to new technology to 9 continue to be safe? That is a question that continues to 10 evolve, and I believe the staff will continue to think about 11- 'that. I know you have done a lot of thinking on that with 12- regards to Appendix VIII. 13 There are other requirements'that a plant may need 14 to be safe to operate today that they don't necessarily need () 15 to change to continue to be safe to operate. There is the
-16 discussion. I think that is the crux of~the matter as they 17 examine this.
18 I have not seen the SECY yet, so I don't really 19 know the exact words that will be in there. DNe do look 20- forward to this workshop in May. I believe the list you put 21' up there is the ten odd questions. This is very similar to 22 what they did in the ESI. Teams take over, and I understand 23 that was an effective way to get all stakeholders an 24 opportunity to have input, and I think staff will probably 25' 'have a good basis to make its final decision on that point. G ANN.RILEY & ASSOCIATES, LTD. ks ,) Court Reporters 1025 Connecticut-Avenue, NW, Suite 1014 Washington, D.C. 20036 ! (202) 842-0034 l
l' 293 1 MR. NORRIS: My name is Wallace Norris from the 2 Office of Research. I would just offer another data point. { 3 I'm on a couple of ASME committees. Talking to ISI 4 coordinators, some of the numbers I've heard thrown around 5 for 10-year updates, it is between $150,000 to $300,000. As 6 far as computerization of their programs, they have done a 7 lot of that now. 8 DR. SHACK: It seems to me the maturity of the 9 programs would make the updates self-limiting in the sense 10 that if the ASME feels the programs are mature, there will 11 not be significant changes in the code. We all know that 12 ASME code changes are not made lightly. 13 MR. TERAO: Actually, with respect to ISI Section 14 XI in the past ten years, or since the 1989 code, there have () 15 not been any new requirements added to Section XI. They are 16 mainly reductions in requirements. From that perspective, 17 the staff feels it is no longer necessary to require these 18 codes. If utilities would like to voluntarily adopt these 19 codes, later editions, addenda, they may do so provided they 20 are endorsed in 50.55a. I believe Section XI has had no 21 enhancements in their requirements in the last ten years. 22 MR. WICHMAN: There is another enhancement, end 23 that is in the area of flaw evaluation and analysis, I 24 Appendix K for the low upper shelf improvements to flaw 1 25 evaluation appendices; Appendix G. All of these things have l (~'
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I 294 l 1 been upgraded tremendously during the past several years. I\ 2 So that's an enhancement. V 3 MR. CAMPBELL: Another enhancement, which is 4 somewhat forgotten about, is Section XI not only covers ISI; 5 it covers repairs and replacements, and there are so,ne 6 unique repair procedures dealing with everything from steam 7 generator tubes to other repair procedures that are 8 contained in Section XI that you will not find in the 9 construction code. So there are rules for repairs, 10 replacements and modifications contained within Section XI. 11 DR. SHACK: Does the 10-year update include all 12 the Section XI? When we say ISI and IST, that is really 13 shorthand for Section XI. 14 MR. WICHMAN: Yes, it does. (O ,f 15 MR. TERAO: I'm sorry. I have to disagree. 16 50.55a does not require that the industry adopt all of 17 Section XI. It only requires in-service testing of pumps
-18 and valves and in-service inspection, including hydrostatic 19 tests. Areas such as repair and replacements are not 20 included under 50.55a in the current regulation.
21 We are trying to consult with our counsel here. 22 MR. CAMPBELL: This is Larry Campbell. Before I 23 joined the NRC I used to prepare ISI and IST submittals. I 24 know the code has changed. In this nice submittal I 25 prepared in 1988 before I joined the NRC we put in there [' ANN RILEY & ASSOCIATES, LTD.
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{ L 295 1 that that submittal for repairs and replacements could L L
) 2 conform to this edition and addenda to the code. I've been 3 away from this for ten years, so I don't know what the.
4 current submittals say. 5 DR. SHACK: I am assuming that the licensees can l 6 voluntarily choose to do that. The question-is whether they !' 7 have to do it. L 8 MR. TERAO: That is correct. We are talking about 9 regulation covering it versus a' licensing commitment. 10 Certainly there are licensing commitments that they would 11 adopt all of Section XI, but as far as what 50.55a requires, 12 it is only in-cervice testing of pumps and valves and i 13 in-service inspections, including hydrostatic tests. 14 MR. CAMPBELL: And 50.55a also addresses codes for ' i s 15 construction, depending on when the construction permit was 16 issued. I 17 MR. MILLMAN: My name is Gilbert Millman. I'm in 18 the Office of Research. I'm the NRC representative on the 19 ASME Board on Nuclear Codes and Standards, the ASME Boiler l 20 and Pressure Vessel Main Committee, and the ASME 21 Subcommittee on Nuclear In-service Inspection, which is the 22 committee responsible for Section XI. 23 This is really a very complicated issue. When 24 Section XI writes its rules, it is always making the l 25 assumption that those rules for any specific edition or ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 i (202) 842-0034 _j
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296 1 addenda will be implemented in their entirety. The code 1
,. J (Q )) 2 itself does have provisions for using portions of later 3 editions and addenda, but the fundamental assumption is that 1
4 the base code would be a specific code edition or addenda. i 1 5 It is also assumed by all many hundreds of people l 6 participating on the Section XI committees that the work ! I 7 they are doing is useful; that when they participate for a i 1 8 week to write new code, that they are taking into account 9 the experiences of 100-odd operating plants. j 10 When people say that they are reducing 11 requirements, that is really not an accurate interpretation 12 of what is going on. I am as cultical as anyone else on the 13 code. I probably have more negatives on valid actions than 14 probably anyone that has ever participated in the code (7) 15 process, but I do recognize where the other participants of 16 the code are coming from. 17 There is a great deal of experience in using j 18 Section XI. We have been using Section XI since 1971. That 19 is 28 years of experience. It was written in a very 20 conservative manner, as were other standards and other 21 portions of the Boiler and Pressure Vessel Code. We have 22 got a great deal of experience. There are certainly 23 examinations that have not proven to be fruitful and can be 24 backed off, and when we back off an examination, it is not 25 just eliminating an examination; it really is reducing (N, ANN RILEY & ASSOCIATES, L1D .
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I~ 297 1 occupational exposure in certain areas. j ) 2 When we say the burden on a utility is $200,000, 3 or whatever,'to update to their new 10-year code, we are not 4: taking into account in that calculation the-fact that when 5 they don't do something that has not proven to be fruitful
- 6. in previous examinations, that is a major reduction in 7 burden that is not accounted for. .It is a reduction in 8 occupational exposure, which is also very significant.
