ML20205K526
| ML20205K526 | |
| Person / Time | |
|---|---|
| Issue date: | 04/07/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3071, NUDOCS 9904130259 | |
| Download: ML20205K526 (198) | |
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nr emry ACRST 30W V ;; a( > t.nL OFFICIAL TRANSCRIPT OF'PROCsEDINGS-
~
NUCLEAR'REGULATORYJCOMMISSIONJ ADYlSORY COMMITTEE ON REACTOR SAFEGUARDS -
Title:
'461ST ADVISORY COMMITTEE ON.
REACTOR' SAFEGUARDS (.ACRS)..
TRO4 (ACRs; RETWE ORIGINAL TO BJWHITE M/S T-2E2c 4
415-7130 THAt:rs :
Docket No.:
Work Order No.:
ASB-300-736
/
14 CATION:
Rocktitle, MD DATE:
Wednesday, Ap'ril 7,1999 PAGES:1 - 152 9904130259 990407 T 10 /
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l DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE.ON REACTOR SAFEGUARDS APRIL 7, 1999 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory
()
Committee on Reactor Safeguards, taken on April ', 1999, as reported herein, is a record of the discussions recorded at' the meeting held on the above date.
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
- f-^g J
1 a
A
1 1
UNITED STATES OF AMERICA
()
2 NUCLEAR REGULATORY COMMISSION 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 461ST ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6
(ACRS) 7 8
USNRC 9
11545 Rockvil ; Pike, Room T-2B3 10 Rockville, Maryland 11 Wednesday, April 7, 1999 12 The subcommittee met pursuant to notice, at 1:01 13 p.m.
14 MEMBERS PRESENT:
()
15 DANA POWERS, Chairman, ACRS 16 GEORGE APOSTOLAKIS, Member, ACRS 17 JOHN BARTON, Men 6er, ACRS 18 MARIO FONTANA, Member, ACRS 19 THOMAS KRESS, Member, ACRS 20 DON MILLER, Member, ACRS 21 ROBERT SEALE, Member, ACRS 22 WILLIAM SHACK, Member, ACRS 23 GRAHAM WALLIS, Member, ACRS 24 MARIO V. BONACA, Member, ACRS 25 ROBERT E.
UHRIG, Member, ACRS I )
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PROCEEDINGS m
)
2
[1:01 p.m.]
3 DR. POWERS:
Let's come into session.
This-is the 4
first day of the 461st meeting of the Advisory Committee on 5
Reactor Safeguards.
During today's meeting, the committee 6
will consider the following:
Draft Commission paper on the 7
proposed improvements to the generic communication process, 8
steam generator tube and reactor pressure vessel f.ntegrity 9
issues, proposed ACRS reports.
10 The meeting is being conducted in accordance with 11 the provisions of the Federal Advisory Committee Act.
Dr.
12 John T.
Larkins is the designated Federal official for the 13 initial portion of this meeting.
14 We have received no written statements or requests 15 for time to make oral statements from the public regarding 16 today's session.
A transcript of portions of the meeting is 17 being kept and it is requested that the speakers use one of 18 the microphones, identify themselves, and speak with 19 sufficient clarity and volume that they can be readily a::
20 heard.
21 I'll begin with some current items of interest.
22 One of those items is that we do have a visitor at today's 23 meeting.
Stan Puchalla is here from the Department of j
24 Energy at the request of the Defense Nuclear Facilities 25 Safety Board to examine how ACRS conducts its business in r"4 ANN RILEY & ASSOCIATES, LTD.
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the thought that this kind of a structure may be useful to
[')
2 the DOE's nuclear explosives safety studies.
I have v
3 welcomed Stan and suggested that he feel free to buttonhole 4
members, staff and whatnot to get any kind of information 5
that he wants to have.
6 Let me also say that we are scheduled on Thursday 7
at noon to get a briefing on ethics issues, and so' Thursday, 8
members should go down and get something for luuch and get 9
right back up here.
You may want to think a little bit 10 about specific questi: ns that you yourself have on the 11 various rules and regulations that govern ourselves.
I'm 12 sure that the speaker who's very knowledgeable in that area 13 will begin his presentation by asking if there are any 3
14 questions that we have on individual issues that he can
()
15 address.
He undoubtedly has some prepared material, but I 16 think he would like to address specific issues and I'm sure, 17 in the interest of efficiency, we would like to get specific 18 issues.
19 With that, I guess we will move to the 20 presentations.
The first topic we're covering is a 21 Commission paper on proposed improvements to the generic 22 communication process, and Dr. Fontana, I believe you're the 23 cognizant member on that issue.
24 DR. FONTANA:
Yes.
Is NRC staff here to present 25 the presentations?
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1 Is Mr. Marion here?
("%
)
2 MR. BOEHNERT:
From NEI?
%J 3
DR. FONTANA:
Marion?
NEI?
4 MR. BOEHNERT:
I dor - believe so.
But he may 5
come later.
6 DR. FONTANA:
May come later.
7 Are you going to make the presentation?
8 MR. TAPPERT:
I was going to, yes.
9 DR. FONTANA:
Okay.
10 MR. TAPPERT:
My manager is supposed to be here, 11 too.
12 DR. SEALE:
We'll be easy on you until he gets 13 here.
14 MR. TAPPERT:
He'll appreciate it.
15 DR. SEALE:
Then we'll put words in your mouth.
16 DR. FONTANA:
The subject of this discussion is 17 the generic communications that the NRC uses to communicate 18 with --
19 DR. APOSTOLAKIS:
We can't hear you.
20 DR. FONTANA:
You can't hear?
21 DR. SEALE:
Now we can hear.
22 DR. FON7 %:
Sorry about that.
23 The purpose of this meeting is to discuss the ff's 24 proposed revision to NRC generic communications process.
25 The concern is that these communications -- at present time, L[
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there are four kinds that exist:
bulletins, generic
(
2 letters, information notices, and administrative letters.
3 The concern is that it's not clearly defined which generic 4
communication is used for which purpose, and the intent is 5
to rationalize them and specify what each communication is 6
supposed to do, and also to make more specific the use of 7
regulatory analysis in asking for industry responses to 8
these communications.
9 With that introduction, I would like to turn it 10 over to John Tappert with the NRC.
11 MR. MARSH:
May I make a few opening comments, 12 too, please?
13 DR. FONTANA:
Yes.
14 MR. MARSH:
Thank y 1.
I'm sorry, I wasn't here I
15 when you started.
16 My name is Tad Marsh.
I'm chief of the events 17 assessment, generic commt nications and non-power reactor 10 branch, and good afternoon.
19 Just a couple opening comments.
I think you've
)
i 20 already made most of the things I wanted to refer to before 21 we get started.
I just wanted to highlight that this is a 22 CTM item and we are getting back to the Commission in short 23 order on what we plan on doing and the results of our 24 assessment of generic communications.
25 That paper is due to the Commission coming up next
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month.
We-have -- the draft paper will be discussed in a I) 2 few minutes by Mr. Tappert, and we have circulated around
\\_J 3
within the organization, we've briefed the executive team, 4
we've gotten some thoughts and comments.
So I did want to 5
leave you with the flavor of a work in progress.
It's by no 6
means finalized, so we certainly appreciate your comments on 7
it.
8 We've sent the paper and draft form to the -- to 9
NEI and are going to have a meeting with them sometime after 10 this meeting to get their feedbacks and comments on it, and 11 the overa.11 thrust of the paper and of the issue is adding 12 more order and adding more predictability to the overall 13 generic communication process.
Generic communication is one 14 of most important things that we do.
We are sometimes not b)
(,
very rigorous in our processes for going forward with 15 16 generic communications, and we've looked very hard at our 17 goals and objectives and made sure that we are repeatable 18 and predictable, and we can add some efficiency to the 19 overall pre, cess.
20 So with that, let me turn to Mr. Tappert and ask l
21 him to present to you the results of our study.
22 MR. TAPPERT:
Thank you.
23 Okay.
My name is John Tappert, I'm the events
-24 assessment, generic communications, and non-power reactors 25 branch in NRR.
We're going to be talking about a draft
' )
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Commission paper on the generic communications process right
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now.
V 3
This effort actually started last summer.
The
-4 genesis was in response to Congressional interest in us and 5
other external stakeholdere.
We had a big stakeholders 6
meeting last July, and also there was a' contentious 7
congressional budget process last year, which our previous 8
EDO likened to a near-death experience.
9 As a result of that, a number of items came out of 10 that and are currently being tracked in the Chairman's 11 tasking memo.
Among them is a review of the generic 12 communications process, and one of the milestones in that 13 effort is to deliver this paper to the Commission next 14 month.
]
g-i (gj 15 The guiding principles for the review were to make.
16 it consistent with the NRC change initiatives to reduce 17 unnecessary regulatory burden.
We wanted to improve 18 clarity, we wanted to make it more business-like, 19 predictability and efficiency improvements, and also to try 20 and increase public confidence, if we could.
21 The paper is still currently a draft.
We have 22 four major issues or opportunities for improvement that 23 we've identified.
We're getting comments every day, so it's 24 a work in progress, but as of April 7th, this is what
e 25 have.
1
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1 We're looking at improving the management of'the (J) 2 generic communications process, clearly defining the 3
products, applying the compliance succession to the backfit 4
rule and use of information gathering, particularly use of 5
50.54 (f).
6 The first thing I wanted to show you was the draft 7
process.
Some of this is already in place and some of it's 8
going to be new.
Before generic communications can be 9
developed, an issue has to be identified, and this is done 10 by the staff, you know, throughout the organization, and 11' I
it's done as a result of operational experience reviews or 12 other inputs.
13 Starting last August, the office director for NRR 14 issued a memo in which he is now requiring an early NRR r\\
(_)
15 executive team brief of emerging issues before significant 16 resources are expended, and that's just to review and 17 validate the issue before a lot of work is spent.
We've had 18 examples when a lot of work has been expended on efforts 19 that have to be abandoned because they are not supported by 20 management.
21 So the issue is identified and it goes to ^ n'.
22 They approve it for further work or the issue is dropped.
23 The next gate it has to go through is if the issue is 24
- u. gent, these are the category 1 issues in the CRGR charter, 25 which are basically issues that the office director
[
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determines requires immediate resolution for safety or D
2 compliance considerations.
(}
3 If it is urgent, the net effect of that is to 4
truncate the preparation time for the generic communication 5
and generally ~ynoss public comment, and these issues are 6
going to be transmitted through a bulletin.
We expect these 7
issues to be very rare.
8 If it isn't urgent, then the next step it has to 9
go to is the staff is going to try and initiate some 10 interaction with industry.
This is a DSI 13 role of 11 industry type initiative.
The DSI 13 process is a work in 12 progress.
Currently there's a paper on the initiative with 13 the Commission.
14 Basically it outlines a cooperative arrangement 15 where the agency is going to try and reach out to industry 16 in order to shape and focus the issue to the benefit of both 17 parties.
An effort is going to be made to try to develop a 18 consensus position for voltinteer initiative by the industry.
19 If that consensus can be reached, we want to 20 document that consensus to the use of what we're going to 21 call a regulatory information letter.
This is a new generic 22 communication product; it doesn't exist right now.
I'll get 23 into it later, but basically, in this context, what we will 24 use to identify the issue, identify what the consensus 25 position of the agency and the industry us, and provide that ANN RILEY & ASSOCIATES, LTD.
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in a'public forum, and this would be to support the public
(~)
2 confidence ini tiatives.
v 3
Consensus may not always be reached on these 4
emergent issues, and if that is the case, then the staff 5
will go back to the NRR ET and brief them on the results of 6
the interaction with industry, providing the two positions.
7 If the agency decides to go forward, we will use a generic 8
letter, and that will go through the public comment process 9
and CRGR reviews and the like, or the agency may decide to 10 pursue other issues.
11 DR. APOSTOLAKIS:
Well, this seems to evolve 12 around from issue-specific actions, but I was reading the 13 Senate -- I don't know what document it is, but where there 14 is a complaint that the NRC frequently imposes regulatory 15 requirements using informal approaches to circumvent legal 16 requirements.
This seems to be a broader complaint.
I 17 mean, you don't have to have a specific issue, and what 18 comes to mind, and this committee has commented on it, is 19 the use of core damage frequency goal of ten to the minus 20 four, which sort of de facto became something that the staff 21 has been using when, in fact, there was not a proper process 22 followed to make it a part of the regulations.
23 So how would that be related to En issue?
I mean, 24 you don't have to identify a specific emergent issue to 25 worry about all this -- I mean, the concern seems to be
['
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broader.than this.
Are you addressing the broader concern
()
2 or just --
3 MR. TAPPERT:
We're looking at the generic 4
communications process.
I mean, if you're worried about 5
positions being imposed through other means, we're not 6
addressing that in this paper.
We're trying to put more 7
discipline into the generic communication, specifically 8
generic letters and bulletins, into that kind of process.
9 We want to put screenings and controls and checks and 10 balances on that.
We're not really taking on anything 11 larger than that.
12 DR. APOSTOLAKIS:
And the Commission specifically 13 asked you to do this?
14 MR. TAPPERT:
That particular item in the
()
15 Chairman's tasking memo was to review the generic 16 communications process.
17 MR. MARSH:
One of the thoughts that's in some of i
18 this Senate comments and also the stakeholder comments was i
19 the informality of the generic communication process; that
]
I 20 is, perhaps you're relying on the exemption associated with j
I 21 compliance backfits, and that was a pretty major issue and I
22 we're going to talk more about that today, or the use of 23 information notices improperly or the use of -- the 24 unclarity of the generic communications themselves, what 25 category of issue or response do you use generic letters and
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bulletins and things of that sort.
()
2 We're not taking on the broader issue -- CALs, for 3
example, the use of confirmatory action letters.
There's 4
another criticism the industry had about imposing 5
requirements on licensees through the CAL process.
That's 6
another vehicle.
7 This is confined to just the generic communication 8
part of the -- that was what we were tasked to do through 9
the CTM process.
I think you're going to hear more 10 structure and more formality in the formation of these 11 documents as we go *hrough, especially in the compliance 12 backfit.
There's some very interesting background 13 information that we've been able to get through reviewing 14 the statement of considerations.
()
15 DR. POWERS:
I agree that in your document, one of 16 the things that come through is a much more disciplined 17 process.
18 MR. MARSH:
Righc.
19 DR. POWERS:
There's a puzzling feature of this 20 particular graph here.
It begins with staff identifying an 21 emergent issue.
It goes through a review and then we begin 22 a series of steps, and it might end up being a bulletin 23 issued, but in general, that would be unusual.
More usual, 24 it would come down to the step that says staff works with 25 industry,'and the question posed, is there a consensus'or I
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not, and it's not uncommon for there not to be a consensus, e
(
2 though in recent years, there seems to be a lot of 3
consensus.
But -- and then we come down to another review 4
that can result in dropping the issue.
5 You, I don't understand how failure to achiave 6
consensus with the industry would change the decisions.made 7
at the top of that that this was indeed an iesue.
8 MR. TAPPERT:
Well, it doesn't change that 9
decision and, of course, you'd issued the generic letter.
10 But it is possible that through the working with industry, 11 even though you haven't achieved these consensus, you have 12 developed additional information that leads you to conclude 13 that it's not necessary to pursue that issue any further.
14 DR. POWERS:
It seems to me that would be a
()
15 consensus, then.
I mean, if you got -- if industry got 16 together and said, hey, we don't think there's an issue here 17 because of this and this and this and this, and you guy 18 marrily, that's true, then you achieve consensus.
.-PERT:
That would be a consensus, but 19 i
20 potentially --
21 DR. POWERS:
I think this sends the wrong message 22 here that --
23 MR. TAPPERT:
Right.
24 DR. POWERS:
-- if I don't achieve consensus, then 25 I'm going to drop this issue, and I think that's not the f~
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kind of image that you want to portray --
()
2 MR. TAPPERT:
Yes.
3 DR. POWERS:
-- to the public.
Maybe this is not 4
what you intended these words to say, but that's what these 5
words say to me.
6 MR. MARSH:
I think that's a fair thought.
The 7
idea is to work with the industry in a very linear way in 8
almost all of these concerns and find out where are we in 9
terms of initiatives that are going on.
But it's not meant 10 to just drop them if consensus is not achieved.
11 DR. APOSTOLAKIS:
I suspect that the word 12 consensus there refers to the members of the staff who 13 worked with the industry, and these are not the same as the 14 NRR ET, are they?
)
15 MR. TAPPERT:
Correct.
16 MR. MARSH:
That's true.
17 DR. APOSTOLAKIS:
Okay.
So there was no consensus 18 at that level, then somebody else reviews it, gets convinced 19 by the industry and drops the issue.
20 MR. MARSH:
Right.
21 DR. APOSTOLAKIS:
But you are sending the wrong j
22 message.
23 DR. POWERS:
I think this -- I just think that 24 this is --
25 MR. MARSH:
That wasn't the intent of the slide.
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DR. POWERS:
-- not the intent.
It can't possibly
()
2 be the intention, V
j 3
MR. MARSH:
It's not.
4 DR. POWERS:
Okay.
5 MR. MARSH:
We'll work on the words or work on a 6
feedback arrow or something to imply that it's -- no 7
consensus equals --
8 DR. SEALE:
It's an invalid issue rather than drop 9
the issue.
10 MR. MARSH:
Or that there have been -- other 11 vahicles have taken care of it.
12 DR. POWERS:
I think you can come down here and 13 say, issue resolution, yes or no.
If it's no, then you go 14 l
to a regulatory information letter.
If it's yes, then issue
,( )
15 conclude -- issue is resolved.
16 MR. TAPPERT:
Yes, but -- yes.
Clearly the intent 17 is not to walk away from a safety issue just because there's 18 no consensus.
19 And the next slide I think should be basically 20 what I just said.
Yes, we say if there's an impasse, ET 21 will be briefed and a generic letter may be authorized.
22 One of the other issues we had when we're talking 23 to the stakeholders is there appeared to be some confusion 24 between the product line that we currently have.
There was 25 some-confusion between the use of bulletins and generic i
[)\\
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letters.
Some of that may be some legacy issues.
The old
()
2 Office of Inspection and Enforcement used to issue 3
bulletins, and the Office of NRR used to issue generic i
4 letters and then they were combined and now we issue both.
5 Bulletins currently are typically short-term. urgent-type 6
issues and generic letters may be longer-term programmatic 7
type issues.
But generic letters also can be used for a 8
whole host of other things.
The provide new staff positions 9
and can offer regulatory relief or they introduce new tech 10 spec line improvements and things of that nature.
11 So we try to develop a new set-of generic 12 communications building on what we have to try to make some 13 of those lines a little bit more crisp, and what we have is 14 before you.
Basically, we want to use bulletins -- we're
()
15 going to use them to request action and/or information, but 16 it's only going to be used for urgent or category 1 type 17 issues.
These are the truncated issues that are going to 18 bypass public comment.
They will, of course, be reviewed by 19 CRFR and we'll typically invoke 50.54 (f) for their 20 information requirements.
21 Generic letters, on the other hand, --
22 DR. POWERS:
It seems to me that this --
23 MR. TAPPERT:
Yes, sir.
decision that you have between 24 DR. POWERS:
25 bulletins and other kinds of communications hinges crucially I\\
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on'the decision of whether it's urgent or not, and I guess
()
2 I'm asking how do.I go about deciding whether something is 3
urgent or not?
4 MR. TAPPERT:
The urgency is basically the 5
decision of the office director with the support of the 6
staff.
But there are issues that require immediace 7
resolution for safety or compliance considerations.
The 8
last one that I recall would be we had some issues a couple 9
years ago about control rods not fully inserting during 10 SCRAMS.
That was considered a bulletin type issue.
Most 13 things are not.
12 MR. MARSH:
The past is not a very good reflection 13 of this type of differentiation at all.
We've had 14 situations that have been issued as bulletins and bypassed
()
15 the public comment period, and on reflection, this was not 16 the appropriate thing.
17 Risk is an element that needs to be mentioned 18 here, too, if there is safety or risk considerations or 19 strong compliance issues.
The thrust here is to reserve 20 bulletins for the smallest set of issues that are there and 21 not to over-use them.
22 DR. POWERS:
What I see is this problem.
I mean, 23 your document is trying to set up some sort of discipline in 24 25 MR. MARSH:
Hierarchy.
[)
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DR. POWERS:
-- this process, and I have an office
()
2 director today and he has one set of views on what's urgent, 3
but there's some turnover in this. organization, and so 4
tomorrow, I may have a different guy with a different set of 5
views on what's urgent or not.
6 Meanwhile, there's an industry out here that is 7
seeing what to them looks like an inconsistency coming out, 8
and I'm wondering if you don't have to go in and at least 9
provide some guidance in the form of examples and maybe more 10 explicitly on what you mean by urgency so that the outside 11 viewers don't see this thing as changing from one day to the 12 next.
13 Now, I will agree, there's going to be some 14 change, but it should not be see change, which right now, O
15 with just, this is urgent or not, you could have that see g j 16 change.
17 MR. TAPPERT:
Yes.
Currently, I think the only 18 guidance is in the CRGR charter, which defines these 19 category 1 issues.
The idea is to have a very high bar, and 20 21 DR. POWERS:
But you need to get that across 22 because it does not come across in your existing document,
{
23 at least it didn't come across to me.
24 MR. MARSH:
Do you think that by referring you I
25 back to the charter, the CRGR for category 1 items, that I
I f
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that language doesn't make it clear enough?
()
2 DR. POWERS:
I don't think that.
I think that you 3
need to make it -- yes, I think the best possible thing is 4
if you can say, urgent means urgent and here's an example.
5 MR. TAPPERT:
That's fine-.
I was hoping you would 6
not ask us to put something quantitative --
7 DR. POWERS:
No, no.
I think that would be 8
difficult to the extreme.
9 MR. TAPPERT:
Right.
Right.
10 DR. POWERS:
I think imparting what you mean by 11 urgent, and if you can pluck out an example from the past 12 whether you think it was appropriate --
13 MR. TAPPERT:
Okay.
14 DR. POWERS:
-- and maybe if nothing else,
()
15 anecdotally you can not write in the document, but 16 anecdotally, you can say, and here's one example of 17 something that's not urgent.
18 MR. TAPPERT:
Okay.
19 DR. POWERS:
Because I think tnere's going to be a 20 subjectivity here that we ought to allow.
Otherwise, we get 21 robots for directors.
22 MR. TAPPERT:
Right.
23 DR. MILLER:
I have a couple of questions on what j
24 you say on this overhead.
)
25 MR. TAPPERT:
Sure.
i l
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DR. MILLER:
And maybe you're going to address (n) 2 them later.
If you are, just tell me to hold off 3
On bulletins, it says "may invoke 50.54(f)."
On 4
generic letter, it says " typically will not invoke 5
50.54 (f). "
And under regulatory information, it says "CRFR 6
will review as needed," and the other place, it says, "may 7
when appropriate."
Now, all those seems like waffle words 8
to me; all could be the same in the end.
9 MR. TAPPERT:
Right.
10 DR. MILLER:
So is there a criteria on which those 11 decisions are going to be made or some judgment, or who is 12 going to do that?
13 MR. TAPPERT:
Well, the criteria on the backfit 14 rule is a lot clearer, you know.
Anything that could
()
15 potentially be interpreted as posing a new requirement --
l 16 DR. MILLER:
I agree.
Yes.
l i
17 MR. TAPPERT:
The question of 50.54 (f), which is a
)
i 18 requirement that allows the NRC to go out and demand 19 information from licensees to make a determination whether 20 to modify, suspend or revoke their license, that's an issue 21 that's currently under active discussion in the staff right 22 now.
l 23 DR. MILLER:
Why does that appear under, say, l
l 24 bulletins and generic letters both?
25 MR. TAPPERT:
Currently, --
( 'I
\\
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DR. MILLER:
What's the difference between typical
(
)
2 and not invoke and may invoke?
3 MR. TAPPERT:
My expectation would be that it 4
would in bulletins under all circumrtances and generally 5
would not in generic letters.
But there may be exceptions, 6
and --
7 DR. MILLER:
So generic letters usually would not, 8
9 MR. TAPPERT:
I would think --
10 DR. MILLER:
-- bulletins usually would or --
11 MR. TAPPERT:
Yes.
12 DR. MILLER:
Okay.
13 MR. TAPPERT:
But there may be exceptions.
I 14 mean, I could say always and never, but that may not be
()
15 appropriate, and we may change our position on that as well.
16 MR. MARSH:
The general idea here is again to 17 avoid the over-use of the 50.54 (f), which was the 18 traditional language which was included in almost all of I
i 19 these.
That was a specific comment that we got from our i
20 stakeholders.
21 DR. MILLER:
Isn't that not only a lot of the 22 comments, isn't that what the allegation or implication was 23
-- you were invoking new requirements came through~that one?
24 MR. MARSH:
I don't believe that was the thrust.
25 I believe the thrust of the concern was, 50.54 (f) language
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is pretty strong language, okay?
It says, we're thinking
()
2 about taking your license away, okay?
And that's not really 3
what we meant in these generic communications.
It wasn't 4
imposing any new requirements; it's a big hammer that's not 5
appropriate for the type of communications being conveyed, 6
whereas in the bulletin, it may be appropriate, and that's 7
what we mean by, you would expect the small set of generic 8
requirements about which you have the highest safety 9
significance to issue the strongest language that you need 10 to imply the' agency's concern, whereas under generic 11 letters, where you're not as concerned, you don't need and 12 should not use that type of language.
13 The concerns that we've heard from -- John, I'm 14 probably on your territory here, but we heard that industry,
()
15 utilities would get these generic communications with this 16 language in it and it would impart a special priority and a 17 special emphasis and would dic: ate their actions, their 18 scheduling, their resource allocation to the exclusion of 19 other things, and it was not the appropriate emphasis.
20 I know what we had done in the days of old, we 21 thought 50. 54 (f) was the appropriate language; it was the 22 legality that we were adding to these communications.
We 23 thought this was the way to do that.
We used to have just 24 generic letters, and we would just write licensees letters 25 without there being any legal stamp to them.
And so in days
[]/
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of old, we would say, we better put something legal
()
2 associated with this.
What's our vehicle?
Ah-ha, 50.54 (f),
3 without really looking at the language that was being used 4
in the regulation itself.
5 DR. POWERS:
I think what you looked at was the 6
language that begins the paragraph, --
j 7
MR. MARSH:
Right.
8 DR. POWERS:
-- which says you can require 9
information of licensees anytime you want to, and not the 10 closing paragraph, --
11 MR. MARSH:
Which is the strongest possible 12 language.
13 DR. POWERS:
-- which says that we're thinking of 1
14 changing and modifying your license, and that looked like a
()
15 blunderbuss --
16 MR. MARSH:
Right.
17 DR. POWERS:
-- to the industry as a whole because 18 that language looks like it's directed at an indiviuual 19 licensee, whereas the generic letter is obviously going to 20 all of them.
21 MR. MARSH:
Exactly.
Exactly.
That's what we're 22 trying to remedy here by not using that language unless you 23 absolutely mean that.
That's the deafferentation that we're 24 trying to impart here.
25 DR. MILLER:
So somebody will make -- or somewhere
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along the -- you make that decision --
O 2
-MR. MARSH:
Yes.
V 3
DR. MILLER:
absolutely.
4 MR. MARSH:
Yes, sir.
5 DR. MILLER:
And that's a decision'-- is that part 6
of the decision tree back there?
7 MR. TAPPERT:
The 50.54?
That's not explicit.
A DR. POWERS:
You also have to understand, there's 9
-- in 50.54, the licensee is required to respond under oath.
10 MR. MARSH:
Right.
11 DR. POWERS:
And that's an imposition on the 12 director of an rperating entity when he's being asked to.
1?
collect a bunch of infnrmation that's done at lower levels, 14 and then he has a major problem of QA/QC --
O
( /
15 MR. MARSH:
Right.
16 LR. POWERS:
-- that he's got to impose, because 17 he goes to jail if they Screw this up, and when, in fact, 18 the agency may be just asking for --
19 MR. MARSH:
Right.
20 DR. POWERS:
-- something of a fairly low 21 significance relative to that oath.
Right.
22 MR. MARF :
23 DR. POWERS:
And so you can appreciate the 24 headache that this language might impose when, in fact, all 25 that was done, you're saying, yes, we have a right to ask
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you for information.
[JT.
2 MR. MARSH:
Exactly.
3 MR TAPPERT:
The difference is in the bulletin.
4 Generic letters are consistent with the concept of a very 5
high bar for the bulletins, and those have been the issues 6
with the 50.54 (f).
7 Moving on to the generic letters.
These will also 8
request action and/or, you know, request a response, but 9
they will never be urgent.
And so we're drawing that line.
10 The bulletin's urgent; generic letter is not urgent.
11 A new requirement on generic letters, well, they 12 cannot be issued without a prior attempt to work with the 13 industry, okay?
And that currently isn't the case.
Will alwayh be issued for public comment.
Will always be 14 N
15 reviewed by CRGT against the backfit rule.
16 DR. POWhkS:
Let me ask you --
17 MR. TAPPERT:
Certainly.
18 DR. POWERS:
A favor.
Typically when you produce 19 these generic letters, we're offered the opportunity to 20 review them both before and after public comment.
And we've 21 been incredibly quixotic about whether to do it before or 22 after or both.
I mean, I could appreciate the staff if they 23 came in and said we haven't got a clue how to schedule our 24 time because we don't know whether you're going to review 25 before, after, or both, f'N ANN RILEY & ASSOCIATES, LTD.
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MR. MARSH:
Right.
[
)
2 DR. POWERS:
And one of the things we want to V
3 struggle with is as an institution ourselves and in the 4
spirit of getting a little more disciplined in this-process 5
have ourselves some criteria for whether we review before 6
public comments or after public comments.
7 I wonder if you and your staff could give this 8
half an hour of thought and see if you can come up with some 9
criteria.by which we could decide whether to review before 10 or after.
11 MR. MARSH:
Okay.
12 DR. POWERS:
Understanding it comes from your f
1 13 perspective.
But I think that would help us a lot, and it 14 offers you the opportunity to at least anticipate for your O) 15 own scheduling purposes.
(,
16 MR. MARSH:
Sure.
Be glad to.
17 DR. POWERS:
Whether we review before or after.
18 We're going to be looking at it and thinking about it h
19 ourselves, but I think we would really appreciate your 20 views --
21 MR. MARSH:
Sure.
22 DR. POWERS:
And maybe between the two of us, we 23 can come up with something that there is a mutual 24 understanding in the scheduling that this is going to be 25 done afterwards versus how the one's going to be done l
(
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1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) _842-0034
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1 before.
/~5
-2 MR. MARSH:
Sure.
Be glad to.
(j 3
MR. TAPPERT:
Okay?
I guess the next product is 4
something new that we want to introduce, and that's this 5
regulatory information letter.
As was mentioned before, 6
currently generic letters have a number of functions that'do 7
not require a response, and we'd like to roll these into a 8
new kind of product.
9 You know, we've used them to transmit NUREGs or 10 transmit inspection guidance like the operability 11 determinations in 91-18 and things like that.
And those 12 types of things are very important to communicate to the 13 industry, but we wanted to put them in a different kind of 14 vehicle that would not -- which they would know right from O
15 the get-go that there's no clock running on when they have
(,j A'
16 to respond to it.
17 DR. MILLER:
So, in the old days, generic letters 18 would have done some of these items.
Right?
19 MR. TAPPERT:
Certainly.
Right.
20 Yes, it's going to capture a lot of the old 21 generic letters.
So we expect the number of generic letters 22 to go down, for a couple of reasons.
One, we're excluding 23 all these policy-type issues,.and also we're going to 24 attempt to work with the industry more and maybe head some 25 of these things off..
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And that's the use that we want to use for these 2
new regulatory information letters, is to document the 3
consensus positions that are arrived at some of these 4
emergent issues that we've had off other generic letters.
5 And also we're going to eliminate administrative 6
letters, which are kind of muddles sometimes, and we're 7
going to capture those types of chings in this as well.
8 CRGR review will be as needed, depending on what 9
type of things, if we're putting out 2nspection guidance or 10 reg guides or things like that, typically CRGR reviews those 11 types of things.
12 DR. MILLER:
There's a pretty defined criterion 13 when CRGR has been written.
14 MR. TAPPERT:
Correct.
And that's not going to
()
15 change.
And some of these will fall within the purview of 16 their charter, and therefore will be reviewed.
17 And then finally we're going to keep information 18 notices, end basically these are just going to provide 19 information that's derived from operational experience.
20 There's no requirements.
It's just for information to help 21 licensees perhaps avoid similar problems at their 22 facilities.
23 DR. BARTON:
I notice that information notices 24 aren't included in your flow chart on how you're going to 25 process generic-communications, and is that just an
(:
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afterthought or oversight, or don't you need to go through
(
2 this process to decide whether what you want to put out 3
eventually is an information notice?
4 MR. TAPPERT:
Right.
An information notice is a 5
little bit different in a number of respects.
The resources 6
associated with developing and issuing an information letter 7
are much less than a generic letter or a bulletin.
8 DR. BARTON:
I understand that.
9 MR. TAPPERT:
We're not going to the executive 10 team to talk about ideas we have for information notices.
11 We're handling"that at the branch level.
And so that's 12 really a different track.
13 MR. MARSH:
Just with one caveat I'd like to add 14 to that, to tb: info.mation notice.
Sometimes information C\\
(,)
15 notices touch subjects that are very sensitive.
16 DR. BARTON:
Um-hum.
17 MR. MARSH:
Like sometimes in the fire-protection 18 area they touch sensitive subjects, and so the ET does want 19 to be briefed on issues that in the judgment of the line 20 organization or the division directors or myself as a branch 21 chief in this branch need to bring up to the ET if they 22 touch those subjects.
It's a subjective area, and you don't 23 want to impart rules for that, but it relies on Judgment of 24 ongoing issues.
23 MR. TAPPERT:
Historically we've had some ANN RILEY & ASSOCIATES, LTD.
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information notices _that have tread very fine lines to
()
2 developing new policy positions or transmitting new 3
technical policy positions.
4 DR. POWERS:
Especially in fire protection.
5 MR. TAPPERT:
Right Exactly.
6 DR. POWERS:
Fire protection is the --
7 DR. MILLER:
Actually there's a generic letter and 8
an information notice that really address the same issue and 9
said similar things.
10 Mk. TAPPERT:
Yes.
And information notices really 11 shouldn't be used to transmit that type of stuff, and with 12 this new regulatory information letter we won't have to.
13 You have a new vehicle.
People have been shying away from 14 generic letters because they've been -- the significant
()
15 resources associated with those.
And we're trying to kind 16 of split the difference with this reg info letter.
17 DR. FONTANA:
With respect to your information 18 notices, on page 7 of the draft SECY it says information 19 notices may not convey or imply new requirements, blah blah 20 blah, and may not require or request specific actions.
21 Shouldn't that "may" be "should" or "shall" not?
22 Because you have other things that may or may not, but the 23 impression I got from reading this, that information notices 24 would not convey new requirements or request specific 25 actions.
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Did I read that properly?
l'}
2 MR. TAPPERT:
They do not and should not, will C
3 not, they shouldn't.
4
[ Laughter.
5 MR. MARSH:
We'll fix that.
6 DR. BARTON:
Yes, your words in here are kind of 7
wuzzy, though.
You say you may.
So that leaves it open.
8 MR. TAPPERT:
Okay.
May not means they may not, 9
to prevent, to preclude.
10 MR. MARSH:
We'll make it clear for you.
We don't 11 want to leave an open door for this one.
12 DR. SEALE:
Yes.
Some wills.
13 MR. MARSH:
Right.
14 MR. TAPPERT:
And the thing about the information
()
15 notices, since there are no new staff positions, signature 1.<
review is not required for those documents.
17 There have been some comments about the names.,
18 They may still be confusing.
We have information in two of 19 the things.
We have letters in two of the things.
So the 20 names may change, but that's basically the outline of the 21 products that we're trying to go forward with.
22 Another concern which was raised by the 23 stakeholders was generic backfitting through the use of 24 generic communications and other items I think somebody 25 raised, that thare's broader issues.
Other efforts have f)
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1 looked at confirmatory action letters and requests for 3
(
2 additional information which were also candidates for 3
improper backfitting, which are being addressed by other l
4 people during other efforts, but we were looking at the 5
generic communications aspects of'it.
6 And just by way of background, bulletins and 7
generic letters are not backfits, because they don't 8
technically impose any requirec. ants.
Only orders and rules 9
do that sort of thing.
But for pragmatic reasons, licensees 10 feel a very strong obligation to respond and conform with 11 these generic communications.
Therefore, we have procedures 12 that treat them as if they were backfits.
And that's the 13 CRGR process, to ensure that they're all in compliance with l
14 the backfit rule.
(%
(,/
15 The backfit rule does require a value-impact 16 assessment for all backfits except for purposes of 17 compliance for adequate protection.
However, most generic 18 communications do invoke this compliance exception to the L
19 backfit rule, and as a consequence, they do not do these j
a 20 value--impact assessments.
21 There were repeated criticisms by the industry of 22 this practice.
Many times they take exception with cur 23 interpretation of the compliance exception.
I 24 So we took a look at this issue again, and what we 25 thought would be most appropriate is to perhaps work with j
i l
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the industry to try and develop simplified analysis
/
2 techniques to evaluate _ values and impacts for actions even
(
3 when the compliance exception is invoked.
So even though 4
the compliance exception is invoked and you dont have to 5
demonstrate tt
- ubstantial safety benefit with justifiable 6
cause, it seems to us to be appropriate to at least have a 7
qualitative view of what the costs being imposed are and 8
what 20 the expected benefit of that.
9 So rather than compliance at all costs, we find 10 out well, what is tne cost of compliance, and is that 11 appropriate.
And the reason for doing that simplified 12 analysis is just to provide additional infc.rmation to the 13 decision makers when they make the decisicn to issue that 14 generic communication.
(
15 DR. POWERS:
I would think that you would run into 16 legal barriers here.
It seems to me that you're bordering 17 on using cost in a decision making process dealing with 18 adequate protection, and it's being done by subterfuge here.
19 Have you run into any legal concern over this?
1 20 MR. TAPPERT:
Cost -- adequate protection is 21 clearly addressed in the backfit rule, and, I mean, yes.
22 Adequate protection backfits cannot consider cost and must 23 be imposed.
There's no ifs, ands, or buts about it.
If 24 it's an adequate-protection issue, it has to be imposed.
25 The problem is with compliance issues, okay?
It I)
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doesn't say that about compliance issues.
But compliance j
2 issues can be imposed witho t doing a value-impact 3
assessment.
And we say well, let's just do a limited one to 4
try and get a qualitative feel for what the costs and what 5
the benefits are.
Maybe the generic communication is the 6
wrong vehicle.
Maybe we need to change tha rule.
Maybe we 7
need to grant relief.
There might be other avenues to 8
- pursue, 1
9 But the idea is just to have additional 10 information rather than you have the issue, you determine 11 its compliance, stop.
We say well, don't stop there, take 12 the next step, you know, and understand what you're doing.
13 DR. POWERS:
I guess I'm perplexed a little bit.
14 MR. TAPPERT:
But not for adequate protection.
()
15 DR. POWERS:
If I define adequate protection as 16 compliance with the regulations, why is a compliance issue 17 not part of adequate protection?
18 MR. TAPPERT:
I don't think they're necessarily 19 synonymous.
20 DR. POWERS:
And I guess I'm asking why do you 21 think that they're not synonymous.
22 MR. TAPPERT:
I guess I don't have a real good 23 answer to that, except they always are addressed as two 24 separate categories, you know.
The backfit rule talks about j
25 safety enhancement backfits, it talks about compliance 1
[}
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backfits, and it talks about adequate protection backfits.
()
2 If they were synonymous, there would be no reason to talk 3
about the two different types.
They further go on to 4
discuss the fact that adequate protection backfits must 5
always be imposed.
It doesn't say that about compliance 6
So there is some subset of issues that speak to 7
compliance with rules but do not reach the threshold of 8
adequate protection.
9 There are rules, talking to some of our OGC 10 friends, there are rules that are adequate-protection rules 11 and there are rules that are safety-enhancement rules.
12 Compliance with a safety-enhancement rule would not fall 13 within the purview of an adequate-protection backfit.
14 MR. MARSH:
I'm not sure -- we're trying to answer l
15 your question; I'm not sure we're --
16 DR. POWERS:
Yes, I think we'll both concede that 17 you need to think about this one a little bit.
18 MR. MARSH:
Yes.
I mean, you could -- Com SHA and 19 the Commission has said that you can be in compliance with 20 the regulations and still not meet tne adequate-protection 21 criteria.
There may be issues which you must impose new 22 requirements.
You can still be in compliance, but there's 23 something inadequate about your regulatory framework such 24 that you must impose a new requirement.
That's an 25 adequate-protection type of threshold..
Absent any problems
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with the regulatory framework, compliance should assure
()
2 adequate protection.
3 DR. POWERS:
Compliance means -- it's presumptive 4
that if you're in compliance --
5 MR. MARSH:
It is presumptive.
6 DR. POWERS:
It is adequate for protection.
7 MR. MARSH:
Yes, sir 8
DR. POWERS:
The inverse and the converse of those 9
statement --
10 MR. MARSH:
May not be true.
11 DR. POWERS:
No one said anything about them.
12 MR. MARSH:
That's right.
13 DR. POWERS:
Okay.
14 MR. MARSH:
Right.
()
15 DR. POWERS:
And so I agree, it is conceptually 16 possible to be out of compliance but Etill have adequate 17 protection.
18 MR. MARSH:
Yes, sir.
19 DR. POWERS:
Conceptually.
20 MR. MARSH:
True.
And you could be in 21 compliance and not have adequate protection.
22 DR. POWERS:
And similarly you can be fully in 23 compliance and not have adequate protection.
24 MR. MARSH:
True.
25 DR. POWERS:
Okay.
. [9 ANN RILEY &-ASSOCIATES, LTD.
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MR. MARSH:
- True, f
2 DR. POWERS:
Because it's only a presumption.
3 MR. MARSH:
True.
4 DR. POWERS:
And it can be disproved by evidence.
5 MR. MARSH:
And the Commission has said that.
6 DR. POWERS:
Um-hum.
7 MR. MARSH:
In their --
8 DR. POWERS:
And I agree with that.
9 MR. MARSH:
And it makes sense.
We have on 10 various times in the past imposed new requiremerits because 11 we felt the regulations were not sufficient, again the 12 statiun-blackout rule, where we had to change the regulatory 13 framawork because it didn't address problems adequatel; 14 The thrust here is to address the concern which we O
(_j 15 feel has legitimacy, that is add order to your process 16 first.
Some of these compliance backfits are not weli 17 thought out on our part and we want to do a better job at 18 the compliance backfits.
Now how do we do a better job?
19 All the way through that chain it is working 20 through the industry.
Improve the dialogue.
Find out what 21 programs are ongoing with the industry.
How can they be 22 addressed?
-- which may obviate ways for you to even issue 23 a generic communication in the first place.
That is the 24 more preferable route.
25 If a generic communication is needed, that second
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part of the line, then be very careful about the basis under l)
2 which you are proceeding.
Don't rely exclusively on this
\\s 3
compliance backfit without understanding what it mean.
I 4
mean that is useful information -- if not bases for the 5
decision it's decision-making information.
1 6
DR. POWERS:
I think you need another paragraph in 7
the document that makes it clear that when you do this 8
mini-value impact assessment that it is being done on a 9
compliance issue and not an adequate protection issue.
10 MR. MARSH:
Fair.
11 DR. POWERS:
And that what its intentions are and 12 this distinction that you have drawn between compliance and
.3 adequate protection, just to cover yourself on a legal 14 standing.
4 15 MR. MARSH:
Fair.
16 DR. POWERS:
I think the overall strategy that you 17 are going to place a step in here that requires some 18 communication with the industry to assure that you are not 19 operating based on a misapprehension or not fully aware of I
20 all of the things that the industry has done may mean that 21 this concern is strictly one of legal theory and not of 22 practicality, but I think I would worry a little bit about 23 the legal theory here.
24 MR. MARSH:
There will be others which will come 25 after us which will look at this and if it doesn't have the j')'";
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adequate framework -- and the paragraph you are. suggesting
()
2 is consistent with what we have found from going through the 3
statement of considerations and the backfit rule too.
4 MR, TAPPERT:
The original backfit rule was thrown 5
out for that very reason.
l DR. POWERS:
That's right.
6 7
MR. TAPPERT:
Because you cannot consider cost 8
radical protection issues and that was always the' intent of 9
what we were discussing as well.
10 DR. POWERS:
I understand.
11 MR. TAPPERT:
That is our discussion of backfit.
12 Does anyone have any questions?
Okay.
13 There is another ingredient here that we didn't 14 bring up in the letter We weren't sure whether it should
(
15 be brought up in the letter but it has to do with how we are 16 going to do these backfits within the organization.