9 Baselining to, say, the 1989 edition is totally 10 contrary to any other code that is used in other areas, like 11 fire protection and electrical, where it is assumed that the 12 later editions and addenda of the code make useful 13 contributions to safety, which is an overwhelming term, and 14 it includes occupational exposure as well. () 15 I believe,. and I believe other members'of.the 16 staff believe, that this is simply a mistake; it is a 17 mistake to remove the 10-year update. 18 DR. SEALE: Thank you very much. 19 DR. SHACK: Thank you very much. 20 [ Recess.] 21 DR. SHACK: We are back in session. Mike Mayfield 22 is going to talk to about PTS. 23 MR. MAYFIELD: Thank you. 24 [ Slides.] 25 MR. MAYFIELD: Yesterday afternoon, when Ed g'~} ANN RILEY & ASSOCIATES, LTD.
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298 1 Hackett was in, he mentioned several times all the great
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(},, 2 things we are going to tell you about this morning. If he 3 oversold your expectations, we will call him back down to 4 explain it. 5 What I am going to talk to you about this morning 6 is a little of the background information. I suspect all of 7 you know, but I wanted to start there. 8 The goal for this activity. 9 Why we think there is a success path. 10 What our approach to it is going to be. 11 And some milestones and schedule for the program. 12 PTS is an overcooling transient that is typically i 13 taken as a rapid cooldown of the vessel, either with 14 concurrent high system pressure or with repressurization. (A) 15 There have been operational transients. Perhaps the most 16 famous of them was the Rancho Seco overcooling transient. 17 In 1985 the NRC finally promulgated a PTS rule, 10 18 CFR 50.61. It established some screening criteria for axial 19 welds and plate and then a separate one for circumferential 20 welds, i 21 If the pressure vessel is projected to exceed the l 22 screening criteria, the licensee is first to implement a ! I 23 flux reduction program. If that doesn't get them to stay J l
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24 below the PTS screening criteria, then they would have to do 25 an analysis and submit that three years in advance of ['T ANN RILEY & ASSOCIATES, LTD. (_ / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
299 1 exceeding the screening criteria to demonstrate that the
-2 Vessel could be operated safely beyond the screening
~3 criteria.
.4 In the 1982 to 1986 time frame Research funded 3 5 plant-specific studies to look at pressurized thermal shock, 6 what would have to go into the plant-specific analysis.
7 That led to.the promulgation of RG 1.154 that lays out the 8 plant-specific analysis methodology. It talks about it 9 being.a format and content guide, but it really does lay out 10 what would have to be in a plant-specific analysis. 11 The staff had always intended that the PTS rule 12 and the regulatory guide would be something that would lay 13 out a process for getting beyond the PTS screening criteria. 14 The notion is you would come in in advance of exceeding the ! () 15 screening criteria. You would deal with plant-specific 16 considerations and then look at what changes might be useful 17 in the plant, for example, heating, safety injection, tank 18 temperature, so that you could mitigate the cooldown in such 19 a way that you could continue to operate the plant. 20 The staff considered the' screening criteria as 21 trip wires as opposed to hard limits. When the Yankee Rowe 22 plant came in, the embrittlement estimates had them some 30 23 degrees or more over the PTS screening criteria. The whole 24 analysis sort of went in the drink, because we were now 25 trying to use the reg guide in a situation that it really
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300 1 wasn't designed to deal with. They were already over the () 2 3-screening criteria and we were playing catch-up. The net result of all of that is that a lot of 4 people in the industry, and I suspect some on the staff, had 5 started viewing the screening criteria as hard limits. 6 Licensees go to some considerable lengths to avoid those 7 limits, and there is also an impact then as people make 8 license' renewal decisions: Oh dear, am I going to have 9 pressure vessel problems? Do I have a PTS problem? Could I 10 ever have a PTS problem if the staff made some further 11 adjustments, for example, to RG 1.99? 12 As we looked at this, it appeared to us that there 13 had been a fair bit of heartburn associated with the rule 14 and the guide. So we thought we probably ought to take that O) (, 15 on and revisit it. , 16 I want to talk a little bit about what is in the 17 guide and the current technology base. 18 The integrated pressurized thermal shock studies, 19 IPTS, involves 3 PWR plants, one from each of the vendors:
- 20 Oconee for B&W;-Calvert Cliffs for_CE; and H.B. Robinson for
-21 the Westinghouse designs. We list here the 3 NUREGs and l
l 22 their publication d.ates.
- 23 When you go back and look at those reports, you '
l 24 find some general classes of transients that cause i 25 pressurized thermal shock. You see small-break LOCAs; you
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r. 301 , i l
- 1 see steam line breaks; you see steam generator overfeed; i
2- reactor trip with a stuck-open secondary. 3 So basically you are talking about a primary site j l 4 break that leads to a rapid cooldown; the repressurization [' 'S comes; if'the operator can isolate that break, safety i 6 injection picks back up and you drive the system pressure
- 7 'back up.
-8 The other kind of transients you see are secondary a
9 side events.where you get a rapid cooldown of the secondary 10 and then an associated cooldown ofithe primary. I 11 This top bullet is just going back to the notion 12 that the dominant PTS transients are the ones where we have 13 repressurization. fairly late in the transient. So the I 14 vessel has gotten cold; you have established some fairly 15 high thermal stresses across the wall; and then you 16 repressurize the vessel. 17 Q1;alitatively, the initial thermal stresses get 18 you a crack initiation, and then the pressure stress that
-19 comes with the repressurization will cause-the crack to 20 drive through the wall.. That is sort of the phenomenology
- 21 that you see.
22 Sensitivity analyses that we did show that the ; 23 flaw-related varitbles are the most significant, and that is 24 driven largely by the level of conservatism that was in the 25 choices for the flaw variables. O- ANN RILEY & ASSOCIATES, LTD. V Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
e 302 1 So what did we do to make the flaws look so bad? () 2 At the point in time we did the IPTS studies we took what 3 were treated as best estimates on the flaw distribution, but 4 they were known to be conservative. I For example, all the I 5 flaws were placed on the inner surface of the vessel. We 6 know that to be the most conservative. Hackett talked about 7 that a little bit yesterday.