17 There is oftentimes a reliance on compliance 18 backfit because there is a reluctance to do this cost 19 benefit study and so if you interpret the regulation one way 20 you can avoid doing a lot of work.
What we are trying to 21 say -- we want to do this limited cost benefit study pretty 22 routinely and organizationally we want it to be done in one 23 place rather than have it be done by different organizations 24 and lose consistency and have it be a burden beyond the 25 technical issue that is involved, so we are going to
[ '}
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centralize where those backfits -- where those analyses will j
2 be done
\\,,)
l 3
The last item that we discuss in the papers is 4
information gathering, particularly the use of the j
5 requirement 10 CFR 50.54 (f) which requires licensees to 6
respond with their affirmation to enable the Commission to j
7 determine whether or not the license should be modified, s
8 suspended or revoked.
9 We got some stakeholrier comments that they thought 10 that this was a little heavy-handed, that it was 11 disproportionate to the needs for that information and that 12 it was having an officer of a company sign something on 13 their oath or affirmation really didn't change how the 14 agency would use that information.
O)
(,
15 If we did not cite that requirement, is it 16 credible to assume the licensees will response to the due 17 diligence and I t' ink of course it is.
They would respond, 18 I believe.
4 19 DR. POWERS:
I mean they are still required for 20 due diligence.
All you are eliminating is the affirmation 21 part.
22 MR. TAPPERT:
Right.
There's other 23 requirements -- 50.9 requiree complete and accurate 24 information in all material respect.
I 25 DR. POWERS:
Right.
I
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MR. TAPPERT:
And that was still the reply.
I) 2 DR. POWERS:
That seems to be the most powerful V
3 argument that you have here is that the licensee still has a 4
very real incentive to do the best job he can on that.
5 MR. TAPPERT:
And there's other -- the Office of 6
Management and Budget also has requi_ements that they place 7
on Federal agencies to justify all information requests, and 8
every year we have to go out and justify an OMB clearance 9
number, which is also required in all these generic 10 comm"nications.
That puts additional controls on how we do 11 these things.
12 DR. POWERS:
That's kind of an effete -- I mean 13 right now you have got kind of a blanket clearance from OMB 14 on this one, so yes, it exists but it is more in principle n/
(,
15 than in fact.
16 MR. TAPPERT:
Eut in theory it is another control 17 on these type things.
18 The proposal in the paper right now, you know, 19 subject to change, is to really limit the use of this, 20 citing this requirement to really the very high threshold 21 issues.
We were thinking maybe just eliminate the 22 bul3atins.
Maybe that is not -- then there might be some 23 subset of generic letters which also would be appropriate to 24 use that and we are still kind of hasning that out.
25 Other people have suggested perhaps just tailoring
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the language or maybe changing the-language in 50.54 (f) to
-2'
.make it clear that we are really not talking about revoking 3
the license.
At' worst we are really talking about 4
potentially an order, depending on what we set'back from you 5
or a modification to the license.
6 Finally, 50.54 (f) in addition to providing/this 7
authority to demand information from the licensees also puts 8
a requirement to the Staff to evaluate the burden imposed' 9
and justify it in terms of the safety significance of the 10 issue, of the information of the issue that you are getting
.11 information on.
12 That analysis needs to be done also but there is 13 an exception to verify compliance again with the licensing 14 basis.
We feel that that standard would still be an (f
15 appropriate standard to use, even if you don't invoke the 16 requirement itself.
17 In a nutshell, that is basically what is in the 18 paper.
That's all the slides we have, so if there's any 19
-other questions --
20 MR. MARSH:
Should this pass the test of going 21 through our management processes and being acceptable, then 22 there is a lot more work to be done to implement this and 23 there's issues about things that are in process already --
24 at what point do you make them fit into the new regime?
25 There's office letters which will need to be Q
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modified to implement the new procedure as well, and
[J) 2 associated with the CTM and telling the Commission what we 3
intend on doing there is a communication plant too, now we 4
intend on communicating this new process to the agency and 5
to the staff, so there's a lot more work associated with 6
this new concept.
7 Again, the thrust is to make it a better process, 8
to more clearly define these vehicles, these communications, 9
and to e.dd some order to it.
10 If one looks back on the past generic 11 communications, there's more examples of imprecision than I 12 think of precision, unfortunately.
He all have those 13 specifics in mind, I'm afraid.
14 MR. BARTON:
It definitely seems like an O
( j 15 improvement.
16 MR. MARSH:
Thank you.
17 DR. POWERS:
Let me see if I can understand a 18 little bit, make sure I understand the difference between a 19 regulatory information letter and an information notice.
20 My tnderstanding from what you have said here is 21 that information noticae -- notices -- will be attempting to 22 capture operational experience and will be more under the 23 control of Branch Chiefs rather than this overall process, 24 that there will be some effort to inform the ET, some effort 25 to inform you, but otherwise.they are kind of freer?
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MR. MARSH:
They go through our branch.
()
2 DR. POWERS:
Through your branch.
3 MR. MARSH:
All the information notices go through 4
our branch.
They are issued by either myself or through the 5
Division Director, but they all go through us.
6 DR. POWERS:
So they are capturing operational 7
experience?
8 MR. MARSH:
Normally.
That is the norm and that 9
is the thrust at this point.
It is normally LER driven, 10 50.72 driven.
It's experience as you see it come through 11 that you want to collect and you want to hold up to the 12 industry as being -- gosh, there's been three or four 13 situations like this -- for your information -- no action 14 needed.
Look at this.
That is what it is intended to do.
()
15 MR. TAPPERT:
Plant X and Y had Problem A.
16 DR. POWERS:
Sure.
I mean we have seen them and 17 they are very useful actually.
18 MR. MARSH:
They impart -- we have been asked why s
19 are you issuing information notices when the indur _ry has 20 issued an LER or a 50.72.
You are trying to share 21 information to the industry -- isn't that good enough?
22 Isn't an LER good enough?
And the answer to that for me is 2.'
no.
When the agency gathers together two or three events 24 and puts an agency perspective on it, without it being a new 25 requirement, it is different.
It sets it up higher and it fD ANN RILEY & ASSOCIATES, LTD.
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is not LERs are normally the licensee's spin on an event.
b 2
It is how they see it with their perspective.
D 3
Sometimes you-need to convey.it in a different 4
way.
5 DR. POWERS:
I think it can be critically. argued 6
that a lesson that we got out of the events at Davis-Besse 7
versus TMI was that there are issues that are a little 8
higher than just the LER and that it does behoove everyone, 9
even if everyone in the world knew it, to put it down on a 10 piece of paper that safs, yeah, we all know this.
11 MR. MARSH:
Absolutely.
12 The regulatory information follows from your 13 network and whatnot, and so it has more of a total 14 management chain and a broad field of coverage.
'O,
(_,
15 MR. TAPPERT:
Right.
It also covers other types 16 of things.
17 DR. POWERS:
Sure.
18 MR. TAPPERT:
That is our catch-all now.
19 DR. POWERS:
That will be the most common 20 communication of the three top ones.
21 MR. TAPPERT:
Yes.
22 DR. POWERS:
Yes.
23 MR. TAPPERT:
The expectation anyway.
You know, 24 this is a conceptual, this is a plan.
We are trying to move 25 forward and do better, but, you know, a lot of things are
[ \\
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still being developed.
The DSI-13 framework, it has been I'
2 sketched out, but all the details haven't been filled in, V) 3 and that is the key component of what we are talking about 4
here.
5 MR. MARSH:
John, would you hold up the charcoal 6
filter generic letter as a letter which at least has in it 7
this qualitative value impact study?
8 MR. TAPPERT:
It has been a whils since I read 9
that.
I think we did have some discussion of benefit and 10 some -- I don't know if there is any cost information in 11 there or not, I can't recall.
12 MR. MARSH:
Yeah, I think there is some cost 13 information.
It was thought to be a compliance backfit.
14 MR. TAPPERT:
Right.
(Oj 15 MR. MARSH:
As it went through the system, the 16 first thing -- the first change to that generic letter was 17 let 's purge the 50. 54 (f) language out because -- to embrace 1
18 what we are talking about here, and also to do some limited i
19 value impact.
That means to provide the decision makers 20 with what are we talking about, what is the cost and what is 21 the benefit, even though we thought it was a compliance 22 backfit.
23 MR. BARTON: to your draft SECY had a 24 block on there for ACRS briefing for bulletins, Generic 25 letters or the new informacion letter, and it said upon l
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request.
Wouldn't ACRS want'to review all bulletins?-
()
2 MR. TAPPERT:
I think that is the current 8._.i -
3
. guidance, is that you have the'-- you can request.
We offer
~
4 to bri?f'you on any of these, and if you choose to have that 4-5~
briefing, we will certain conduct it, but I think it is on 6
an ad hoc basis right now.
It is not 100 percent, is it?
7 DR. POWERS:
I think we get noticed on
- I think 8
you let us kncw about everything.
9 MR. TAPPERT:
We let you know about everything, 10 but you don't necessarily get briefed on everything.
11 DR. POWERS:
That's right.
We pick and choose and 12 that -- and, as I said, our picking and choosing is 13 sometimes quixotic.
14 MR. TAPPERT:
Would you like some suggestions?
35 MR. BARTON:
Well, I can see when, before public s
~J 16 or after public comment.
17 MR. MARSH:
Right.
18 MR. BARTON:
This looks like, you know, we would 19 have to request a briefing.
20 DR. POWERS:
I think there is a memo of 21 understanding.
22 MR. BARTON:
Okay.
23 DR. POWERS:
That it is not like we have to have a 24 spy to go find out about it.
They let us know that they are 25' doing this.
o, ; ]/
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47 11 request.
Wouldn't ACRS want to review all bulletins?
. y~~
..MR. TAPPERT:
I think that is-the' current D).
+
3' guidance, is that you.have the -- you can request.
We offer
_4 to brief you on any of.these, and if you choose to have-that 5L briefing, we will certain conduct'it, but I think it is on.
6 an.ad hoc basis.right now.
It is not 100 percent, is it?
7-DR. POWERS:
I think we get noticed on -- I think 8
you let us know about everything.
9 MR. TAPPERT:
We let you know about everything, 10 but you don't necessarily get briefed on everything.
11 DR. POWERS:
That's right.
We pick and choose and 12 that -- and, as I said, our picking and choosing is 13-sometimes quixotic.
14 MR. TAPPERT:
Would you like some suggestions?
(' %
s
)
15 MR. BARTON:
Well, I can see when, before public
_/
16 or after public comment.
17 MR. MARSH-Right.
18' MR. BARTON:
This looks like, you know, we would 19 have to request a briefing.
20 DR. POWERS:
I think there is a memo of 21 understanding.
-22 MR. BARTON:
Okay.
23 DR. POWERS:
That it is not like we have to have a 24 spy.to go find out about it.
They let us know that they are
- 25.
doing this.
f(]
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MR. MARSH:
Right.
(
2 DR. POWERS:
And then we put it through our P&P 3
process' and if we choose not to, we send them a 4
Larkins-gram, a memorandum that says we are not going to 5
review this or we are not going to review this till after i
6 public comments, or we are going to hear it by what.
7 MR. BARTON:
Okay.
If you feel it is adequately 8
covered, that is fine.
9 DR. POWERS:
And what I want to do is try to put 10
-- give us some guidelines which, in turn, turns into 11 guidelines for you so that you can better anticipate what we 12 might do.
13 MR. MARSH:
Right.
Sure.
We will be glad to do 14 some thinking on that, but there are some natural divisions rs
(
)
15 thau we have -- which would probably guide you, too, I would x_/
16 think.
Is it of high safety significance?
You would want 17 to be briefed.
18 DR. POWERS:
Well, I am sure that we would look at 19 bulletins.
20 MR. MARSH:
Right.
21 DR. POWERS:
Even though they are on an urgent 22 pathway, and we won't be in the -- we won't be on that 23 pathway, but we will do them in parallel.
24 MR. MARSH:
Right.
25 DR. "7WERS:
I am sure that generic letters will
.'~')
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still attract our attention.
[D 2
MR. MARSH:
Right.
J 3'
DR. POWERS:
I suspect that regulatory information 4
letters based on mutual interest and things like that.
- But, 5
no, I am just trying to get some of the standardization 6
here.
I am just following along exactly your plan, put-some 7
discipline and a little better anticipation.
8 MR. MARSH:
I would be glad to.
Sure.
9 DR. FONTANA:
Any additional questions of Mr.
10 Tappert or Mr. Marsh?
11 DR. WALLIS:
I have.had a question all along, 12 which I have wondered if I should ask.
13 DR. FONTANA:
You don't have to.
14 DR. WALLIS:
What is the role of the ACRS in all f
15 this?
It seems to me there is something that needs to be 16 done, and the staff can work it out with industry.
What are 17 you expecting us to do?
Or what do we expect to contribute 18 to this issue, or these activities?
19 DR. POWERS:
Well, I can tell you historically 20 that there have been one than one issue where we have been 21 instigators of generic 3etters, and been more than one 22 instance where we have said this is a non-issue, why are you 23 pursuing it?
24 DR. WALLIS:
That's right.
Is this some issue 25 which requires us attention, that we can help to resolve?
I l
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can't sort of figure out what is.
2 DR. POWERS:
Well, if it is a bulletin, I T
3 guarantee you it gets our attention, because it is a 4
bulletin, by definition means that there is some reason that 5
the plants --
6 DR. WALLIS:
So we need to know what is going to 7
on in case something might come up.
8 DR. POWERS:
Sure.
9 DR. WALLIS:
Okay.
10 MR. MARSH:
Okay.
Thank you very much.
11 DR. FONTANA:
Okay.
Thank you.
NEI has requested 12 time to make a presentation.
Alex Marion.
13 MR. MARION:
Thank you.
I don't have a 14 presentation, but there are a couple of comments I would n()
15 like to make.
My name is Alex Marion, I am the Director of 16 the Programs Department at the Nuclear Energy Institute, and 17 I thank you for the opportunity to chat with you about this 18 generic communication process.
19 Overall, I believe the NRC staff should be 20 commended in the way they articulated the industry's 21 concerns with the past generic communication process, and I 22 think during the staff presentation, those concerns were 23 identified in terms of use of the compliance exception, 24 invoking 50.54 (f) as a basis for action or response, if you 25 will, from licensees.
9 ANN RILEY & ASSOCIATES, LTD.
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The process that war previously used to define
()
2 when a bulletin is issued versus a generic letter was nr 3
clear, and I think in the staff proposal, they are movins 4
forward and providing significant clarity.
Historically, we 5
have been very successful in working with the NRC staff to 6
identify the problem that needs to be addressed, and once-7 that identification and understanding is established, it 8
becomes very clear in terms of what the role of the 9
regulator or the NRC should be in dealing with that problem.
10 So that we are very pleased to see the emphasis on the early 11 interaction with industry.
We, quite frankly, think that is 12 becoming more and more important as we look into the future.
13 In terms of the process that is proposed in the 14 draft SECY, we fundamentally believe in the concept of
()
15 simplicity.
I think everyone kind of agrees with that.
And 16 so it is not clear to us the rationale or the NRC's thinking 17 for this new mechanisms for generic communication that they 18 refer to as regulatory information 'etter.
I think, 19 historically, recognizing that generic letters were used in 20 the past, it is not clear to us at this point what the 21 differentiation or what the distinction is becween generic 22 letters as the staff currently proposes and this new generic 23 comn.inication mechanism, so that is one area we hope to 24 clarify.
25 Let me just offer a thought about bulletins.
I
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think, histcrically, bulletins have always dealt with
()
2 specific hardware related issues.
There is aLpiece of 3
equipment that the NRC knows has been used at a number of 4
plants in the industry, and the NRC feels immediate action 5
is necessary to deal with that problem in terms of the 6
performance of the equipment and the performance of the 7
equipment within the system, et cetera.
And I think that 8
procesr., or the ability of the NRC to deal with those kinds 9
of issues needs to continue.
10 But, again, I think, over the years where the NRC 11 and industry have interacted on the scope and magnitude of 12 the problem, that has been very effective in helping the NRC 13 articulate the specific requirements to be imposed in the 14 bulletin or the specific requested actions, and I hope that
()
15 that process continues.
16 We are looking forward to meeting with the NRC I
17 staff sometime in the not too distant future, hopefully, to 18 get a better understanding of what is being recommended.
19 I found the flow chart or decision chart that the 20 NRC identified during the presentation earlier to be of 21 interest because I had the same concerns that some of you, 22 ACRS members, had relative to the identification of the 23 emerging concern, the specific issue -- what is the problem 24 that creates some concern or interest on the part of the 25 NRC, and what is the best way to deal with it?
- But,
-(
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fundamentally, in terms of identifying the best way to deal e~s
[
)
2 with it, there are a couple of other questions that need to
\\_/
3 be addressed, and that is one of safety significance, in 4
terms of impact.
There is another once with regard to 5
adequate protection, and whether or not the concern falls 6
within the scope or the existing framework of a regulatory 7
requirement, as captured in 10 CFR Part 50.
Those are the 8
kinds of questions and issues that need to get thrashed out 9
and a better understanding established to make this new 10 process work.
11 DR. KRESS:
In your opinion, what should be the 12 criteria for this urgency gate?
What should constitute 13 something urgent enough to issue a bull'etin?
14 MR. MARION:
Well, historica31y, it has been (n) 15 situations where the NRC was aware of equipment being g
16 installed in a plant whose performance was questionable.
17 And I go back to the bulletin on Rosemount transmitters, the 18 bulletins on substandard circuit breakers, and those were 19 both excellent examples of where the industry and the NRC 20 worked together to understand the scope and magnitude of the 21 problem.
And once you achieve that understanding, then it 22 becomes clear what NRC's statutory role and responsibility 23 is, and in those cases, they issued bulletins focused on 1
24 safety-related applications.
25 In a complementary way, the industry, through ANN RILEY & ASSOCIATES, LTD.
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NUMARC at the time,-pursued action that the NRC felt was
()
2 necessary, but more comfortable with the industry taking the 3
lead on dealing with.
And I think when both efforts in 4
parallel were completed, the problem was adequately resolved 5
and addressed by everyone concerned.
6 So I think the urgency is based upon specific 7
knowledge of a hardware problem"at a plant 8
DR. KRESS:
That hardware should be 9
safety-related?
10 MR. MARION:
Fundamentally safety-related, yeah.
11 That is -- you know, that is the way it has worked in the 12 past, and it is an area I think we need to discuss in detail 13 with the NRC staff to see if it serves us into the future, 14 in light of this new process.
()
15 There were some comments made during the staff 16 presentation about DSI-13 and I would like to just elaborate 17 on it a little bit.
There are two elements of that 18 direction setting initiative.
The fir' Jals with NRC 19 participation and endorsement in codes and standards and the 20 second deals with NRC use of voluntary industry initiatives 21 in lieu of regulatory action, and there are two separate 22 SECY letters that have been issued on both of those.
23 However, I hope we don' t move forward in de.aling with these 24 separately.
I think they are all connected.
25 Obviously, the question that I have of the NRC is, O)
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in tarms of NRC endorsement of a code or standard at some
()
2 time in the future, what generic communication, or which 3
generic ccmmunication mechanism will be used?
4 Will it be a generic letter or regulatory 5
information letter or some other mechanism.
I am not sure, 6
but those are the kinds of questions we need to address.
7 With regard to voluntary initiatives we are very 8
sensitive -- yes?
9 DR. POWERS:
The answer to the question -- if I 10 follow their decision logic, I suppose if they saw a 11 consensus and that it's pretty standard and it was 12 attractive to them, they would get together and say you, 13 industry, do you find this attractive?
And you say oh, 14 yeah, we're 100 percent on that -- then it would come out as
()
15 a regulatory information letter.
16 MR. MARION:
I would concur with your 17 interpretation but I think we need to have detailed 18 discussions with the NRC to make sure that that is adequate i
l 19 and sufficient from their perspective.
1 20 The point I was going to make about voluntary 21 industry initiatives is that we recognize that there are 22 some things that the NRC has not choice but to do in terms 23 of regulatory action.
In our reviewing the SECY letter on 24 the voluntary initiative, which is SECY-99-163, I believe, 25 it because clear that the NRC Staff concept of regulatory f
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action may be different than the industry's concept of what
>()
2 regulatory action is, so given that that terminology is used 3
throughout all three of these documents and these three 4
areas, that is one of the key areas I think we need to have 5
some good extensive dialogue with the NRC Staff on.
6 I can tell you now if, depending on which 7
interpretation you use, your understanding and reaction to 8
the SECY letters can be quite different, and I think we need 9
to clarify that given the importance of these documents.
10 Also --
11 DR. POWERS:
I think what ycu are saying, to 12 interrupt you, is that the industry is a little more 13 sensitive, and things that NRC thinks "well, we are just 14 trying to get information and what not and learn a little
)
13 more about that issue" his the impact on the licensee of NRC 16 is taking an action here, and I am being forced to do things 17 that I would not ordinarily do, and so it must be an NRC 18 action, whereas these guys over here will think, well, we 19 are just trying to get a little information and think about 20 this thing.
Your gain is turned up higher than theirs on 21 this.
22 MR. MARION:
Well, if I might just take it a i
23 little bit further, if you read that SECY on voluntary 24 industry initiatives and think about regulatory 25 decision-making process, a lot of what the NRC has ANN RILEY & ASSOCIATES, LTD.
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articulated I submit makes sense, but if you look at it from
()
2 the standpoint of an actionable thing in terms of the output 3
of NRC's regulatory decision-making process, you get a 4
different read on a document and so that is why I think that 5
is a very important point that needs to be clarified.
6 One other area we are very careful about is -- and 7
there is a flavor of this in all three letters -- and there 8
is a suggestion that the voluntary industry action, whether 9
it is through an industry-wide effort via the Nuclear Energy 10 Institute or through a particular owners' group or a 11 combination of owners groups or EPRI, there is language that 12 suggests that this is an alternative option for the NRC 13 Staff to pursue because they can't justify it through their 14 internal processes.
)
15 That is something that has to be very carefully 16 thought about and discussed because it would not serve 17 either the industry or the NRC well if externalized to the 18 public this perception exists, okay?
-- and I just plant 19 that for your thought and future consideration.
20 In closing, let me just say that overall we are 21 really positive of the improvements that have been 22 articulated.
There are some things that we need further 23 clarification on and we are looking forward to working with 24 the Staff in all of these areas in the hope that generic 25 communications in the future once the process is agreed to I
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1 are understandable to the NRC Staff and understandable to
(' ]\\
2 the recipients who are the utility licensees as well as to
\\_
3 the public, and I think that is our fundamental objective in 4
all of this, and so I would like to ask if there are any 5
questions at this point.
6 DR. POWERS:
I guess I am a little surprised that 7
you -- we haven't been more concerned about this difference 8
between the regulatory information letter and the 9
information notice.
10 MR. MARION:
Oh, I can get into that a little bit 11 more, if you like.
12 (Laughter.]
13 DR. POWERS:
I would like to hear what you have to 14 say.
)
15 MR. MARION:
My concern is terminologv is 16 terminology but I think today given the legal ramifications 17 of everything you say and do, you have to be extremely 18 careful about the words that you use.
19 My concern is not so much in terms of the 20 regulatory information letter and the information notice, 21 because I think information notices have a certain standing 22 and a history that is well established and understood.
23 The area of clarification that I have is between a 24 regulatory information letter and a generic letter.
That is 25 where I think we need to thrash out some specific details,
[
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and I little bit-of a clarification on-bulletins.
I think
()
2 if bulletins we : : focused on hardware related problems it 3
would clearly take that mechanism of generic _ communication 4
and separate it from the other three, and I think bulletins 5
are very important and when NRC issues one they are taken 6
very, very seriously by the industry.
7 In terms of the information request -- you got me 8
started now, Dr. Powers, since we are still ahead of 9
schedule I would like to take a couple more minutes, if that 10 is okay.
11 In the discussion in the draft SECY the NRC 12 indicates that the generic letters will be used to request 13 action or request information so the red flag that raises is 14 request action, and the thinking is that if you use A(,/
15 bulletins to request action that are immediate, then why not 16 use a bulletin?
If you want to request action that is of a 17 different priority then you need to identify and 18 characterize what kind of action that is, and it gets back 19 to this earlier comment 7 made about regulatory action on 20 the part of the NRC versus the recipients.
21 DR. MILLER:
But you said you thought bulletins 22 should be primarily on hardware issues.
23 MR. MARION:
Yes.
24 DR. MILLER:
There could be actions of course that 25 would not be hardware issues.
That would apply through the V(h.
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avenue of the generic letter.
()
2 MR.'MARION.:
Well, that is something that we would 3
like to discuss with the Staff.
I am going through my 4
recollection of bulletins.
The majority of them, nearly 5
all -- okay, there might be one or two -- they are really 6
focused on hardware issues.
'/
DR. MILLER:
I think the other question would be 8
do they real2y need generic letters and regulatory 9
information, both categories.
10 MR. MARION:
That is one of the questions I think 11 w.
.leed to address.
That is a good point.
12 DR. POWERS:
I guess I am really concerned if we 13 put a constraint on bulletins to be strictly hardware, just 14 because I kind of look at the world and I say we have got an O)
(,
15 awful lot of operational experience.
A lot of the hardware 16 problems arE disappearing.
But we may have other problems 17 that operational experience hasn't resolved that may appear 18 and I wouldn't want to foreclose, it seems to me, the 19 possibility of using a bulletin if it was called for on a 20 non-haraware problem.
21 MR. MARION:
That is a fair point but that is 22 something we'd like to discuss with the Staff and thrash out 23 the details.
Examples of that I think would be very 24 helpful.
25 One other aspect of the regulatory information t'~D ANN RILEY & ASSOCIATES, LTD.
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1 letter, and recognize that the SECY paper is a work in 2
progress as I think Tad Marsh indicated earlier, is one of 3
the first reasons they are going to be used is to announce 4
Staff technical or policy positions not previously 5
communicated to the industry.
6 That again raises the flag and it gets back to 7
this compliance exception discussion.
The thinking is, 8
well, if it is a regulatory position then it shouls be 9
articulated in the regulation -- fundamental, okay?
-- or l
10 it should be articulated in the licensing basis commitment 11 by a licensee -- very fundamental.
12 If there is something else that needs to be 13 addressed via this communication mechanism then we need to 14 find out what that is and get it integrated into this 15 process so it is very clear when you use any one of these 16 four mechanisms and that is another area of question I have 17 on this regulatory information letter.
18 That's pretty much it because I can go on with 19 specific details but I would rather discuss them with the 20 NRC Staff and work it out.
2' DR. FONTANA:
Additional questions?
Any from the 22 floor?
23 (No response.]
24 DR. FONTANA:
Well, thank you very much.
25 MR. MARION:
Thar.k you.
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DR. FONTANA:
Enjoyed the discussion.
Turn the
[V'l 2
meeting back to the Chairman.
3 DR. POWERS:
Thank you.
I am going to' declare a 4
recess I believe until 3 o' clock.
5
[ Recess.]
6 DR. POWERS:
I know that the Members have. spent 7
the last 45 minutes in detailed discussions on highly 8
technical issues, and that they will be prepared to delve 9
into the next topic with an enthusiasm that's unparalleled.
10 And I am also informed by John that he's making arrangements 11 that all future breaks will be accompanied with the same 12 sorts of refreshments, and his failure to do so should be 13 brought to his attention immediately.
14 DR. SHACK:
I'd say there's a year's supply of
()
15 stuff still sitting there.
16
[ Laughter.]
17 DR. SEALE:
What do you think you're going to get 18 Saturday?
19 DR. POWERS:
The next topic on our agenda is a 20 potpourri of everything that you've ever wanted to know 21 about the pressure boundary in a reactor, and it's been the 22 subject of a subcommittee that hopefully has distilled out 23 of this the salient points.
So I won't anticipate what all 24 we'll hear about, but I'll turn it over to Professor Seale.
25 DR. SEALE:
I think Bill's going to start it-,
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DR. SHACK:
- Im going toistart-and.then I m going; 2
to recuse myself.
3.
DR. POWERS:
Dr. Shack.will begin the discussions 4
'then.
5 1DR. SHACK:
Okay.
We'had a Materials-and 6
Metallurgy Subcommittee 1 meeting on March 24'and 25 where we 7
did hear about a variety of things.
Among them was.the 8
-resolution of Generic Letter 92-01.
This generic letter 9
arose out of the Yankee Rowe situation where the -- we 10 wanted to avoid some surprises and have the licensees review 11 the bases for their vessel integrity and their embrittlement 12 programs.
13 That initial generic letter did produce a surprise 14 of its own and in Palisades, and anothe' Teneric letter,
()
15 92-01, Rev.
1, went out where the licensees were asked to.
16 look at the impact of any new data on their embrittlement 17 analyses and to -- the NRC used the responses from that 18 generic letter to come up with a complete and integrated-19 data' base on reactor vessel integrity, the so-called reactor 20 vessel integrity data base.
21 One other item we heard about related to pressure 22 vessel integrity was a change to the ASME Appendix G, which-23 was changed to use the K-1-c initiation toughness rather 24 than the arrest toughness in doing your pressure-temperature 25 curve evaluations.
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Essentially it's a rather sensible change that
(- )
2 since you are worried about initiating a crack, the original 3
work to use the arrest had been for fear that there were 4
brittle regions that would pop in and you would have to 5
arrest.
Since nobody's ever found these brittle regions in 6
an operating reactor, they decided to change the initiation 7
toughness curve.
8 That will give the operator some flexibility in 9
going through their startups.
The licensees will have to 10 apply for an exemption to use this as a proposed 11 alternative, since we already have an Appendix G -- another 12 Appendix G in 10 CFR 50 that prescribes the use of the 13 K-1-a.
14 We heard about a new initiative from the PWR
()
15 people, a materials reliability program, dealing with a 16 number of issues that arose out of the work that they had 17 done on Alloy 600 cracking on pressure vessel penetrt*, ions.
18 They're picking a number of issues to work on related to 19 pressure vessel integrity, pressurized thermal shock and PT 20 limits.
They'll also be doing some work on reactor pressure 21 vessel internals in PWRs, and they've also decided to look 22 at some problems with thermal fatigue in PWRs.
23 We heard a resolution of Generic Letter 97-01, 24 which was involved with the Alloy 600 penetrations in 25 reactor pressure vessels.
You may recall that in France
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they've had a substantial-number of-these penetrations that 2
exhibit ed cracking.
In the U.S. the. owners -- or the PWR 3
owners' groups developed susceptibility models and a number 4
of the high-susceptibility. plants have now done inspections.
5 Basically a half dozen of these plants have had 6
comprehensive exams, and only one vessel had penetration, at 7
D.C.
Cook did they find any flaws, and these were three 8
small flaws.
And the staff has accepted the industry 9
integrated program for the management of this problem, and 10 it's intended by the industry that this will be a management 11 for the operating reactors and for license renewal.
12 We also heard from the BWR vessel Internals 13 program people, BWR VIP, which was actually the model for 14 the PWR owners' group.
The BWR group started out in 1994 to 15 address the issues arising from the core shroud cracks.
And I
16 they have decided to sort of proactively address a number of 17 issues associated with BWR vessels and internals.
We heard 18 a rather detailed presentation on BWRVIP-05 dealing with the 19 inspection of the circumferential welds in pressure vessels 20 where they effectively managed to convince the tIRC to grant 21 them relief from the inspection of those circumferential I
22 welds base 3 essentially on a probabilistic fracture 23 mechanics argument.
l 24 DR. POWERS:
That was a particular case where the 25 staff went through and did their own independent analyses, ANN RILEY & ASSOCIATES, LTD.
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and the convincing was that they came to the same (n) 2 conclusions.
\\/
3 DR. SHACK:
They've also_ develope a number of 4
inspection and assessment guidelines for most of the BWR 5
internals.
Again the only one of those internals that's 6
really covered by the ASME code is the shroud.
They have 7
now developed inspection and assessment guidelines for 8
essentially all the components in the BWR jet pumps and 9
such, guidelines for hydrogen water chemistry.
10 Again, the staff has not accepted all these BWR 11 VIP documents, and many of them are still under review, and 12 they're in various states, but again, it seems to be a very 13 successful program.
The BWR VIP people have now decided to 14 move on to dealing with problems in the recirculation r
(,h) 15 piping.
I guess they're not going to change the name, but 16 they'll just move on to essentially update some of the 17 inspection efforts associated with NUREG-0313.
18 We also heard an update on the work on the piping 19 seismic design criteria.
If you recall, the 1994 addenda to 20 the ASME Code, section 3, raised allowable seismic stresses 21 for piping.
The NRC decided not to accept that.
They 22 thought the stresses were too high, that there was a 23 misinterpretation of the results.
The code has set up a 24 Special working group, and I guess the answer is they're 25 still working on the problem.
It hasn't really been 1
/)
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. resolved yet.
They have some other approaches to defining-(
2 margins that are being considered.
So thisJis still a work 3
in progress.
4 One particular element _of interest is the 5
discussion of proposed modification of 10 CFR 50.55(a).
6 Currently plants are required to update their in-service 7
incpection programs every 10 years to the latest code case 8
that's incorporated by reference in the code.
One of the 9
proposed modifications is to change 50.55 (a) to eliminate 10 this requirement to go through the update, that it would be 11 made voluntary rather than mandatory.
And we may want to 12 write a letter discussing that.
13 The other issues that were presented were dealing 14 with steam generator tube integrity, a slightly different
()
15 approach to the handling the regulatory issues in which the 16 staff is really considering endorsing a guideline being 17 developed by the industry.
There's a number of unresolved 18 technical and regulatory i.ssues associated with that yet, 19 and some risk issues associated with the steam generator 20 tube integrity.
Again, this is a question of whether we're 21 working on a design -- current design basis or considering 22 risk when we're considering changes to the steam generator 23 tube integrity.
24 DR. SHACK:
We'll be hearing presentations on that 25 today.
We'll also be hearing some presentations on the
(
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proposed approach for modifying the PTS rule and some of the
()
2 other ongoing research activities associated with the 3
pressure vessel research integrity program.
4 I'm not sure who is going to start off.
5 MR. DUDLEY:
That will be Tom Scarbrough.
6 DR. SEALE:
Tom Scarbrough I think is the --
7 MR. DUDLEY:
With 50.55 (a).
8 DR. APOSTOLAKIS:
So do you recuse yourself now?
9 DR. SHACK:
No, not yet.
10 DR. APOSTOLAKIS:
Not yet.
Still have the power.
11 MR. SCARBROUGH:
Okay.
I'll wait until you get 12 your copies there.
13 Okay.
Good afternoon.
My name is Tom Scarbrough, 14 I'm in the mechanical engineering branch of NRR, and we're
()
15 going to give you a very brief overview of
- 7. proposal to 16 supplement an amendment -- a proposed amendment to 10 CFR 17 50.55(a) that was issued in December of 1997, and it deals 18 with the ten-year update requirement.
19 Okay.
Just a little introduction.
Let me sort of this is kind of an overview slide, and then some slides 20 21 that have some more detail, which I won't go into much 22 discussion.
But the regulations require plant owners to 23 construct, inspect and test specific components in 24 accordance with ASME boiler and pressure vessel code.
The 25 current requirements in 50.55(a) require licensees to update ANN RILEY & ASSOCIATES, LTD.
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their in-service inspection and in-service testing programs (a) 2 every 120 months, every ten years.
V' 3
In December of 1997, the NRC published an 4
amendment to 50.55(a) to update the regulations to 5
incorporate by reference more recent additions and addenda 6
of the boiler and pressure vessel code and also a new code 7
which deals more with IST service testing, the code for 8
operation and maintenance of nuclear power plants, and I'll 9
indicate which versions they were going to endorse in just a 10 minute.
11 Based on public comments we've received and the 12 maturity of the code, the scaff is considering eliminating 13 the requirement for licensees to update their ISI and IST 14 programs to every ten years.
So to start that off, we
(%
(,)
15 prepared a supplement to that proposed rule which we intend 16 to send out for public comment which would propose the 17 elimination of that ten-year update requirement, and we 18 discussed this in Commission paper SECY 99-017.
The 19 Commission sent us a staff requirements memo accepting that 20 proposal to go out for public comment, but also indicating 21 that we should address advantages and disadvantages, 22 benefits and impacts of that proposal before the proposed 23 amendment goes final.
24 Okay.
The current requirements in 50.55(a) 25 currently require that class 1, 2 and 3 components be ANN RILEY & ASSOCIATES, LTD.
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constructed to the 1989 edition of section 3, so it's a few
,O
.2 years ol'd.
In terms of inspection, also.the 1989 edition of
-y/
3 section 3.
Metal containment and concrete containment =
4 components are required to be inspected to the 1992 edition 5
of section 11, and then class 1, 2,
and 3 pumps and valves 6
are to be tested in accordance with the 1989, and then there 7
is a slight reference to the ASME OEM Code, but it's very 8
preliminary in that the code was more of a standard back at 9
that point in time.
10 But that's what the current requirenkuts are.
11 Then in 1997, December, there was a proposal to 12 revise 50.55(a) to incorporate by reference the 1995 edition 13 with the 1996 addenda of section 11 for ISI requirements for 14 class 1, 2,
and 3.
It also required PWRs, pressurized water
(
15 reactors, to perform volumetric examinations of class 1 16 portion welds in high pressure safety injection systems.
It 17 also expedited the implementation of Appendix 8 of the 1996 18 addenda dealing with the qualification of personnel 19 performing ultrasonic examinations.
20 It incorporated by reference the 1995 edition with 21 the 1996 addenda of the ASME O&M code for IST requirements 22 for pumps and valves and also required licensees to 23 supplement their IST stroke time testing for motor-operated 24 valves, but it also -- and it also permitted the
~
25 implementation of certain code cases and port 1'ons of ASME
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code.
\\
[d 2
So that's what was proposed back in '97.
3 Now, the supplement will go out and just be an 4
additional add-on to that December '97.
We're not going to 5
do anything more than just deal with the ten-year update t
6 issue in the supplement, and we hope to have it out for 7
public comment in the next -- within the next month.
It's 8
with the EDO right now for his signature.
9 What the supplement would do, it would eliminate 10 or proposed elimination of the requirement for licensees to 11 update their ISI and IST programs.
It would establish a 12 baseline edition for the ASME code of ISI and IST, and 13 that's something that we're going to specifically ask for 14 public comment regarding as to what is the proper baseline.
()
15 But right now, in the current version, we are proposing a 16 1989 edition for ISI and IST requirements for class 1, 2 and 17 3 components, to 1992 edition for subsections IWE and IWL of 18 section 11 having to do with containments, and then the 1995 19 edition with the '96 addenda for the Appendix 8 requirements 20 regarding the qualification of personnel.
21 It will also allow licensees to voluntarily 22 implement later editions of the code.
There would be 23 conditions on that.
24 Now, for future licensees, they would be --
25 continue to be required to incorporate the latest version of
[]/
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72 1-the code endorsed by reference in the regulations prior to
[V) 2 their receiving their operating license.
But once they 3
implemented that version of the code, they would not be 4
required to update periodically like licensees do now.
5 DR. FONTANA:
Future licenses also refer to 6
7 MR. SCARBROUGH:
They would continue to use what 8
they're doing now.
9 DR. FONTANA:
What they're already doing.
10 MR. SCARBROUGH:
Right.
11 Okay.
So as you can imagine, this has a number of 12 issues associated with it, and in our public comment notice, 13 we outlined all of these and highlight all of these issues 14 that we would like to have public comment to come into us so O)
(
15 that we an address these.
16 For example, the potential effect on safety, will 17 this have any reductions in the effectiveness of the ASME 18 code?
What is the proper baseline edition to select -- '89?
19
'95?
'98?
The regulatory benefits and burdens to 20 licensees, also industry suppliers, nuclear insurers, the 21 states and standards organizations all have a role here 22 regarding the 50.55(a) ASME code, and we want to find out as 23 much as we can regarding the benefits and burdens associated 24 with them.
25 The burden on licensees to update their INIC l\\ -
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programs.
We've received differing information in terma of (G
2 how significant that burden is and we want to be able to N/
3 characterize it properly as we go forward.
4 We want to know more about the potential effect on 5
the licensees' submittals in terms of the number and details 6
if we establish a baseline and licensees want to use later 7
versions.
8 We also want to find out if there's going to be a 9
significant change in the range of code editions that 10 licensees might be applying which might have an effect on 11 inspection effectiveness and efficiency.
12 We also want to find out about any potential 13 effect on processing of licensing actions.
The regulatory 14 guides that endorse the code, h,
ill that be processed, tO
(,/
15 how will that be taken care of, and any effect that this 16 might have on the risk-informed ISI a: 'l IST initiatives, 17 which we have a lot of effort involved with.
18 We also want to find out more about the potential 19 effect on state and other organizations that rely on the 20 code in their interactions.
There's a lot of 21 cross-referencing there in the states and nuclear insurers 22 we want find out more about.
Also, we want to be able to 23 determine what's the proper application of portions of 24 future ASME codes.
It's referred to as cherry-picking in 25 terms of future codes, and how will that be dealt with in
[
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terns of licensees wanting to use only portions of later l
2 codes.
3 So those are the major issues that we feel we need 4
to discuss.
The Commission in their SRM back to us on this 5
issue indicated that they also want to hear more about the 6
advantages and disadvantages before this goes final.
So we 7
intend to deal with that before this is finalized.
8 Future plans.
We have scheduled a public workshop 9
for May 27th here in the 2 White Flint North auditorium.
10 We've invited ASME and NEI.
We're also going to make sure 11 that it's on the Web, NRC Website, and also get as much 12 information as we can out there to potential stakeholders so l
13 that they can feel that they should come and provide input i
14 as much as possible.
15 Then once we go through the public workshop and 16 the document is issued for public comment, which we hope to 17 have happen sometime the first of May, then we're going to 18 have a 60-day public comment period.
That's the current l
l 19 plan.
After that, we'll take the comments we receive from i
^J the public workshop and the interactions there, the written 21 comments we receive from all the stakeholders and the publi-22 and begin the preparation of the final draft rule.
23 So we hope in the fall of '99 to hava that ready 24 for NRC agency review, nd then, in late 1999, to be able to 25 present a draft final rule to the ACRS and CRGR for their ANN RILEY & ASSOCIATES, LTD.
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and your review, and then in early 2000, to submit a final
()
2 rule to the Commission for their approval.
3 So that's our current plan.
I'll be happy to 4
answer any questions about it.
5 DR. POWERS:
A lot of the topics that you're 6
dealing with reflect on the ASME code.
In fact, I think you 7
had one of them there that's entitled something -- impact on i
8 the effectiveness of the ASME code.
(
9 MR. SCARBROUGH:
Right.
10 DR. POWERS:
My understanding is the ASME has a 11 standing committee that annually updates relevant portions 12 of the code.
13 MR. SCARBROUGH:
It's an ongoing basis, yes.
(
14 DR. POWERS:
I wondered how this schedule 1,,()
15 interfaced with their schedule, and was this committee going 16 to be able to respond to your call for public comments?
17 MR. SCARBROUGH:
Yes.
We've talked to Jerry 18 Eisenberg, who is our contact with ASME, and we rescheduled 19 the public workshop to fit their schedule better, and also 20 extended the public comment period from an initial 30 days 21 to 60 days to be able *' -- better be able to serve them, to 22 allow them to give us.., much comment as they possibly can, 23 So yes, we've been in discussion with'them on 24 that, and also with NEI as well.
25 DR. FONTANA:
Should we be concerned that they O)
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don't have a requirement to update their ISA and IST every 2
10 years?
3 MR. SCARBROUGH:
I think one of-the ongoing 4
philosophies with this process of the 10-year update was 5
over time the testing requirements, the techniques, the new 6
equipment was e
.mprovement in safety over time.
If you go 7
back and look at the very early descriptions of the 50.55 (a) 8 and the statement of considerations, that was one of the 9
bases for the 10-year update requirement. If that is 10 eliminated that will have to be taken into consideration or 11 the plants as they are now with the equipment they have now, 12 the techniques they have now, is that sufficient f., r 13 long-term?
Now if we did -- as the ASME code is continued 14 to be revised -- if we did find something that was safety
(
15 significant that met a backfit test, of course we would gu 16 through that process and apply that, so that wouldn't 17 eliminate the 51.09 backfit process.
That would still be in 18 place.
19 Then also licensees would have the option to 20 update where they saw a benefit to that and I know there's 21 going to be an effort to try to have licensees take future 22 editions of the code in total rather than cherry-picking 23 bits and pieces so that you get the whole concept of the 24 code rather than just bits and pieces.
25 I know that there's going to be an effort to do h
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that as well, so I think there's going to be an effort there 2.
to continue the improvement of the techniques over time, so s
3 I think there is some safety net there and there's some 4
goals to try to make sure that we continue to improve the 5
techniques and such but I think it is a consideration 6
without a mandated 10-year update, as we have done in the 7
past, will that have any adverse effect on safety and that 8
is something we will have to consider.