)
8 The flaw size and flaw density distributions were 9 assumed to follow this Marshall distribution, I will talk a 10 little bit more about that as we go. That distribution was 11 based on expert judgment based on early vintage NDE data 12 where they tended to gate out the first inch of material. 13 So you lost that inner inch of material. You don't really 14 know what is there from those early studies. () 15 It also lumped nuclear and non-nuclear vessel 16 data. So you've got this real mixture of information that 17 went into the Marshall distribution. We knew then and we 18 can now confirm that those data were not appropriate for 19 this application. 12 0 There were some other factors that were found to 21 be important. The embrittlement variables, both the shift 22 and the reference temperature as well as the unirradiated 23 reference temperature, were found to be sort of the second-24 most important variable. 25 The fracture toughness characterization, the K1c [^}
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p 303 1 curve,'was sort of the third most important. ;
/ T' 2 Finally, the thermal-hydraulic transient data came N.)
3 .in. 4 Then there is a list'of other variables of lesser 5 significance. But the flaw-related variables dominated the 6 whole business. 7 DR. FONTANA: Is that in order of importance? 8- MR. MAYFIELD: 'Yes. It starts with the flaws and 9 then pretty much runs down that list. k 10 Most of what I am going to tell you this morning 11 are generalizations that come from those three studies and i 12 some other work we have done. It gets to be somewhat plant 13 specific. So you could see some swapping arount The flaw 14 variables dominate in all of these. That is one that we A Q 15 know for a fact. The relative importance of some of these 16 others moves around a bit vessel to vessel. 17 What are we trying to do with this? 18 Our overall goal is to promulgate a risk-informed 19 revision to 50.61. That, of course, involves both Research 20 to develop a technical basis and then NRR to promulgate the 21 rules. 22 The Research goals are, first, to develop the 23 . technical basis for this fundamental change. That would 24 build on a lot of the work we have been doing over the last 25 several years with some real emphasis on the stuff in the
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l 304 1 last five or so years. t
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[d 2' Secondly, to approach this project as a full 3 participatory project bringing input in from the industry 4 and other technical experts. We want to make sure that 5 everybody that has something useful to say has a place at 6 the table. 7 Finally, we want to achieve a common understanding 8 among the stakeholders.about the proposed revisions, that 9 they are practical, that they are technically credible, they 10 are cost-effective to implement, and that they are 11 scrutable. 12- DR. SHACK: You've got every ACRS buzzword in the 13 world there. 14 MR. MAYFIELD: We have been reviewing the 15 l l [\-)\ transcripts. l 16 [ Laughter.] l 17 MR. MAYFIELD: Those are important issues. It is 18 some feedback we have heard not just from the committee, but 19- also from the industry and others: What are you people off 20 doing? We don't know what you mean. We don't know why you 21 said that. 22 Then when we revisit some of the SECY papers, some 23 of the statements of consideration, occasionally the staff I 24 is left saying, what does that mean? 25 So what we want to try to do here, at least our T ANN RILEY & ASSOCIATES, LTD. s) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 j (202) 842-0034 l 1 1 1.
305 1 goal, is to five years from now or ten years'from now people
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2 that look_at the documents will understand how we got where 13 we are and the basis for it. 4 -It was a. noble goal. Why do we think we would 5- _ever get.there? 6 Research results have made some considerable 7 improvement in'the understanding of these critical 8 . variables. We now believe that we can develop a technically 9 defensible approach to dealing with the flaw variables. 10 Ed talked yesterday about the investigations of 11 the PVRUF vessel and the flaw distributions being put 12 together. This is cumulative distribution of flaws as a ! 13 function of flaw depth, the lower curve being the original 14 . Marshall distribution, the upper curve being the information () 15 16 from the PVRUF vessel; those flaws with an inner tip between the cladding and about 1/8 of the vessel thickness. 17 What ycu see is a much larger proportion of small 18 flaws than what you have with the Marshall distribution. 19 The range of interest in flaw sizes for pressurized thermal 20 shock is sort of in the 1/2 to 1 inch. If you get real 21 deep, you don't care, because the thermal stresses don't do 22 much. If you are real shallow, you don't care, because the 23 thermal stresses don't do much. ! 24 What you find is that the much larger fraction of ; 25 the flows are coming outside of the size range of interest ! 4 l (N ANN RILEY & ASSOCIATES, LTD.
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306 1 with the PVRUF distribution. D 2 The other thing'that you would do and that we are .Q 3 working on is to figure out how to distribute the flaws 4 through thickness. We have that information from the PVRUF. 5 vessel. So we are looking at how do you generalize that { 6 vessel-specific information into a flaw distribution both-in l 7 terms of size and location that would be suitable for these 8 -probabilistic analyses. 9 DR '. SHACK: How many feet of PV..L ' are we talking 10 'about? 'How many feet of weld are we lookizig at here? 11 MR. MAYFIELD: Shah, do you remember? 12 MR. MALIK: Twenty meters of weld. l 13 MR. MAYFIELD: We also have acquired not quite 14 that much. I think there were about 11 feet at. the Midlard 15 weld. We also have the material from the Shoreham vessel. 16 'W'e got some material from River Bend. I think that is all ; 17 of them. So we are going to continue the work on the flaw 18 distribution. 19 We felt the PVRUF-was representative. PVRUF was a i 20 Combustion Engineering fabricated vessel and it was one of 21 the last two or three they made. We acquired it because the 22 plant that was destined for was canceled. Oak Ridge bought 23 it and had'it shipped, which was quite a story in and of 24 itself. Insurance, what happens if the barge sinks, and 25 that sort of thing got interesting. h%/
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1 l l 307 1 DR. KRESS: They brought it up the Tennessee River I 2 to Chattanooga. V 3 MR. MAYFIELD: Yes. It is quite an undertaking
-4 just to get these big vessels shipped. If you never had the
- 5. opportunity to see any of these, the way they handle these l
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6 vessels is really remarkable. 7 At any. rate,'we acquired that vessel and ran out
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i 8 of things to do with it. So we starting doing the 9 . nondestructive examination. It's a late vintage vessel. So 10 there was some concern about, well, what about the earlier 11 -vintage vessels? Would we expect to see any real difference 12 in the flaw distribution? 13 Statistically we see some difference between the 14 Midland data and the PVRUF data, Midland being a B&W () 15 fabricated vessel, much earlier vintage vessel. Some 16 difference, but there is a lot more data off PVRUF than 17 there was off Midland. We are still reconciling some of 18 these pieces of information. 19 The scatter band is not that large. It is not so 20 large that you have to throw your hands up and say, well, 21 distributions have to be vessel specific. That is not where 22 we are, but we have got some work to do yet in terms of what 23 would be the distribution when actually doing this analysis. 24 DR. SHACK: That cumulative distribution you 25 showed, is that based on the nondestructive examination, the C)
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p 308 1 NDE results for the flaw sizes that you had? () 2 3 MR. MAYFIELD: It's based on the SAT'T UT results. They are off now doing some destructive examination to i 4 confirm that. It looks pretty good. We have done a lot of 5 work with SAFT UT on sizing accuracy. So we felt reasonably 6- comfortable going in. This is not'the sort of inspection 7 .you would see in the field. This was people up close and 8 personal with that vessel where they-could scan and go back 9 over regions and acquire the data. If they needed to, they 10 could reacquire the data. We are pretty comfortable with 11 that. { l 12 DR. SEALE: Mike, one wonders how risk averse one 13 should be. It's risky to get another vessel to look at it,- 14 in a sense. () 15 DR. SHACK: Risky to the budget, for sure. 16 DR. SEALE: That's the other part of it. There 17 are several vessels that ought to be coming available from 18 various plants. Is there any thought of trying to get 19 -another candidate or to look at these in more detail? 1 20 MR. MAYFIELD: We wanted to stay with the ones we 21 have simply because they are all unirradiated and we can get 22 up close and personal with them. As you start getting on
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23 the more highly irradiated vessels the quality of the UT 24 results -- I want to be careful to not imply that what we 25 are doing in any way relates to what would be done during a t O ANN RILEY & ASSOCIATES, LTD.