9 MR. BARTON:
I noticed at the March 25th meeting 10 that the dates, your dates here have slipped since the dates 11 several weeks ago.
Are you confident in these dates now?
12 MR. SCARBROUGH:
As much as I was on the other 13 ones.
14
[ Laughter.]
'(9
/
,/
15 MR. BARTON:
That's not very comforting.
16 MR. SCARBROUGH:
Yes, I know.
What we did was 17 there were a couple of things that caused us to adjust it.
18 Some of the dates we gave the subcommittee a few weeks ago 19 were the actual dates in the SECY paper, 99-17, and it 20 took -- the Commission is very interested in this issue and 21 took a significant look at it and took longer to review than 22 we had anticipated, so we go off to a late start there.
23 In addition, we decided to extend the public 24 comment period from 30 days to 60 days, so we added another 25 month on, so what we basically did was we slid the schedule
(.-.
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about two months from the original December, late December
)
2
' 99 to like February 2000.
w/
3 MR. BARTON:
Okay.
Understand what you did.
4 MR. SCARBROUGH:
Okay.
5 DR. POWERS:
I guess I am intrigued by a lot of 6
this and I am going to offer some comments that you don't 7
really have to respond to because they are really more 8
directed to the rest of the members, but if you have a 9
response I would be interested in what you have to say.
10 In our recent quadripartite meeting we saw 11 numerous of our partners discussing their approaches to 12 episodic updates of plant safety, and it was not uncommon 13 for them to have 5 and 10 year updates in which they were 14 requirinc plants to use the latest of technology.
I think ry
,)
15 that was true with all three of our partners -- Germany, 16 France and Japan.
17 They did that because they don't have a prescribed 18 license period and in fact in principle each of their 19 licensees at all times is supposed to be up to date, but 20 they have these major reviews at either 5 or 10 years.
We 21 seem to be moving even further away from that concept that 22 the rest of the Western reactor world has.
23 I am wondering if it isn't our obligation to make 24 sure the Commission is aware that the rest of the world is 25 taking a different view on this process than we are.
]
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DR. APOSTOLAKIS:
What is the rest of the world
(
2 updating?
ISI requirements too?
Are they using ASME codes 3
and so on or --
4 DR. POWERS:
It is not uncommon for them to use 5
the ASME code, particularly in Japan.
I am not absolutely 6
positive about France.
It wouldn' t, trprise me in Germany.
7 I mean they clearly have a different regulatory 8
approach but nevertheless I am wondering if it isn't useful 9
for the Commission to be aware that that we are taking a 10 tack that in not the same -- better or worse, I am not sure 11 we are in a position to comment on -- but it is certainly 12 different.
13 DR. APOSTOLAKIS:
It seems to me we would have to 14 tell them more than just that.
/"N
( )
15 DR. POWERS:
Why?
16 DR. APOSTOLAKIS:
Well, just to say that somebody 17 is updating his or her requirements more frequently without 18 explaining what kinds of requirements you are talking about, 19 and why they have to do it and all that would not be very 20 useful to them, would it?
Of course the system may be 21 different.
Maybe their requirements are different.
I don't 22 know.
23 If you only say that they are doing it more 24 frequently there is an assumption the.e that we are all 25 operating using the same codes and the same --
(~'
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DR. POWERS:
7 think it is not the frequency that
()
2 is of interest here.
It is that when they come to these 10 3
year reviews they say, okay, you should be using the latest 4
technology, which means you use the latest version of the 5
codes, you use the latest research results to re-evaluate 6
your plant.
7 DR. SHACK:
We saw something of that in the 8
presentation we had on the Swiss enalysis.
9 DR. POWERS:
That's right.
10 DR. SHACK:
They really wanted their plants to be 11 at the state-of-the-art.
12 DR. POWERS:
At the state-of-the-art, that's 13 right.
I think the Swiss do the same thing.
They are not a 14 member of the quadripartite, but I am pretty sure most of (9
,/
15 Europe does this.
It is their approach.
16 We have a little different regulatory philosophy 17 and that is that what existed at the time you got your 18 license you can preserve.,
You have the option to update it 19 but you can preserve that through all time, so somewhere in 20 this planet there is every version of the ASME code that has 21 ever come out because it applies to some reactor.
Is that 22 correct?
23 MR. SCARBROUGH:
Well, right now they are required 24 to update and everyone up to '89 right now.
I think that is 25 one reason why I think '89 was sort of picked, because the
[~'}
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starting point was'there's only a handful of plants that (A) 2 haven't updated to '89, so everybody from '89 upward update 3
only under certain conditions.
4 DR. POWERS:
It's intriguing.
That is the only 5
thing I can say about the thing.
I am not willing to offer 6
an opinion, better or worse, here because I think you have 7
to have some idea of how the updates are going.
Are they.
8 going in a more conservative or more liberal direction, and 9
I think the answer is both.
10 MR SCARBROUGH:
There's a little bit of both in 11 all of them.
12 DR. POWERS:
I think I can point to cases in which 13 the ASME codes become more conservative over time and I can 14 point to cases where it's become more liberal in time.
O
(,/
15 DR. APOSTOLAKIS:
And I have a comment also that 16 may not require a response.
I remember our Chairman saying 17 in the past several times, asking a rhetorical quescion, 18 whether a regulatory agency should be using state-of-the-art 19 methods or methods that are good enough.
20
[ Laughter.]
21 DR. POWERS:
He did indeed ask that question many 22 times, and he was no* shy about expressing his opinion on 23 that either.
24 DR. MILLER:
As unusual as that may be.
25 DR. SHACK:
I have a little problem with you make
's]/
[
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82
('
1 your-argument based on the maturity of the inspection
[O
\\
2 technology and then you look at the past110 years and you 3
say, well, you know, I have got baffle bolts cracking, I've 4
got BWR internals cracking, erosion / corrosion has suddenly 5
come to the fore.
I have decided-that rather than 6
prescribing how the guy ought to do the inspections I ought 7
to have performance demonstrations so that in fact he 8
demonstrates that he can actua? ly find something when he 9
does the inspections.
10 A technology that depends strongly on 11 instrumentation and computers in 10 years is four 12 generations and to say that it has matured, you know, in 13 1999 --
14 DR. POWERS:
A bit on the arrogant side.
f~%
(,)
15 DR. SHACK:
-- is almost mind-boggling.
I really 16 find it very difficult to -- inservice inspection is a 17 difficult thing.
Does it make the plant safer?
It's really 18 a defense-in-depth argument, that the plant is operating 19 safety.
It is there to detect changes in the situation and 20 I don't find 10 years at all an unreasonable interval to go 21 back and make sure that I am using effective techniques that 22 detect degradation.
23 MR. SCARBROUGH:
I think there is quite a 24 difference of opinion on this and there's lots of issues 25 that we have mentioned that need to be addressed.
We want
h j
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to gather as much information as we can to be able to make f ')
2 the most informed decisions before we go forward, so all V
3 this is just in line of what we have heard.
4 We have heard go slow, be careful, you know, make 5
sure you look at all the pros and cons before you go too far 6
down this path.
7 DR. UHRIG:
What is the driving force behind this?
8 Is it economics?
Is it relief of burden?
9 MR. SCARBROUGH:
I think that is -- at some point 10 you say we have been doing the 10 year updates for many, 11 many years through these plant lives, and has it got to the 12 point where the code has matured enough that it is an 13 unnecessary burden on licensees to do the 10 year updates?
14 I think that is a question that is reasonable to ask at this O()
15 point in the lives of the plants.
16 DR. SHACK:
Yes, but then you lock at the last 10 17 years, and what is the answer you get?
18 MR. SCARBROUGH:
There's a date on the other side, 19 ton.
20 DR. POWERS:
It's been a busy 10 years.
21 DR. SEALE:
I think your comment about the fact 22 that it is four lifetimes -- 10 years is four lifetimes on 23 some of the test equipment and so on is appropriate too and 24 that is why when you say you give a little and take a 25 little, it's because it's the whole package that gives you ANN RILEY & ASSOCIATES, LTD.
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what you want and it's the giving.and taking that gives you
()
2 the'new balance, and cherry-picking can get very, very risk 3
in those cases, because you may throw away the important-4 part of a process if you pick and choose among the 5
requirements of the different' code cases.
6 MR. SCARBROUGH:
We have that same concern.
7 DR. SHACK:
Do we have any comments from NEI?
8 Kurt, care to say anything?
9 MR. COZENS:
No, not at this time.
10 DR. SHACK:
Any additional comments from the 11 Committee?
12 DR. APOSTOLAKIS:
Are-we expected to write a 13 letter on this?
14 DR. SHACK:
I think we can discuss that since it
()
15 just goes out for public comment.
We could either --
16 DR. APOSTOLAKIS:
Is the staff requesting a 17 letter?
18 MR. SCARBROUGH:
No, we are not requesting a 19 letter.
We appreciate your feedback you are giving us 20 because it reaffirms our need to look at these issues very 21 carefully.
22 DR. SEALE:
If the points that Dr. Powers has 23 raised, though, are generally shared and so forth, it might 24 be more appropriate to bring them to the attention of the 25 Commissioners now.
,[$
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DR. APOSTOLAKIS:
Which points now?
Today or two
()
2 years ago?
3 DR. POWERS:
In this environment, I am not sure 4
that either one of my points are off the board here.
5 DR. SEALE:
That's right.
6 DR. POWERS:
Part of our obligation to the 7
Commission is to acquaint them with the dilemmas, the 8
uncertainties, and the considerations and, given the status 9
of the staff's investigation and the apparent genuine 10 interest in understanding axactly those things, presenting 11 two sides of the coin is not a bad position to take right 12 now.
13 DR. SEALE:
It is better to bring it up now than 14 to wait until after the comment period to bring them up, if C
' \\g\\
15 we really feel that those are important issues.
We are-16 messing up our schedule.
17 DR. BONACA:
I just have one question.
You know, j
)
18 with this -- from some perspective, one might see several of I
19 these as relaxations.
What happens for life extension?
20 MR. SCARBROUGH:
Life extension would -- the 21 plants that are currently operating and licensed, once the 22 baseline is selected, that is their baseline for the 23 remaining life of the plant.
You know, they would only be 24 required to update to something if there was a 51.09 backfit' 25 analysis, where they might choose to encompass an entire new i
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version of a code and go up.
But they wou?' be treated just
()
2 like any other currently operating plant.
3 DR. SHACK:
I think that completes it.
I am going 4
to turn this over to Dr. Seale now since we are on to steam 5
generators and I have a conflict of interest there.
6 DR. SEALE:
Thank you very much.
7 DR. POWERS:
You didn't say a lack of interest did 8
you?
9 DR. SHACK:
No.
10 DR. SEALE:
Well, just to show how, when you are 11 having fun, times passes in a hurry, we last talked about 12 steam generator tube integrity with the staff back in 13 September of
'97, and wrote a letter in which we recommended 14 that a proposed generic letter be issued for public comment A) 15 and draft guide 1074.
At the time we believed these s
16 specifications contained in the proposed letter and in the 17 draft guide would provide improvements by requiring 18 licensees to perform condition monitoring, operational 19 assessment and non-destructive examination and 20 qualification.
21 Since then, the staff has postponed the issue of 22 the draft -- of the proposed generic letter, withdrawn the 23 associated advanced notice of proposed rulemaking and met 24 with the NEI concerning technical and regulatory issues 25 related to steam generator integrity.
f
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The staff and the industry representatives have
()
2 made progress in resolving the technical issues and reached 3
a conceptual agreement on the regulatory issues.
Neither 4
the staff or the industry have yet identified a particular 5
regulatory approach to implement this agreement, however.
l 6
We might be interested or wish to comment on the 7
following topics:
proposed changes in tPc technical 8
specifications for plants, reliance on ME code I
9 requirements, allowable or worse -- I should say worst 10 differential pressures, secondary to primary, accident i
11 induced leakage, the definition of tube burst and tube 12 rupture conditions, what those are, and the risk issues 13 concerning each of these.
j l
14 Mr. Murphy is going to fill us in on this I
()
15 particular topic, and we are expected to write a letter.
I 16 MR. MURPHY:
Can you hear me?
i 17 DR. SEALE:
Yes, sir.
18 MR. MURPHY:
Well, it was my intention today to 19 give you a brief update, in the ten minutes that I have, on 20 the status of NRC and industry initiatives on steam 21 generator tube integrity issues.
So, it wasn't my intention 22 to get down to any real detail on some of the details of the 1
23 "echnical issues, other than to give you a sense for how we 24 are proceeding and the chance for success.
25 When we last met-in September and October of '98 O
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to discuss the draft GL package, we explained that the
(
)
2 purpose of the draft GL, or the proposed GL, was to inform
. \\,s 3
utilities that actions beyond minimum technical s
4 specification requirements were necessary to ensure tube 5
integrity, and to request that they submit changes to the 6
tech specs-as needed to ensure that tube integrity is 7
maintained.
8 The package included a draft regulatory guide 9
which provided an acceptable methodology for accomplishing 10 the goals of the GL and the methodology was intended to be 11 performance-based.
It identified a set of performance 12 criteria or performance goals in the areas of tubs 13 structural integrity and tube leakage integrity. and 14 provided for periodic tube integrity assessments on the
()
15 condition of the tubing relative to the performance 16 criteria.
17 Finally, the packhge included a proposed 18 resolution of a' differing professional opinion which was 19 filed by an NRC staff member.
The fundamental concern on 20 his part was that operation with degraded steam generators 21 may lead to a high frequency of core melt scenarios and 22 accompanying containment bypass.
There were a number of 23 sub-issues or sub-topics relating to that DPO, but that was 24 the bottom line concern, and, furthermore, that, in his 25 mind, the proposed GL and accompanying regulatory-ruide j'
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would not really resolve the issue.
And that was our i
l
(
2 proposed resolution of the DFO and a discussion from the 3
individual concerned were both made to the ACRS in October
)
4
'97.
5 In December of '97 industry informed NRC of an 6
initiative that they had taken to adopt a formal industry 7
position which stipulates that each licensee will e n>.uate 8
its steam generator program and where nccessary revise and 9
strengthen the program to meet the guidance provided in NEI 10 97-06 entitled " Steam Generator Program Guidelines," and 11 that implementation of this program should be uncertaken no 12 later than the first refueling outage after January 1, 1999.
13 And, incidentally, the industry has, you know, 14 that commitment remains in fo ce, and the industry is --
individual utilities are in fact implementing the 15 16 guidelines.
17 NEI 97-06 is programmatically similar to DG-1074 18 in terms of general program elements and strategy, that is, j
19 it relies on a set of performance criteria in the structural 20 and leakage arena and periodic tube integrity assessments to 21 ensure that the criteria are being met.
- However, 22 significant differences exist in the details, including J
23 technical, regulatory, and risk issues.
24 After considerable deliberation then the staff 25 proposed to the Commission in SECY-98-248 that the staff i
/
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would delay issuance of the draft GL while it works with the ID 2
industry to resolve issues relating to the NEI guidelines.
V 3
We noted that technical differences still remain between the 4
staff and the industry, not just in the technical arena but 5
including the appropriate regulatory framework for 6
implementing the industry guidelines, and that it was our 7
objective to be in a position to endorse an industry 8
initiative for ensuring steam generator tube integrity in 9
lieu of issuing a GL.
10.
However, we also proposed and the Commission 11 accepted the issuance of the draft DG-1074 and the proposed 12 DPO reso]ution for public comment, and this was done in 13 January of this year.
The comments on the reg guide and the 14 DPO resolution are due by the end of June of this year.
()
15 DR. SHACK:
I know you wanted to avoid details 16 here, but I just wanted to clarify something I'm just trying 17 to remember from the subcommittee meeting.
18 There was the intent when the licensee wanted to 19 propose a repair procedure criterion that you would review 20 the first application of that.
21 MR. MURPHY:
Yes.
22 DR. SHACK:
Would that then become part of h#
23 tech specs, or he would do that under 50.59 for sube at 24 applications and for other licensees?
25 MR. MURPHY:
Mr. Mizuno, in the back of the room,
[~)
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1 may care also to chirp in if I misspeak here, but our l' N 2
intention, our goal, is to have a tech spec written in such d
3 a way that a licensee who's proposing to make first-time use 4
of a new ARC would be obliged to come in for NRC review and 5
approval.
u:
6 Staff's SE in response would, assuming that we 7
approve the proposal, would identify the parameters defining 8
the limits of applicability of the staff's approval to that 9
specific methodology, because the proposal will be made in 10 the context of a plant-specific situation.
But the idea is 11 the staff will say yes, we approve the licensee's proposal, 12 and we find a similar proposal from other licensees to be 13 acceptable provided, you know, they fall within a certain 14 box, and we'll define that box very carefully in the SE.
()
15 other licensees -- once the staff has issued such 16 an SE, other licensees, if tbsy find that they fall -- under 17 a 50.59 evaluation fall within the box, could implement the 18 new ARC without a change to tech specs or NRC review and 19 approval.
20 So that is the goal we're trying to get to.
I'm 21 getting a little ahead of myself here, but in addition to 22 trying to dovetail our ef forts with the industry initiative 23 as best we can to have a mutually agreeable approach, for it 24 to be a win-win situation, we want a product that is going 25 to improve the ability of the existing regulatory framework,
[])
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primarily the tech specs, to ensure that tube integrity will (qj in fact be maintained, but at the same time gives licensees 2
3 more freedom of action to respond to their specific 4
circumstances without having to come in to NRC for review 5
and approval.
6 There are an awful lot of tech spec amendment 7
requests that come in every year -- I'll say dozens -- that 8
propose a repair method or plugging limit that is similar to 9
what we've already approved for the units, and very 10 frequently there are no new unique issues pertaining to 11 these follow-on submittals beyond what we've already 12 considered in our initial approval.
So this will I think 13 certainly reduce the burden on utilities and be helpful to 14 them and the same time I think give us a regulatory hook
()
15 that we think is more effective.
16 We've had extensive interactions with NEI and 17 their members over the past six months on this particular 18 topic, and I think it's fair to say that we're making very 19 good progress.
There remain a small number of high-priority 20 technical issues that we still need to come to resolution on 21 before we are in a position to endorse the industry 22 initiative and proceed.
However, the need to come to 23 agreement on these issues exists irrespective of whether or 1
24 not the industry is going to proceed with its initiative and 25 irrespective of whether we're going to have a new regulatory
()
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framework.
/m) 2 In fact, utilities today are already implementing g
3 the major program elements of DG-1074 and '.ha ndustry 4-initiative.
And they are confronting the issues, what the 5
appropriate performance criteria are to perform the tube 6
integrity assessments, and there is considerable discussion 7
going on between NRC and individual utilities as to the 8
appropriate performance criteria.
So these are issues that 9
we have to face up with irrespective of this generic effort, 10 and, you know, once we have resolution on these technical 11 issues, I think that this new regulatory framework and 12 industry initiative will leave us with a framework that I 13 think is far superior for them and for us than we have 14 today.
(Q,y 15 DR. UHRIG:
Will this go out for public comment 16 after you resolve the issues?
17 MR. MURPHY:
Yea.
The specific scenario over the 18 next six months is not set yet, but it generally works 19 something like this.
The industry -- well, in the next two 20 or three months, before July of this year, we'll hope to 21 resolve the outstanding technical and regulatory issues.
22 Industry would then submit a generic change package which 23 would include in our mind, NRC staff's mind, proposed 24 generic technical specifications that are consistent with 25 the resolved industry initiative.
And we would prepare an
'/
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SE that,.you know, evaluates the proposed generic tech
( )
2 specs.
3 As a generic action of course this is something 4
that we'd have to put through CRGR and meet with you on and 5
ultimately go to the Commission on, and we anticipate this 6
will take at least, you know, six months to get through.
7 But that's the general game plan at this point.
8 DR. UHRIG:
There would be individual tech spec 9
changes by each plant that implemented this?
10 MR. MURPHY:
Yes.
For the industry to have the 11 flexibility they would like to have, basically they woult 12 have to eliminate existing tech specs that pertain to 13 surveillance of tubing, and for us to have any sort of 14 effective regulatory hook or enforcement ability, you know, I
)
15 we need a tech spec -- an appropriate tech spec.
And what 16 we -- the nature of such a tech spec we think would be a 17 statement of the performance criteria, a statement that one 18 needs to periodically assess the condition of his tubing 19 relative to those performance criteria, that one needs to 20 have plugging criteria that have been reviewed and approved 21 by NRC staff.
22 Those are the essential elements of a tech spec.
23 They would be quite short and concise.
Existing tech specs 24 pertaining to steam generators are about ten pages long, 25 and, yr. know, these kinds of tech specs will be two pages
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long or less.
And, you know, the details of how they meet
()
2 the performance criteria will be defined not just in the-3 industry top-tier document but in supporting guidelines that 4
are referenced in the industry top-tier document.
5 These are referenced in the FSAR and other 6
licensee controlled documents.
However, as part of this 7
generic package, I mean the generic -- as part of our review 8
of the generic change submittal and the tech specs that 9
would be accompanying that change submittal, we would expect 10 to be in a position to be able to endorse the industry top 11 tier program.
So we would want to be able to endorse the 12 generic tech specs and the industry top tier program.
13 DR. UHRIG:
What about the technology of the 14 inspection systems, could this continue to be basically
(
)
15 current technology or would this be upgraded, or is this 16 even addressed in the tech specs?
17 MR. MURPHY:
Well, it is our belief that this 18 approach will be consistent with not taking away and perhaps 19 enhancing the incentive for people to use the best 20 technology out there.
When one is taking a 21 performance-based approach, and trying to demonstrate that 22 the tubes maintain certain specific factors of safety, the 23 less uncertainty you have in the problem, that is beneficial 24 to you in terms of the numbers of tubes you can leave in 25 service, perhaps how long you can operate between
..[~}
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And the key to reducing -- one of the keys to f
2 reducing uncertainty is, you know, more precise NDE 3
' measurements.
4 So none of the -- the tech specs would'not say 5
anything specifically about the nature of the NDE that you 6
do.
7 DR. UHRIG:
Thank you.
8 DR. POWERS:
My recollection of a lot of this 9
performance stuff may be incorrect, and do correct me if I 10 am wrong on this, that it hinges upon finding indications 11 and having a criterion for deciding whether that indication 12 is likely to fail over the next cycle or not.
And that, in 13 turn, hinges upon having a database of indications, and then 14 tubes get pulled and pressure tested, and checked.