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g 309 1 traditional ISI. Consequently, our confidence in the sizing [3v; 2 is much higher than you could reasonably expect with people 3 working off the end of an ISI mast with all the 4 complications that go with handling an irradiated vessel. 5 's there any interest? Risk averse maybe is the 6 right consideration there. We have been interested in 7 getting as much material as we can simply because we tend to 8 reduce the uncertainties at the end of the analysis. 9 We did some analysis. I will show you a plot in a 10 second. We are seeing about an order of magnitude in 11 probability of thru-wall cracking for this example case. We 12 know that there are additional conservatisms in the 13 analysis. 14 The flaw size and density for the plate material. () 15 We really haven t done much on that and we were staying with 16 some conservative assumptions. l 17 We are still dealing with flaw density in welds ! 18 and the number of surface-breaking flaws you would actually 19 have to consider. If you inspect 20 meters of weld and you 20 find no surface-breaking defects, statistically you can't 21 say there aren't any. There are ways of estimating how many 22 surface-breaking defects you should consider in that 23 material. 24 We need to impose an up-to-date fluence map, 25 because we just assumed that peak fluence occurs uniformly [] ANN RILEY & ASSOCIATES, LTD. (/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
310
=1 around the vessel.
./~') 2 And you would need accurate information on the V
-3 chemistry so that we could influence the reference null 4 ductility values.
5 Finally, there is reason to believe the PTS 6 screening criteria can be increased significantly by simply _ 7 reducing some of the excessive conservatism in the analysis. 8 This is the result of one of the example 9 calculations. This is from the IPTS study for the Calvert 10 Cliffs plant. I want to emphasize;that this does not 11 represent Calvert Cliffs as it sits today. This is simply
' 12 the vessel that we were working on at that point in time.
13 The upper curve represents essentially what you 14 would get out of RG 1.154 as it sits today. The lower curve () 15 is what you get out of these example calculations. So you 16 pick up about an order of magnitude reduction at 32 EFPY 17 between what you would get out of the reg guide calculation 3 J 18 and where we can get without having to work at it very hard. 19 This is basically just the flaw distribution 20 information and making some distribution of the flaws
'21 through thickness. By the time we impose the fluence map, 22 we sharpen up the embrittlement estimates, and we do some of 23- these_other things, we think it's conceivable you could get 24- another order out of this analysis.
25 DR. SHACK: I don't need another order.
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, =
1 MR. MAYFIELD: Let me come back to that. In 1
'fi 2 principle you don't need another order, but what we don't b
3 want to do is revisit this in another. ten years; we want to 4 try and do it right today and get this as sharp as you can 5 justify it. 6 The approach we are taking will be basically a 7- two-track approach. 8 .The bulk of the work will be determining the 9 appropriate screening criteria. 10 The other piece of it is.to look at the numerous j i 11 other aspects of the existing rule that need to be 12 revis~ited: the embrittlement correlations that Ed Hackett 13 talked about a bit yesterday; what margins need to be 14 included in this analysis. The idea isn't to embed () 15 conservatism at each stage but rather to do the analysis 16 using your best technical input and then put a known margin 17 at the end of it. 18 There are issues such as credibility collapse for 19 the surveillance data that need to be addressed. There are j 20 several of these points that need to be dealt with. 21 As I mentioned, we see this as a fully 22 participative process that would involve the public and 23 industry at each stage. This isn't something where the 24 staff goes behind closed doors, does some stuff, and then 25 comes back out and pronounces what the answer is. Rather, ["' ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NJ, Snite 1014 Washington, D.C. 20036 (202) 842-0034 LL - - - --
312 1 people would be involved all along. f) 2 We are hoping that would include this committee. V 3 I think we are scheduled with'the full Committee in April. 4 The notion would be to inform the committee, seek your 5 comments, if any, as we go along, and then provide 6 additional status briefings during the course of the 7 project. 8- What we don't want to do is get to the end and 9 then have somebody identify a fundamental flaw that should' 10 have been picked up in the early stages. 11 DR. KRESS: No pun-intended. 12 MR. MAYFIELD: Yes. 13 This little flow chart tries to lay out -- it is 14 probably difficult to read. I have to get my glasses fixed. () 15 DR. SHACK: It's not a whole lot better on the 16 page either. I 17 [ Laughter.) q 18 MR. MAYFIELD: I started to bring the 11 by 17's 19 and the just didn't get them printed. 20 We would start up at the top using some public 21 meetings to identify the major issues that need to be 22 addressed. We have those meetings scheduled, at least the 23 'first cut at them. One we have already had; the second one 24 we would have April.20th and 21st here in Washington. 25 We would be collecting the output from those two i i
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4 l 313 1 meetings, assimilating that, and that'would lead to some
-] ) 2 specific analyses and additional meetings, so that we could 3 come up with the list of questions that need to be resolved.