)
15 Where do we stand on that database?
16 MR. MURPHY:
These databases, of course, are 17 developed on a degradation specific basis, and frequently 18 they are also tied in to the specific inspection 19 methodology, and they are developed to support a so-called 20 steam generator, defect-specific management strategy, which 21 would normally include an alternate repair criteria or ARC.
22 So, you know, the people, licensees have incentive 23 to develop SGDSM programs and ARCS.
It allows them the 24 flexibility to leave tubes in service longer, I assume it 25 gives them more operational flexibility, so that is their
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incentive for developing the appropriate databases that are
(
2 necessary to demonstrate, submit for NRC review and approval L
3 that the methodology is satisfactory and does the job.
It 4
ensures that the performance criteria will be met.
5 Now, there are many degradation mechanisms out 6
there for which we don't have SGDSM strategies and ARCS at 7
the present time.
There continues to be an industry-eide 8
database that gives us insights on degraded tube behavior 9
for generalized type defects out there.
So one is able to 10 perform tube integrity assessments relative to the 11 traditional margin of three type criteria, or deterministic 12 type structural criteria, without developing new databases.
13 But, you know, he is motivated to go out and develop these 14 new databases so that he can have more liberal performance
(~%
(,)
15 criteria, more liberal plugging criteria that will enhance 16 his operational flexibility.
17 DR. POWERS:
What I don't have a feel for is the 18 amount of data that we have on, say, tube rupture during 19 pressurization versus some sort of a defect, by whichever 20 detection may have been -- by whichever type of degradation 21 mechanism that is going on.
Is this a case of 10 or 15 data 22 points, 10 or 15,000 data points?
I am fishing here because 23 I don't know.
24 MR. MURPHY:
Well, I would say, you know, I think 25 that, you know, we literally have hundreds of data points on
[ )\\
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a variety _of different defect types that allow us to have a
()
2 good handle, experimentally, on. burst strengths as a 3
function of defect aid;.
Also, you know, these tend to 4
correlate very well with analytical methods that have been 5
developed to assess the damaging influence of specific size 6
flaws.
7 Where one might need to develop a new database, 8
however, is where -- a prime example was the voltage based 9
criteria that were developed for ODSCC at tube support 10 plates.
Now here it was being proposed that the plugging 11 criteria wouldn't be the size of the flaw, or allowable size 12 of flaw, but would be a voltage response.
And so now you 13 have -- you know, the existing database doesn't help you 14 understand this, and I think it is the voltage role to burst
()
15 strength and leakage, so you needed really to develop a 16 whole new database that allowed you to make that kind of 17 correlation.
So the need for new data -- the fact that you 18 are proposing a new ARC does not necessarily mean you have 19 to go out and generate new data, but, depending upon the 20 nature of the ARC, you may have to.
But there is a pretty 21 extensive and robust database out there already that covers 22 pretty much the spectrum of flaws that we have.
There are a 23 nr.mber of data points, I think it is in the hundreds.
24 DR. POWERS:
When you say the database is out j
25 there, is there a document that says the grand database that O
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gets updated periodically, or is it distributed all over the
)
E "C*
3 MR. MURPHY:
It is distributed all over the place.
4 However, specific degradation, like at ODSCC at tubes and 5
core plates, there is a central location, and we have an 6
agreed-upon protocol with NEI as to how that database is 7
maintained and updated and disseminated to the utilities.
8 DR. POWERS:
How would I go about looking at it?
9 MR. MURPHY:
In terms of the ODSCC database for 10 voltage -- that supports voltage based criteria, one could 11 look at the SCs written for the individual plants and they 12 reference, you know, an EPRI report that contains the 13 database.
Okay.
So in that case then there is an EPRI 14 report and if you would like, we can identify the EPRI 15 report that identifies the latest database.
16 With respect to other kinds of data, I mean we 17 would have to compile a list, I mean there is a lot of 18 industry generated data.
There is data generated by PNNL, 19 by Argonne and by others that are all relevant to the 20 integrity of degraded tubing, and so the list of documents 21 is quite long.
22 DR. SHACK:
But just recently, for example, Diablo 23 Canyon came in with a new -- essentially, the data that 24 demonstrate that sizing capability for a particular type of 25 flaw.
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MR. MURPHY:
Yes.
rx
/
2 DR. SHACK:
And so these things do come in.
3 MR. MURPHY:
Yes.
4 DR. SHACK:
The actually statistical -- you know, 5
the performance request that you are asking for is sort of 6
in the draft Reg. Guide.
7 MR. MURPHY:
Right.
But the list, you know, the 8
list of all the data that is out there that would help you 9
understand the damaging influence of a particular flaw, I 10 mean licensees have developed their own data, you know, run 11 their own tests and run their own data.
We have the NSSS 12 vendors do it.
We have had other -- we have had national 13 labs do it and so this data is all over the map.
14 DR. SEALE:
I hope that is a geographic map and
(
6 15 not a data spread.
16 MR. MURPHY:
That is true, too.
17 DR. POWERS:
I will bet there is a little bit of 18 spread in the data, Bob.
19 DR.'SEALE:
I bet there is, too.
20 MR. MURPHY:
Okay.
Well, just one closing comment 21 regarding the outstanding technical issues.
The hard spot 22 areas.
A primary reason these are hard spot areas is 23 because there continues to be discussion under how and when 24 licensees may propose to implement different criteria than 25 the traditional criteria that have been -- you know, the I
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traditional criteria.
And the issue that we have to
/~
t 2
confront here is the potential risk implications of, for
(
3 example, using structural performance criteria that maybe 4
are probabilistic criteria, conditionally probability of 5
rupture during steam line break, for example, in lieu of 6
traditional deterministic type safety factors such as, for 7
example, the factor of three against burst under normal 8
operating conditions.
9 Depending upon the circumstances during which the 10 probabilistic criteria might be implemented, there may be 11 potential risk implications, and this is, I think, the main 12 gut of the outstanding technical issues that we have with 13 NEI and the industry today.
14 I think we're be talking about risk in a few iO
(,/
15 minutes, if not right away.
i 16 DR. BONACA:
Just one question.
As NDE techniques f
1 17 have improved, for a period of time also new degradation 18 modes were identified.
1 19 MR. MURPHY:
Yes.
{
20 DR. BONACA:
Do you feel that that is pretty 21 much -- we have an understanding of all degradation modes 22 that are there?
23 MR. MURPHY:
I guess I have been working with 24 steam generators for 20 years and after that period of time 25 I would never say we saw the-last mechanism.
1 A-]s/
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[ Laughter.)
(}
2 MR. BARTON:
Always a new one, right?
I 3
MR. MURPHY:
There's always something new.
4 There's always surprises out there.
It's amazing.
5 DR. POWERS:
We have not exhausted all of the 6
letters that se can put in front of SCC.
7 DR. BONACA:
But my next question in fact is how 8
do you correlate that -- I guess the uncertainty with this 9
going to a new criterion that would be probabilistic and 10 trying to understand it.
11 You would go beyond a difficulty that not knowing 12 what other degradation processes that may be there that we 13 don't understand because of our ability to detect.
14 MR. MURPHY:
Well, understand that under the
()
15 status quo it is our position that, well, everybody has a 40 16 percent plug-in crit'ria they need to implement.
That's 17 applicable to all defect types, and it is our opinion that 18 when people are trying to assess whether their program is 19 working that they should be evaluating their structural 20 margins versus the traditional deterministic safety factors j
1 21 that are consistent with the stress limits in Section 3 of 22 the code.
.I 23 If one wants to use alternate repair criteria to 24 do the 40 percent work, one wants to do his tube integrity j
25 assessments to different performance criteria, these sculd (O
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be done on a defect type specific basis, and I don't just.
/~'N 2
mean cracks versus thinning type flaws, but they wc-uld be, V
3 these methode would be applicable to cracks at a specific 4
location, perhaps applicable to situations where noise 5
levels are no higher than "x" 6
DR. SEALE:
You would want the pedigree of the i
7 crack.
)
i 8
MR. MURPHY:
Right -- I mean because the 9
methodologies that support the use of the ARC and the tube i
10 integrity assessments tend to depend upon the NDE method j
11 that is being employed and its precision and its accuracy 12 and that very much depends upon the circumstances of the 13 specific flaws you are worried about, so the use of ARCS and 14 the use of performance criteria pretty much have to be
()
15 defended relative to each of the unique characteristics of 16 flaws, of crackL', say at different locations where they 17 maybe occur and the NDE performance is different, at 18 expansion transition locations, for example, than it is in 19 the U-bend or the tube support plates and these differences 20 need to be take, into account to ensure that a ARC that is l
l 21 operable at a tube support plate can be applied somewhere 22 else for example.
23 DR. SEALE:
I think we get the idea.
24 I have one more question.
We have been sitting 25 here or teetering here on the brink for lo these many years
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now, I guess we can say.
When you and NEI finally resolve
-.s i
2 the outstanding technical issues that still remain and so J
3 on, I think we. would like for you to come and tell us what l
4 the resolution of those are, things like burst margins and 5
things like that, because those are specific questions that t
6 you have educated us so much on now that we just can't wait 7
until we get the answers to it.
8
[ Laughter.]
9 DR. SEALE:
So to bcd.
Well, I think that is all 10 on steam generator tubes.
11 DR. SHACK:
Steve's got something.
12 DR SEALE:
Okay, Steve.
I 13 DR. SHACK:
I don't think Steve is going to talk f
l 14 about internals.
I bet he's going to talk about tubes.
l,,
)
15 DR. SEALE:
Okay.
Well, we anticipated that we 16 were maybe fortunate that this was the last topic of the 17 day.
I mean this whole set of issues.
18 MR. LONG:
First of all, my name is Steve Long.
I 19 am with the Probabilistic Safety Assessment Branch, NRR, and 20 I have been asked to make a fairly quick overview of the 21 presentation that we made to the subcommittee on the 22 relationship of the requirements we have on steam generator 23 tube integrity to the risk from failures to have good 24 integrity.
25 You have the whole package of slides that we used G-ANN RILEY & ASSOCIATES, ITD.
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'for the' subcommittee.
I' don't intend to go through-each_of
()
2 those.
I will hit ~about_four of them and'if necessary.on 3
questions we can go to the others.
4 The genesis of this white paper was a meeting last 5
October in which there was sort of a general agreement 6
between the industry and NRC management participants that we 7
needed to get the NRC's understanding >and position about 8
this clarified.
9 We ended up producing a white paper and the Staff 10 is essentially serving the function of understanding the 11 l relationship of what we now regulate to the control-of the 12 risk.
It is essentially a policy development process that 13 is ongoing right now, so we have a white paper that is in 14 draft.
He has not gotten far enough through the concurrence (O
15 chain for us to give you a copy.
That was true for the j
16 subcommittee -- it's still true now, unfortunately.
17 It is interesting that we keep being pulled away 18 from the development of the paper itself by plant-specific 19 issues which then at least help us focus on the issues that 20 are in the paper, so I don't think we are standing still but 21 the prose hasn't caught up yet.
22 The subject is when and why to consider risk, as 23 opposed to how to consider risk.
We think there has been 24 quite a bit of progress on how and if we can get the when' 25 ands why straight, we can probably get the guidance on how D.
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fairly promptly after that.
(
)
2 The' paper contains a-lot of material that is sort 3
of tutorial-that I. don't intend to go through with the 4
committee but I do want to say that as we --
5 DR. POWERS:
Do you presume that we don't need to' 6
be tutored?
7 MR. LONG:
I think you have heard it all..
8 DR. POWERS:
Oh, 9
MR. LONG:
At least twice.
It's referred to in 10 the slides and we can go through it if you wish with 11 questions, but I just want to note that as we go through 12 that we have done a fair number of risk assessments in the 13 past where we have tried to include steam generator 14 integrity issues in the risk calculations and our findings (G,)
15 have pretty much been that the way we think we are 16 regulating the integrity of the tubes now does adequately 17 control the risk but it is an indirect control.
It 18 doesn't -- yes?
19 DR. APOSTOLAKIS:
The title of your talk, when and 20 why to consider risk, you mean when and why to consider 21 quantitative risk, because you always consider risk.
22 MR. LONG:
Let me reserve that to the end, but I 23 think we consider safety.
We have words in the legislation 24 and in the rules to consider risk.
How we consider risk has 25 been qualitative'to a large degree in several respects in O
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the past.
(
2 There is quite a discussion going on right now.
- 3 about how to make that more quantitative, both-the legal 4
aspects and the. technical aspects.
5 DR APOSTOLAKIS:
But if it becomes quantitative 6
there is no question when and why -- then you must use it.
7 MR. LONG:
You are getting right to one of the 8
reasons you don't have the white paper draft in front of you 9
right now.
The guidance to the Staff is to try to use risk 10 assessment to the maximum extent supported by the 11 state-of-the-art.
12 DR. APOSTOLAKIS:
Quantitative risk assessment.
13 MR. LONG:
Quantitative risk assessment 14 probabilistic risk assessment.
15 The regulations require us to find,when an 16 application is submitted that we -- that the application 17 meets our applicable rules and regulations and also as a 18 separately stated finding that there is reasonable assurance 19 of adequate protection to public health and safety.
20 The processes that are in place, the existing 21 rules and regulations don't explicitly include probabilistic 22 risk assessment processes and as we will get to in a minute, 23 they seem to have so far kept the risk down to a level that 24 we are comfortable with, but as we think about relaxing some 25.
of the existing controls it is not clear that you can always O
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108-1 just1 generally assume that;will be the case.
j )
2 YouLhave to go back and'look atfthe probabilistic-3 characteristics of the change and the. difficulty.with that 4
is doing so is not:in our current-procedures and practices 5
We are trying to figure out how to add that on and we.are 6
also trying to consider if when.you add.it on quantitatively 7
where is the threshold for acceptability.
8 We have some voluntary thresholds.that have been 9
agreed to in Reg Guide 1.174, but right now the process 10 allows the applicant to essentially disregard that and to 11 ask that it be done solely on the deterministic processes 12 that are written down and adopted.
13 If we get.to a situation where we think it pretty 14 much complies with the written and adopted practices and
()
15 procedures but we think there is still an outstanding risk 16 question, how we proceed in the case is not yet really clear 17 on the policy.
18 It gets to what's the definition of adequate 19 protection, who bears the burden of showing that there's a 20 reasonable assurance that there is adequate protection, or 21 do we have to show that there's reasonable assurance that 22 there's not adequate protection in order to deal with this?
23 Those questions are still open for discussion.
24 At any rate, I think in-discussing them, it's 25
'important that people understand exactly what is controlling
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the risk right now given the set of things that are written
/'
'2 down, agreed to, and abided by the licensees as they, you 3
know, construct and operate and in-service inspect their 4
plants.
So this table is laying out a lot of what we think 5
we're working with there and pointing out what controls risk 6
and what doesn't seem to have much of a handle on risk.
7 The structural integrity requirements in the ASME 8
l code, either three times the normal operating delta P or 1.4 9
times the design basis accident delta P, when applied to 10 Inconel tubes, which are now what's used in the steam 11 generators, really helps not only minimize the probability 12 of bursting a tube in their design basis accidents, but 13 because of the extra margin, provides approximately enough 14 capability to withstand the severe accident challenges which
()
15 involve higher temperatures and approximately the same delta 16 Ps as the design basis accidents.
I say approximately --
17 we're definitely in a no more margin case for those 18 particular sequences.
19 It looks like, for some plants with a high delta 20 P,
- here's a lot of margin, more potential for withstanding 21 high temperature sequences.
For some plants with lower 22 delta Ps or with thermal hydraulics that present higher 23 temperatures to the tubes more rapidly during severe 24 accidents, it looks like the margin is not quite en; ugh.
25 Given the uncertainty in the process, it's just a
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close call.
I wouldn't want to say this plant definitely
- D 2
will or will not have this sequence, survive with a flaw d
3 that just barely meets the ASME code requirements.
On the 4
other hand, whr.e we are right now is we don't plug tubes 5
exactly at the ASME code requirements; we try to find tubes 6
that have flaws that are getting large, project ahead with 7
some confidence that they will not exceed the ASME code 8
requirements at the end of the next cycle.
If we aren't 9
able to size them, size the flaws very well when we detect 10 them, we add some margin there.
11 So right now, what we're doing is a process that 12 pretty removes the flaws that we can find before they get 13 close to or past this ASME code requirement.
So the process 14 is kind of keeping us from having a population of flaws in 15 the generator that are likely to fail if you ever have a s
16 severe accident challenge.
17 DR. POWERS:
My recollection may be imperfect on 18 this -- in fact, it's sure to be imperfect -- but my 19 recollection is that when we had gross flow through tubes 20 during the course of a severe accident -- that is, we had no 21 loop seal, we were getting natural circulation flows through 22 them -- that we did overheat tubes.
23 MR. LONG:
You're right in that there are some 24 cases where if you leave the RCS at high pressure -- and by 25 high pressure, I mean at least at the accumulator setpoint G
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^111
.1 or ' thereabouts 12 DR'.
POWERS:
Sure.
3 MR. LONG:
-- let the secondary side of the" steam 4
. generator depressurize, put natural -~ a full.look natural 5
circulation through, we think that you'll fail'the steam 6
generator tubes _even if they have no flaws.
These hopefully i
7 have been small enough inffrequency that it's not putting 8
the rink out of hand.
9 Now, if any one of those criteria isn't met,. it
~
10 looks'like a pristine tube at least will have a pretty good 11 chance of survival.
12 DR. POWERS:
And if we do have a loop seal so'that 13 we're only going to get some sort of a convective _ transport 14 through the tubes, we concluded that we probably wouldn't
()
15 fail tubes, but in coming to that conclusion, we had 16 relatively limited fission product deposition on the tubes.
17 MR. LONG:
Well, you came to the conclusion that a 18 tube with no flaw --
19 DR. POWERS:
That's right..
Yes.
I'm speaking of 20 flawless tubes.
21 MR. LONG:
Yes.
-22 DR. POWERS:
What's the story with a flawed tube?
23 MR. LONG:
Well, as I was saying, with the flawed 24 tube, the flaws that are about at the AS?d structural 25 integrity requirement'are ab^ut where you would expect the f7 ANN RILEY & ASSOCIATES, LTD.
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strength requirement to be for this. convective counterflow
(
2 in the hot leg heat transfer process.
3 DR.' POWERS:
My recollection is that the Japanese 4
had been looking at this area and that when they do the 5
analyses, they come up with much higher fission product 6
loading on these tubes and a much higher portion of the heat
~
7 coming from the fission products.
8 MR. LONG:
I'm aware of the study you're talking 9
about.
I think Office of Research has looked at the study 10 and run some Victoria analyses and come to a different 11 conclusion, but I'm not prepared to speak in detail on 12 those.
13 DR. POWERS:
Is it a case that the Japanese now 14 have an experimental research program looking at this, or is f
(_
15 this just the battle between computer codes?
16 MR. LONG:
I believe they have some experimental 17 work, and the question was whether or not it's applicable to 18 the scenarios and the accident sequences.
19 DR., POWERS:
Do we have any forecast on outcome of 20 this der'te or is this --
21 MR..ONG:
_ don't.
22 DR. POWERS:
Okay.
23 MR. LONG.
I mean, all I can tell you is we're 24 aware of the u bate.
I think there are others that are 25 engaged in the debate, and as I've asked are we changing our
/'
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conclusion, the answer I'm getting now is, not really.
j
)
2 DR. POWERS:
If it's a battle between computer 3
coder vbe we'll let them go ahead and argue with each 4
other.
If there's some hope that we'll get some 5
experimental data, then it seems to me that we ought to be 6
looking for that experimental data.
7 MR. LONG:
I agree with that.
I mean, I'm not in 8
charge of the Office of Research, --
9 DR. POWERS:
Sure.
10 MR. LONG:
-- but I do agree with you.
11 DR. POWERS:
It would be nice to know what the 12 hope is here because fission product deposition on surfaces 13 is a strange and arcane field, ari I'm a little bit out of 14 my depth here, I aamit.
Dr. Kress probably knows more about V) 15 this than I do.
It's easy to know more than I do.
16 MR. LONG:
Ed, am I correct in assuming there's 17 nobody here from Research that can address this, or Mike?
18 Okay.
We just don't have anybody present today 19 that can address that.
20 DR. APOSTOLAKIS:
The reason for the criterion 21 there, how do you know it's a minimum?
You have a 22 quantitative relationship or is it just English language?
23 MR. LONG:
Which minimum are you referring to?
j 24 DR. APOSTOLAKIS:
The first under structure 25 integrity, reason for criterion?
)
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MR. LONG:
Minimize probability?
()
2 DR. APOSTOLAKIS:
Yes.
You're minimizing it 3
really or you're reducing it to a level where you're 4
comfortable?
Do you have a quantitative relationship 5
between the three times normal delta P and the probability?
6 MR. LONG:
If you can be sure you're succeeding at 7
three times normal delta P or 1.4 times accident delta P, 8
then the failure probability during the accident should be 9
zero.
So there's some English in there as opposed to a 10 mathematical expression if that's what you're asking.
11 DR. APOSTOLAKIS:
That's a minimum, all right.
12
[ Laughter.]
13 DR. SEALE:
Preclude is maybe a better word.
14 MR. LONG:
Okay.
I can fix that.
/()
15 If we're ready to go to column 2.
16 DR. SEALE:
Yes.
Let's go right ahead.
17 MR. LONG:
Okay.
The other criterion that seems 18 to have a fairly large effect on controlling risk is to make 19 sure that the leakage during an accident is small.
There 20 are two things that now control that.
First of all, there 21 is just sort of an assumption that one GPM was a reasonable 22 rate to which to keep leakage from a heat exchanger, so one 23 GPM was provided to-the tech specs.
It wasn't a derived 24 value; it was an input to the technical specifications and 25 the design basis accident analyses that were in chapter 15 O
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and part of the licensing process.
/m) 2 The tech specs later were developed to have a
\\_/
3 plugging criteria for flaws that attempts to keep flaws 4
greater than 40 percent through-wall from occurring., and you 5
can more than minimize, you can preclude the possibility of 6
a leak if in fact there's nothing that goes more.than 40 7
percent t hrough the wall.
8 Again, if you were really succensful in doing 9
that, 40 percent through-wall looks like it will survive 10 most of the severe-accident challenges.
11 The idea in the licensing ba31s is to compare the 12 postulated accidents to a dose guide]Ine that's in Part 100 13 of the regulations for such postula'.ed accidents, and the 14 leakage rate from the primary to '.he secondary typically
()
15 does not include fuel damage, it typically -- with an iodine 16 spike and that's a much less challenging let's say 17 requirement than is a gross failure of the fuel cladding.