4 DR. KRESS: Who~shows up at a public meeting like 5 that? 6 MR.- MAYFIELD: By and large the industry. 7 DR. KRESS: People who know about-this thing. 8 MR. MAYFIELD: We notice the meetings. 9 Occasionally we will get some folks not directly associated 10 with the industry. We will see vendors; we will see some of 11 the A&E show up. 12 DR. KRESS: But these are technically minded 13 people. 14 MR. MAYFIELD: They tend to be technical people f~ 15 that show up at these meetings. 16 Right after the Yankee Rowe experience, when we 17 first started doing these kinds of public meetings, we had a 18 couple of the UCS folks show up; we had a couple of 19 reporters show up. For reasons of their own, they 20 apparently decided their resources were best put elsewhere. 21 We see more involvement from a broader range as you get 22 towards the end of some of these-things, but when you are 23 dealing with the detailed technical meetings, by and large 24 it's the engineering sciences folks that show up. 4
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25 So we have come up with our list of questions.
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314 1 This other path'would be to deal-with these other issues in l L.,/} 2 the rule, the embrittlement correlations, credibility 3 criteria'. 4- DR. KRESS: Are you going to talk about the square 5 on the right?
- 6. MR. MAYFIELD: .That's why I started over here, so
- 7. I can come back to this one.
8 These are the more mundane parts of what we want 9 to change on the rule. Although they may be more difficult-10 to deal with, they are the more routine considerations. 11 Over here is to reevaluate the technical basis for 12 that 5 times 10 to the minus 6 target. That one seems-to l' 13 capture everybody's attention. That is an area that Mark l l 14 Cunningham and his guys will lead. (f 15 The notion is that we would base that criteria on 16 some'of the other risk-informed initiatives. I don't want 17 to. leave you the impression we have decided on this, but as 4 18 an example, work backwards from either the CDF or the LERF 19 criteria in RG 1.174 to,come up with what would be an 20 appropriate vessel failure criteria. 21 DR. KRESS: This is one set of sequences among 22 many. Are you going to distribute the LERF among some 23 sequences? Is this the idea, Mark? 24 MR. CUNNINGHAM: Mark Cunningham from Research. 25l Yes, that is exactly the type of issue we will have to talk { l I ANN RILEY.& ASSOCIATES, LTD. Gi Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202).842-0034
~ z 315 l 1 about, coming from 1.174 or coming from the regulatory 2 analysis guidelines for backfits, which are interrelated at [^)) 3 this point; talk about what does it mean for a relaxation I 4 like this for a subset, if you will, of whole plant risk. j 5 DR. KRESS: That was my issue. 6 MR. CUNNINGHAM: I envision a number of 7 interesting meetings with the committee talking about just 8 that subject. 9 DR. KRESS: We look forward to it. 10 MR. MAYFIELD: Mark will be in front of the 11 committee for those. 12 DR. FONTANA: A related question on the curve that 1 13 you showed for Calvert Cliffs. This frequency of vessel ' 14 failure, does that assume the whole spectrum of initiating () 15 events that can get you into this kind of a failure? 16 MR. MAYFIELD: For this the original study did. 17 They went through a very detailed system evaluation and bin I i 18 events. For this particular calculation, the small break 19 LOCA gets you 90 percent of so, and they just ratio it up. 20 The original IPTS study and what we would do in this overall 21 study, we will go back and look at the full range. 22 DR. FONTANA: You were discussing the acceptance. 23 That heavy line is an acceptance line? 24 MR. MAYFIELD: That's the 5 times 10 to the minus 25 6 that we have today. Bill said, well, you've done enough. O ANN RILEY & ASSOCIATES, LTD. C/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
y 316 1 If' for example, this came down tomorrow like 10 to the 2; minus 6, now I'd like to pick up some more. You want to l 3 Jsharpen this analysis and make sure we are making the best j 4' use.we can of all of the available.information. 5 DR. KRESS: You are reevaluating this solid line, ! 6 too. I 7 MR. ~MAYFIELD: We are ree'raluating the solid line 4 8: as well as what would go into these others. 4
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9 DR. FONTANA: I hate to bring up ancient history, 10 but back'in WASH-1400 weren't they guessing around 10 to the ] 11 minus-7 for vessel failure? 12 MR. CUliNINGHAM: Yes. I don't think people 13 recognized in WASH-1400 PTS was not on the table at all. It 14 was by and large a traditional, spontaneous, if you will, () 15 rupture of the vessel. 16 MR. MAYFIELD: This box will be a key input to 17 everything else we are going to do in terms of reevaluating 18 screening criteria. We are anticipating that will involve a 19 fair bit of public discussion. 20 In one of the schedules that we had put out for 21 t' .s program we had that activity completing much later in 22 he program. One of the comments we got from the industry 23 ineeting we had a week or two ago was that that was coming 24 too late. We agreed. We have moved that up oignificantly. l 25 This is also something thar. potentially will ANN RILEY & ASSOCIATES, LTD. {s/% Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
317 1' icontinue during the whole course of this program, but we 2 needed'to focus on that activity much earlier. So we have 3 moved-that up much further in the schedule. 4- DR. SEALE: It kind of washes over into these 5 other things quite a bit. l 6 MR. MAYFIELD: Absolutely. This is something I l 7 anticipate there will be continuing dialogue on, but you 1 8 need to frame it up front and make sure you understand the 4 9 context of that answer and then look at the rest of the
- 10. program.