18 On the other hand, it's a notentially higher 19 frequency occurrence, so it's in the design basis.
eO If we meet that design basis and we do have the 21 severe accident, the 1 gpm leak rate may not be quite 22 sufficient to make sure you meet Part 100.
It depends on 23 how much scrubbing you can credit in the secondary side, 24 which normally isn't in the calculation.
25 However, it does look like it would keep the dose i
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rate low enough that-the risk level'to the population would-(
2 be fairly well controlled.
3' A couple of other things that are in our 4
requirements but don't really have very much effect on the 5
overall risk to the public are first;of all the operational 6
leakage, which started off at about 1 gpm,'perhaps 7
apportioned-among. steam generators, but it was. reduced.in an 8
attempt to capitalize on the leak-before-break process to' 9
the extent that it really occurs with steam generator tubes, 10 and we feel it does to some extent but not with a very high 11 probability.
12 DR. POWERS:
Could I come back to the second 13 column under your "would limit releases in severe 14 accidents"?
)
15 MR. LONG:
Yes.
16 DR. POWERS:
When you say that, are you saying 17 that because it's only a gallon per minute, that's limiting 18 it, or are you saying that the growth over the course of the 19 leakage that develops over the course of the accident is 20 such that it never gets up to the high levels?
21 MR. LONG:
You're asking if a 1 gpm leak would 22 essentially cut open and give you a much larger leak rate 23 during the course of an accident?
24 DR. POWERS:
Yes, I guess that's --
25 MR. LONG:
- Okay, I'll try to get to that, but-now
- ANN RILEY & ASSOCIATES, LTD.
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'the idea is if you can keep it to 1 gpm, it will limit the-(
2 dose effect.
L 3
DR. POWERS:
Okay.
Okay, fine.
4 DR. SHACK:
But you're really saying that because 5
that's limiting the population of flaws.
6 MR. LONG:
Well, I'm really sa,ing if you have no 7
flaws that go through a wall --
B DR. SHACK:
Right.
9 MR. LOK 3:
Then there's no leakage.
If you have 10 small pinholes that go through a wall and give you 1 gpm, 11 that 1 gpm of ler" e turns into some number of pounds of 12 steam with associ
-ission products involved leaking for 13 the period of, you knc.
whatever time it takes before you 14 depressurize the RCS in a severe accident would not be (Oj 15 anything like a.najor bypass of containment during that 16 severe accident.
It does keep the doses down towards the 17 Part 100 guidelines as opposed to up in the, you know, large-18 1400 PWR-1 type release categories.
19 DR. POWERS:
I hope it's below PWR-1.
20 MR. LONG:
It's definitely below there.
21 DR. POWERS:
That's not a difficult bound to fall 22 below.
23 MR. LONG:
Okay.
Third column.
The point with 24 150 gpm is that it does operationally give you the 25 opportunity to prevent some ruptures from occurring, but
/
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from the standpoint-of really-getting you a frequency of
/~D 2
failure of tubes under severe accident conditions, its-O 3
quite possible to have flaws that are not leaking in normal 4
operation or leaking extremely tiny amounts become failures during severe accidents if in fact the tubes heat up, 6
experience a higher delta p flaw that's not thro,gh wall may 7
propagate through a flaw that is through wall but is very 8
tight, maybe with a ligament or two may pop open, flaw u
9 that's much shorter than critical length at normal operating 10 temperatures may be longer than critical length at higher 11 temperatures and go ahead and fail catastrophically So 12 you're gettint a little bit, but not a whole lot, from the 13 operational leakage restriction.
14 DR. POWERS:
Again, with trepidation, I may reveal
()
15 ignorance here, if a crack is below critical length at a low 16 temperature, can it become of critical length at high 17 temperature?
18 MR. LONG:
Yes.
If a material flow stress or its 19 ability to, you know, withstand the pressure gets lower, a 20 smaller flaw can go ahead and tear it open.
21 DR. POWERS:
The strength goes down, but doesn't 22 ductility go up?
23 MR. LONG:
It's -- I'm not a materials person, but 24 as I understand, the ductility will go up, but it will 25 essentially tear.
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DR. SHACK:
You get ductile tearing.
2 DR. POWERS:
Okay.
3 DR. SHACK:
Feel better.
4 MR. LONG:
This isn't a brittle fracture 5
mechanism.
Inconel is quiet tonqh material even at normal 6
temperatures.
7 DR. POWERS:
Even at high temperatures.
8 MR. LONG:
Okay.
Fourth column.
The containment 9
calculations as they're done under chapter 15 analyses 10 really don't address a high-pressure core melt phenomenon.
11 The containment does have a different design basis than the 12 RCS.
It's there essentially to help provide defense in 13 depth if you haven't met the design bases for the RCS and 14 the ECCS, and historically we put a fairly large fuel clad h
15 failure source term into containment at containment design 16 pressure and require that the leak rate of the containment 17 keep the dose to the public down below Part 100 criteria.
18 The calculation there usually explicitly takes 19 credit for the idea that it's a large LOCA that would cause 20 that kind of fuel damage.
In a large LOCA the RCS pressure 21 will be whatever the containment pressure is.
The pressure 22 in the steam generator should be whatever the safety valve t
{
23 set point or lower is.
Any leakage will be from the steam 1
24 generator in.
No need to calculate a source term by leakage 25 from the steam generator out to the public.
l l
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If you ask yourself what happens in a
()
2 high-pressure core damage sequence where that TID source 3
term might be released into a reactor coolant system that is 4
at let's say the PORV set point or the safety valve set 5
point, and there is some potential for leakage out, to the 6
extent that you have the secondary side wet, it's scrubbed.
7 To the extent that that's really a station blackout core 8
damage sequence, and the secondary side may be dry, it's not 9
scrubbed, but we don't treat that in the design basis 10 process.
So this really does illustrate a place where we're 11 not tightly controlling the issue that we're concerned 12 about.
13 Next slide.
14 Some of the things that we've been asked to if 15 consider in the way of changing these requirements are, 16 first of all, to replace the 40-percent through-wall 17 criterion with a criterion that would allow through-wall 18 cracks to remain in service as long as they don't leak and 19 they show that they can withstand, you know, the ASME code 20 requirement for structural 1-tegrity, which would be short 21 cracks but through-wall.
The question is, would they become 22 greater than critical length or would they open up and leak 23 a lot if they were exposed to severe accident conditions.
24 That's a concern that's hard to address without 25 some data.
We have some experimental processes to look at f)
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it.
So far, as we've discussed with you before, we really 2
haven't approved anything like this except where there's 3
some additional confining capability like a drill hole tube 4
support plate or having it down in the crevice of a tube 5
sheet.
So we still have an open -- couple of open issues 6
with regard to doing the same thing in the free span.
7 Associated with that have been requests for 8
increase in the accident leakage limit including a what's 9
called a flex program that would allow the licensee to 10 essentially trade off allowable iodine concentration in the 11 coolant which is related linearly to the concentration of 12 radioactive material in the coolant during the design basis 13 accident against the leak rate in the design basis accident.
14 The difficulty with allowing that is that you can, if you 15 drive the allowable level for operation of the iodine in 16 your coolant down to the level that you can typically 17 sustain it with good fuel, you can at the same time relax 18 the primary to secondary leak rate into the multiple hundred 19 gpm range and still meet this particular design basis 20 accident calculation.
21 What you are doing is you are saying that is not 22 constrained by this originally non-derived parameter of 1 23 gpm, you are going back to the licensing basis calculations 24 and using those to back calculate something that was 25 originally an input.
If you do that, the problem is leakage
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may be quite high in and of'itself.
In a severe accident, 2
you would not like to have multiple hundreds, maybe up to a 3
thousand gpm leak from one steam generator times two, three 4
or four generators perhaps with a severe accident type 5
source term, as opposed to an iodine source term -- iodine 6
spike source term.
7 So that, again, is going to require some careful 8
look before we say the risk aspects of it are okay.
9 There is one issue that you brought up about 10 leakage that we also have discussed before and not really 11 addressed, and that is if you allow the leakage to be maybe 12 even 1 gpm, but certainly multiple gpm, and it is all coming 13 from one leak, how big does that leak have to get before the 14 erosion of the leak itself, the heat flow to the leak, O)
(
15 because it is now no longer convective, it is forced flow, 16 the cutting effect of the jet coming from that leak and 17 impinging on adjacent tubes effectively leads to a gross I
18 failure of the steam generator boundary with even higher 19 than the predicted leak rate.
20 So, there may also be a need to not only limit i
21 total leak rate but to go back and limit how much an 22 individual maximum leaker can be.
And that partly gets into l
23 the definition that Emmett mentioned about what is a burst 24 and what is a leak.
There have been some proposed i
25 definitions of burst which are quite high.
Something would jO ANN RILEY & ASSOCIATES, LTD.
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be a leaker if it doesn't exceed the charging flow of the
'v) 2 system, which is typically around 100 gpm, but there is one 3
plant that I believe is 550 gpm.
We think some of the 4
definitional problems have a bearing there as well.
5 And, finally, there is the request that the ASME 6
code requirement for structural integrity be replaced with a 7
probabilistic statement of structural integrity that 8
addresses not the strength of the ASME code level, but the 9
strength directly at the design basis accident level, and 10 that a value of 5 percent is the conditional failure 11 probability during the design basis accident to be accepted.
12 We have a problem with that in the following 13 sense.
It not so much that using a probabilistic criterion 14 to address the strength is at issue, the problem is that the
~
level of strength is actually be reduced substantially in 15 16 the proposed criterion.
We feel that we, because of the way 17 inservice inspection occurs with steam generator tubes, we 18 pretty much have to be somewhat.probabilistic in the way we 19 interpret what is in the tubes and what will be there at the 20 end of the next cycle.
So it is really the reduction in the 21 strength level is a concern.
22 DR. KRESS:
Let me ask you a somewhat thinly 23 disguised question about these three?
Would not your view 24 as to whether or not any of these three modifications were 25 acceptable depend on level of CDP that is actually achieved 9
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by the particularly plant that might want to do it?
(
2 MR. LONG:
Not so much the CDF as the -- I 3
hesitate to call it large early release frequency but the 4
frequency of containment bypass through the steam generator 5
tubes is what we would really aim at.
And, yes, it would 6
be --
7 DR. KRESS:
But these.are contributors to that?
8 MR. LONG:
Yes.
And the reason we are interested 9
is that frequency.
10 DR. KRESS:
I am saying that there are allowing 11 that to go up a little bit maybe and, of course --
12 MR. LONG:
The question is how much.
13 DR. KRESS:
Yes.
And, of course, how much you are 14 going to allow it to go up could depend on what the CDF,
/^%
(,)
15 because it is also a contributor to the LERF.
It could be 16 dependent on either the LERF or the CDF, it seems to me 17 like.
18 MR. LONG:
Okay.
I think as we have looked at 19 this in the past, if you relax the criteria, you may allow 20 CDP to go up a little bit, but we don't think that the 21 effect on CDF --
22 DR. KRESS:
It doesn't look like this would CDF 23 very much.
24 MR. LONG:
Not very much.
There will be a small 25 increase in the CDF.
Unfortunately, the part -- the
)
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increase in the CDF would also be an increase in the
()
2 LERF/ containment bypass, whatever it really is by 3
definition, plus it may take some of the existing CDF and 4
turn that also into LERF where it was not LERF before.
So 5
our real focus is on how much containment bypass CDF is 6
created.
7 DR. APOSTOLAKIS:
I don't understand this.
We 8
Now, you seem to be reluctant 9
to use LERF.
10 MR. LONG:
The difficulty with LERF is that LERF 11 was originally intended, and I think generally used, to say 12 there is a class of accidents that are much worse than the 13 average, the bulk of the accidents.
They somehow bypass 14 containment.
They produce much higher consequences than a
()
15 core damage ar-ident where the containment essentially 16 serves its function and contains most of the radioactive 17 material.
18 The difficulty with the regulatory process here is 19 that if you start going to something like the leak rate you 20 can allow from the primary to the secondary, you now have 21 sort of a dial in the regulatory process.
If you want to 22 play with that dial, you can essentially adjust the effect 23 on the public all the way from a contained reactor damage 24 accident all the way out to no containment, continuously, by 25 how much leakage you would allow.
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DR. KRESS:
That was the thin disguise I was 2
talking about.
3 MR. LONG:
At that point --
4 DR. APOSTOLAKIS:
So how do you control that?
5 DR. KRESS:
By CDF, that's why I said CDF.
6 DR. APOSTOLAKIS:
He said CDF and you agreed that 7
CDF --
8 DR. KRESS:
No, I didn't agree, that is what he 9
- said, I didn't agree that you couldn't use CDF to control i
10 it.
j 11 DR. APOSTOLAKIS:
But the consequences is where 12 you have the impact, the CDF changes a little bit.
13 DR. KRESS:
When you look at it, though, what you i
14 are dealing with is a large uncertainty in that dial, and j
h 15 you could probably deal better with that uncertainty if you 16 had a much lower CDF, is what I was --
l 17 MR. LONG:
If you could get CDF --
)
18 DR. KRESS:
Even though you end up with about the 19 same, with an acceptable LERF, you probably would rather 20 that to be due to a small CDF in the case where you had lots l
21 of uncertainty associated with this part of it.
This was 22 the disguise I was -- my question.
I figured you two would 23 pick up on it.
24 MR. LONG:
What we are trying not to do, George, 25 is have a precise definition of LERF and then not worry ANN RILEY & ASSOCIATES, LTD.
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about anything that falls just barely short of that precise
^\\
2 detinitely, irregardless of the large consequences on the
[d 3
public.
4 DR. APOSTOLAKIS:
I am trying to understand 5
whether the CDF and LERF nre the appropriate measures here, 6
and whether there are any sequences where --
7 DR. SHACK:
Well, the sequence depends on having a 8
core damage accident.
9 DR. APOSTOLAKIS:
Yes.
10 DR. SHACK:
I mean you don't have damage accident, 11 then there ain't a problem.
So if you get the CDF down low 12 enough, --
13 DR. KRESS:
Your LERP is low.
14 DR. SHACK:
Your LERF is low.
15 MR. LONG:
Sure.
That is pretty hard to do, 16 though.
I think you are better off trying to make sure that 17 you have somehow protected the tubes if you -- you know, 18 during your CDF situation.
19 DR. BONACA:
I just would like to go back to, you 20 know, one thing -- I mean here is a specific part of the 21 plant that is difficult to inspect, other than going back to 22 this failure mechanism.
So not all locations are inspected.
23 Typically, you go back and inspect those areas that you know 24 that have been affected.
So there is a lot of unknown about 25 these tubes in certain regions.
For example, it took years (O
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for us to decide that we are going to inspect the cold side, 2
and, lo and behold, we found problems that we never thought 3
were there.
4 Okay.
So now we are inferring from testing a 5
plant for the next cycle, all right, and that is all we 6
know.
But we don't know really whet else is out there.
So 7
I am trying to understand still how we can reduce this 8
margin here by saying that, you know, the criterion is going 9
to come down significantly, you know, in this kind of 10 scenario.
I mean I always thought that to some degree the 11 fact that we had a lot of margin, by going to the 40 percent 12 criterion, gave us also some comfort for what we don't know 13 about these tubes.
So I would like to understand more about 11 these alternate proposals here, because they don't give me
()
15 any comfort right now without hearing some more about that.
16 MR. LONG:
I think you're saying what I'm saying.
17 The reason that I have listed these three things here, and 18 there is a fourth one I guess I should add, is that we think 19 these things are potentially challenging the finding that we 20 have made in the past, that we think risk is adequately 21 controlled.
With what we are doing now, we think if we move 22 to these things we need to look at them very carefully to 23 see if we can still draw that conclusion or if we have to 24 limit them in some way before we grant them to make sure we 25 can still have some reasonable assurance that the public is
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adequately protected, whether adequate protection is LERP or rm C) somewhat short of LERP or what, is still a policy discussion 2
3 that is ongoing.
4 The fourth thing I should probably add is remember 5
the slide I said with Inconel tubes -- there's now actually 6
a proposal to use a different material as a sleeve that has
'7 different performance characteristics under severe accident 8
conditions, so that is yet another thing that I think no one 9
really thought of when we even wrote the white paper less 10 than half a year ago that we might be having to look at.
11 The conclusion from the risk assessment is really 12 based on everything that we are doing now -- the materials 13 we are using not just for the tubes but also let's say for 14 the surge line.
A lot of the reason that the tubes survive
(
15 is that the surge line doesn't -- is, you know, it fails 16 before the tubes do.
If you made the surge line out of 17 Inconel the tubes would probably fail first, so changing 18 anything very substantially in what we are now doing may get 19 you into a problem here.
20 DR. BONACA:
What would be the advantage to a 21 licensee to allow for such large leakage?
22 MR. LONG:
You are asking what is their incentive 23 for doing this?
24 DR. BONACA:
Yes.
25 MR. LONo.
Basically economics and the uncertainty
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of the inspection process.
m
}
When inspections are done with the tubes, the 2
3 inference of what is there and how fast it grew to get there 4
for this inspection and therefore trying to infer the size 1
5 of things that you have at the next inspection at the end of 6
the next outage, is very uncertain, so trying to show that 7
there is not -- trying to show that you can actually find 8
everything that might be a problem.at the end of the next 9
cycle may be difficult.
The licensees spend a lot of money 10 doing it.
11 In particular, if they have to shut down at a 12 short cycle and just do an inspection without doing 13 refueling, that costs them a lot of money.
The inspection 14 process is expensive and the not producing electricity is
)
15 expensive.
Replacing generators, plugging generator tubes, 16 sleeving generator tubes is expensive, so this is really a 17 large economic burden on the licensees and to the extent 18 that you can reduce the burden era maintain safety, you 19 know, it's in everybody's interest to try to do that.
l 20 DR. BONACA:
But wouldn't you have to change all 21 your programs?
For example, based on the leakage rate you 22 have a lot of analysis that have to be redone and certain 23 limits, control room and everything else is affected by 24 that.
25 MR. LONG:
There are some things we are doing
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1 that -- let me get to the last slide here.
(
2 DR. SEALE:
Let's hurry it up here.
3 MR. LONG:
I'm trying.
Okay.
There are a few-4 things that we think are worth doing.
One of them is there 5
is no guarantee for instance that 1 gpm was the right number 6
with regard to protecting the public, so there's work going 7
on at the Office of Research now to investigate as a 8
parameter what the dose consequences are, multiple measures 9
of dose consequence to the public given reactor accidents 10 with various levels of primary and secondary leakage.
11 When we get the technical information there is 12 then a policy question of how much consequence is too much 13 consequence for saying that your containment performance has 14 been achieved as being allowed to improperly degrade, so we
()
15 can get just so far with the technical information we can 16 provide.
17 Some of it is going to be uncertain and even to 18 the extent that we knew it perfectly there's policy 19 questions that are yet to be resolved.
20 In the interest of speeding it up, I think I 21 should just ask for questions at this point.
l l
22 DR. APOSTOLAKIS:
It seems to me that Slide 8 --
l j
23
[ Laughter.)
l 24 DR. POWERS:
Don't laugh, because I am going to go
]
25 to 5.
l
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DR. APOSTOLAKIS:
The English language should be 2
modified.
I think if you look at the penultimate statement 3
there, the key to controlling risk is use.-- and so on.
4 The reason for that is that we cannot really 5
quantify the impact on risk from degradation of steam 6
generator tubes.
Is that correct?
7 MR. LONG:
The thrust of this is to say we cannot 8
do it precisely enough to regulate to a limit that is a 9
computed risk.
10 DR. APOSTOLAKIS:
So we cannot quantify.
That is 11 rea)1y what it is.
12 MR. LONG:
Yes.
13 DR. APOSTOLAKIS:
So that comes back to my earlier 14 comment about when and why to consider risk.
If you can
()
15 quantify it, you consider it.
If you cannot quantify it, 16 you resort to deterministic requirements.
17 MR. LONG:
Why you resort to them, but I am saying 18 the risk-informed process, you can use a risk assessment 19 with the uncertainty associated with it if you can show that 20 you are clearly not at risk or you clearly are at risk.
You 21 have-done something quantitative.
22 If you are somewhere in the middle, you can at 23 least establish which parameteis look like the level of risk 24 is sensitive to them and then you can try to put your 25 deterministic controls on thor i parameters.
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DR. APOSTOLAKIS:
I am stating that in a different
()
2 way.
I am saying that I wouldn't say that risk assessment 3
will clearly demonstrate something is safe or unsafe, but if 4
I cannot really quantify the impact on my matrix from the 5
degradation of steam generator tubes, than I have to resort 6
to other means.
7 In other words, it is not sensitive enough, the 8
PRA, right now the way it is.
9 MR. LONG:
It is not precise enough, you are 10 saying.
11 DR. APOSTOLAKIS:
Precise?
12 MR. LONG:
It may not even be accurate enough but 13 ce.tainly two good PRA analysta can get in a room and argue 14 virtually forever about whether the number is different by a O) i, 15 factor of two.
s 16 DR. SHACK:
George, you can compate risk up the 17 wazoo to 13 decimal places but that doesn't control risk.
I 18 mea' the way you control risk is to keep the number of 19 flaws --
20 DR. APOSTOLAKIS:
But can you really calculate it?
21 I doubt it.
Degradation --
22 DR. SHACK:
Well, I mean that is a Gedanken 23 experiment.
Even if you could compute it, you don't control 24 risk thac way.
You control risk by keeping the population 25 of flaws small.
The thing that keeps the population of
[)/
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1 flaws small --
L 2
DR. APOSTOLAKIS:
I keep trying to go back to that 3
paper on defense-in-depth.
4 DR. KRESS:
I know, and I am too.
5 DR. APOSTOLAKIS:
And I don't think we should have 6
a million principles here.
7 DR. KRESS:
No.
I don't think so either.
8 DR. APOSTOLAKIS:
This is a case in my mind where 9
the PRA is incomplete.
We have a steam generator tube 10 rupture initiating event but we are talking about the 11 frequency per year.
We are not talking about individual or 12 groups of tubes failing or being degraded.
That is way 13 beyond what a PRA does, so now you say, well, gee, the PRA 14 doesn't do that, I resort to traditional methods, G )
15 prescriptive methods.
16 MR. LONG:
I don't think --
17 DR. APOSTOLAKIS:
I think that is perfectly all 18 right.
19 MR. LONG:
-- we are saying quite that.
I think 20 what we are saying is that actually you can put that into a 21 PRA now.
There's uncertainties when you do it.
Oregon Gas 22
& Electric is doing it.