11 DR. KRESS: That is an interesting box over there. i 12 That is where defense in depth has a head-on col.lision with 13 risk criteria,
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i 14 MR. MAYFIELD: The other part of the approach is () 15 in the middle. 16 One of'the things that we have been emphasizing 17 was a mistake that was made in some of the earlier studies, 18 a mistake that we have made a couple of different times, to 19 not involve the statisticians up front. 20 We know we want to do a detailed sensitivity and 21 uncertainty analysis. We don't want to wait until the 22- mechanical engineers and the metallurgists are done having 23 fun and then bring those folks in to make sure that we can 24 .put together the sensitivity and uncertainty analysis. Put 25 them in up front; make sure we understand the type of ANN RILEY & ASSOCIATES, LTD. \~. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, ' C. 20036 (202) 84.-0034
g 318 1 analysis we need to do and the level of rigor we need to do, i j L2' so-that at the end we can have a sensitivity and uncertainty i 3 ' analysis that is believable. { 4 DR. KRESS: I would recommend you draw some sort 5 of line to that box and the other box. I think uncertainty j 6 is going to be important in your acceptance criteria. 7 MR. CUNNINGHAM: Yes. 8 MR. MAYFIELD: Coming out of listing the 9 questions, making sure that we'have an approach framed in a 10 way that will be credible at the end of the day, we will 11 look at three pieces, identify.and bin the events, meaning. 12 going back and revisiting existing PRAs for the plants. Our } 13 hope is to build on the IPTS 3-plant study. However, 14 Palisades has volunteered to make themselves the fourth () 15 ' plant in the study and to be totally participative. That 16 was a nice addition. 17 One of the first things that Mark and his guys J 18 have to do is to look at the existing PRAs, contrast those 19 that were used in the original IPTS study, and see what 20 additional work we need to do to bring that list of events 21 up to reflect the current plant. It may be a lot of work; 22 it may not be very much work. It just depends on how the 23 systems have changed over time. 24 DR. KRESS: Going to your box on sensitivity and 25 uncertainty, since you already know that it is the flaw l i 1
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319 1 : parameters that are most' sensitive, more than likely that is j { 2 where you would need to -- 3 MR. CUNNINGHAM: Probably the most uncertain. 4 DR. KRESS: Mest uncertain also. I don't think 5 you can rely on the data spread to get an uncertainty in ( 6 this case. 'Your only recourse is probably going to be 7 expert opinion. It sounds to me like you are back to 8 Marshall. 9 MR. MAYFIELD: Except we've got a lot better 10 information to feed that panel. 11 DR. KRESS: Your experts can be fed with better 12 stuff, and you can sharpen up this expert opinion. 13 MR. MAYFIELD: I think that is exactly the case. 14 We had to start somewhere. Making the next step based on O) g 15 the PVRUF information just to see if we were even close, we 16 felt that s, we were close. That next step is how do you ! 17 generalize that vessel-specific information into something 18 that can be used in this kind of program? Do you do that 19 .with expert elicitation? Exactly how do you get there? 20 DR. KRESS: I think you are going to have to. 21 DR. SEALE: The Marshall distribution was terribly 22 subjective. I think everybody knows that it was terribly i 23 subjective. l l 24 DR. KRESS: I think Dana would have been appalled 25 at the expert elicitation that went into that. ANN RILEY & ASSOCIATES, LTD.
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'l DR. SEALE: They loaded the deck because they had 0 '()
2 2. 3 a loaded agenda. MR. MAYFIELD: Yes. The other thing is that the i
'. 4 people from HSE came in and told us ten years ago that the I 5 Marshall distribution wasn't credible. There wasn't 6 anything else on the table. We really didn't have anything 7 else to use, but even the people that generated that 8 distribution have been disavowing the thing for a long time.
9 This is the stuff we have done on PVRUF and the 10 continuing work on that activity, some of the really major I 11 stepsforwardingettingalookatwhatreallybanbeina 12 reactor pressure vessel. I 13 DR. KRESS: I have to say it looks like a good 14 approach, Mike. I think you are going to have problems in a (. 15 couple of the boxes. These problems are tough, but you guys 16 can do it. 17 DR. SEALE: They look like the right boxes. 18 DR. KRESS: They got the right boxes. That's for 19 sure. l 20 DR. SHACK: Let me ask you a question you will get 1 21 to answer next week. That box on the right is clearly NRC 22 turf. What about the rest of this? Why isn't industry 23 doing it? 24 MR. MAYFIELD: Industry is certainly involved 25 significantly. Bob Hardies is here-with us again today. O ANN RILEY & ASSOCIATES, LTD. h Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
321 1 The industry is involved. The reason the NRC takes this on ( 2 is it is NRC's regulation.
)
3 DR. KRESS: I think that is.a reasonable criteria. 4 DR. SHACK: We'll see how it flies next' week. 5 MR. MAYFIELD: That same question can be posed on 6- virtually anything we do. The criteria we have looked at is ( 7 that it is in fact NRC's regulation. There is in fact a ' 8 Commission initiative to reduce unnecessary burt.n. There 9 is also a Commission initiative to risk-inform Part 50. We 10 believe that this activity is consistent with both of those 11 l initiatives. We can reduce excessive conservatism and it is i 12 consistent with risk-informing Part 50. 13 DR. SEALE: And if we are going to have the gall 14 to continue to license plants on a full-term basis or the A) ( 15 next 20-year term basis instead of in a progressive way that 16 a lot of the countries and the rest of the world do, then we i l 17 need these data in a mature fashion so that we don't ask I 18 ourselves 50 years instead of 60 years out is the whole 1 l, j 19 story there. That is clearly an NRC imperative at this 20 time. 21 MR. MAYFIELD: This is something where we are the 22 ones that ultimately get faced with making the yes-or-no 23 decision on continued operation of the plant. The industry 24 has a vested interest in looking at license renewal and 25 other major-plant considerations about whether they want to [N
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322 1
.1 continue _ operation. Thht is why there is interest on both l 1
( 2 sides; both. sides are participating in this activity; both l 3 sides are putting money on the table in terms of resources
)
4 that are being brought to bear on this program. 5 DR. KRESS: When you come out with a new screening 6 criteria,.will it be like the old one in the sense that it 7 will be a flag, or is it actually going to be a limit? l 8 MR. MAYFIELD: It is interesting you raise that. l 9 That is something we talked about just a little bit. There j 10 is a presumption in some of these lower boxes that the rule 11 is going to fundamentally look about like it looks today; j
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12 just the numbers would change. { 1 13 One of the things that Jack Strosnider and I have 14 talked about, and I think Mark and I a little bit, is, () 15 should the nature of the rule change? Jack has commented a 16 couple of times that 50.61 was one of the very first efforts 17 by the staff to be risk informed and performance based. 18 By today's criteria, you just scoff at that; it's 19 laughable. But the fact is the screening criteria were 20 spproached from a probabilistic risk assessment. Certainly 21 not by the standards that Mark and his colleagues would 22 apply today, but in the late 1970s or early 1980s that was 23 the kind of thinking that went into it. It is performance 2
.4 based in terms of there is a trip wire screening criteria 25 that would lead you to do something else rather than just go
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l 323 1 shut the plant down. j 2 The idea is laughable by today's standards, but it
. Q}
3 -was an approach that dealt with some of those concepts very 4 early on. We would like to try and get there. The formula 5 Lin the rule where you have got the screening criteria and 6- then you go do something else, does that still hold water? 7~ That is one of the things we want to talk about as we go. 8 Again, there is a presumption in some of these 9 lower boxes that that is how it is going to go, but we are 10 not locked into that. 11 DR. KRESS: If you follow the attributes that 12 define performance based, you would go that way. You want 13 your performance criteria to be something that you can live 14' with. () 15 MR. MAYFIELD: That is the notion. Again, you 16 will see a lot of boxes down through here talking about 17 public meetings to gain shared understanding. That doesn't 18 necessarily imply agreement, but everybody needs to 19 understand where we are and how the staff is going about 20 making its decisions. 21 There is a final box over here, a meeting to 22 resolve any outstanding issues. This would be sort of the
-23 last look at what the staff is going to consider as it 24 develops the proposed technical basis that would be provided :
1 25 to the RES and NRR office directors as a proposal for how f il
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'324 1- you could go about revising the _lS rule.
t 2 Going back tc your question of what would it look 3' like and can it be performance based, a specific regulatory 4 approach is what we would be proposing to the office 5 directors and then along the way dealing with the notion of 6 how do you make it performance based and what should it 7 really'look like. 8 Finally, we started laying out a schedule for 9 this. Most of what'is listed here is the public meetings. 10 We figure those are the big targets where we need to have 11 specific things done. So we listed those as the major 12 milestones. 13 The notion here is that we would be done with the 14 activity and would propose the revisions to the rule to the () 15 16 office directors by the end of 2001. That provides NRR roughly two years to promulgate a rule change. That would 17 support Palisades as the first plant that has a PTS problem, 18 and they run into the screening criteria in December of I 19 2003. 20 If nothing else is done with that plant, they have l 21 PTS screening problems December of 2003. This schedule is 22 consistent with getting a rule change promulgated in time to 23 support the staff's consideration as well as licensee 24 consideration.
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i 25l DR. SEALE: Have you thought about how many times I ON/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 (202)- 842-0034
E 325 1 you are going to want to meet with the ACRS on this thing in 2- 'the next' dix months to a year? 3 MR. MAYFIELD: I'm guessing at least once more. 4 .It is goitig to depend on how quickly this starts to go 5 together, 6 DR. SEALE: You have 10/99. There is a lot of 7 input, I would think, that the committee would have into 8 that rigut-hand box over there, and 10/99 is not that far 9 -away. 10 MR. MAYFIELD: It is not.that far away. I guess I 11 do need to defer to Mark on this. I don't know if he has 12 thought much about how many times we would be back with the 13 committ ee. Certainly at 10/99 we would be back. 14 MR. CUNNINGHAM: I envision this discussion, () 15- particalarly the right-hand box, being of-the style like we 16 did as we developed 1.174. 17 DR. SEALE: In other words, fairly interactive. l 18 DR. KRESS: We could help you decide the approach. 19 MR. CUNNINGHAM: Absolutely. I'm sure we would 20 like to do that. 21 DR. KRESS: I'm sure we would like to do t. hat. 22- MR. CUNNINGHAM: The ACRS was very much involved 23 in tne original decision on why 5 times 10 to the minus 6 24 was >:he right number to use. I would envision several 25 subiommittee meetings just on that issue this spring and f*)
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ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
326 1 summer. ()
~
2 DR. KRESS: I would-suggest we have meetings on 3 the box ~on.the' uncertainty too, because that is whereLyou 4 'are likely to hear some criticism from some members of the I 5 committee. 6 MR. MAYFIELD: Just don't invite them, 7 [ Laughter.) 8 DR. KRESS: I thought about that. 9 DR. SEALE: You are doing us a service too. We 10 have been noodling this question around for a while now, as I 11 you are perfectly aware, but we have been awfully general, 12 unfortunately, or fortunately, however you want to look . l 13 it. The time has come to. grab the nettle, if you will, and 14 this is certainly an important area to do that in. I think () 15 this is happening at the right time as far as ACRS is 16- concerned. 1 L 17 DR. KRESS: We have on our agenda how to do deal 18 with defense in depth in a risk-informed regulatory world. i 19 This is a beautiful example right here. 20 DR. SEALE: This is it. i 21 DR. KRESS: This is defense in depth and risk I 22 -informed right together. So it fits right in. j 23 DR. SEALE: We'll come looking for you if you 24 haven't come here. 25 DR. FC ';TANA : How many man-years of effort does it ANN RILEY & ASSOCIATES, LTD.
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327 1 -take to do something like this in this schedule you have got 2 here?
-3 MR. MAYFIELD: We have done those estimates and 4 I've just gone brain dead. 3 5 Shah, du you remember?
6 MR. MALIK: Two to three man-years 4 7- MR. MAYFIELD: So it's about a man-year per year. 8 Maybe it's a couple of man-years per year. 9 DR. KRESS: Are you guys going to do the 10 reevaluation in house, the IPTS? 11 MR. MAYFIELD: It'will be a mixture of in-house 12 and contractor support. Part of it will be in house. We 13 simply don't have the contractor support resources to keep l l
\
14 running out and doing everything with contractors. j O(/ 15 DR. SHACK: I don't see any box that says improve j l i 16 FAVOR here. You think the fracture mechanics code is 17 basically in a state that it will do this job? 18 MR. MAYFIELD: There will almost certainly be some 19 level of tinkering. By tinkering, I mean making specific ; 20 changes to address specific questions. We are not having to 21 reinvent the FAVOR code. We are pretty well satisfied with 22 'that code. It has had a lot of look from a number of 23 reviewers. 24 DR. SHACK: You don't need to incorporate biaxial 25 effects? O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
328 l ~ 1' MR. MAYFIELD: Some of that is already available. [ 2 That is~ one of the considerations that Shah and his group 3 will be looking at, exactly how you want to do that, exactly 4 what changes need to be made.
'S Out of this box and some of these, there will be ;
6 specific questions' listed and specific approaches on how we 7 are going to address those questions that will be coming l 8 down. As we need to make changes to FAVOR, they would be 1 9 made on the input' side to that lower box. It is our intent 10 to.use FAVOR essentially as it sits today. 11 DR. KRESS: That middle box called thermal-12 hydraulics, will Theofanous be part of that, do you think? 13 MR. MAYFIELD: We have had some conversations with 14 Professor Theofanous. It is my understanding Farouk I () 15 Eltawila, who unfortunately couldn't be~with us this 16 morning, he and his staff will be leading up that piece of
~
17' it. The last understanding I had was that we would 18 anticipate using Professor Theofanous and others as j i 19 consultants to the activity but.not as the leader of the 20 activity. l 21 DR. SEALE: This expert elicitation thing that Tom j i 1 22 referred to as the input over here on the right-hand box is : i 23 something that is going to be interesting to see.