We have done it to some degree, so 23 it is just a matter of when you do it the result you get is 24 not something that you can take to the bank on the first 25 significant digit any more than any other piece of a PRA.
i
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DR. KRESS:
What he is saying is that the i
2 uncertainties are too large to be acceptable.
You either 3
reduce the uncertainties --
4 DR. APOSTOLAKIS:
Right.
5 DR. KRESS:
-- or you reduce the CDF.
Since the 6
CDP is wha; it is and you don't reduce it, they reduce the 7
uncertainties by this process.
8 DR. APOSTOLAKIS:
Right.
9 DR. KRESS:
That is what they are doing, reducing 10 the uncertainties.
11 DR. APOSTOLAKIS:
That's right.
I agree with that 12 but I wouldn't use those statements about PRAs useful to 13 demonstrate that something is clearly safe when rish 14 assessment is not precise enough to define a regulatory (n) 15 limit.
I don't know about all these things.
16 The uncertainty is large enough, I resort to 17 defense-in-depth and safety margins.
18 DR. SHACK:
I don't think you are reducing 19 uncertainty.
You are reducing the failure probability of 20 the tube.
21 DR. SEALE:
That's right.
22 DR. KRESS:
You are doing both.
23 DR. APOSTOLAKIS:
Both -- you are doing both.
24 DR. SRACK:
Yes.
If I reduce the failure i
25 probability of the tube, I reduce the uncertainty but I i
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mean --
l
()
2 DR. KRESS:
But you are doing two things.
You are 3
reducing LERF by doing that, and you are also reducing your 4
uncertainty a little bit because you are able to calculate f
5 within whether the tubes are going t) bust or not better as 6
you do these sort of things.
You are increasing your 7
ability to both reduce LERF and reduce the uncertainties and 8
you get both of them to a level you are ccafortable with is 9
what he's saying.
10 DR. APOSTOLAKIS:
Yes.
11 DR. SEALE:
Are there any other questions?
12 DR. KRESS:
And that is the right way to use 13 defense-in-depth.
14 DR. APOSTOLAKIS:
Yes. Exactly.
I
)
15 DR. POWERS:
It seems to me that the statement 16 being entirely accurate, if I look at the PRAs we have 17 available to us today, I don't think there is an inherent 18 flaw in PRA technology that forces us into the deterministic 19 requirements here.
20 I think some people just haven't done it.
T.1 DR. KRESS:
I would agree with you.
22 DR. POWERS:
I think it could in principle be done 23 and done well and I think that we run into difficulties 24 deciding what appropriate margins are because we don't have 25 that kind of risk information.
(
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'l DR. KRESS:
But they are related to the-2
' uncertainties.
3 DR. POWERS:
It seems to'me that we -- I know that 4'
when we have tried to set up the event trees for the NUREG 5
1150 effort there was a lot of talk about let's go in and'-
6 work the steam generator issue for what's. called the 7
progressing accident, because, yes, we have a steam 8
generator rupture accident as initiator but we became very 9
concerned about progression of the high pressure sequences 10 which we knew were risk dominating in'the NUREG 1150, that
.11 -
they would progress toward the steam generator tube --
12 We did go back to the Quest study which looked at 13 how pristine tubes responded to the accident,.and all that 14 lead to not doing this.
But'I was convinced at the time and 15 I'm convinced now that you can do this, and that we're as 16 this data base that they're talking about grows the 17 imperative for doing this seems to me to grow higher because 18 until you do that, you have no idea whether these 19 deterministic requirements with what are called appropriate 20 margins are good enough.
'i 21 DR. FONTANA:
Wait a minute.
I don't have any 22 problem with the penultimate statement there.
No matter how 23 good your PRA is, I don't see any problem with developing 24 requirements on how you're going to build and inspect.and 25 maintain tubes and the amount of time that you allow a-plant O
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1 138 l'
to run
--'to fail to' meet these margi's-
.You.can' determine.
n 12 -
these things on'the basis'of PRAs.
3 DR. POWERS:
What we're saying is that yes, you--
4 can.in principle, but you can't now in fact.
5 DR. SEALE:
Or we haven't in fact.
6 DR. POWERS:
We haven't up till now because I-7 think nobody's worked the problem.
8 DR. SEALE:
That's what I mean.
9 DR. POWERS:
And I think we're getting a data base 10 here that ought to allow us to do this.
11 DR. FONTANA:
So you don't really have an issue 12 with that statement.
13 DR. POWERS:
I think it's entirely accurate if I-14 take the current state of the art.
I think it's terrible
()
15 that we don't have pepple trying to' advance the state of the 16 art here, because this is a thing that's been around.
Since 17 1989 for sure people were concerned over this and said we.
18 can do this, but they didn't go ahead and do it.
Now they-19 probably couldn't have done it in-89, but we're getting an 20 awful lot of data that looks to me like it sets up an 21 awfully nice probabilistic model.
22 MR. LONG:
Let me say that we have been trying to 23' advance the state of the art since 1150 on this subject,_and 24 there's_been industry as well as NRC work to do that,.but 25
-the point of the slide-was we think with the best that we're T
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doing now and'the best that we expect to be able to do in
()
2 the future, we don't believe that we can set a risk value
%)
'3 and say that however you show that your PRA comes out below 4
this number, it's acceptable.
But if it comes out above 5
this number by any number of significant digits off, it's 6
not acceptable.
We just don't feel that it's a precise 7
enough tool to regulate that way.
8 We also found when we did 1074, released it for 9
public comment, the industry was saying just the 10 probabilistic part of projecting ahead to the end of cycle 11 was something that they had a very hard time doing because 12 of the uncettainty of what the flaw was once they saw a 13 signal for it in the ISI process.
So we there really this 14 is addressing that problem.
)
15 We're saying that what we really think we need to 16 do is try to figure out what the sensitive parameters are, 17 try to control them with some deterministic processes tha; 18 we feel comfortable to keep the risk reasonably well 19 controlled, and even if the licensee is exceeding the 20 criteria that we choose, the deterministic criteria that we 21 choose, we want them set in a place where as long as they're 22 there for just a short period of time, the risk will still 23 remain low, as ve believe it does now rather than put the 24 burden for precise statistics on ISI.
25 DR. POWERS:
This is all regulation by religion.
[~ )\\
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I don't think you've got the kind -- I mean you're saying I
[ )i 2
feel comfortable.
You haven't seen enough severe accidents 3
and the progression of those severe accidents into the steam 4
generator to have a defensible basis for your comfort.
5 MR. LONG:
I think you're right in the sense that 6
it's hard to generate that level of comfort, and every time 7
you think you've got it, somebody brings up some other 8
subject.
So you're right, it's difficult-, but I think we 9
have tried to do what we can with the information we have 10 now.
11 DR. APOSTOLAKIS:
That's true.
That's true.
12 MR. LONG:
And our conclusion'is we don't really 13 see a big problem right now that we think we s/6uld be 14 backfitting.
Now tomorrow maybe somebody will walk in the
()
15 door from Sandia or wherever and say look at this problem 16 and we'll be in backfitting space.
But right now we 17 don't --
18 DR. POWERS:
Sandia never comes up with problems, 19 only solutions.
20
[ Laughter.)
21 DR. APOSTOLAKIS:
I want to understand something 22 here, because I was told earlier that because of the bypass 23 nature of these accidents, containment bypass, you want to
-24 control the core damage frequency, because core damage has 25 to occur first.
(
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MR. LONG:
Well, whar T was really --
2 DR. KRESS:
That was Dr. Kress.
3 DR. APOSTOLAKIS:
Well, Dr. Shack, too, said in 4
order to have -- you have to have core damage.
5 MR. LONG:
But we aren't trying to make core 6
damage frequency so low that it doesn't matter if the tubes 7
fail.
8 DR. APOSTOLAKIS:
Well, but that now creates a new 9
problem.
What you're saying is that you will have an 10 additional goal for core damage frequency, aren't you, the 11 10 to the minus 4 is not good enough for you because of the 12 special nature of these core damages.
13 MR. LONG:
We're saying that --
14 DR. APOSTOLAKIS:
That drives me up the wall 15 again.
16 MR. LONG:
Well, there's already a criterion for 17 large early release which is different from core damage.
18 DR. APOSTOLAKIS:
Right.
But you can't use LERF.
19 You said you're not going to use it.
20 DR. KRESS:
This is captured in large early 21 release.
22 MR. LONG:
We're saying we're treating this as if 23 it's LERF as far as that's concerned, and there may be some 24 quibbling about whether it exactly meets the definition of 25 LERF.
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DR. SEALE:
What he's saying is that the margin 2
between LERF and CDF is in part due to the fact tha't you 3
have these deterministically established relatively 4
conservative criteria for steam generator tube plugging and 5
so on, and that if you relax those, you may very well be 6
bringing those two nearer to each other.
7 DR. POWERS:
There was a time when people became 8
very concerned that all core damage accidents would progress 9
to --
10 DR. SEALE:
Would be steam generator --
11 DR. POWERS:
Steam generator tube rupture.
12 DR. SEALE:
And then they're the same.
13 DR. POWERS:
And then LERF and CDF are exactly the 14 same.
That's right.
/
15 DR. SEALE:
Yes.
Yes.
16 I think we beat this horse as tired as we can beat 17 him.
18 DR. POWERS:
No, we haven't.
[
19
[ Laughter.)
20 DR. KRESS:
Turn to page 5.
21 DR. POWERS:
I'd like to just touch on page 5 just 22 for clarification.
I'll avoid discussion.
I get to discuss 23 this later.
24 Say new risk-informed limit on accident leakage 25 could be developed.
It needs to address defense in depth.
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Okay.
This is a containment boundary that we're discussing
(
2 here.
That's an element of defense in depth.
Why should 3
defense in depth be applied to an element of defense in 4
depth?
5 MR. LONG:
I'm not sure I understand the question, 6
so --
7 DR. POWERS:
See, I don't understand the sentence, 8
so --
9 MR. LONG:
What we're really saying is that we're 10 trying to step away from the risk equation itself and ask 11 just the consequences part of the question to address the 12 defense-in-depth issue, so if we start playing with this 13 dial that's the leak rate from primary to secondary during a 14 high-pressure core-melt accident, and we're not going to let
()
15 it go so far that it essentially just rips apart the 16 primary-to-secondary boundary, but we're letting it leak 17 maybe thro' ugh a myriad of little, tiny leaks for a certain 18 amount until the RCS fails inside containment at least.
19 We're really asking not is my frequency times my 20 consequences an okay number, we're trying to look just at 21 the consequences and saying if you want to preserve defense 22 in depth, how much leakage can we allow through this 23 cont
, nt boundary -- part of the containment boundary --
24 before you're really seriously degrading the 25 defense-in-depth function, before you're really saying a lot
(']/
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of the core damage accidents that used to be successfully ps
(
)
2 contained in our models now have a pretty sizable 3
consequence, and it's because we allowed it to be a sizable 4
consequence, not because the physics prevented us from 5
stopping the sizable consequence.
6 DR. POWERS:
Well, to keep the discussion track 7
and to assure that I get the last word on this, that seems 8
to me that this is an appropriate risk question and not a 9
defense-in-depth question.
10 DR. KRESS:
It seems to redefine defense in depth 11 in my. mind.
12 DR. APOF"".AKIS :
And I -- well, it redefines it 13 in many ways when you spell it with a "c," but the last 14 paragraph, in order to apply the -- I don't understand it --
0) 15 to apply the guidance in RG 1.174 it will be necessary to i
16 determine appropriate accident leakage limits such that the 17 containment function is not substantially compromised during 18 accidents that are not in the LERF category.
19 DR. POWERS:
That one I understand.
That sentence 20 I have no trouble with.
21 MR. LONG:
Reg guide 1.174 says consider the risk 22 value --
23 DR. APOSTOLAKIS:
Right.
l 24 MR. LONG:
It also says maintain defense i-
^
t 25 There are quantitative acceptance criteria for the risk
[
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increases.
There is no quantitative value for change in the
(
2 defense in depth.
We're trying to figure out how to address G
3 that.
But the point of the sentence is to say we have to 4
develop some sort of policy there, because there is none 5
right now, other than maintain defense in depth, but we 6
don't think that means don't let the consequences go up by 7
1/100 of a perceat.
We're trying to figure out what's 8
adequate defense in depth and what's not.
9 DR. APOSTOLAKIS:
Accidents that are not in the 10 LERF category, what are these accidents?
11 DR. POWERS:
I think -
'my interpretation, and 12 please correct me if I'm wrong, was exactly what Bob was 13 saying, that staff has looked around and says okay, I've got 14 CDP here, and I like numbers like 10 to the minus 4 and CDF,
(~%
(_,)
15 don't like higher numbers, like lower numbers even better.
16 I've got LERF at 10 to the minus 5.
I like numbers less 17 than 10 to the minus 5, don't like numbers that are bigger 18 than 10 to the minus c.
Okay?
There is a presumption that 19 the ratio of core damage accidents that lead to LERF is 20 about the same in all plants, as we've calculated up to now.
21 If we have degradation of our steam generator 22 tubes such that those accidents that used to involve failure 23 inside of the containment now involve failure of the 24 pressure boundary at the steam generator tubes and become 25 LERF accidents, that is
- have a large early release, if
[
)-
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that ratio starts getting very, very different than what we
(
)
2 found in the past, then suddenly these numbers are no longer 3
good guidelines for you anymore.
4 DR. APOSTOLAKIS:
So now you are going to control 5
these accidents so that the CDF that results from these 6
initiators will be, in fact, substantially lower than 10 to 7
the minus 4, isn't that the natural conclusion from this?
8 DR. POWERS:
It already is.
9 DR. AFOSTOLAKIS:
It already is.
10 MR. LONG:
We think with the current controls we 11 have in place that the LERF is in the low 10 to the minus 6 12 range from this kind of accident.
13 DR. KRESS:
These are differential contributions 14 by sequence, and the CDF for a given sequence like this is
()
15 pretty low.
I mean you add them all up to get the 10 to the 16 minus 4.
17 DR. APOSTOLAKIS:
Right.
18 DR. KRESS:
And so these --
19 DR. BONACA:
These are sequences that right now 20 don't contribute LERF.
What happens is that because of the 21 failure --
22 DR. SEALE:
Get closer to the microphone, Mario.
23 DR. BONACA-I am saying that those are sequences 24 right now that contrii'ute to the LERF category.
What you 25 are saying is that if you allow them to release
,(d~')
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significantly to ruptures, they would add to the LERF
)
2 category, that is what you are saying.
You would increase 3
your LERF category by a significant amount by adding 4
sequences for which right now you have assumed no failure of 5
steam generator tubes.
6 DR. APOSTOLAKIS:
I have to understand.
Is there 7
a place where I can read about this?
8 DR. POWERS:
I will talk to you offline about it.
9 MR. LONG:
If we can get the -- well, there is 10 1570, but if we can get the white papers, we will make sure 11 you get a copy of that.
It is a little clear than the 12 slides.
13 DR. APOSTOLAKIS:
Okay.
14 DR. SEALE:
Any other questions that are r
15 absolutely burning a hole in people's chair?
16 (No response.]
17 DR. SEALE:
Do you want to take a little short 18 break before we go on?
Or should we let Mike go first?
19 DR. POWERS:
We have more presentations?
20 DR. SEALE:
We have one more.
21 DR. POWERS:
Why don't we take a 15 minute break 22 then?
23 DR. SEALE:
If that is all right with you.
24 MR. MAYFIELD:
Let me offer at least a proposal.
25 DR. SEALE:
Okay.
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148 1-MR. MAYFIELD:
What we.can do is leave the handout
()
2 with'you, given the lateness of the our, leave the' handout
'3 with you.
Steve had a quick 10 minute -- or four-slide 4
presentation, it burned off the better part of an hour.
I 5
foolishly had the work " risk" on my. slide.
'I figured about
'6 a half hour, so God only knows how late this might go.
I 7
would propose to you that we might leave the handout with 8
you and come back in June after we have met with the 9'
industry on the PTS program, and we can at least at that 10 point give you an update and give you a look at how the 11 program is starting to shape up.
12 DR. APOSTOLAKIS:
We will have this document by 13 then, right?
We will have read this document by then?
14 MR. MAYFIELD:
I have no idea.
()
15 DR. SEALE:
That has nothing to do with this~.
16 This is --
17 DR. APOSTOLAKIS:
It has nothing to do with this.
18 DR. KRESS:
This is PTS.
19 DR. APOSTOLAKIS:
A separate issue.
20 DR. SHACK:
Just that it has got risk and he knows 21 that creates problems.
22 MR. MAYFIELD:
I have been forewarned.
23 DR. POWERS:
And to be quite honest with you, Bob, 24 I would like to go through PTS'rather carefully.
25 DR..KRESS:.Rather than hurry it up.
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149 1
DR. SEALE:
I have no argument with that.
()
2 DR. POWERS:
Quite honestly, I want to have a good 3
understanding on PTS and what is going on there, and not --
4 I have gotten lots of snippets.
I now need to have somebody 5
take me from top to bottom and say what is and what should 6
be.
7 DR. APOSTOLAKIS:
So you are supporting the 8
suggestion then?
9 DR. POWERS:
Yes.
10 DR. APOSTOLAKIS:
Okay.
11 MR. MAYFIELD:
So we need to put this off and try 12 and get back on your agenda, I would suspect in June or 13 July.
I 14 DR. POWERS:
July would be better for us.
l
()
15 MR. MAYFIELD:
The only thing I would ask is don't 16 put me on after Steve.
17
[ Laughter.]
18 DR. SEALE:
The only thing I will point out to 19 you, gentlemen, that this is actually part of a -- well, it 20 is an introduction to a process which has embedded in it a 21 fair amount of ACRS interaction with the staff.
And so you 22 will not be getting that -- let's say a high sign on what 23 some of the details of that interaction are going to be 24 until July.
25 DR. POWERS:
Well, it is because there is a lot of I'
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ACRS interaction here that I would like to; start the process
()
2 off with a pretty thorough grounding on this, beginning even 3
fairly elementary.
4 MR. MAYFIELD:
We will come back and give you 5
whatever briefing you would like to have.
I have to say 6
because of the way we have gotten this program up and going, 7
since we are going to be moving, you know, April 20th and 8
21st is the first meeting with the public, to talk about how 9
we are going forward and to actually start some of this 10 process.
It is going to extend over a couple of years and 11 we anticipated visiting with you a number of times during 12 that period of time.
But we will be up and moving between 13 now and then.
14 DR. SEAL 3:
There is a significant
()
15 thermal-hydraulic component, by the way, to the overall 16 program.
17 DR. POWERS:
Oh, dear.
Just make sure your 18 documents are in good shape.
19 DR. SEALE:
Mike, I apologize.
20 MR. MAYFIELD:
No problem.
21 DR. SEALE:
I knew we were going to get in trouble 22 when these guys put their planning and procedures hat back j
23 on.
Bill and I got scolded.
It is back to you.
24 DR. POWERS:
Okay.
Sam, is Sam here?
25 MR. BOEHNERT:
I can get him.
I)/
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DR. POWERS:
More importantly, are the by-laws 2
here?
Would you distribute the by-laws, please?
(
)
3 DR. SHACK:
Well, if we are not going to have a 4
presentation, are we going to have a break?
5 DR. POWERS:
You will get a break shortly.
I just 6
have to do a couple of little functions.
Dr. Kress, you 7
have the floor.
You were supposed to be making a motion 8
quickly.
9 DR. KRESS:
Okay.
I forgot where we were.
I make 10 a motion that the members -- I make a motion that these 11 by-laws be approved.
12 DR. POWERS:
Do I have a second for this motion?
13 I really need a second.
14 DR. WALLIS:
Without any question?
)
15 DR. SHACK:
Second the motion so we can go on to 16 discussion.
17 DR. WALLIS:
Now we can discuss.
18 DR. POWERS:
Now, the motion -- we have a motion 19 on the floor for discussion.
What I would like to do is to 20 table that discussion and allow the members to review these 21 by-laws over the course of the next three days.
If you have 22 comments and whatnot on them, please submit the written 23 comments to Sam for corrections and we~will propose taking a 24 vote on this motion on Saturday morning, first thing off the 25 bat.
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152 1
DR. MILLER:
I move we postpone till Saturday
()
2 morning.
I move we postpone till Saturday morning.
3 DR. POWERS:
There is a movement to postpone the 4
vote.
5 DR. SHACK:
Second.
6 DR. POWERS:
All in favor of the motion?
All 7
opposed?
Now, we can take a break till 5:30.
8
[Whereupon, at 5:17 p.m.,
the recorded portion of 9
the meeting was recessed, to reconvene at 8:30 a.m.,
10 Thursday, April 8, 1999.]
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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REPORTER 5S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in N_
the matter of:
NAME OF PROCEEDING:
461ST ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
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 co'2rt reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
[b t
WM :
on Hundley Official Reporter Ann Riley & Associates, Ltd.
qb
INTRODUCTORY STATEMENT BY THE CHAIRMEN OF THE SUBCOMMITTEES ON RELIABILIW AND PRA Q
AND ON REGULATORY POLICIES AND PRACTICES 11545 ROCKVILLE PIKE, ROOM T-2B3 ROCKVILLE, MARYLAND APRIL 7,1999 The meeting will now come to order. This is a meeting of the ACRS Subcommittees on Reliability and Probabilistic Risk Assessment and on Regulatory Policies and Practices.
I am George Apostolakis, Chairman of the Subcommittee. Dr. Kress is the Chairman of the Subcommittee on Regulatory Policies and Practices.
ACRS Members in attendance are: John Barton, Mario Bonaca, Mario Fontana, Don Miller, Dana Powers, Robert Seale, William Shack, Robert Uhrig, and Graham Wallis.
The purpose of this meeting is to discuss the staff's approach for revising the Commission's Safety Goal Policy Statement. The Subcommittees will gatherinformation, analyze relevant issues and facts, and formulate proposed positions and actions, as appropriate, for deliberation by the full Committee. Michael T. Markley is the Cognizant ACRS Staff Engineer for this meeting.
The rules for participation in today's meeting have been announced as part of the notice of this meeting previously published in the Federa/ Registeron March 22,1999.
O A transcript of the meeting is being kept and will be made available as stated in the Federal Register Notice. it is requested that speakers first identify themselves and speak with sufficient clarity and volume so that they can be readily heard.
We have received no written comments or requests for time to make oral statements from members of the public.
(Chairman's Comments-if any)
We will now proceed with the meeting and I call upon Messrs. Thomas King and Joseph Murphy, RES, and Gary Holahan, NRR, to begin.
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