]
24 MR. MAYFIELD: That one will be interesting. The 25 other one that we think is going to be interesting is to : A!G' RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington,.D.C. 20036 (202) 842-0034
329 i 1 look at_ uncertainty bounds on the thermal-hydraulics l 2 .calcul'ations. We know that we cannot do a brute force Monte 3 CarloLapproach to calculate uncertainty bounds on the 4 thermal-hydraulics for each of the transients. That is just 5' not a practical matter to undertake. How you then go about 6 estimatingftheluncertainty bounds in a credible manner, hat 7, is one that Farouk and his guys are talking about. 8 DR. SEALE: Graham will love that. 9 DR. KRESS: Yes. 10 DR. SHACK: Something for everybody in this. 11 MR. MAYFIELD: That was one of the reasons we 12 wanted to meet both with this subcommittee and then with the 13 full committee early on, so that you see what we are off 14 doing; you can identify where you would like to be more () -15 involved or less involved, rather than just wait until we 16 got to the end of the day and then ask you to try and review 17 several years worth of work. 18 .DR. KRESS: We certainly like all your boxes. 19 There are three of them in particular. The 20 thermal-hydraulic box, the uncertainty box, and the RG 1.174 21 box are ones we would be particularly interested in. 22 DR. SHACK: Is there a danger you are going to 23 have a disconnect here on your revision to the embrittlement 24 rule? This is going to come ahead of the embrittlement. 25 MR. MAYFIELD: One of the things we will do here l O
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ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) '842-0034 1 3
330 1 is to include those new 'correla. sus and include that as
,)
( 2 part of the sensitivity and uncertainty analysis. We know L 3 there are going to be a number of-things. Hackett talked
,4 . yesterday a good bit about the master curve and that
~5 approach versus the K1c curve. 'That is something that Bob 6 Hardies and I have talked about a little bit.
7 The notion would be accept the fact that there are 8 two different notions on how to deal with these things: ,
)
9 Accept the fact that there is some uncertainty in the 10 embrittlement correlation, and deal with that rigorously. 11 Rather than try and dance your way around it, here it is, 12 .and here is what kind of impact that has. 13 DR. SHACK: Then you just build it into the 14 uncertainty analysis. 15 MR. MAYFIELD: Build it in and deal with it 16 explicitly, i 17 I think we mentioned yesterday the notion about 18- taking on the P-T limits as a second question. I think you 19 can see that a lot of the elements of this approach could i 20 -c tally apply to the P-T limits . So when we put the i 21 question on the table with the industry at our last meeting, 22 the notion was to get people to think about what might go 23 into a revision to the P-T limit approach and then keep that 24 in mind as we take on these activities. There may be some 25 tweak we can make here and there. It would be a little more ANN RILEY & ASSOCIATES, LTD.
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l-331 l 1 than we need to do just for this purpose but that would t 2 satisfy that end goal.
)
l 3 DR. SEALE: Sharpen up the learning curve. t 4 MR. MAYFIELD: The best of all possible worlds is l 5 at the end of this we are proposing not just changes to 6 50.61 but changes to Appendix G as well. That would be a 7 wonderful end to this. I am not overly optimistic that we l 8 are going to get there, but if keep those things in mind, 9 then we are going to stand a better chance. i 10 DR. KRESS: According to what we heard yesterday, l 11 the changes to Appendix G would be worth more to industry. 12 MR. MAYFIELD: I think in terms of operating 13 costs, that is true. PTS tends to be a plant killer issue. 14 DR. KRESS: That's really a killer. You're right. () 15' MR. MAYFIELD: Whereas Appendix G is a routine l 16 operation issue. 17 DR. KRESS: They are different. 18 MP. . MAYFIELD: That's why we want to make sure we 19 are getting both of them. l 20 That was all-I had, Mr. Chairman. 21 MR. DUDLEY: Do you have additional needs for l 22 experiments? 23 MR. MAYFIELD: Not so much in the fracture area. 24 We think that is pretty well in hand. Farouk has some 25 interest in trying to experimentally assess flow stagnation. ANN RILEY & ASSOCIATES, LTD.
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332
'1 That is in-the thermal-hydraulics part of this analysis, the j 2 notion about whether if you really stagnate flow it tends to 3- drive.the cooldown severity. If you continue circulation, 4 the cooldowns are city!"ificantly mitigated.
5 DR. KRESS: That'could be a real significant 6 uncertainty. 7 MR. MAYFIELD: Farouk has the notion of trying to 8 build in some limited-experimentation in one of the flows 9 they have used previously. Those are budgeti..g 10 considerations, how much of that can we really do and can it 11 be done in a timely manner. We are still struggling with 12 budget formulation, as I think you all know. There is an 13 interest in that kind of experimentation. We believe the 14 rest of it we are in pretty good shape. It's a fair bit of () 15 work to get to the end product, but we think we have all the 16 fundamental pieces in place. 17 Anything else? 18 [:N o r e s p o n.s c . ]
'19 MR. MAYFIELD: Thank you.
20 DR. SHACK: Thank you very much. 21 DR. FONTANA: .Let me add:that we have seen some 22 presentations where we wished that they were planned as well 23 as this is. 24- MR. MAYFIELD: We hope you are saying nice things 25 to us six months from now. I p/ s_s ANN RILEY & ASSOCIATES, LTD. Cours Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington,'D.C. 20036 (202) 842-0034 l
)
l L 233 J 1 DR. SEALE: There is no question that you are [ 2' tackling the problems that-count. L 3 [Whereupon at 11:15 a.m. the' meeting was ! 4- concluded.] l 5 6 i 7. { l- 8 i
.9 10.
11 12 13 l 14 i i (4'r 15 (_s) 16 17 18 19
-20 21 22 22 l 24 25
/"'\ ANN RILEY & ASSOCIATES, LTD.
(s / - Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 .j L i L
i l l-REPORTER'S CERTIFICATE l This is to certify that the attached proceedings [ before-the United States Nuclear Regulatory Commission in I the matter of: NAME OF PROCEEDING: MEETING: MATERIALS AND METALLURGY l CASE NUMBER: PLACE OF PROCEEDING: Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true .nd accurate record of the foregoing proceedings. i Y t_ _ > Mike Paulus i l Official Reporter i Ann Riley & Associates, Ltd. O 1
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